ILLINOIS

POLLUTION CONTROL BOARD

June 10,

1982

IN THE MATTER OF:

)

AMENDMENTS TO CHAPTER

2:

AIR POLLUTION;)

R82-12

PART III:

AIR

QUALITY

STANDARDS;

RULE

)

313

(Lead)

proposed Rule,

Submitted by the Board.

OPINION AND

ORDER

OF THE BOARD (by J.D.

Dumelle):

The 1970 Clean Air Act Amendments required the Administrator

of the United States Environmental protection Agency to promulgate

National 7unbient Air Quality Standards (NAAQS)

for five criteria

pollutants

(TSP,

SO

,

NO

,

0

and CO) under Section 108 of that

Act.

These standards we~ep~omu1gatedunder Section 109 of that

Act in 1971,

and were set at levels necessary to protect the

public health and welfare,

In 1976 the court in NRDC,

Inc., et al.

v. Train,

411 F.

Supp.

864

(S,D.N.Y,,

1976) aff~d

545 F,~

2d 320

(2d Cir.

1976)

ordered

USEPA to list lead as a criteria pollutant and to develop an

ambient air quality standard,

USEPA so listed lead on March 31,

1976, proposed an ambient air quality standard on December

14,

1977

(42 Fed.

~.

63092) and published the final rule on

October

5,

1978

(43 Fed.

~

46258).

The Federal reference

method for collecting and measuring lead and its compounds in the

ambient air was also published in appendix G to that promulgation,

as were final rules for the development of state implementation

plans under 40 CFR 51,

Appendix

G

was amended on June

29,

1979

(44

Fed.

Reg,

37915),

The Board has existing

rules

in conformity with federal regu-

lations which set standards and measurement methods for each of

the original five criteria

pollutants

(Rules 307—312 of Chapter

2:

Air Pollution),

However, despite the passage of over three

years since the federal lead regulations have been in effect,

no

one has proposed similar regulati3ns before the Board concerning

lead.

The Board therefore proposes the following new rule

for lead

as an amendment to Chapter

2:

Rule

313:

Lead,

(a)

Standard.

The ambient air quality standards for

lead and its compounds are

1.5

micrograms per

cubic meter, maximum arithmetic mean averaged

47-289

---

(b)

Measurement_Metho$~

1~rdetermining

conformance

with

the

amhienb

air

quality

standards

for

lead

and

its

cemp~tnds

lead

ann

its

compounds

shall

be

measured

by

the

atomic

absorbtion

spectrometry

method

as

described

in

43

Pederal

Register

46258—

46261,

October

5~

:L~78

as

amended

by 44

Federal

Register

3791~-37l8,

~ii~n~

29,

1979.

Statement

o~ Reasons

Lead is a

stable

compound.

ubiquit3usly

distributed,

which

persists

and

accumulates

hath

in

the

environment

and

the

human

body.

Lead

is

emitted

into

the

atmosphere

by

vehicles burning

leaded

fuel

and

by

certata

stationary

sources,

It

enters

the

body through

ingesbi~n

and

inhaJat:on

with

consequent

absorbtion

into

the

bloodstream

and

ais~:r.ib

on

to

all

body

tissues.

Three

body

systems

appear

to

be

most

sensitive

to

the

effects

of

lead

—

the

hematopoietic

system

~:nenervous system,

and

the

renal

system.

It has aieo

ceen

shown

to affect normal

functioning

of

the

reproductive,

endoc~~ne,

nenazic, cardiovascular,

immuno-

logic,

and

gastrointestinal

vs’Lems.

Clearly,

high

air

:Leaa

concentrations

can cause

significant

health

risks.

In

developing

its

proposed

standard

USEPA

determined

that

the

maximum

safe

blood

~e~e1

I geometric

mean)

for

young

children

was

15

ug

Ph/dl

~dccijrte~),

This

was

based

on

blood

lead

level

thresholds

tar

watious

h~clogic effects

ranging

from

the

risk

of

permanent,

severe

neurological

damage

or

death

at

levels

over

80 ug

Ph/dl

in

children

to

enzyme

system

inhibition

at levels as low

as 10

ug

Pb/al,

Since

children

appear

to

be

at

greatest

risk,

that

group

was

~sed

to

establish

safe

levels.

12

ug

Pb/dl

of

the

15

ug

Pb/di

safe

level

was

found

to

be

attributable

to

nor~air sources.

The

3

ug

Pb/dl

difference

was,

therefore,

estimated

to

he

the

allowab:Le

safe

contribution

to

mean

population

blood

level

from

lead

in

the

air,

Since

epidemiological

data

ind~cates

a

general

relationship

of

1:

2

between

air

lead

(ug

Pb/rn

)

and

blood

lead

(ug

Pb1’dL),~~u5EPA

determined

that

the

air

standard

should

be set

at

1,5

ug

Pb/r~

3The

Board

proposes

to

adopt

the

federal

standard

of

1,5 ug

Pb/m

as

well

as

the

federal

reicrence

method,

In

so

doing

the

Board

will

have

treated

lead

consistently

with

the

other criteria

pollutants:

all

will

be

subject

~o

enforceable

State

standards

and

may

be

enforced

through

the

Board

and

the

State

courts.

While

the

Illinois

Environmental

Protection

Agency

(Agency)

has

determined

that

the

only

non~-attainment

area

in

the

State

for

lead

is

the

Granite

City area

(see

III,

SIP,

Volume

9:

Lead,

pp.

2—3), the potential

for

violation

of

the

proposed

standard is

47-290

---

—3—

sufficient to justify a

State standard

to protect the health and

welfare of the People of the State,

Further, such a rulemaking

may be required

for approval of the Illinois State Implementation

Plan.

Although the Agency has apparently taken the position that

the reduction of lead in mobile sources under the Federal Motor

Vehicle Control Program and the federal lead-in-gasoline phase-

down regulations along with particulate standards will allow the

State to demonstrate attainment of NAAQS,

that position may not

be an accurate one, especially in light of possible amendments to

the Clean Air Act.

Promulgation and enforcement of a State

IT IS SO ORDERED.

I,

Christart L. Moffett~Clerk of the Illinois Pollution

Control Board, hereby certify that the above Opinion and Order

were adopte on the

/o’~

day of

,

Christan L.

Moff

Illinois Pollution

äñtrol Board