Document 91kMRybo31k2r7NwGR1Kw2aaL

fl-$7P0 UTitfuiKco wo;. E. L DU Po n t d e Ne mo u r s 51 Co mp a n y INCOR PORATCD cc: G, C. Tunis/R. O, Braendle W. K. Park D. H. Payne A, J. Pahnke/E. S. Jacobs R. D. Snee - ESD, Louviers ORGANIC CHEMICALS DEPARTMENT p e t r o l e u m c h e mic a l s d i v i s i o n February 1, 1977 TO: FROM: J. F. DICKMANN - MANAGER, CENTRAL REGION B. B. RUSSELL - MANAGER, EASTERN REGION L. Z. CAREY - MANAGER, GULF COAST REGION D. H. GEORGE - MANAGER, MID-CONTINENT REGION W. L. MITCHELL - MANAGER, WESTERN REGION D, - DIGGS ?ING MANAGER - ANTIKNOCKS EPA EXTERNAL REVIEW DRAFT "AIR QUALITY CRITERIA FOR ATMOSPHERIC LEAD" MEETING OF THE SUBCOMMITTEE OF THE SCIENCE ADVISORY BOARD On January 31, 1977, the Subcommittee on Scientific Criteria for Environmental Lead of the Executive Committee of the Science Advisory Board of the EPA met in open session in Washington, D, C. The specific charge by EPA to the Subcommittee was "to provide advice and consultation in the review and evaluation of the draft Air. Quality Criteria document for atmospheric lead --. That document was issued in November 1976, as I have previously advised, in response to a Court order requiring EPA to establish an ambient air standard for lead. In the draft EPA suggested that an ambient air standard for lead of 5 (90 day average) would be protective of public health. Since the draft document was made available for review, environmental groups and others have severely criticized the suggested standard as far too lenient. At the beginning of the Subcommittee meeting EPA represent atives said that a criteria document should not suggest or recommend a standard, but instead lay out all the information on which a standard should be based. Without quite saying so EPA admitted that it should not have mentioned any numerical standard in its draft document. EPA said standard setting should come only after an accept able criteria document was available, and was the responsibility of the top management of EPA not the authors of the criteria document. This was, I believe, an attempt to head off argument about the standard itself and confine the discussion to the scientific merits of the information in the document. The attempt was not successful. BETTER THINGS f'0R BETTER LIVING . . .THROUGH CHEMISTRY TEH 0470247 TO: REGIONAL MANAGERS PROM D. R. DIGGS 2 February 1, 1977 The Subcommittee is composed mostly of academics in the fields of medicine, biology and environmental control (list attached). It lost no time in attacking both the document and the suggested standard. The kindest statement made about the document was that it was "inadequate". The Subcommittee was critical in three major areas: Not enough attention was directed to the ingestion by children of dust and dirt contaminated by lead fallout from automobile exhaust, The significance of populations at special risk from lead - children and pregnant women - was not discussed sufficiently, The relationship between airborne lead and blood lead was not adequately developed. Despite ERA efforts to avoid discussion of its suggested xu icuuiiuuciiucu x juy/h i j j c iv a XII X.7 / X CLO J UD UX J L. UCl UXWii iUi its xxxau try at promulgating lead phasedown regulations. The Subcommittee felt that all that had been learned since 1972 about lead in the environment indicated more of a problem rather than less, but the EPA had relaxed the suggested standard. EPA's answer, which was in essence that 5 jag was the "effect" limit with no safety factor and 2 jug did have a safety factor, failed entirely to satisfy the Sub committee. Members felt the standard should be 1-2 jug. After hours of discussion the Subcommittee came up with a long list of suggested revisions, additions, omissions, clarifications, etc. which it thought EPA should include in a revised document. The thrust of all these suggestions was to make environmental lead a matter of much greater concern and thus subject to more stringent control than was the case in the draft document. It remains to be seen how the EPA will react to the Sub committee criticisms, which are only advisory not binding. EPA is TEH 0470248 DUP050083066 N42442.01 TOi PROM; REGIONAL MANAGERS D. R. DIGGS 3 February 1, 1977 working to have the final document ready for internal review by April 1 with publication and setting of the air quality standard done by August of this year. Considering the intense criticism of the 5 jag standard, it may not survive. As we advised you earlier, we prepared a detailed critique of the draft document and sent it to ERA. Copies have been sent to the Technical Managers. We also provided our critique to the Subcommittee. Because of a tight time schedule, however, the Subcommittee did not have copies in time for its meeting, and it was accordingly not discussed. We will, however, be reviewing our comments with selected members of the Subcommittee and with the appropriate people in EPA as the revision process goes forward. DRD/pwh Attachment ________..................................... ,.........................._ TEH 0470249 DUP050083067 ' SUBCOMMITTEE ON SCIENTIFIC CRITERIA FOR ENVIRONMENTAL LEAD January 31, 1977 Participants '(Anticipated) Chairman Dr, Roger 0. McClellan Lovelace Foundation Dr, J. Julian Chisolm, Jr. Baltimore City Hospital Consultants Dr, Paul B. Hammond University of Cincinnati Members Dr. Eula Bingham University of Cincinnati Dr. Ruth R, Levine Boston University Dr. Samuel S. Epstein University of Illinois Dr. Bailus Walker, Jr. Govt, of the District of Columbia Dr. Edward F. Ferrand NYC Department for Air Resources Dr, Geoffrey S. Watson Princeton University Dr, Sheldon K. Friedlander California Institute of Technology Ms, Anne M, Wolven Syntex Corporation Dr. James G. Horsfall Conn. Agriculture Experiment Station SAB Staff Officer Mr, Ernst Unde Science Advisory Board f J ? * u j I* TEH 0470250 DUP050083068 - _