Document aJMKXwvMxxp50wB7ZMV8r7epR

l"1 " 1", *>> W1 -' < ' ;- . ,. \ t *****& ,-v~ -. ^ ^r. LEAD INDUSTRIES ASSOCIATION, INC tS MADtIOH AVINUI Htw vome. n . v. toot* TUfMM - A*a* CMI til -i-^4ff--n -, y^-fr '* -i'" __ July 26, 1966 Toj All Henbers of the Lead Healthand Safety Ccanlttee cci Board of Director*, UA Industry Derelopneat Ccnxlttee, UA 8. T. Radtks Ret lead Air Quality Standard tn the State of Pennsylvania At a regular nesting of the Air Pollutloo Coco In loo, Depertaent of Health, Cognocvealth of Pennsylvania, July 12th a tentative etandard of 10 alcro|rtM per cubic aeter of tr for lead averaged over 2U hour* was proposed, with 00 oc-r* then * alrgl# occurrence of higher value allowed in each 100 coc*ecutlve day*. It 1* our understanding thst *t the next nesting of this Corvlttloa vote will he taken to accept or reject tht* standard. If the Ccmlttloo accepts the standard, public hearings suet he held after a JO-day notice before the etandsrd take* effect. The State of Pennsylvania pasted as Air Pollut loo Control Act In 19^0 and aaorur the mr.y prcvl*1 < * of thle Act was the designation of an Air Pollution Ccanltslon appointed by the governor. Anong the car./ duties of thle Air Pollution Cccalttlon It the following! *t# tab 11 ah and pub 11 eh snxlsaai (j-jantltlee of air contaatnant* that any ha {emitted under various condition* at the point of use fran any air contaainant source 1a rsrloua area* of the Caceocvealth *0 aa to control air pollution.* Such staodarda would he proarulgated as Regulation* snd would he enforced *t part of the Air Pollution Control Act. Co far 10 He history the Ccoalssloo hat adopted fo*ir Regulation*, together with appropriate Guide# for Cc*rpllance with Fegulatlcr.*. Boo# of the prevloualy adopted Regulation* 1* specific for any air pollutant and the proponed standard for lead would he In the first hatch of tpeciric air <r*llty staodarda. At lta nesting on July 12th the Ccanltstvn alto accepted tentative etandard# for #1* other naterlals hetldet lead. I contacted Pr. Allen E>. Riandt of the Rethlehe* Steel C(*pany, who It Chatman of the Air Pollution Ciwslttlor*. and pointed out to hi* that we felt that 10 alfrogra*# p*r euMr iulr It ur,rl let tc, not dictated hy eoralderallc-nt of health, and. In Million, that we have several research program* under wy at U,e preAtnt tine designed to preside e'lentlfH edge to tho!# Interested tn setting 'iet> standards. Pr. Brandt advlttd ae to write a letter to the Pwnne/lvanla.Cteeslttlon telling forth our position, and I did. ' 'v' t". S9q*ggy*M j i^< myiu.i!|ii .1 rew.v.'WHjge.t!" w . B> 1 v ba1 p an'j.. -mcmei!1 4 Lead Air Quality 8torxiard In th# State of Pennsylvania -2 July 26, 19& Kext, Z obtained on appointment at Harrisburg vlth th* Director of th* Division of Air Pollution Control of th* Department of Health, Mr. Victor 8. 8u*soon, in ord*r to explain In gr*at*r d*tail our poaltlon In th* natter of air quality standards. Mr. fluasoan asked that John Cl*land, Chief, Abatement Compliance Section and Ben Brodovlct, Jr., Chief, Technical Service* Section, *lt In on our dl*cu**lon. Z reported to the** gentlemen that v* had anticipated th* need for elr quality *tandard1, had dl*cu**ed thl* vlth the United States Public Health Service and th* State of California Department of Public Be*1th (vhlch has a aandate to set such standard*) and had all agreed th*t acre Information It needed before logical end reasonable standard* can he eet. That about four year* ago v* had asked Kettering laboratory to conduct for us human erpoeur* etudlet involving low level amount* of lead In epee tally designed chambers, vfclch etudle* vould be relerast to the health of th* general public. Th* (tat* people appeared to be Impressed vlth th* detail* of our studio* sad th* scientific approach that our Industry 1* taking through research. j .1 r- V* Z then asked upon vhst basis the 10 alcrogram figure had been derived, and vaa told that it vas about l/20th of the industrial hygiene Threshold Velue of 200 nlcrt^rao* per cubic meter of air. V* then had a technical discussion concerning the fallacy of such an approach to ambient air quality standard*, 1 and Mr. Susscon pointed out to me that v* should really be pleased that they bad only takeo l/?Oth of th* Industrial hygiene limit, since In th* case of beryllium they bed used 1/lOOth of th# Industrial hygiene Halt. Mr. Sustman further pointed out to me that In hie opinion the Three Cities Survey has sbMO that average amounts of lead to air do not exceed 3 mlcrogreme per cufcle meter aod therefore ve had nothing to complain about. Vben I pointed out to bin that In ay opinion the 10 mlcrognu* value vould be difficult for * 3 some of our lead plant* to meet, he told me of a secondary smelter In Peon* sylvonl* st vhlch 2k hour samples had been taken by the Dlrlelcm and that p th* highest value obtained had been 3 mlcrogrmoa per cubic mrter. ?! In s enary, ve had a very Interesting discussion and the state sir pollution people vere very Interested In our research project*, but did not agree that their action in setting a standard at the present time la premature. Zt seems to me that vt must taka all necessary step* to nake certain that Mr vole* 1* heard before th* next meeting of th* Air Pollution Ccxmalttloo. These meet teg* are held et th* call of the Chairman, and th* next cm* has not been seted-ried a* yet. At the md of thl* report X list for you th* Boats of th* members of this Conslttlon. Z think ve sre faced vlth s rather eerlou* situation, a *lt-atli that Is sere aerlc'4 In its Implication* for th# future than it Is rlrfht nov, because, a* you )uv<v, se tooo e* ora jTvtrwvnt agency takes an acllcm of lb Is kind ve vtll hare many others vantlrg to do th# earns. I hare no concrete sug gestion* far action to offer to yr, et thl# time, but X thtrvk It behoove* *11 of us to make an elteayt to accumulate a* *"h factual data a* te pee stole about the air outside of our ovn plant*. In the msantUe ytur Staff OCMCKVZAUH 07 PCCT3YLVASIA nmjTXOT 07 amis AIR POLLOTICM OCMdSSICi Dr. Alien D. Brandt, Chalraeo Bethlehem 6tl Compay Bethlehem, P*on*7lenlA Boo. L. H. Bull Secretary of Agriculture Boo. B. B. Cbanribury Secretary of Kloe* aad Mineral Indue trlea Mr. Louie C. flolth r. 0. Box l8l Berehey, PecaaylTanla Boo. John K. Tabor Secretary of Caaaerce Mr*. Ruth S. Donahue tl I. Mrrttv St. Lock Bareo, Pennaylvaala Mr. Barold 7. Klkla Duo Oil Ccopoiqr 1600 Walnut Street Fhlladeljibta 3, Pennaylvaola Dr. B. B. Bchreak 31k BtRood Tlttaburgb 11, Tenoeylvealm Kr. Thoona J. White 830 Tbceae Rood Lafayette Bill, Moetgooery Co. Perr.,71 rania Boo. C. L. Wilber, Jr., M.D. Secretary of Beelib Boo. Villlao 7. Young Secretary of labor ead Iaduetry -g N 401.01 1