Document bvaRbLQEwpxVYEZo1j1L7Nm3

Lead Industries Association, Inc. 292 Madison Avenue New York. N.Y. 10017 Telephone: (212) 578-4750 \ February 13, 1986 (t.GrPh^ To: Lead Industries Association Environmental Health Commitee Lead Industries Association Regulatories Activities Committee FR: Giovlna L. Leone Director Environmental Health pyr RE: Joint Meeting of LIA, BCI, and SLSA regarding EPA Staff Paper on Lead Ambient Air Quality Standard. Attached are :the minutes to the January 21, 1986 joint meeting between LIA, BCI, and SLSA to discuss the EPA draft staff paper on the lead NAAQS. The Clean Air Science Advisory Committee is scheduled to meet on this in early March. Giovina L. Leone GLL/keg enclosure TEH 0412523 JOINT MEETING OF THE LEAD INDUSTRIES ASSOCIATION BATTERY COUNCIL INTERNATIONAL AND SECONDARY LEAD SMELTERS ASSOCIATION January 21, 1986 LIA Offices New York, NY A joint meeting of the LIA, BCI and SLSA was held at 10:30 a.m. on Tuesday, January 21, 1986 at the LIA offices in New York City. The purpose of the meeting was to discuss the LIA sponsored TRC study into the impact of a reduced ambient air quality standard for lead on the entire lead industry. Gale Hoffnagle of TRC presented information on the progress of the study to the representatives of LIA, BCI and SLSA. Gale began with a discussion of EPA's oost benefit analysis. According to EPA, the copt analysis, done by GCA, is complete while the benefits analysis remains incomplete. An outline of the benefits analysis will be presented at a Clean Air Science Advisory Board meeting scheduled for early March, but will not be finalized until after CASAC reviews the health criteria upon which it is based. Gale summarized the TRC study as: 1. determination of the impact area of plant emissions in terms of lead in air 2. determination of resulting costs and benefits after careful examination of controls necessary to meet target air lead levels and number of children actually at risk of having blood lead levels over 20 ug/dl. TRC went about determining this through a questionnaire which was sent out to the lead industry with the assistance of LIA, BCI and SLSA. The categories of the lead industry include: primary smelters, secondary smelters, battery manufacturers, lead chemical manufacturers and one TEL facility. According to Gale, the response was adequate, but not as good as it could be (see attachment 1). All the primary smelters have either sent or are in the process of completing their questionnaires. Of the battery companies, 38/138 have responded representing five major companies. Of the secondary smelters, 9/26 responded, which will make analysis of this group difficult. Of the lead chemical facilities, none have responded. The one TEL facility has responded. Unfortunately, the only way to get a more accurate count of the children at risk than the EPA Battye count of 2^0,000 is to obtain it from the questionnaire. Another important factor is determining the distances from each facility where air lead levels drop off. According to most data, a concentration of 1.5 ug/m3 occurs at the fenceline and significantly drops off within 1 kilometer from the fenceline. Given this information along with the number of children living at various distances from the plant, a determination of the actual number of children at risk can be made. 1 TEH 0412524 DUP050453576 N 30999.01 With regard to air modelingi it appears that a significant amount of data is available for primary and secondary facilities, but not very muoh for battery plants. The questionnaire has revealed 6 blood lead studies that have not been published. This will help to establish how many children are at risk of getting high blood lead levels as a result of exposure from nearby facilities. Two additional studies at an RSR and USS Lead facility were brought up at the meeting. According to the studies which TRC ha3 evaluated the highest number of children to have blood lead levels above 20 was 6. Gale completed the update of the study with a discussion of TRC's preliminary cost benefit analysis (see attachment 2). According to the benefit analysis, there are an estimated 57,753 children living around lead facilities. If 6$ are at risk, then the total number at risk is 12 million, a significant reduction ffrom the 240,000 count. It becomes apparent why EPA is so interested in including hypertension as a health effect. When adults are included, the benefit costs rise significantly according to the methodology used in the lead in gasoline proceedings. Even though the cost analysis is complete, it probably won't be presented at the CASAC meeting since it is a science advisory group. TRC will be coordinating their cost numbers with a Bureau of Mines study that is presently being conducted with the primary industry. A BOM study with secondaries is also being coordinated. Members of the committee volunteered to contact those companies which have not responded to the questionnaire. There was some discussion about whether or not a macro-economic study should be completed by TRC on the impact of this regulation and others on the lead industry. Of particular importance is the impact this regulation will hare on secondary smelters since many are closing and others feel certain that closing of their facilities are imminent if a reduction in the lead NAAQS is accomplished. There was a suggestion that later in the process other interested government and quasi government agencies should be informed of impact, this regulation may have on the industry 0MB is among the groups that were mentioned. LIA has been in contact with 0MB and they seem very receptive to any information we could provide them. The EPA has al30 indicated interest in obtaining our data before the CASAC meeting. A decision was made to provide them with an updated count of facility closings and possibly a count of the number of children at risk. 2 TEH 0412525 DUP050453577 Children GCA 7 Primaries & Refining 5 kilometers - Tetra Alkyl Lead 2 kilometers 60 Secondary 2 kilometers 132 Battery 1 kilometer Reporting 4 Children 10,031 Open 6 Children 15,046 l 365 1 365 6 5,183 26 22,459 39 5,619 138 19,883 21,198 57,753 If all require assistance ($3500) If 6% Estimate of Adult men (40-59yr) If all require treatment for HI $220/yr for 10 years If ,291% have heart attacks ($60,000) If .06% have strokes ($44,000) If .286% die (1M) 202M 12M 28,805 63M 5M .8M ' 82M 151M GCA 240,000 kids If all If 6% 840M 5M TEH 0412526 DUP050453578 N 30999.02 Control Costs (5ug/m3) Primary and Refining Tetra Alkyl Secondary Battery D+M over 10 years Compare to benefit for children . for adults for both Capitol (M) 45.6 3 39.2 49.4 137.2 TOTAL COST 04M (M) 1.4 .5 2.7 10.4 15.0 150 287.2K 12M 151M 163M TEH 0412527 DUP050453579 TEH 0412528 ...jsp.' 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