EPA 450-8-90-022
REVIEW OF THE NATIONAL AMBIENT AIR QUALITY STANDARDS FOR LEAD:

      ASSESSMENT OF SCIENTIFIC AND TECHNICAL INFORMATION
                      OAQPS STAFF PAPER
               Air Quality Management  Division
         Office  of Air Quality Planning and Standards
             U.S. Environmental Protection Agency
              Research Triangle Park, N.C. 27711
                        December  1990

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                                    Preface

      Though this document was finalized in December 1990, it does not
incorporate information from all  the potentially relevant studies of lead
health effects or exposures that  were published after March 1989.  However,
this document does reflect the complete Lead Criteria Document,  comprised of:
1) the Air Quality Criteria for Lead, 1986;  2) the Addendum to the Air Quality
Criteria for Lead, 1986; and 3) the Supplement to the 1986 Addendum to the Air
Quality Criteria for Lead, 1990.

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                               Acknowledgments
      This staff paper is the product of the Office of Air Quality Planning
and Standards.  The principal authors include Jeff Cohen, Gail Brion, and John
Haines.  Technical contributions were provided by David McLamb, Neil Berg, and
Neil Frank.  THe report incorporates comments from OAQPS, the Office of
Research and Development, the Office of General Counsel, and the Office of
Drinking Water within EPA, and was formally reviewed by the Clean Air
Scientific Advisory Committee.
      Helpful comments were also submitted by  independent scientists, and by
environmental and industry groups including the Environmental Defense Fund,
the Lead Industries Association,  and the International Lead and Zinc Research
Organization.
      The authors wish to thank Tricia Crabtree, Teresa demons, and Virginia
Wyatt for excellence in word processing and overall secretarial assistance.

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                               Ill
                        TABLE OF  CONTENTS
                                                             Page
List of Figures 	    v
List of Tables 	    vi
Executive Summary	    vii
I.   Introduction 	    I-l
     A.  Purpose 	    I-l
     B.  Background 	    1—2
     C.  Approach 	    1-3
II.  Air Quality and Exposure Considerations 	    II-l
III. Critical Elements in the Review of the
     Primary Standard 	  III-l
     A.  Sensitive Population Groups 	  III-l
     B.  Mechanisms of Toxicity 	  III-5
     C.  Effects of Concern  	  111-10
     D.  Dose-Response Information 	  III-ll
     E.  Summary of Health Risks Associated
         with Different Blood Lead Levels of Concern ....  111-51
IV.  Factors to be Considered in Selecting a Primary
     Standard for Lead 	    IV-1
     A.  Averaging Time 	    IV-1
     B.  Form of the Standard and Sampling Frequency ....    IV-7
     C.  Level of the Standard 	    IV-16
     D.  Summary of Staff Conclusions and
         Recommendations 	    IV-33
V.   Critical Elements in the Review of the Secondary
     Standard	    V-l
     A.  Effects In Terrestrial Ecosystems 	    V-l

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                                IV
     B.  Effects in Aquatic Ecosystems 	    V-5
     C.  Staff Conclusions and Recommendations 	    V-7
Appendix A.  Summary of Probability Encodings on
             Lead-Induced Health Effects 	    A-l
             A.  Encoding Judgments on Lead-Induced
                 Hemoglobin Decrements 	    A-3
             B.  Encoding Judgments on Lead-Induced
                 IQ Decrements 	    A-8
             C.  Discussion 	-.. .    A-15
Appendix B.  Exposure Case Studies:  Sensitivity
             Analyses 	    B-l
Appendix C.  CASAC Closure Report	•	    C-l
References

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                         LIST OF FIGURES

Number                                                       Page

2-1       Principal Pathways of Human Exposure to       .     II-l
          Lead and Subsequent Physiological
          Distribution

2-2       National Trend in Air Lead Emissions,              II-3
          1978-1987

2-3       Trends in Maximum Quarterly Air Lead               II-5
          Concentrations at Urban and Point-Source
          Oriented Monitor Sites

2-4       Maximum Quarterly Average Air Lead                 II-7
          Concentrations in U.S. for 1987

2-5       Daily Variability of Ambient Lead                  II-9
          Concentration at Omaha Refinery, July,
          August, and September, 1984

3-1       Multi-organ Impact of Reductions of              111-19
          Heme Body Pool by Lead

3-2       Cumulative Frequency Distribution of             111-33
          Verbal IQ Scores in Subjects with Low
          or High Levels of Lead

A-l       Probabilistic Judgments of Experts Regarding       A-4
          Lead-Induced Hemoglobin Levels'< 9.5 M-g/dl in
          Children Aged 0-3 Years

A-2       Comparison of Judgments Across Experts Regarding   A-6
          Probability of Hemoglobin Levels <9.5 ng/dl,  in
          Children Ages 0-3 years at Different Blood Lead
          Levels

A-3       Probabilistic Judgments of Experts Regarding       A-ll
          Mean, Lead-Induced IQ Decrements for Low SES
          Group

A-4       Comparison of Judgments Across Experts Regarding   A-l2
          Mean IQ Decrements for Low SES Group

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                                vi


                          LIST OF TABLES

Number                                                       Page

2-1       National Air Lead Emission Estimates,             II-3
          1978-1987

2-2       Frequency Distribution of Maximum Quarterly       II-5
          Air Lead Concentrations

3-1       Populations Living Near Major U.S. Lead         III-4
          Point Sources

3-2       Summary of Lowest Observed Effect Levels        111-12
          for Key Lead-Induced Health Effects in
          Children

3-3       Summary of Lowest Observed Effects Levels       111-13
          for Key Lead-Induced Health Effects in Adults

3-4       Summary of Lead's Effects on Heme               111-15
          Biosynthesis and Related Systems in
          Children

3-5       Summary of Lead's Effects on the Nervous        111-22
          System

3-6       Significant Exposure/Effect Relationships       111-28
          from Key Prospective Studies

4-1       Alternative standard Forms and Their Relative    IV-9
          Stringency

4-2       Daily Air Lead Data from a Lead Refinery         IV-13

4-3       Estimated Children's PbB Levels Under            IV-23
          Alternative Lead NAAQS in 3 Case-Study
          Analyses:  1990-1996

4-4       Estimated Men's PbB Levels Under Alternative     IV-27
          Lead NAAQS in 3 Case-Study Analyses

B-l       Lower Bound Sensitivity Analysis:  Children's     B-2
          PbB Levels in 3 Case-Studies

B-2       Upper Bound Sensitivity Analysis:  Children's     B-3
          PbB Levels in 3 Case-Studies

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                             vii
                        EXECUTIVE SUMMARY

     This paper evaluates and interprets the available  scientific
and technical information that the EPA staff believes is most
relevant to the review of primary (health) and secondary
(welfare) National Ambient Air Quality Standards  (NAAQS) for lead
and presents staff recommendations on revising the standards.
Review of the NAAQS is a periodic process instituted to ensure
the scientific adequacy of air quality standards  and is required
by Section 109 of the 1977 Clean Air Act Amendments.  The
assessment in this staff paper is intended to help bridge the gap
between the scientific review contained in the EPA criteria
document "Air Quality Criteria for Lead", its 1986 Addendum and
1990 Supplement, the "Review of National Ambient  Air Quality
Standards for Lead:  Exposure Methodology and Validation" and the
judgments required of the Administrator in setting ambient
standards for lead.  The staff paper is, therefore, an important
element in the standards review process and provides an
opportunity for public comment on proposed staff  recommendations
before they are presented to the Administrator.

     Human exposure to lead occurs through multiple pathways
including: paint pigments, solder in food cans and plumbing, and
airborne emissions from motor vehicles and a variety of
stationary lead point sources.  Over the past decade, there has
been a marked decline in lead exposure.  Significant dietary
declines have resulted from the gradual phaseout  of lead in
solder and reductions in deposition of atmospheric lead.
Additional exposure reductions are expected due to the impact of
new drinking water regulations and the continued  shrinking leaded
gasoline market.

     Total lead emissions to air have dropped 94% between 1978
and 1987 resulting in an air lead level of 0.1 to 0.3 |ig/m3 in
most U.S. cities without a major lead point source.   Most of

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                              viii

this is directly attributable to the lead-in-gasoline phasedown.
Analysis indicated the largest single year drop in average air
lead concentrations (42%) occurred between 1985 and 1986 when the
lead content in gasoline shifted from 1.0 grams/gallon at the
start of 1985, to 0.5 grams/gallon in July 1985, and finally to
0.1 grams/gallon in January 1986.  The decline in air lead
attributable to leaded gasoline is expected to continue as the
leaded gasoline market shrinks.

     While these downward trends are encouraging, several
important sources of lead exposure persist.  The focus of this
review is on areas near stationary sources of lead emissions.
Although such sources in the past have not made a significant
contribution (as compared to lead-in-gasoline) to the overall
lead pollution across large, urban or regional areas, lead
emissions from such sources can have a significant impact on a
local scale; air, and especially soil and dust lead
concentrations have been associated with elevated levels of lead
absorption in children and adults in numerous lead point source
community studies.  Exceedances of the current NAAQS (1.5 |ig/m3)
are found only in the vicinity of nonferrous smelters or other
point sources of lead.

Primary Standard

     The staff has reviewed scientific and technical information
on the known and potential health effects of lead cited in the
Criteria Document, its 1986 Addendum and 1990 Supplement.  This
includes information on sensitive populations, mechanisms of lead
toxicity, health effects of concern, and relationships between
blood lead (PbB), the most commonly used index of exposure, and
different health effects of concern.  Based on this review, the
staff derives the following conclusions and recommendations.

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                                    xiii
         TABLE 1.   ESTIMATED CHILDREN'S (0-6 YRS.) PbB LEVELS UNDER
         ALTERNATIVE LEAD NAAQS IN 3 CASE STUDY ANALYSES:  1990-1996*
Case Study
(# Children) /
PbB Level*
                           Lead NAAQS Level  (|j.g/m3)
                            1.5               Monthly^
                 Baseline13  Quarterly0  1.5   1.25    1.0
                              0.75
                           0.5
Dallas
Mean PbB (|ig/dl)
% > 10 M-g/dl
% > 15 M.g/dl

East Helena (217}
                    6.9
                   14.2
                    1.3
 4.9
 2.2
0.08
 4.8   4.8    4.7   4.6    4.5
 1.9   1.7    1.5   1.4    1.2
0.06  0.05   0.04  0.04   0.03
Mean PbB (ng/dl)    6.2
% > 10 ng/dl        8.3
% > 15 ng/dl        0.6

Tampa flO^
                              5.2
                              2.9
                              0.1
           5.1   4.9
           2.6   2.1
           0.1   0.07
              4.8   4.6    4.4
              1.7   1.4    1.0
              0.05  0.04   0.02
Mean PbB (jig/dl) 10.
% > 10
% > 15
iag/dl
ng/dl
50.
12.
1
9
9
8
29
4
.3
.7
.6
7
23
3
.8
.4
.0
7.4
19.4
2.2
7.0
15.6
1.5
6.6
12.1
1.0
6.3
9.2
0.6
* Assumes soil Pb remains at baseline levels
* PbB distributions calculated assuming GSD = 1.42
to Baseline scenario represents current conditions for air quality,  as  well
  as soil and dust Pb.  Dietary intake assumed to be at 1990-1996  levels
0 Current NAAQS level and averaging time (calendar quarter)
** Alternative NAAQS levels with monthly averaging time

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                               xiv
     2)  A monthly averaging period would better capture short-
term increases in lead exposure and would more fully protect
children's health than the current quarterly average.

     3)  The most appropriate form of the standard appears to be
the second highest monthly averages in a 3-year span.  This form
would be nearly as stringent as -a form that does not permit any
exceedances and allows for discounting of one "bad" month in 3
years which may be caused, for example, by unusual meteorology.

     4)  With a revision to a monthly averaging time more
frequent sampling is needed, except in areas, like roadways
remote from lead point sources, where the standard is not
expected to be violated.  In those situations, the current l-in-6
day sampling schedule would sufficiently reflect air quality and
trends.

     5)  Because exposure to atmospheric lead particles occurs
not only via direct inhalation, but via ingestion of deposited
particles as well, especially among young children, the hi-volume
sampler provides a reasonable indicator for determining
compliance with a monthly standard and should be retained as the
instrument to monitor compliance with the lead NAAQS until more
refined instruments can be developed.

     The analyses summarized in Table 1 omit young children who
cannot be substantially affected by any changes in atmospheric
lead emissions under different standards.  These children (e.g.,
those with excessive pica and/or living in overtly deteriorated
lead-paint homes) total several million and require direct
parental and public health intervention to reduce their high-
level exposures.  Nevertheless, any reduction in air lead levels
can be expected to have at least a small beneficial effect on
these children and should be considered in establishing the lead
NAAQS.  Similarly, adult women whose blood pressure is affected
by ongoing lead exposure, and women experiencing bone

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                                XV
demineralization during osteoporosis (as well as during
pregnancy) and increased lead mobilization, will also benefit
from any reduction in ambient air lead levels.

     The results from Tampa should not be extrapolated since the
secondary smelter and battery plant modeled there were surrounded
by mainly non-residential areas and thus only 10 children and 20
men live close enough to these point sources to be significantly
effected by changes in emissions.  Further analyses are necessary
to determine whether these results are applicable to other point
source areas with small populations nearby.

     Because young children are exposed to, absorb, and retain
proportionally more environmental lead than other populations,'
the staff believes they are most responsive to changes in
atmospheric lead emissions and provide sensitive indications of
relative protection afforded by alternative NAAQS.  Any lead
standard designed to protect them should also protect other
sensitive groups evaluated quantitatively (adult men) or
qualitatively (pregnant women/fetus).  Case-study analyses of
children populations living near Dallas and East Helena smelters
indicate that substantial reductions in lead exposure could be
achieved through attainment of the current lead NAAQS.
Progressively smaller improvements are estimated for the
alternative monthly lead NAAQS levels evaluated, ranging from 1.5
      to 0.5 jig/m3.
     According to the best estimate analyses, over 99.5% of
children living in areas significantly affected by the smelters
would have PbB levels below 15 jttg/dl if the current standard (1.5
Mg/m3) were achieved.  However, the staff believes that
evaluation of alternative standards based on children's PbB
levels above 10 jug/dl is more appropriate given the health risks
associated with lead.  Reducing the NAAQS levels would reduce the

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                               xvi
estimated proportion of children with PbB levels above 10 jig/dl.
For the Dallas and East Helena case studies, assuming a GSD value
of 1.42, an estimated 8.3-14.2% of nearby children currently
exceed 10 jug/dl, whereas a monthly lead NAAQS of 1.5 A*g/m3 would
reduce this fraction to 1.9-2.6%, and a monthly NAAQS of 0.5
Mg/m3 would reduce it to 1.0-1.2%.  Because of unavoidable
background exposures to lead in the diet, historically-
contaminated soils and dusts, and maternal bone lead stores in
utero f no lead air emission standard can keep all children below
a PbB of 10 jug/dl.  It is estimated that even with zero air lead..
emissions, 0.7% of children would have PbB levels above 10 ng/dl
and there would be a range of average PbBs from 4.2 to 5.2 /ig/dl.
Compared to a zero air lead scenario, a NAAQS of 0.5 Mg/^3
appears to minimize the number of children with PbB levels above
10 /jg/dl, the range being from 1.0 to 1.2%.  The 0.5 /ug/m3 NAAQS
also appears to be a reasonable lower bound for consideration of
a revised lead standard because it would keep more than 99.97% of
the exposed children below a PbB of 15 jig/dl.  Intermediate
increments are indicated for lead NAAQS levels of 0.75, 1.0 and
1.25 /jg/m3.

     While the basis for a decision on the lead standard should
be the most sensitive population, i.e., young children, the case-
study results on adult men indicated small PbB reductions with
progressively lower monthly lead NAAQS levels evaluated,
beginning with 1.5 jjg/»3 down to 0.5 /ug/m3.  A PbB threshold for
blood pressure effects in men has not been defined.  Two PbB
levels, 10 and 12 /ig/dl, are selected to compare the relative
protectiveness of alternative lead NAAQS.  The results indicate
that a monthly NAAQS between 0.5 and 1.5 jug/m3 would result in
between 1.4 - 3.5% of non-occupationally exposed men with PbB
levels above 10 /jg/dl, compared to 7.2-12.1% at current baseline
exposures and 0.6% above 10 pg/dl simply because of non-air
background exposure.  The percentages above 12 ng/dl for this

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                               XVll
range of standards are estimated to be 0.3-0.9%, compared to  0.1%
due to background exposures.
SECONDARY STANDARD
     The staff review of available laboratory and field data
indicate that at high concentrations, lead can:

     1)   affect certain plants (inhibition of photosynthesis,
          reduced growth, changes in species composition);
     2)   affect fish (neurological changes);
     3)   alter the composition of soil microbial communities and
          inhibit invertebrate activity resulting in delayed
          decomposition, reduced nutrient supply, and altered
          soil properties (lower organic content).

Toxicological data suggests that domestic animals and wildlife
are as susceptible to the effects of lead as laboratory animals
used to investigate human lead toxicity risks.

     The available data also raise concerns about the continued
accumulation of lead in soil and sediment reservoirs.  Due to the
persistence of lead in the environment, such accumulations are
expected to continue as long as inputs exceed outputs.  Thus,
even at relatively low deposition rates, lead could affect an
ecosystem over time.  This concern is 'primarily directed to urban
and stationary, source areas that may already be approaching or
have exceeded their soil capacity to bind lead.

     Until a stronger data base is developed that more accurately
guantifies ecological effects of different lead concentrations,
the staff recommends that consideration be given to retaining a
secondary standard at or below the level of the current secondary
standard of 1.5 ng/m3.   If the level, averaging time, or form is
changed for the primary standard,  consideration should be given
to making a similar change for the secondary standard to
facilitate implementation.

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  REVIEW OF THE NATIONAL AMBIENT AIR QUALITY STANDARDS FOR LEAD:
        ASSESSMENT OF SCIENTIFIC AND TECHNICAL INFORMATION
                     OAQPS DRAFT STAFF PAPER
I.   INTRODUCTION        .                          ,

A.   Purpose

     This paper evaluates and interprets the most relevant
scientific and technical information reviewed in the EPA document
"Air Quality Criteria for Lead" (EPA, 1986a), the 1986 Addendum
to the Air Quality Criteria Document for Lead (1986b), and the
1990 Supplement to the Addendum (EPA 1990), that EPA staff
believes is most relevant to the review of the primary and
secondary National Ambient Air Quality Standards (NAAQS) for
lead.  This assessment is intended to help bridge the gap between
the scientific review contained in the air quality criteria
document and the judgments required of the Administrator in
setting ambient standards for lead.  Particular emphasis is
placed on identifying those conclusions and uncertainties in the
available scientific literature that the staff believes should be
considered in selecting the averaging times, forms, and levels
for the primary and secondary standards.  While the paper should
be of use to all parties interested in the standards review, it
is written for those decision makers, scientists, and staff who
have some familiarity with the technical discussions contained in
the criteria document,•the 1986 Addendum, and the 1990 supplement
(hereafter referenced as "CD", "CDA" and the "CDA Supplement",
respectively).

     A critical element to this review is the assessment of lead
exposure from multiple sources, including air, and prediction of
lead exposures  among sensitive populations under alternative
standards.   A separate staff report (EPA, 1989a) summarizes

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relevant information on lead exposure and presents the exposure
modeling methodologies that the staff believes should be
considered for the lead NAAQS exposure analysis.  Using
methodologies described and validated in that report, exposure
analyses of populations living near stationary lead sources are
presented here to better inform the Administrator of the
potential impacts of alternative standards.

B.   Background

     Since 1970 the Clean Air Act, as amended, has provided
authority and guidance for the listing of certain ambient air
pollutants that may endanger public health or welfare and the
setting and revising of NAAQS for those pollutants.  Primary
standards must be based on health effects criteria and provide an
adequate margin of safety to ensure protection of public health.
As several judicial decisions have made clear, the economic and
technological feasibility of attaining primary standards are not
to be considered in setting them, although such factors may be
considered to a degree in the development of state plans to
implement the standards (D.C. Cir., 1980, 1981).  Further
guidance provided in the legislative history of the Act indicates
that the standards should be set at "the maximum permissible
ambient air level . . . which will protect the health of any
[sensitive] group of the population."  Also, margins of safety
are to be provided such that the standards will afford "a
reasonable degree of protection . . . against hazards which
research has not yet identified" (Committee on Public Works,
1974).  In the final analysis, the EPA Administrator must make a
policy decision in setting the primary standard, based on his
judgment regarding the implications of all the health effects
evidence and on the requirement that an adequate margin of safety
be provided.

     Secondary ambient air quality standards must be adequate to
protect the public welfare from any known or anticipated adverse

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                               1-3

effects associated with the presence of a listed ambient air
pollutant.  Welfare effects, which are defined in section  302(h)
of the Act, include effects on vegetation, visibility, water,
crops, man-made materials, animals, economic values and personal
comfort and well-being.  In specifying a level or levels for
secondary standards the Administrator must determine at which
point the effects become "adverse" and base his"judgment on the  .
welfare effects criteria.

     The current primary standard for lead (to protect public
health) is 1.5 micrograms per cubic meter (jig/m3), maximum
arithmetic mean averaged over a calendar quarter.  The current
secondary standard for lead (to protect public welfare) is
identical to the primary standard. For both primary and secondary
standards, lead and its compounds are measured as elemental lead
and currently are collected using a high volume air sampler.

C.  Approach

     The approach used in this paper is to assess and integrate
information derived from the criteria review and the OAQPS staff
exposure report (EPA, 1989a) in the context of those critical
elements that the staff believes should be considered in the
review of the primary and secondary standards.  Particular
attention is drawn to those judgments that must be based on the
careful interpretation of incomplete or uncertain evidence.  In
such instances, the paper states the staff's evaluation of the
evidence as it relates to a specific judgment, sets forth
appropriate alternatives that should be considered, and
recommends a course of action.

     Since the original lead NAAQS was established in 1978, the
use of lead in gasoline has dropped dramatically.  As a result,
controlling and monitoring air lead emissions has shifted  from an
area-wide problem to one of specific,  localized sources.
Accordingly,  the focus of this paper is on the effects of
inorganic lead, either airborne or deposited from the air  onto

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                                1-4
dusts, soils, vegetation, food, and water, from point sources of
lead.  The multi-media aspects of lead exposure, related to both
air and non-air sources, are addressed in the staff exposure
report (EPA, 1989a).  Hazardous concentrations of lead in and
around lead-based painted housing and in soils with historical
accumulations will" remain persistent problems not significantly
diminished by any. change in ambient air emissions.  Such- hazards
will require further coordinated public health intervention
measures by parents and appropriate governmental activities.

     Section II summarizes information on current air lead
exposures; information on other routes of exposure is presented
and incorporated into exposure modeling methodologies in EPA
(1989a).  Section III addresses the critical elements in the
review of the primary standards including:  1) identification of
the most sensitive population groups; 2) mechanisms of toxicity;
3) health effects of concern; and 4) dose-response information
relating the health effects of concern to lead exposures.
Drawing on information presented in Sections II and III and the
OAQPS staff exposure report (EPA, 1989a), Section IV identifies
and assesses the critical elements the staff believes should be
considered in selecting an averaging time, form, and level of the
primary standard.  Results from exposure analyses described in
the staff exposure report are presented in Section IV that
include estimated blood lead distributions in sensitive
populations under alternative lead NAAQS.  Staff conclusions
regarding alternative policy options in each of these areas are
also presented.

     Section V examines relevant information on the welfare
effects of lead and presents the staff recommendation concerning
the secondary standard.

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II.  AIR QUALITY AND  LEAD  EXPOSURE CONSIDERATIONS

     Human exposure to  lead  occurs through multiple pathways,  and
can be traced primarily to lead in paint pigments, solder  in
canned foods and plumbing, and atmospheric emissions from  motor
vehicles and stationary lead sources.   Although airborne lead  is
a principal starting  point of environmental contamination, oral
intake of deposited atmospheric lead is often the primary
identifiable factor in  predicting blood lead levels, particularly
in young children.  It  is  necessary, therefore, to assess  not
only human exposures  through direct inhalation of lead containing
particles, but also the ingestion of lead deposited onto soil,
dusts, vegetation and other  environmental surfaces.  The
principal pathways of human  exposure can be seen in Figure 2-1.
Figure 2-1.
PRINCIPAL PATHWAYS OF HUMAN EXPOSURE TO LEAD AND SUBSEQUENT
PHYSIOLOGICAL DISTRIBUTION. ADAPTED FROM CD, FIGURE 7-1.

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                            II-2
     The OAQPS staff exposure report (EPA, 1989a) discusses the
relevant information on the principal pathways of lead exposure:
airborne lead, and lead in soil, dust, diet, water and paint.  As
detailed in that report and the CD, there have been marked
downward trends in lead exposure from several sources.  For
example, total lead emissions to air dropped 94% between 1978 and
1987 (see Table 2-1 and Figure 2-2).  Most of this decline is
attributable to reductions in gasoline lead consumption, which
has dropped by about 90% since 1978.  This trend will continue as
compliance with the 1986 gasoline phasedown regulations
progresses, and as the fleet of lead-burning cars shrinks.  In
addition, lead emissions from stationary sources have been
substantially reduced by control programs oriented toward
attainment of the particulate matter and lead NAAQS.  In 1987,
lead emissions from industrial sources (e.g., primary and
secondary smelters) dropped by more than one-half from levels
reported in the late 1970's (EPA, 1989c).  Emissions of lead from
solid waste disposal are down 35% since the late 1970's but now
represent the second largest category of total air lead emissions
behind transportation.  If emissions from sewage sludge
incineration were included, the two categories would be nearly
equal.  While aggregate solid waste emissions are relatively high
because of the numerous sources, local air quality impacts from
individual incinerators are generally low, particularly compared
to major stationary industrial sources.

     The overall effect of the different control programs has
been paralleled by a major reduction in ambient air lead levels,
which now average .between 0.1 and 0.3 ng/ra3 in most U.S. cities
without major point sources.  Recent (1980-1986) air quality data
for both point source-oriented sites (predominantly "SLAMS"
sites), roadside sites ("NAMS", micro-scale) and other sites
(middle-scale, neighborhood), are summarized in Table 2-2
(Battye, 1988a).  By 1986, the only quarterly average
concentrations over 1.5 iJig/m3 were recorded at monitors near
stationary sources.  Twelve counties in the U.S. reported

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                                           II-3
            TABLE  2-1.  NATIONAL AIR LEAD EMISSION ESTIMATES,  1978-1987
Source Category

Transportation

Fuel Combustion

Industrial
  Processes

Solid Haste*

    Total
                       (thousand setric tons/year)

1978    1979     1980    1981    1982    1983     1984    1985    1986    1987




112.4   94.6     59.4    46.4    46.9    40.7     34.7    15.5     3.5     3.0

  6.1    4.9     3.9     2.8     1.7     0.6     0.5    0.5     0.5     0.5
  5.4    5.2     3.6

  4.0    4.0     3.7

127.9  108.7    70.6
 3.0     2.7     2.4     2.3     2.3     1.9     2.0

 3.7     3.1     2.6     2.6     2.8     2.7     2.6

55.9    54.4    46.3    40.1    21.1     8.6     S.I
 RIS:  fie sns of sob-categories 137 not equal total doe to rounding.
SOURCE:   EPA,  1989c
* Does  not include lead  emissions  from sewage sludge incineration  which currently
  amounts to 0.2  - 0.3 thousand metric tons per year.
       200
              LEAD EMISSIONS, 103 METRIC TONS/YEAR
                                   SOURCE CATEGORY
                                  C3 TRANSPORTATION
                                  O FUEL
                                            INDUSTRIAL PROCESSES
                                            SOUD WASTE
        150-
        100-
           1978    1979   1980   1981    1982   1983    1984   1985   1986   1987
 Figure  2-2.  NATIONAL TREND IN AIR LEAD EMISSIONS,  1978 -  1987 (from EPA,  1989c)

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                               11-4
quarterly averages above 1.5 ng/m3 in the 1986-1987 period; 13
more were on the margin of exceeding the NAAQS but either had
inadequate numbers of samples or were slightly below the standard
level.

     Trends in maximum quarterly averages for 97 urban- and 24-
point source sites over 10 years (1978-1987) are illustrated in
Figure 2-3.  Data selected for this trends analysis had to
satisfy data completeness criteria of at least 8 out of 10
"valid" years of data in the 1978-1987 period.  A year was
included as valid if at least 3 of the 4 quarterly averages were
available (EPA, 1989d).  Some of the dramatic improvement in air
quality near point sources is attributable to plant shutdowns.
Average air lead trends were also studied over the shorter period
1983-1987 to include more monitoring sites (1989c).  This
analysis indicated that the largest single year drop in average
lead concentrations, 42 percent, occurred as expected between
1985 and 1986, because of the shift from 1.0 grams/gallon of lead
in leaded gasoline for the first half of 19ff5 to 0.5 grams/gallon
of lead in July 1985, and finally to 0.1 grams of lead/gallon on
January 1, 1986.  Average lead concentrations in 1987 declined by
19% from 1986 levels.  This trend is expected to continue
primarily because the leaded gasoline market will continue to
shrink.  Some major petroleum companies have discontinued
refining leaded gasoline because of the dwindling market.

     There have also been significant declines in dietary lead
intake as a result of the gradual phaseout of lead solder in
canned food manufacturing, and reductions in atmospheric
deposition as ambient lead levels have declined (Section II. E;
EPA, 1989a).  Additional reductions are expected as the recent
ban of lead solder in plumbing takes effect and compliance with a
revised National Primary Drinking Water Regulation for lead
occurs within the next few years.  These recent and anticipated
changes in nationwide exposures, and other expected future trends
in contributions from non-air sources of lead (e.g., contaminated

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                                              J.J.-J

                 TABLE 2-2.  FREQUENCY DISTRIBUTION OF MAXIMUM QUARTERLY AIR  LEAD CONCENTRATIONS
          Site  type/time frame
                                     Percentage of  sites in concentration
                                      ranges (concentrations In
                                   <0.5
                                          0.5-1.0   1.0-1.5   1.5-Z.O  >Z.O
                                                                      Number  of
                                                                        site-
                                                                 Mean   years
          1980  through 1986
            A11 monitors°            77.5     15.4      3.2       1.5     2.3   0.3y   3,279
            NAMSC                   76.9     17.2      4.7       1.1     0.2   0.41     471
            SLAMS                   7b.4     16.7      2.8       1.7     3.4   0.38   1,158
            Mlcroscale roadside"     24.1     37.9     25.9      10.3     1.7   0.74      58
            Middle scale            45.7     47.1      7.1       0.0     U.O   0.46      7U
            Neighborhood scale       68.7     24.3      7.0       0.0     0.0   0.37     115

          1986  only
            All monitors            93.0      2.5      1.2       1.6  .   1.8   0.17     514
            NAMS                    97.5      1.3      1.3       0.0     0.0   0.14      79
            SLAMS                   92.9      2.2      0.9       1.3     2.7   0.21     226
            Mlcroscale roadside     100.0      0.0      0.0       0.0     0.0   0.18       9
            Middle scale           100.0      0.0      0.0       0.0     0.0   0.12       9
            Neighborhood scale       94.4      0.0      0.0       5.6     0.0   0.14      18
1987 only
All monitors
NAMS
SLAMS

93.0
97.4
93.1

2.8
0.0
2.3

1.7
1.3
1.7

0.4
0.0
0.0

2.0
1.3
2.9

0.20
0.20
0.20

458
78
175

          •Data are from the SAROAO and AIRS systems and represent  the number of site-years  for
           which the maximum quarterly concentration fall within the designated ranges.  To  be
           included, a valid site-year- must have at least three quarters of data with at least 6
           observations per quarter.
blncludes sites  previously classified into categories (e.g.,
 meet  any of the current definitions.
                                                                   "urban")  that do not
          CNAMS  refers to the National  Ambient Monitoring Station network, while SLAMS refers
           to the State and  Local Ambient Monitoring Station network.  Each of  these two networks
           includes both roadside and point source monitors; however, in the case of lead, the NAMS
           network tends to  focus on roadside sites, while the SLAMS network incorporates more
           point sources and other special purpose monitors.

          Mlcroscale sites  were within 5-15 meters from a major roadway.  Middle scale sites
           had further setbacks and define concentrations up to several city blocks.  Neighborhood
           scale sites define concentrations in more extended areas of uniform  land use within
           cities (0.5-4 km2).  After 1986, data collection at these sites stopped.

          Source:  Battye (1988«)
00
3
                     POINT SOURCE SITES (24)      a URBANSITES_(97)	
                1978  1979  1980   1981   1982  1983  1984  1985  1986  1987
    FIGURE  2-3.  TRENDS  IN  MAXIMUM QUARTERLY  AIR LEAD  CONCENTRATIONS  FOR
                     URBAN AND  POINT-SOURCE  ORIENTED MONITOR  SITES  (EPA,  1989c)

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                            II-6

soils and dusts), are important considerations in estimating lead
exposures among sensitive populations under alternative lead
NAAQS (see Section IV.C).

     While these downward trends are encouraging, several
important sources of lead exposure persist.  Lead-based paint
continues to be the major- source of high-dose lead exposure.and
symptomatic lead poisoning for children in the U.S.  As discussed
in Section III.A, children excessively exposed to lead-based
paint cannot be protected by a lead NAAQS and quantitative
exposure analyses for them will not be presented in this paper.
Similarly, soils contaminated by a long history of atmospheric
lead deposition will remain a potential hazard around roadways
and closed industrial facilities and will not be substantially
affected by changes in the lead NAAQS.

     The focus of this review is on areas near stationary sources
of lead emissions.  Although such sources in the past have not
made a significant contribution (as compared to lead-in-gasoline)
to the overall lead pollution across large, urban or regional
areas, lead emissions from such sources can have a significant
impact on a local scale; air, and especially soil and dust lead
concentrations have been associated with elevated levels of lead
absorption in children and adults in numerous lead point source
                                         *
community studies (CD, Chapter 11).  Figure 2-4 displays the
maximum quarterly average air lead concentrations in the nation.
Exceedances of the current NAAQS (1.5 \JLg/m3)  are  found, only  in
the vicinity of nonferrous smelters or other point sources of
lead.  When assessing the available air quality data, it is
important to recognize that up to this time, the focus of the
monitoring networks has been on mobile rather than stationary
sources of lead.  Thus the available data may under-represent or
understate stationary source problems.

     High lead concentration levels which are found around lead
smelters in particular, result mainly from fugitive emissions

-------
II-7
                   s .
                         k&
                      ^ O <~> §5

                      "23 8 fei
                   i§?!i|2g
                   5C »-< 3C U CC OS i—i
                   s « s g « a „
                   I

-------
                          II-8

predominately made up of large (> 7 micrometers, or nm) lead
particles resulting from materials handling, furnace upsets, and
furnace charging and tapping operations (Landrigan et al., 1975;
Jennett et al., 1977; Battye et al., 1985).  Beyond the immediate
area («2 km) of lead stationary sources, process emissions from
stacks, predominant as lead sulfates and oxides with a size range
between 1 and 10 jim, become the major source of lead in soils and
air (Dorn et al., 1976; Roels et al., 1980; Davidson and Osborn,
1984).  A recent study of controlled process emissions from three
non-ferrous smelters (1 zinc, 1 lead, and 1 copper smelter)
reported that the mass median aerodynamic diameters (MMAD) of
process particulate emissions are near 1 \i-rn or less (Bennett and
Knapp, 1989).

     Size-specific data collected near primary and secondary
smelters and battery, plants indicate approximately 25% of ambient
lead particle mass is less than 2.5 p.m MMAD, 20% is between 2.5
and 15 pirn, 40% is between 15-30 urn, and 15% is larger than 30 |im
(Cohen, 1987).  It should be noted, however, that for every lead
smelter, refiner, or manufacturer, the particle size distribution
will be unique to that facility depending on the proportions and
types of fugitive and controlled emissions present.

     Because of fugitive emissions and process operating
parameters, air guality levels in close proximity of stationary
sources can vary significantly day-to-day.  While daily sampling
data in the vicinity of major sources is sparse, one monitor near
(100 meters) a lead refinery in Omaha was operated on a daily
basis during 1984.  Figure 2-5 illustrates the day-to-day
variation in observed air quality levels for the three month
period of July, August, and September 1984.

     Other months of the year displayed similar variations, but
July-September was chosen as representative of a period of usual
plant operations.  It is interesting to note that despite the
high daily peaks, the quarterly average air lead concentration

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Concentration (ug/m3)
       12
       10
                                                  July
           1    3   5   7   9   11   13  15  17   19  21  23   25  27  29
Concentration (ug/m3)           Day of month
       20
       15
       10
                  August
           1357
Concentration (ug/m3)
      16
11   13  15  17  19  21  23  25  27
    Day of month
                                                            29  31
                             11.  13  15  17  19  21  23  25   27
                               Day of month
                                 29
  FIGURE 2-5.  DAILY VARIABILITY  OF AMBIENT LEAD  CONCENTRATION
               AT  OMAHA REFINERY,  JULY,  AUGUST, SEPTEMBER, 1984
   * Denotes where data are discontinuous

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                             11-10

for the period, composed of l-in-6 day (1/6) samples, was 1.51
M-g/m3  which would  demonstrate  attainment  of the current NAAQS.
If all of the available daily data are used for this quarter, the
average concentration is 2.84 |j.g/m3.   The air quality monthly
averages, composed of 1/6 day sampling for this quarter are  .832,
.65, and 3.05 iig/m3,  respectively.  However,  when  computing
monthly averages,  the 1/6.day average is not always less than an
average computed from all available daily data.  Several monthly
averages from this data set show larger 1/6 day averages than
averages comprised of daily samples.   For example, the month of
May had a monthly average of 5.07 based on 1/6 sampling and a
monthly average of 2.44 based on daily sampling.  Three other
months that year displayed a similar but less extreme pattern.
As this illustrates, the degree of daily variability in air lead
levels around major lead point sources, coupled with the
available data on particle size distributions, has important
implications when considering the appropriate averaging period,
form,  and sampling methodology for the lead NAAQS.  These issues
are discussed more fully in Section IV.

-------
III. CRITICAL ELEMENTS IN THE REVIEW OF THE PRIMARY STANDARD

     To characterize and assess risks associated with alternative
lead NAAQS, information is necessary on:  a) sensitive
populations;  b) mechanisms of lead toxicity;  c) health effects
of concern; d) relationships between blood lead (i.e., "dose")
and different health effects (i.e., "response"); and e) the
effects of alternative lead NAAQS on blood lead distributions
among the sensitive populations.  As part of the current lead
NAAQS review, OAQPS staff is estimating blood lead responses
under different standards using methods that account for past,
current, and future exposures to lead in food, water, soil,
dusts, and air, and the cumulative effects of lead in the
environment as well as in different tissues within the body.  A
separate staff report has been prepared to ensure that complex
multi-media modeling methodologies are fully documented and
reviewed (EPA, 1989a).  The exposure methodologies described in
that supplemental report have been used to predict, under
alternative lead NAAQS, blood lead distributions in populations
living near lead point sources.  Results of three "case studies"
are presented in Section IV.C.   This section summarizes
information on the other critical elements needed to.determine a
primary lead NAAQS.

A.   Sensitive Population Groups

     Lead is harmful to any exposed organism.  At least three
populations have been identified as especially sensitive:  pre-
school age children, pregnant women—as exposure surrogates for
the fetus,  and middle-aged men.  Several factors predispose young
children to lead-related risks:  1) normal mouthing behavior
(e.g., finger licking and immature dietary habits), as well as
abnormal ingestion of non-food  items ("pica"), which can result
in excessive ingestion of lead-contaminated soils and dusts; 2)
greater lead absorption and retention rates; 3)  greater
prevalence of nutritional deficiencies which enhance

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                          III-2

gastrointestinal lead absorption; 4) relatively greater
proportion of lead body burden in labile pools (e.g., soft
tissues) rather than in slow exchange pools (e.g., dense bone
matrix) compared to adults; 5) a less developed blood-brain
barrier that can allow greater entry of lead into the brain; and
6) an inherently greater physiological sensitivity of developing
tissues and organs, as indicated by heightened hematological and
neurological responses to lead among children.

     Physiological sensitivity to lead is also high during fetal
development when the central nervous system is undergoing its
most pronounced growth.  Persistent effects on neurological
function have been observed following in vitro lead exposure in
experimental animals.  Early developmental impairments associated
with fetal exposure have been found in several human longitudinal
studies (see Section III.D.2).  The pregnant woman is considered
sensitive not only because of risks of delivery complications,
but because she is the exposure vehicle for the fetus since lead
is readily transferred across the placenta.  As discussed in the
lead exposure staff report (EPA, 1989a), blood lead estimates for
pregnant women will not be made under alternative lead NAAQS in
this review.  This decision was made jointly by EPA staff and the
CASAC subcommittee on the lead NAAQS exposure modeling (see
Appendix E; EPA, 1989a) because of the lack of biokinetic data
for pregnancy that could be used to estimate the distribution of
lead among tissues (including fetal) during this complex and
dynamic metabolic period.  As discussed in Section IV.C., after
accounting for the relative contributions to the fetus of
maternal bone lead stores versus contemporaneous environmental
exposures to young children, it appears reasonable to consider
children as the most sensitive group for purposes of this review.

     Blood lead has been found in some recent studies to be a
small, but significant factor in predicting blood pressure in
adult men (see Section III.D.5.), and to a lesser extent in adult
women (Schwartz, 1989), including pregnant women (Rabinowitz et

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                             III-3

al., 1984).  In the largest of these studies, the association  was
strongest in white males, ages 40-59 years  (Pirkle  et  al.,  1985).
Because black men are in general more susceptible to blood
pressure changes, the impacts of alternative  lead NAAQS  on  blood
lead distributions for both white and black middle-aged  men will
be presented.

     Post-menopausal women also appear to be  at increased risk
due to major changes in mineral metabolism and in bone lead
mobilization (Silbergeld et al., 1988); at this time,  there are
insufficient data to quantify their risks under alternative
standards.

     Estimated numbers of the three sensitive population
subgroups and total populations living around major, operating
lead point sources are given in Table 3-1.  Populations  living
within 5 kilometers (km) of 5 primary lead smelters and  1 primary
refinery, within 2 km of 23 secondary lead smelters, and within 1
km of 87 lead-acid battery plants were estimated using U.S.
Census Bureau-defined block groups or enumeration districts
(Battye, 1988b).  These distances were selected to  include  all
areas affected by emissions resulting in air lead levels of at
least 0.25 M-g/m3 from the different sources, and not necessarily
the high-impact areas.  In the exposure modeling discussed  in
Section IV.C, only populations exposed to air-lead  levels at
least as high as 0.4 ng/m3 are analyzed.

     Many more Americans can be identified as especially
susceptible to lead toxicity because of excessive exposures to
lead in paint,  drinking water, and contaminated soil from
historical deposition.  It is estimated that in 1980,  between  6.2
and 13.6 million children under age 7 lived in homes containing
hazardous levels of lead in paint surfaces, as defined by CDC,
with between 235,000 to 840,000 of them residing in unsound
housing conditions (e.g., peeling paint, cracked plaster) (Pope,
1986).   Lead-based paint, in combination with poverty,  poor

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                              III-4
       TABLE 3-1.
POPULATIONS LIVING NEAR MAJOR U.S. LEAD
       POINT SOURCES*
SOURCE TYPE
(Number Ooeratina^
    Total.
    Peculation
Children*
   Women of
Child-Bearing Adult
    Aaeto       Men0
Primary Smelters and
Primary Refinery ( 6 )
Secondary smelters (23)
Battery Plants (87)
136,265
114,301
322,000
14,649 32,700
12,165 27,471
34,269 77,400
13,052
10,965
30,890

*Distances given in text.  Point sources operating as of
February, 1988.
"Children 0-6 years of age.
toln any given year, pregnant women comprise about 7% of all women
of child-bearing age (15-44 years).
=Adult men 40-59 years of age are focused on because the
relationship between blood pressure and PbB appears strongest in
that age group.  Significant associations have been found,
however, for all ages of adult men and women (>20 years of age).

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                                IX
     1)   Everyone is susceptible to toxic effects from lead.
The major subgroups of the population who appear to be especially
sensitive are young children, middle-aged men, and pregnant women
and their fetuses.

     2)   Although it remains uncertain whether a common
underlying mechanism is involved in the diverse functional
impairments produced by lead, it does appear that lead affects
biological systems directly, rather than through metabolic
transformation, and that there may be no biological threshold for
effects of lead ions at subcellular or cellular sites of action.

     3)   The major low-level effects of concern include:
               Heme biosynthesis and related functions
               Neurological development and function
          -    Reproduction and physical development
               Kidney function
          -    Cardiovascular function

     4)   The critical dose-response findings at low PbB levels
are as follows:
               Inhibition of the activity of enzymes involved in
               red blood cell metabolism, ALA-D and Py-5-N, at
               10-15 ng/dl and possibly below, with no evident
               threshold.
               Interference in heme synthesis indicated by
               elevated EP (erythrocyte protoporphyrin) levels at
               12-23 ng/dl in children, depending on their iron
               status.
               Interference with vitamin D hormone synthesis .in
               children with no apparent threshold down to the
               lowest levels measured (12 p,g/dl);
               Reduced auditory function in children with no
               apparent threshold down to the lowest measured
               levels (4-6 M-g/dl);
               Altered electrical brain wave activity with no
               evident threshold down to 15 ng/dl, and possibly
               lower;

-------
               Deficits in IQ and other measures of cognitive
               function (e.g., attention span) in children at PbB
               levels above 30 ng/dl, and small deficits as low
               as 15 ng/dl (or possibly lower) in socially
               disadvantaged children;

               Slowed peripheral nerve conduction at PbB as low
               as 20-30 ncr/cll in children;

               Deficits in mental developmental indices in
               infants with maternal or umbilical cord PbB levels
               as low as 10-15 ng/dl.

               Low birth weight and decreased gestational age,
               which may also influence early neurological
               development, at maternal PbB levels above 12-14
               ng/dl; .

               Reduction in early childhood growth with no
               apparent threshold in one study across the range
               of 5-35 ng/dl; a threshold at 40 M-g/dl was
               identified in another study;

               Small increases in blood pressure in adult men
               with no apparent threshold from cross-sectional
               .data down possibly, to 7
     5)   There is evidence that lead produces renal tumors in

lab animals and lead has been classified a probable carcinogen.

While this is of concern, the non-cancer effects at low lead
exposure levels are the focus of this staff paper.


     The lack of an apparent PbB threshold in several studies is

supported by the fact that many of the biochemical changes, or
mechanisms, that appear to underlie lead toxicity (e.g., altered

enzyme activity, membrane receptors, calcium homeostasis) have
been observed at the lowest experimental dosages administered,

often with no discernible threshold.  There is a. great deal of
uncertainty regarding the point at which subtle molecular changes

individually or collectively, become significant enough that they
should be regarded as constituting "adverse" effects for purposes

of standard setting under the Clean Air Act.  However, such
effects clearly become more pronounced (and likely), and broaden

-------
                                xi
to cause more severe disruptions of the normal functioning of
many organ systems, as PbB levels increase.  This continuum of
effects, from biochemical responses, cellular dysfunction and
morphological changes, to organ system alterations and clinical
toxicity, makes it difficult to identify clearly what PbB level
constitutes an appropriate "threshold", if any, below which there
are no significant risks of adverse effects.

     The approach taken in this staff paper is to identify those
effects that individually or collectively represent an adverse
pattern that should be avoided.  For children, the collective
impact of the effects at PbB levels above 15 (ig/dl can be seen as
representing a clear pattern of adverse effects worthy of
avoidance.   At levels of 10-15 p.g/dl, there appears to be a
convergence of evidence of lead-induced interference with a
diverse set of physiological functions and processes,
particularly evident in several independent studies showing
impaired neurobehavioral function and development.  The available
data do not indicate a clear threshold at 10-15 \j.g/dl, but rather
suggest a continuum of health risks down to the lowest levels
measured.  The effects of lead below this range become
increasingly difficult to detect and their significance more
difficult to determine.  For purposes of comparing the relative
protectiveness of alternative lead NAAQS, the staff has estimated
the percentages of children with PbB levels above 10 and above 15
M-g/dl.

     While the dose-response information on blood pressure
changes in men is less clear than the information on children,
the same approximate range of PbB levels can also be considered
for assessing risks among adult men.  In this staff paper,
percentages of middle-aged men with PbB levels above 10 and 12
ng/dl are estimated to compare relative protection afforded by
alternative NAAQS.

-------
                               Xll
     Quantitative analyses of differences in prenatal lead
exposures under alternative lead NAAQS are not done in this
review.  Although it is likely that there is extensive
mobilization of lead, like calcium, during pregnancy, there are
no biokinetic data available to quantify this dynamic process.
Given the sensitivity of the fetus and neonate, potential.risks
associated with fetal lead exposures must be considered in
determining an appropriate margin of safety for the lead
standard.  There are approximately 140,000 women of child-bearing
age living near major lead point sources whose offspring may be
at risk.

     Other factors that warrant consideration in evaluating the
margin of safety are the significance and persistence of observed
or potential health effects, the persistence of lead in the body
and in accessible environmental reservoirs (i.e., soil), the
sensitivity of exposure analyses to alternative assumptions, and
the potential carcinogenicity of lead.  It should be considered
that for groups that have excessive background exposures,
children with pica and/or children living in deteriorated lead-
paint homes, any reduction in ambient air lead levels is
beneficial.  Also other groups, not quantified in this paper,
(e.g., post-menopausal women) will also benefit from a reduction
in ambient lead levels.

     Based on scientific and technical reviews, as well as policy
considerations, the staff makes the following recommendations
with respect to the primary lead standard.

     1)  The range of standards for consideration for the primary
lead NAAQS should be from .5 to 1.5 fig/m3.  The results of
exposure analyses for children living near three lead smelter
sites are summarized in Table 1.

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                             J.XJ.-J
nutrition, and parental stresses and limitations, will continue
to be the major source of lead toxicity during the coming decades
(Chisolm, 1984; Schneider and Levander, 1986).  In addition, as
many as 290,000 children may receive enough lead from drinking
water via either old plumbing or new lead-soldered plumbing to
elevate their blood lead levels to toxic levels (ATSDR, 1988).
The numbers of children exposed to potentially hazardous levels
of lead in contaminated soils and dusts from historical
deposition is difficult to quantify, but likely represents a
significant fraction of those living near busy roadways, old
housing, and old industrial facilities.

     Even the most stringent lead NAAQS cannot be expected to
sufficiently reduce health risks in these groups exposed
excessively to "non-air" sources of lead and no attempt will be
made in this paper to predict their exposures under different air
lead scenarios.  To abate existing hazards and regulate high
intensity exposure sources, better interagency (EPA, FDA, HUD,
HHS) coordination to address total lead exposure from multiple
sources is needed, as well as a commitment for housing inspection
and enforcement, parental education, incentives for property
owners, and continued lead screening and research programs.

     Although the potential effects of alternative lead NAAQS on
some of the other sensitive groups are not evaluated
quantitatively, risks related to lead exposure among these groups
will be considered in establishing the margin of safety.

B.   Mechanisms of Toxicity

     The toxicological impact of environmental lead can be the
cumulative product of continuous low-level exposure, or of single
or repeated acute exposures.  Adverse effects are due essentially
to the mobile fraction of absorbed lead within the body.  A major
determinant of toxicity is the distribution of lead among binding
proteins and compartments that contain susceptible enzyme systems
or other target sites (Raghavan et al., 1981;  Silbergeld,  1983).

-------
On a larger scale, the selective accumulation of lead in the
heart, kidney cortex, liver, and particularly in the brain during
the early stages of pre- and post-natal life may be associated
with the sensitivity of these organs to lead.  The effects of
lead on subcellular structures and processes result in
biochemical derangements- common to, and affecting, many tissues
and organ systems.  These biochemical alterations can be linked
to the diverse types of lead-based functional disruptions of
organ systems that operate in a coordinated, interdependent way.

     One molecular basis underlying lead's toxicity in various
human tissues is believed to be its ability as a metallic cation.
to bind with specific biochemical ligands, such as sulfhydryl,
amino, and carboxyl groups, which are present in biomolecular
substances crucial to normal physiological functions (Moore et
al., 1980).  Another fundamental mechanism and early
manifestation of lead toxicity common to diverse cell types is
related to perturbations in intracellular calcium ion homeostasis
(Pounds et al., 1982).  Lead alters calcium mediated cellular
processes and may mimic calcium in binding to various regulatory
proteins (Haberman et al., 1983).  These disturbances in turn
interfere with a constellation of biochemical events, summarized
below, which appear to contribute to the more obvious
manifestations of lead toxicity.

     1.   Alteration of enzyme activity
          Lead inhibits at least two enzymes in the heme
biosynthetic pathway, delta-aminolevulinate dehydrase (ALA-D) and
ferrochelatase (Chisolm, 1981), as well as several enzymes and
cofactors involved in maintaining the structural integrity of red
blood cells and protecting them against oxidation — Na*, in-
activated adenosine triphosphatase (Na~", K~" - ATPase) ,
pyrimidine-5'-nucleotidase (Py-5-N), superoxide dismutase, and
glutathione (Hasan et al., 1967; Secchi et al., 1973; Angle et
al., 1975; Valentine et al., 1976; Levander et al., 1980; Gelman
et al., 1978).  Altered synthesis of tetrahydrobiopterin and
activity of protein kinase C and brain adenyl cyclase (associated
with neurochemical receptors; see below) has also been reported

-------
                              Hi-/
with lead in vitro and in vivo at low concentrations  (Purdy et
al., 1981; Mclntosh et al., 1985; Nathanson and Bloom, 1975;
Markovac and Goldstein, 1988a,b).

     2.   Altered cellular energy metabolism and ion  transport
          Energy metabolism occupies a central position in all
biologic processes.  Substantial interference with one or more
steps in cellular energetics can have immediate and severe
effects on the usual functioning of a cell, tissue, or organ.
Mitochondrial structure and a variety of its functions in energy
metabolism are very sensitive to lead, particularly in rapidly
developing tissues in the young (Bull et al., 1979).  Effects
including uncoupled oxidative phosphorylation (Goyer  and Moore,
1974), inhibited substrate oxidation, and changes in
mitochondria! membrane permeability and transport of  ions,
(especially calcium, sodium, and potassium), occur at levels of
lead as low as 15 micromolar in intact cellular systems (Holtzman
et al., 1977; Bull, 1980; Van Rossum et al., 1985).

     3.   Competition with ions for essential binding sites and
          altered neurochemistry
          Lead absorption, distribution, and retention is known
to vary depending on dietary intake of calcium, iron, copper, and
zinc, as well as other nutrients (e.g., protein, fat, vitamin D)
(Mahaffey and Michaelson, 1980).  In addition, increased
susceptibility to the toxic effects of lead on heme synthesis and
on neurological function has been associated with deficiencies in
calcium, iron, copper,  and zinc (Mahaffey-Six and Goyer,  1970,
1972; Klauder and Petering, 1977; Cerklewski and Forbes,  1976).
These metabolic interactions can be expected among elements that
share common chemical properties and compete for common metabolic
binding sites, such as the mucosal proteins responsible for
absorption and transport across the intestinal wall, and on
specific intracellular enzymes.

     Lead-induced alteration of cellular calcium homeostasis has
been observed at lead concentrations as low as 50 micromolar,
either by direct competition at receptor binding sites (Barton et

-------
                            III-8
al., 1978; Ong and Lee, 1980; Haberraann et. al., 1983), or
indirectly by reducing energy production and impairing
mitochondrial and cell membrane transport "pumps" (Pounds et al. ,
1982).  This could disturb multiple cell functions of different
tissues that depend upon calcium as a messenger of hormonal and
electrical stimuli, or as a modulator of cyclic nucleotide
metabolism (Rasmussen and Waisman, 1983; Rosen, 1983).  For
example, low levels of lead inhibit the calcium-mediated
regulation of pyruvate kinase activity essential to hepatic
glycolysis (Pounds et al., 1982), and some calcium-dependent
neurotransraission which regulates the propagation of nerve
impulses in the brain (Silbergeld et al., 1977; Silbergeld and
Adler, 1978), as well as peripheral neuromuscular junctions
(Cooper et al., 1984).  A wide range of linkages between lead's
impact on calcium and energy metabolism, and altered functional
activity and developmental delays in the kidney, liver, brain,
cardiovascular system, and smooth muscle have been proposed (Bull
et al., 1979;  McCauley et al., 1979; Silbergeld, 1983; Pounds et
al., 1982).

     Besides competition with calcium at synaptic binding sites,
other mechanisms by which lead at low doses may alter the
functioning of neurotransmitter pathways (see CD, Table 12-7)
include:  1) inhibition in the brain of the enzymes (Na,K)-
ATPase, which helps maintain the ion distribution about the
cellular membrane reguired for neuronal activity (Vallee and
Ulmer, 1972), and adenyl cyclase, which regulates cyclic AMP
metabolism and synaptic transmission (Nathanson and Bloom, 1975);
2) inhibition of sodium-dependent neurotransmitter uptake
(Silbergeld and Goldberg, 1975); 3) impairment of cerebellar and
cerebral energy metabolism (Holtzman et al., 1978; Bull et al.,
1979); 4) altered metabolism of tetrahydrobiopterin, which helps
control the synthesis of the neurotransmitters dopamine and
norepinephrine (Purdy et al., 1981; Mclntosh et al., 1985); 5)
altered GABA neurotransmission, linked to either inhibition of
heme synthesis in brain and an accumulation of ALA, altered
glutamate metabolism, or lead-induced increase in zinc
concentrations in the brain (Sassa et al., 1979; Silbergeld and

-------
Lamon, 1980; Regunathan and Sundaresan, 1985; Baraldi et al.,
1985); 6) reduced heme levels in the liver that appear to
indirectly alter associated activity in the brain of the amino
acid, tryptophan, and the transmitter to which it contributes,
serotonin (Litman and Correia, 1983); 7) altered levels of
endogenous opiate (e.g., endorphin) and increased sensitivity of
brain opiate receptors which may directly affect motor functions
(Memo et al., 1981; Baraldi et al., 1985); 8) increased axonal
growth and innervation in adrenergic neural pathways in the brain
(Freedman et al., 1988); 9) retarded development of other
dendritic and axonal connections (Petit and Alfano, 1983) and of
neural support cells ( Ohnishi and Dyck, 1981; Scott and Lew,
1986) .

     Most of the above jji vitro findings were elicited by
micromolar concentrations of lead.  Recently, picomolar
concentrations of lead were reported to mimic calcium and
activate brain protein kinase C, a regulatory enzyme localized in
presynaptic terminals and brain microvessels and critical to
neurotransmission, neuronal growth and differentiation, and the
integrity of the blood-brain barrier (Markovac and Goldstein,
1988a,b).  Although this enzyme is only one of several potential
mediators of lead toxicity, this finding is important given that
cellular concentrations of lead would be expected to be in the
picomolar range in humans with typical blood levels today (i.e.,
5-25 ^ig/dl) (Markovac and Goldstein, I988a).  Lead-induced
activation of membrane-bound protein kinase C in red blood cells
has also been hypothesized to mediate the enhanced vascular
reactivity, and in turn, increased blood pressure, associated
with lead exposure (Chai and Webb, 1988).

     These different effects on neurotransmitter function may
reflect either a different accumulation of the metal within
distinct anatomical regions or differences in the mechanisms
regulating synthesis,  release and uptake of the neurotransmitters
involved in various brain areas (Collins et al.,  1984;  Lucci et
al., 1981).  It is apparent, however,  that the type of

-------
                           111-10

neurotransmitter receptor changes induced by lead is determined
by the developmental phase during which exposure occurs  (Roussouw
et al., 1987).

     In summary, it remains uncertain whether a common underlying
.mechanism is  involved in the diverse functional impairments
produced by lead.  It does appear, however, that lead affects
biological systems directly rather than through metabolic
transformation, and that if present, there may be no biological
threshold for effects of lead ions at subcellular or cellular
sites of action.  The factors that determine the distributions
and ultimate  availability of lead at these many sites are poorly
understood.  Thus external exposure levels or internal
circulating levels (blood lead  concentrations) of lead sufficient
to achieve subcellular or cellular concentrations associated with
biochemical changes described above remain to be defined.

C.   Effects of Concern

     Lead is a poison with no known normal function in the body.
Lead produces physiological, and ultimately, pathological effects
in a variety  of tissues and organ systems across a broad range of
exposure levels.  Evidence for  such effects is drawn from in
vitro, animal toxicological, and human clinical and
epidemiological studies.  Based on these data, summarized in the
CD (Chapter 12), the 1986 CDA and the 1990 CDA Supplement,
relatively low-level effects in the following areas are of
primary interest:
     1) heme biosynthesis and related functions
     2) neurological development and function
     3) reproduction and physical development
     4) kidney function
     5) cardiovascular function

     Lead also affects immunological, liver, gastrointestinal,
and endocrine functions, and at high dosages produces tumors in

-------
                             lll-ii
laboratory animals.  Information on these effects is generally
limited to high exposure levels.  The major implications of the
available literature and dose-response information related to
each of the key effect areas listed above, as well as the
potential carcinogenicity of lead, are summarized in Section
III.D. as they relate to assessing the risks associated with
alternative lead NAAQS.                       -            -

     D.   Dose-Response Information

          The amount of lead measured in whole blood (PbB) has
been the most widely used indicator of lead exposure in the many
studies of health effects associated with lead.  Although blood
lead is only an indirect surrogate of toxicologically active
dosages at target sites, and may under-represent total body
burden of lead especially after high exposures, it does provide a
reliable index of fairly stable exposures and can respond
relatively rapidly to short-term changes in lead intake.  Future
research is expected to increasingly rely on serial blood
measurements in combination with in sitja bone lead analysis as
indices of long-term integrated exposures.
     Tables 3-2 and 3-3 summarize the lowest observed effect
levels (in terms of PbB levels) that have thus far been credibly
associated with health effects of concern observed in children
and in adults, respectively.  The tables are adapted from Tables
13-7 and 13-8 in the 1986 CD, and have been updated to include
more recent data, as evaluated in the 1986 CDA and its 1990
supplement, as well as the 1988 ATSDR Report to Congress.
Because of variations in individual biological susceptibility,
nutritional status, exposure patterns, and other factors, many
people would not experience the stated effects until higher PbB
levels while others may respond to even lower levels.  Lead
affects many levels of physiological and anatomical organization
within the body across a wide range of exposure levels.   These
effects range from biochemical changes in energy metabolism and
synaptic neurotransmission, with no apparent threshold on a

-------
111-12
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subcellular molecular level, to severe, irreversible central
nervous system damage manifested by mental retardation,
encephalopathy (degenerative brain disease), and possibly, death
at PbB levels starting between 80 and 100 ng/dl in the most
highly susceptible children (EPA, 1986a, p. 12-69).  Other overt
neurological damage such as peripheral neuropathies, have been
observed at PbB levels possibly as low as 40-60 jig/dl (EPA,
1986a, p. 12-108).  Clearly adverse effects occur in other organ
systems at these elevated levels (60-100 |ig/dl) including chronic
nephropathy, gastrointestinal symptoms, and frank anemia, which
represents an extreme manifestation of reduced hemoglobin
synthesis.  The focus here will be on the most sensitive targets
of low-level lead toxicity:  in children, heme synthesis and
related functions, neurological function, and mental and physical
development; and, the cardiovascular system in adults.  Potential
carcinogenicity of lead will also be discussed.  The PbB levels
of concern in evaluating a range of alternative lead NAAQS are
discussed in Section III.E.

     1.   Heme Biosynthesis and Related Functions
          Other than some changes in neurochemistry discussed in
Section III.B., hematological changes are generally the earliest
effects seen in lead exposure.  Under normal circumstances, heme
biosynthesis is a highly efficient and coordinated pathway, which
produces only sufficient amounts of intermediates and,
ultimately, heme to service reguirements for hemoglobin — the
blood pigment responsible for transporting oxygen to the
tissues — as well as a multitude of functions mediated in most
cells by heme-containing proteins.  These hemoproteins include
myoglobin, the hemoglobin of muscle, and the mitochondrial
respiratory pigments, cytochromes, responsible for cellular
energetics.  As summarized in Table 3-4, moderately elevated lead
exposure has been demonstrated to disturb the biosynthetic
sequence so as to produce large quantities of redundant
intermediates that must then be excreted.  More severe lead
intoxication may result in the development of anemia due to

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                            111-16
reduced hemoglobin production and shortened red blood cell
survival.  Because heme synthesis is a continuous process, most
of these effects are reversible upon removal or reduction of
lead.  However, given:  a) there may be long-term functional
consequences of even transitory changes in developing tissues in
children; b) heme's pervasive role in many organ systems and
physiological processes; and c) the sensitivity of heme
production to lead, lead's interference in the heme synthetic
pathway may have long-lasting implications that must be carefully
considered.

     As discussed in the CD (Section 12.3), lead interferes with
heme synthesis at several points in its metabolic pathway:

     1) Activity of the enzyme ALA-D (porphobilinogen synthase),
which catalyzes the conversion of ALA to porphobilinogen, is
inhibited in red blood cells at PbB levels below 10-15 M-g/dl with
no clear threshold (Hernberg and Nikkanen, 1970);

     2) Accumulations of ALA, which result from inhibited ALA-D
activity, have been noted in plasma and urine at PbB levels of
40 ng/dl, and possibly as low as 18 ng/dl.  Inhibition of ALA-D
activity, and increases in non-utilized ALA appear to occur in
brain, kidney, and the liver at roughly the same PbB levels
associated with ALA accumulations in plasma (Millar et al., 1970;
Secchi et al., 1974; Silbergeld et al., 1982);

     3) Lead impairs the transmitochondrial transport of iron and
instead of producing heme, the mitochondria accumulate its
precursor, protoporphyrin which, lacking iron, is incapable of
performing its essential respiratory function.  As a result of
lead intoxication in newly forming erythrocytes, protoporphyrin
(referred to as erythrocyte protoporphyrin or EP) takes the place
of heme in the specific pocket of the hemoglobin molecule.  As
the red blood cells remain in the circulation, zinc is rapidly
chelated at the center of the molecule in the site normally

-------
                            111-17

occupied by iron (Piomelli et al., 1982).  The resulting  zinc
protoporphyrin (ZPP) is tightly bound in the available heme
pocket for the life of the erythrocyte, normally 120-130  days
(Lamola et al., 1975).  Impairment of iron utilization for heme
synthesis by lead is enhanced by iron deficiency.  Persons with
both low iron status and PbB levels above 30 ng/dl were
approximately 6.5 times as likely to have elevated EP. than those
with normal iron status in the same PbB range (Mahaffey and
Annest, 1986).  The interaction of iron status and lead in
elevating EP in children should be considered.  Several studies
have found progressive increases in EP with increasing PbB with
an apparent threshold between 15 and 18 ng/dl (Roels  et al.,
1976; Piomelli et al., 1982; Rabinowitz et al., 1986).
Significant EP elevations greater than one and two standard
deviations above normal were found in 50% of children with PbB
levels of 25-30 and 35 M-g/cil, respectively.  Some of  these
studies selected children so as to minimize the number with iron
deficiency, although direct data on nutritional status were not
available and it is likely that children with different iron
stores were grouped together.  Data on U.S. children  surveyed in
NHANES II were reanalyzed to more directly examine the impact of
iron status on the dose-response relationships between PbB and EP
(Marcus and Schwartz, 1987).  While no actual threshold exists in
the fitted, non-linear model, the typical estimated EP response
increases sharply at about 12 M-g/dl in iron-deficient children,
and at about 23 ng/dl for children with high iron stores.

     The health significance of EP or ZPP accumulation is that it
indicates that heme or hemoprotein synthesis in many tissues has
been impaired as a result of lead's entry into mitochondria (EPA,
1986a, p. 12-46).  Previously, EP elevations at PbB levels around
30 |ig/dl were considered to be of concern based on functional
disruptions in hemoglobin synthesis at 40 ng/dl and
neurobehavioral effects above 50 M-g/dl (EPA, 1977).  Recent data,
however, have provided more information on the extensive impact

-------
                          111-18
of lead on the body heme pool and associated disruptions of many
physiological processes (see Figure 3-1).  With increasing lead
exposure, impairment of heme and hemoprotein synthesis
intensifies in different organ systems which can result in
reductions in oxygen transport, changes in cellular energetics,
interference with neurotransmitter synthesis and function,
reduced detoxification of certain , drugs and other foreign agents
in the liver due to inhibition of cytochrome P-450, impairments
in the biosynthesis of 1,25-dihydroxyvitamin D (1,25-OH2-D) in
the kidney, and possibly impairment of the immune system (EPA,
1986a, p. 13-30).

     Most of these linkages between the biochemical effects of
lead on heme synthesis, and effects on other functions such as
neurotransmission, are primarily based on animal or in vitro
experimental data.  It is, therefore, difficult to determine a
PbB level of concern for heme-related disturbances in humans.
Nevertheless, the common biochemical processes operating across
mammalian species suggest the abnormalities in heme synthesis
caused by low level lead exposure in humans may also indicate
some risk of broader functional impairments.

     Of the functional consequences associated with heme
reductions and lead's interaction with those processes, perhaps
the best quantitative data are available on the negative
correlation between PbB levels and circulating levels of the
vitamin D hormone, 1,25(OH)2D (Rosen et al., 1980).  Synthesis of
this hormone, which is the major active form of vitamin D, is
mediated by a heme-requiring cytochrome P-450 enzyme system
(renal 1-hydroxylase) in the kidney.  It is also controlled by
the functional integrity of the renal mitochondria, by the ionic
(calcium, phosphorous) environment of the extracellular fluid,
and by the active uptake of calcium by mitochondria (EPA, 1986a,
p. 12-38).  Given lead's effects on mitochondria, cellular
energetics, cytochrome P-450 function, and ferrochelatase
activity in kidneys, it is not surprising that lower 1,25(OH)2D

-------
                               111-19
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Figure 3-1.  Multi-organ impact of reductions  of  heme body pool
by lead.  Impairment of heme synthesis by  lead results in
disruption of wide variety of important physiological processes
in many organs and tissues.  Particularly  well documented are
erythropoietic, neural, renal-endocrine, and hepatic effects
indicated above by solid arrows (	•»).   Plausible further
consequences of heme synthesis interference by lead which remain
to be more conclusively established are indicated by dashed
arrows (	•>).

Source:  Criteria Document (Figure 13-4).

-------
                            111-20
levels occur at PbB levels corresponding to those associated with
the onset of EP accumulation in red blood cells.  A strong
negative correlation between vitamin-D hormone and PbB levels was
found over a range of 12-120 ng/dl (Mahaffey et al., 1982) with
no apparent threshold.  Above 33 ng/dl, the reductions in vitamin
D hormone were comparable to these observed in children lacking
two-thirds of normal renal function.

     The CD concludes that it appears likely that lead-induced
reductions in heme underlie this association, and that impaired
production of 1,25(OH)2D can have profound and pervasive effects
on tissues and cells of diverse type and function throughout the
body (EPA, 1986a, p. 12-51).  Altered levels of 1,25(OH)2D may
affect calcium homeostasis and thus calcium-dependent processes
essential to several enzyme systems,  the transport of and
response to various hormonal and electrical stimuli, and cyclic
nucleotide metabolism.  In addition,  lead may affect the role of
1,25(OH)2D in cell differentiation/maturation, immunoregulation,
pancreatic function (e.g., insulin secretion), and mediation of
tumorigenesis (EPA, 1986a, pp. 12-40 to 12-42).

     At higher levels, lead's interference with heme synthesis
and other red blood cell functions (e.g., inhibition of Py-5-N
activity which affects membrane stability) may result in anemia.
A PbB threshold for apparent reductions in hemoglobin levels in
children has been commonly cited at 40 |ig/dl (WHO, 1977) although
this has not been conclusively established (EPA, 1986a, p. 12-
29).  Judgments of experts were encoded in 1985-86 in an attempt
to address the uncertainty in the dose-response relationship
between lead absorption and hematologic dysfunction.  These
judgments are described in Wallsten and Whitfield (1986) and
summarized in Appendix A.  Three of four experts assigned at least a
50% chance that some children with a PbB level of 35 M-9/dl (±.5-11%)
would have lead-induced anemia and that there would be some children
at small risk at even lower levels.  A fourth expert felt there was
no measurable lead-induced hemoglobin effects at PbB levels below

-------
                             111-21

45-55 p.g/dl.  Recent analysis of data collected in 1974 from
Idaho children living near a lead smelter and rural control areas
indicate that hematocrit levels were depressed below normal (an
index of anemia) in one-year olds beginning at a PbB level of
about 20 M-g/dl/ and at about 40-50 n-g/dl in older children
(Schwartz et al., 1989).  Although anemia is a serious clinical
manifestation, the inhibition of heme synthesis at lower PbB
levels has much wider implications for a multitude of organs and
physiological systems.

     2.   Neurological Effects of Lead
          The nervous system is a critical target for low-level
lead effects.  Alterations in neurotransmission and brain
mitochondrial function are evident within minutes of exposure for
submicromolar lead concentrations in vitro and in vivo.  Although
the functional significance is difficult to assess and PbB levels
at which .such effects occur in humans have not yet been
determined, these neurochemical changes (e.g., inhibition of
acetylcholine release and Na, K-ATPase activity) exhibit
continuous dose-response relationships which may form the bases
of delayed brain development and disrupted neurobehavioral
function (Silbergeld, 1983).

     The effects of lead on the nervous system, summarized in
Table 3-5, are both structural and functional, involving various
regions of the brain and spinal cord (i.e., the central nervous
system) as well as the motor and sensory nerves leading to
specific areas of the body (i.e., the peripheral nervous system).
These effects can result in deterioration of intellectual,
sensory, neuromuscular,  and/or psychological functions.

a)   Acute Effects
     Acute encephalopathy (degenerative brain disease) is the
most severe consequence of lead intoxication and can abruptly
progress to delirium, convulsions, coma, and ultimately death
(Cumings et al., 1959).   Acute encephalopathy in adults usually

-------
                         Table 3-5.  SUMMARY OF LEAD'S EFFECTS ON THE NERVOUS SYSTEM
 Effect
                                                     Exposure
                                                                          References*
Biochemical
 In vitro  impairment  in rat brain of: synthesis
 on tetrahydrobiopterin  (neurotransmitter
 cofactor),  adenyl  cyclase; Na, K-ATPase
 activity,
 energy  metabolism; activation of protein kinase
 C

 Delayed development  of rat brain energy
 metabolism and respiration  (in vivo)
 Altered synthesis,  release,  and/or uptake of
 several neutotransmitters  and cofactors  in vivo
 (dopamine, norepinepbrine, serotonin, GABA,
 tetrahydrobiopterin}
 0.001  -  5  uM
 lead  solution
0.02%  lead salt
in drinking
water

0.2  -  2.0% lead
salt in
drinking water
Purdy et al.,  1981; Goddard and
Robinson,  1976; Taylor  et  al.,
1978; Gmerek al.,1981;  Markovac
Goldstein,  1988a,b
McCauley et al.,  1979; Bull  et  a.
1977; Bull, 1983
Shellenberger,  1984*; Litman  and
Correla,  1983;  Mclntosh  et  al.,
1985; Baraldi et al. 1985
 Morphological  and Functional Development

 Impaired myelin,  glial cell development in rat
 brain.
 Delayed synaptogenesis and neuronal development
 in young,  rat brain
 0.05  -  2.0%
 lead  in diet
 0.1  -  2.0%  lead
 in diet
Reyners et al.,  1979; Widebank el
al., 1980; Stephens  and Gerber,
1981

Petit et al.,  1983;* Costa  and Fc
1983; Bull et  al.. 1983;  Roussow
et al. 1987
 Delayed development of reflexes and  locoraotor
 activity;  alterations in  social interactions;
 some  persistent  learning  and behavior
 deficits,in  rats and monkeys exposed in  utero
 or  post-natally
 Deficits  in  early mental development  in  infants
 >0.001% lead in
 diet
mean maternal
and neonatal
PbB 10-15
ug/dl, possibly
below
Brown, 1975; Overmann et  al.,  19t
Hastings et al.,  1979; Bull  et  a]
1983; Bushnell and Bowman,  1979;
Bushnell & Levin, 1987; Cory-
Slechta et al.,  1985; Rice,  1984,
1985; Winneke et  al., 1982b;
Barrett and Livesey, 1983

See Table 3-6
 Electroohvsiolooical
Altered  electrical  activity, neurotransmission
in  isolated neurons (in vitro)
 Altered visual  and  electrical  evoked  responses,
 visual  acuity,  and  spatial  resolution in young
 rats, monkeys

 Subtle, alterations of brain electical activity
 (ESS patterns), auditory  function in  young
 children;  inconsistent findings on slow-wave
 potential, visual and auditory evoked
 potential.

 Depressed  conduction velocities in sensory and
 motor nerves of adults and  children
 (conflicting results at similar exposure
 levels)
>1 -  SUM lead
solution
0.2%  lead in
drinking
water/diet

No apparent
threshold down
to 15 ug/dl PbB
and possibly
below

>20-30 ug/dl
PbB
Sillman et al., 1982; Taylor  et
al., 1978; Olson et al.,  1984;
Cooper et al., 1984; Silbergeld  a
Adler, 1978

Bushnell et al., 1977; Fox  et al.
1982; Winneka, 1980
Otto et al., 1981,  1982; Otto,  199
Robinson et al., 1985; Benignus et
al., 1981; Burchfiel et al.,  1980;
Winneke et al., 1984; Schwartz  and
Otto, 1987


Seppalainen'et al.,  1975,  1979,
1983; Schwartz et al.,  1988  (Spiv
et al., 1980; Triebig et al.,  198
Motor Nerve Function
Small deficits in perceptual-motor integration,
fine motor coordination and balance in young
children
Conflicting results at similar exposure levels
50 - 60 ug/dl        de la Burde and Choate, 1972,  1975
PbB, possibly        Landrigan et al., 1975; McBnde et
as low as 30 -       al.,  1982; Needleman et al . , 1979,
40 ug/dl or          1984; Winneke et al., 1982,  1983;
lower                Bhattacharya et al.,
                                                                          Rummo,  1974;  Rummo et al.,  1979;
                                                                          Perino  and Ernhart ,  1974;  Kotok et
                                                                          al.,  1977;  Winneke et al.,  1984

-------
                                                     111-23

                     TABLE-3-5.   SUMMARY OF LEAD'S EFFECTS ON THE NERVOUS SYSTEM  (CONT'D)
Behavioral Disorders

Symptoms associated with neuropsyctuatnc
disorders  (hyperactivity, mental retardation)
in children
Attention  (reaction time) deficits and
distractability in young children
Effect level
not adequately
defined
>30 - SO ug/dl
PbB and
possibly as low
as 15 - 30
ug/dl
Baloh et al., 1975; Gittleman 4
Eskenazi, 1983; David et al., 1977,
1983, 1985: Beattie et al.,  1975;
Moore et al., 1982; Youroukos et
al., 1978

HinneJce et al., 1983, i!984;
Needleman et al., 1979, 1984; Yule
and Landsdown, 1983; Hunter  et al.,
1983; HatzaJcis et al., 1989
Auditory and Language Processing

Abnormal processing of complex auditory  stimuli
in infant monkeys
Deficits in motor speech behavior,  language
comprehension, formulation behaviors,  auditory
processing and function in children
Prenatal and
neonatal PbB 50
- 80 ug/dl

>30 - 50 ug/dl
PbB; no
threshold for
auditory
function
Morse et al., 1987
de la Burde and Choate,  1975;
Needleman et al., 1979,  1984;
Schwartz and Otto, 1987
Cognitive Function

1-4 point deficits  in  IQ  scores  on  verbal
performance, visual-motor perception,  short-
term memory/ general  intelligence  among young
children
>30 - 50 ug/dl
PbB;
[possibly below
30 ug/dl in
socially
di sadvantaged
children]
de la Burde and Choate, 1972, 1975;
Rummo, 1974; Rummo et al., 1979;
Perino and Ernhart,  1974; Ernhart
et al., 1981; Ernhart, 1983,.  1984;
Needleman et al., 1979, Needleman,
1984; Schroeder et al., 1985;
Fulton et al., 1987; Hatzakis et
al., 1989 [Harvey et al., 1983,
1984; Hinneke et al., 1983;
Schroeder and Hawk,  1987]
1-2 point,  IQ differences  due  to lead at
lower exposure levels  in  children
 15 -  30 ug/dl         Smith et al.,  1983;  Harvey  et  al.,
 PbB                   1983, 1984;  Yule  et  al.,  1983;  Yule
                      and  Landsdown,  1983; Hinneke et
                      al.,. 1984;  Landsdown et  al., 1986
Overt Toxicitv

Peripheral nerve  damage  among chronically
exposed adults and  children
Encephalopathy, mental  retardation,  possibly
death among  children
>40 ug/dl
>80 - 100 ug/dl
Lillis et al., 1977; Spivey et al.
1980; Haenninen et al., 1979;
Zimmerman-Tansella et al., 1983;
Erenberg et al., 1974

Gant et al.,  1938; Smith et al.,
1938; Chisolm and Harrison, 1956;
Chisolm, 1965; Bradley and
Baumgartner,  1958; Rummo et al.,
1979
•In some cases,  review  articles  are cited.   Refer to CD for more comprehensive referencing

-------
                           111-24
is manifested at PbB levels of approximately 100-120
(Chisolm, 1965); this syndrome may be associated with PbB levels
between 80 and 100 M-g/dl in the most susceptible children (EPA,
1986a, p. 12-69) and can lead to permanent dysfunctions ranging
from short attention span to mental retardation.

b)   Peripheral Nerve Damage
     Peripheral nerve damage (neuropathy) due to high lead
exposure has been more commonly found in adults occupationally
exposed to lead.  Overt symptoms such as muscle tremor, palsy
(e.g., "wrist drop") or weakness, muscle and joint pain, and
gastrointestinal complaints have been observed in workers with
PbB levels exceeding 40 M-g/dl (e.g., Lilis et al., 1977; Spivey
et al., 1980).  Small reductions in conduction velocities of
electrically-stimulated sensory and motor nerves (NCVs) have been
observed in some apparently asymptomatic workers with PbB levels
as low as 30-50 ng/dl (e.g., Seppalainen et al., 1983).  It is
difficult to draw conclusions from the many studies (more than 30
published) in light of contrasting, negative findings (Spivey et
al., 1980; Triebig et al., 1984), as well as a lack of
consistency in the nerves examined and in the statistical
significance of the effects.  Nevertheless, the preponderance of
results have been positive, and the most consistently decreased
NCVs appear to involve the median motor nerve in the arm.
Although lead-induced impairment of nerve conduction may be
reversible (peripheral nerves can regenerate), at least in part
by a reduction in PbB levels through chelation therapy (Feldman
et al., 1977; Araki et al., 1980), electrophysiologic dysfunction
in adults is accompanied by alterations in neuromuscular
performance (e.g. reduced grip strength and eye-hand
coordination) and by subclinical tremor, and reduced visual
sensitivity and reactivity (Repko et al., 1979; Baloh et al.,
1979).  Even small changes in nerve conduction thus may be early
warning signals of progressively more serious neuropathy in
otherwise undiagnosed lead intoxication (Feldman et al., 1977;
Seppalainen and Hernberg, 1980).

-------
                            111-25
     Overt, lead-induced peripheral neuropathy has been
documented in children with PbB levels above  60  (ig/dl  (Erenberg
et al., 1974), possibly as low as 40 M-g/dl  (EPA,  1986a, p.  12-
108).  Unlike the data base for adults, no  longitudinal data  on
nerve conduction are available for children which precludes clear
conclusions regarding a threshold for lead-induced neuropathy.
Schwartz et al. (1988) reanalyzed cross-sectional data and  found
a small effect on motor nerve conduction velocity in asymptomatic
children at PbB levels beginning at 20-30 ng/dl,  with about a 2%
slowing in NCV associated with every 10 M-g/dl increment in  PbB.

c)   Effects Associated with Chronic Low—Level Exposures
     Besides the severe pathophysiological  changes observed in
the central nervous system (CNS) associated with  childhood  lead
intoxication, various maladaptive behaviors, neuropsychological
deficits, and neuro-anatomical changes have been  associated with
chronic exposures to relatively low concentrations of lead.
Table 3-5 summarizes the numerous biochemical, morphological, and
functional effects of lead at low dosages and exposures that  have
been found in developing nervous systems and the  discussion below
highlights the key dose-response information.

     i)   Brain Development;  Prospective Studies
          Lead readily enters the brain and appears to be
selectively deposited in the hippocampus and cortex as well as in
non-neuronal elements (e.g., glial cells, endothelial cells of
brain capillaries) that are important in the maintenance of
"blood-brain barrier" functions (Fjerdingstad et  al., 1974;
Stumpf et al., 1980).  Once deposited,  lead is retained in  the
brain for long periods of time even after external exposure
ceases and PbB levels decline (Mykkanen et  al.,  1979; Goldstein
et al., 1974).

     The sensitivity of the brain during the period of maximal
brain growth and differentiation in the first 2  years of life
tends to magnify the severity of the long-term consequences of

-------
                             111-26
any toxin encountered during that period (Dobbing, 1974).  The
immaturity of specific brain tissues (i.e., hippocampus,
cerebellum and neocortex) at birth and their relatively late
development suggests that post-natal lead exposure could
interfere with mitosis, cellular migration, differentiation of
dendritic and axonal processes, synaptogenesis, and myelin
production, as well as exerting biochemical and cytotoxic effects
(Campbell et al., 1982).  While the developing nervous system may
possess considerable reserve for functional compensation
(involving plasticity, regeneration, and redundancy of neural
pathways), specific processes affected by lead apparently may not
be reversed, either because lead is not removed from brain cells
(Silbergeld, 1983) or because of interruption or damage to
neurostructural elements undergoing rapid development at the time
of the lead insult.

     Rat pups exposed to low levels of lead during the pre-natal
or neonatal period show retarded development in cerebral energy
metabolic pathways, delayed cerebral cortex synaptogenesis, and
reductions in hippocampal morphometric, dendritic, and axonal
development (See Table 3-5).  These biochemical and morphological
disruptions are paralleled by delays in the development of
exploratory and locomotor activity, and by learning and
behavioral deficits in young, lead-exposed animals (EPA, 1986a,
Tables 12-4 and 12-5).  Emerging findings from well-conducted,
ongoing prospective studies indicating that low levels of in
utero or neonatal lead exposure are associated with disturbances
in early neurobehavioral development are therefore not
surprising.

     These studies are reviewed in the CDA and CDA Supplement.
Prospective studies have several advantages over cross-sectional
or retrospective studies.  For example, lead exposure histories
can be ascertained and potential confounding variables are better
controlled.  In addition, efforts were made by the different
investigators to use comparable study designs, analytical
techniques, and covariate and outcome measures.  The study groups

-------
                             111-27
inevitably had different exposure/environmental/socioeconomic
profiles, which probably accounts in part for contrasting
findings.  Numerous combinations of blood lead measures  (e.g.,
maternal, umbilical cord, 3-,6-,12-,24-months, etc.) and mental
and psychomotor test measures (e.g., Bayley Mental and Physical
Development Indices - MDI and PDI, General Cognitive Index-GCI,
etc.) were tested for associations after adjustment for numerous .
covariates.  The many results from the individual studies differ
in terms of temporal associations, or lag periods between
exposure and outcome measures, statistical significance, and in
some cases, direction of effect (PbB positively correlated with
some neurological scores in some studies).  A generally
consistent pattern, however, is evident from these studies
linking low-level lead exposure during early development and
later neurobehavioral performance.  Table 3-6, adapted from Table
13 in the CDA Supplement, summarizes for the most completely
documented studies so far, the strongest relationships between
different PbB and outcome measures.  Other more recent studies
provide preliminary results or incomplete analyses that are given
less weight in the CDA Supplement (Rothenberg et al., 1989;
Graziano et al., 1989a,b; Moore et al., 1989; Fergusson et al.,
1988; Winneke et al., 1985 a,b).

     Considering the difficulties in assessing neurological
function in infants and young children, the different measures
used in the prospective studies are generally considered the most
reliable and sensitive indicators available. The MDI, for
example, reflects the infant's attentiveness and responsiveness
to stimuli, rudimentary problem solving, and display of early
communicative behavior.  While the predictive ability of the MDI
is debatable, the correlation between infant MDI scores and
childhood test scores are, in general,  moderately high, positive,
and statistically significant (Davis and Svendsgaard, 1987).

     Based on an assessment of earlier  results from the Boston,
Cincinnati, Cleveland,  and Port Pirie studies, the 1986 CDA

-------
111-28












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-------
                           111-29
concluded that "these studies taken together suggest that

neurobehavioral deficits, including declines in Bayley Mental

Development Index scores and other assessments of neurobehavioral

function, are associated with prenatal PbB exposure levels on the

order of 10 to 15 M-g/dl and possibly even lower, as indexed by

maternal or cord PbB concentrations" (EPA,- 1986b, p. A-48).


      The updated assessment from those and other more recent
studies in the CDA Supplement concludes that:

     "Various lines of evidence still relate neurobehavioral
     effects to blood lead levels of '10-15 (ig/dl, and
     possibly lower,' as was previously concluded in the
     1986 CDA.  Further analyses from the Boston study,
     which has provided the most direct information bearing
     on dose-response relationships for neurobehavioral
     effects, not only supported the 10-15 ng/dl level of
     concern but indicated that MDI deficits can be detected
     in relation to cord blood lead levels of 6-7 ng/dl in
     "lower" SES children (Bellinger et al., 1988).  Since
     the Boston cohort was mostly middle to upper-middle
     class, "lower" SES merely refers to less than the
     highest SES levels and is probably in fact much closer
     to the median of the U.S. population.  Although the
     postnatal lead exposure levels were somewhat higher in
     the Port Pirie study, analyses of the relationship
     between postnatal blood lead levels and covariate-
     adjusted MDI scores provided 'no evidence of a
     threshold effect' (Wigg et al., 1988).  Indeed,
     restricting the analysis to children with blood lead
     levels below 25 M-g/dl in the Port Pirie study yielded
     an even stronger association between covariate-adjusted
     McCarthy GCI scores and integrated postnatal blood lead
     measures (McMichael et al., 1988)"  (EPA, 1990, p. 53).

     Recent data from these studies suggest that effects of early

lead exposure may be attenuated.  Sizable increases in. postnatal
PbB levels were noted in the Cincinnati, Cleveland, and
especially in the Port Pirie studies, but not in the Boston

study.   None of the first 3 studies showed a significant

association between pre- or post-natal PbB and MDI scores at or

past 2  years of age.   Results from the Boston study suggest that

the association between prenatal lead exposure and development
only persisted beyond age 2 if postnatal exposure remained at

-------
                             111-30
levels above 10 M-g/dl (Bellinger et al., 1989).  In the Port
Pirie study, the strongest relationship was between MDI and
integrated postnatal average lead exposure, suggesting that it is
cumulative exposure from pre-birth and early childhood that is
critical in affecting subsequent mental development (Vimpani et
al., 1989).

     Future reports from these studies will perhaps provide
insight into the causal linkages involved and help clarify
uncertainties, including: (a) which period of exposure (pre- or
post-natal, cumulative versus concurrent) is most critical under
different conditions; (b) the persistence of the effects given
the nervous system's ability of adapting to and even compensating
for early developmental insults; and (c) the possibility that
important effects are obscured by indirect measures of target
dose levels or rapid post-natal changes in lead exposure (see CDA
Supplement, pp. 57 to 62).  Until then, it must be assumed that
any disturbance in a child's developmental potential, even if
reversible, can have long-lasting secondary effects.  For
example, otitis media itself may be transient and fully
reversible, but secondary effects on language development in
young children may be much longer lived (EPA, 1990, p. 62).
Further, the potentially large public health implications of even
small neurobehavioral deficits associated with PbB increments
warrants minimization of lead exposure from any source.  For
example, the CDA Supplement notes that the Boston, Cincinnati,
and Port Pirie studies found that Bayley MDI scores declined by
2-6 points for approximately every 10 iig/dl increase in PbB level
(EPA, 1990, p. 62).  An overall 4-point downward shift in a
normal distribution of scores such as the MDI or GCI would result
in 50% more children scoring below 80 on these exams (Davis and
Svendsgaard, 1987).

-------
                            111-31
    ii)  Behavior and Motor/Communication/Cognitive Functions
        1. Animal Data
           A variety of behavioral changes, abnormalities and/or
developmental delays in motor ability, and deficits in learning,
have been observed in young animals following early lead exposure
(see Table 3-5).  It has been suggested that the animal
experiments indicate that lead exposure during early development
is associated with an underlying tendency to respond excessively
(a behavioral "overreactivity"), whether or not such response is
appropriate.  This overreactivity facilitates active avoidance
and other simple learning tasks but is disruptive in demanding,
difficult discrimination learning and complex neuropsychological
performance (pvermann, 1977; Winneke et al., 1982; Rice, 1985;
Alfano and Petit, 1985).

     Interpretation of the animal data is limited given:  a)
inconsistent measures and results across studies;, b)
uncertainties in comparing "learning" impairments and behavioral
measures (e.g., locomotive activity) across species; c) possible
confounding effects of nutrition, route of exposure, litter size,
maternal care, and differential species and strain-sensitivity
(CD, pp. 12-110 to 12-117); and d) uncertainties in relating
external and internal exposure indices across species.  Despite
these limitations, it is likely that lead-induced effects
observed in animal studies at least qualitatively parallel
altered neurobehavioral function seen in children.

       2.  Cross-Sectional Data on Children
       Since 1979, when Needleman et al. reported small but
significant deficits in IQ, attention span, and auditory and
speech processing in apparently normal children at lower exposure
levels than had previously been suspected,  over 20 cross-
sectional studies from 9 countries have been published along with
numerous reviews (e.g., Rutter, 1980; Bellinger and Needleman,
1982;  Smith,  1985; EPA, 1986a,  1989b).

-------
                             111-32

     Determining the subtle interactive effects of low level lead
exposure on children's neuropsychological development in relation
to social (especially caregiving), genetic, nutritional, and
other influential variables over time, while controlling for
experimental and analytical biases has proved to be difficult.
Problems encountered in the conduct and interpretation of
childhood lead studies are discussed in the CD (pp. 12-53 to
12-56).

     Based on five methodological criteria (adequate markers of
lead exposure, sensitive measures of neurobehavioral function,
appropriate subject selection, control of confounding covariates,
and appropriate statistical analysis), the criteria document has
identified a group of neurobehavioral studies that "were
conducted rigorously enough to warrant at least some
consideration here" (EPA, 1986a, p. 12-72).

     There have been mixed findings regarding lead's association
with children's scores on standardized IQ tests,  which measure
some combination of literacy, information, academic capacity, and
intelligence (Flynn, 1984).  Several well-controlled studies have
found effects that are clearly statistically significant, whereas
others have found "non-significant" but borderline effects.  It
is important to note that:  1) the definition of "statistical
significance" (p < 0.05) is somewhat arbitrary and should not be
used to totally exclude results that may have important public
health implications; and 2) given the likely subtle nature of the
behavioral or neural effects probable at low levels of lead
exposure, the differential maturation patterns and sensitivities
among different brain processes, and the many other factors that
play a larger role in an individual's developmental trajectory,
one would not expect to find striking differences in every study,
especially in those that use standardized but non-specific
measures of intelligence or academic capacity.

-------
                              111-33
     The criteria document  concludes that:

     "none of the available studies on the subject,
     individually, can be said to prove conclusively that
     significant cognitive  (IQ)  or behavioral effects occur
     in children at PbB  levels < 30 jig/dl.  Rather, the
     collective neurobehavioral studies can probably now be
     most reasonably  interpreted as being clearly indicative
     of likely associations between neurop.sychologic
     deficits and low level lead exposures in young children
     resulting in PbB levels ranging to as low as 30-50
     ng/dl.  The magnitude  of average observed IQ deficits
     appears to be approximately 5 points at mean PbB levels
     of 50-70 M-g/dl and  about 4 points at mean PbB levels of
     30-50 M-g/dl (CD, p. 13-35).  Although such IQ deficits
     are relatively small on average,  such shifts in the
     mean -can make a  substantial difference in the
     percentage of children with IQ's in the extremes of the
     population distribution (i.e., below 80 and above 125)
     and may impact the  intellectual development, school
     achievement, and social development of the affected
     children sufficiently  so as to be regarded as adverse"
     (EPA, 1986a, p.  13-36).
     Figure 3-2 illustrates that  an  apparently small shift (4

points) in IQ in the mean of  a  normal  distribution may result in
            f. n-
            i-
               SO  «0  70
      FIGURE 3-2.
        VCRUU. 10.

CUMULATIVE FREQUENCY DISTRIBUTION OF VERBAL
IQ SCORES IN SUBJECTS WITH LOW OR HIGH
LEAD LEVELS (Source: Needleman et al., 1982)

-------
                             111-34

a nearly four-fold increase in the likelihood of children having
severe deficits (IQ < 80), along with an approximately three-fold
reduction in the likelihood of children attaining superior
function (IQ > 125).

     Associations at lower exposure levels have been more
difficult to disentangle from other factors.  In European
children estimated to have PbB levels between 15 and 30 ng/dl,
small deficits in IQ and attentiveness have been observed,
although no consistent, statistically significant associations
have been found (Smith et al., 1983; Harvey et al., 1983, 1984;
Yule et al., 1984; Hunter et al., 1983; Winneke et al., 1983,
1984).  The criteria document concluded from these studies that
"the possibility of small neuropsychologic deficits being
associated with lead exposure in apparently asymptomatic children
at the exposure levels studied (i.e., 15-30 ng/dl) cannot be
completely ruled out, given the overall pattern of results
obtained with the cross-sectional study designs employed by
Winneke and the British investigators.  Small, 1-2 point
differences in IQ, seen in some of their studies between control
and lead exposure groups might in fact be due to lead effects
masked by much larger effects of socioeconomic factors, home
environment, or parental IQ" (EPA, 1986a, p. 12-98).

     Four recent cross-sectional studies have found continuous
exposure-response relationships across the following measured PbB
ranges: 7.4 - 63.9 ng/dl, mean =23.7 ng/dl (with IQ and reaction
time performance; Hatzakis et al., 1989); 3.3 - 34.0 (ig/dl, mean
=11.5 ng/dl (with British Ability Scales of perceptual, short-
terra memory, and language functions; Fulton et al., 1987); 6-59
p-g/dl (with IQ; Schroeder et al., 1985); 6-47 nq/dl, mean =
20.8 (ig/dl (with IQ; Schroeder and Hawk, 1987).  The latter 3
studies found linear relationships with no detectable thresholds.
The cohort of 3-7 year-old, low SES children studied by Schroeder
et al. (1985) were followed up 5 years later after PbB levels
declined (all were below 30 |ig/dl); after covariate adjustment,
the relationship between PbB and IQ was not significant.

-------
                           111-35
     Smaller cross-sectional studies recently reported  either
consistent findings at moderate-high exposure levels  (Faust  and
Brown, 1987; PbB levels between 30 and 60 \i.g/dl) , or  no
significant associations among children with lower exposure
levels, for example: 5.4 - 21.5 |j.g/dl, mean = 10.8 M-g/dl  (with
Bayley MDI; Wolf et al., 1987); mean PbB = 11.5  p.g/dl (with  IQ;
Vivoli et al., 1989).

     Given the experimental problems encountered in studying
subtle, low-level lead effects on children's neurobehavior,  it is
important to recognize the limits of evaluating  studies in
isolation.  Although results from several studies failed  to
attain statistical significance individually at  the p = 0.05
level, in nearly all studies children with higher lead  exposures
consistently showed lower mean IQs (after covariate adjustment).
Simply tallying "positive and negative" studies  according to
whether the observed association achieved some "arbitrary level
of significance" in an attempt to seek a consensus summary is
misleading (Pocock and Smith, 1987; Needleman and Bellinger,
1989).  For example, two apparently contradictory studies (Fulton
et al, 1987, discussed above; and Pocock et al., 1987,  who found
no significant association between tooth lead and IQ) were
compared in terms of their regression coefficients and  confidence
intervals and were shown to have considerable overlap (Pocock and
Smith, 1987).  Needleman and Bellinger (1989) integrated  recent
studies on lead-IQ relationships in children (<12 years of age)
into a meta-analysis whereby each study is treated as a subject
in a study of studies, and then combined effects are  computed.
Criteria for selection of the studies were based on adequate
information regarding statistical analyses and methodology.
Thirteen studies were included; the joint probability was found
to be less than 3 in a trillion (2.97 x lO"12)  that the observed
pattern of results (lower IQ in higher lead exposure  groups)
could have been due to chance if there were really no effect.
Only if the studies were consistently biased towards  finding an
effect would the robustness of this result be questionable.

-------
Actually, these studies subtract out variance due to lead  (i.e.,
"overcontrol").  For example, adjusting for covariates such as
maternal IQ or maternal caregiving, which negatively correlate
with prior lead exposure, likely removes some "transgenerational"
influences of lead (Needleman and Bellinger, 1989).

     Results of encoding experts' probability judgments on lead-
induced IQ decrements, summarized in Appendix A, provide
additional insight.  The encodings were done in 1984 and 1985
before several key studies were published.  According to five of
the six experts, risks of small but measurable IQ deficits exist
at PbB levels as low as 15 ng/dl in children living in households
with incomes in the lowest 15th percentile.  Three of the experts
felt that there would be some risk of very small lead-induced IQ
deficits in low SES children with PbB levels as low as 5 jig/dl.

     In addition to IQ decrements, PbB levels in the 30-50 M-g/dl
range, and possibly lower, may be associated with deficits in
auditory and language processing, motor coordination, postural
equilibrium, appropriate social behavior, and the ability to
focus attention (de la Burde and Choate, 1972, 1975; Needleman et
al., 1979; Winneke et al., 1983; Bhattacharya et al., 1988).  The
degree to which lead's effects on neuropsychological performance
at these levels persist into later life remains to be
established.  One study followed the academic performance of a
subset of the children initially evaluated by Needleman et al.
(1979) and found that grade retention was clearly associated with
past dentine lead levels, while the relationship between other
outcomes and past dentine levels were either marginally -  (e.g.,
•IQ scores, classroom behavior) or statistically non-significant
(e.g., teacher ratings) (Bellinger et al., 1984).

iii) Electrophysiological Effects and Altered Auditory Function
     As discussed earlier, in addition to its varied effects on
neuronal development and chemically-mediated synaptic
transmission, lead impairs peripheral nerve conduction

-------
                            111-37
velocities, at levels possibly as low as 20-30 [ig/dl.  Similarly,
lead exposure affects brain morphology and metabolism, interferes
with neurotransmission in central nervous system tissue  (e.g.,
cerebellum, retina) (Palmer et al., 1981; Fox and Sillman,  1979;
Sillman et al., 1982), and depresses conduction velocities  in the
visual pathways of rats accompanied by persistent decreases in
visual acuity and spatial resolution (Fox et al., 1977;  Cooper et
al., 1980; Winneke, 1980; Impelman et al., 1982; Fox and Wright,
1982).  Neurological assessments of adult workers indicate  that a
wide range of lead levels may be associated with impaired
function in the visual-motor and auditory systems (Repko and
Corum, 1979; Haenninen et al., 1978).

     Electrical activity in the brain, determined by
electroencephalograms (EEC), is disrupted in animals and humans
suffering from lead intoxication (Cooper et al., 1980).  More
subtle abnormalities in brain wave patterns have been associated
with PbB levels in children (along with IQ decrements; Burchfiel
et al., 1980) in the range of 30-50 M-g/dl, with no evident
threshold down to 15 ng/dl, or somewhat lower (Benignus  et  al.,
1981; Otto et al., 1981, 1982, 1985).  The functional
significance of many of the electrophysiological changes observed
below 30 |ig/dl (i.e., slow wave potentials, synchronized EEC
amplitudes, visual evoked potentials) has not been established,
although some changes persisted for at least two years (Otto et
al., 1982).  Inconsistent or unexpected findings across  studies
at PbB <30 |ig/dl (e.g., decreased evoked potential latencies with
increased PbB) (Winneke et al., 1984; Otto et al., 1985; Baumann
et al., 1987) require clarification but may indicate hyper-
excitability of the peripheral and central nervous system.  This
would be compatible with symptoms of cognitive impairment
associated with lead such as attention deficits, learning
disorders, and developmental delays.
     The effects on hearing or nerve conduction in the auditory
pathway that have been related to lead exposure in children may
also be indicative of subtle,  but potentially important

-------
                            111-38
neurological impairment.  Slowed nerve conduction in the auditory
pathway (i.e., increased latencies of brainstem auditory evoked
potentials [BAEP]) was directly related to increased PbB levels
in children 6-12 years old across the range of 6 to 59 p.g/dl
(Otto et al., 1985).  Attempts to replicate these findings in an
independent group of children 3 to 7 years old found that the
latency of BAEP waves, as well as hearing threshold at 2000HZ,
increased with the maximal PbB levels found in the children's
medical records, from 6 to 56 |ig/dl (Otto, 1985; Robinson et al.,
1985) .

     Probability of elevated hearing thresholds in 4 different
freguencies (500-400Hz) increased significantly with increasing
PbB in an analysis of 4,500 children and adolescents (4-19 years
of age) studied in NHANES II (Schwartz and Otto, 1987).  An
association with PbB was apparent across the entire exposure
range down to the lowest levels measured (4 jig/dl) after
adjustment for covariates including history of recent and chronic
ear infections or other disorders.  The age at which a child
first sat, walked, and spoke also appeared to be associated with
PbB levels above 11.5 jig/dl.

     Given that lead exposure may impair hearing and the
peripheral segment of the auditory pathway, and that a hearing
loss occurring in early childhood that remains undetected may
result in speech and learning impairments as the child develops,
the implications of these findings should be pursued as part of
understanding lead's putative role in subtle performance
deficiencies among pre-school and school-age children.  The
preliminary nature of these auditory function results must be
emphasized, however, and until comprehensive longitudinal,
audiometric, electrophysiological, and speech measurements in
children are done, it will be difficult to resolve this issue.

     In summary, there have been some inconclusive findings and
contrasting interpretations regarding lead's effects on specific

-------
                        111-39
neurobehavioral indicators and functions  (e.g., verbal
performance, emotional reactivity, perceptual-motor  integration,
short-term memory, attention, electrical  activity in the brain)
and the mechanisms involved.  The overall evidence,  however,
indicates that lead is associated with neurological  impairment in
some children with PbB levels between 30  and 50 M-g/dl'and that
effects on certain behavioral and electrophysiological measures
which may have some small, but potentially important and
persistent effects on neurological function, support a continuous
dose-effect gradient down to exposure levels as low  as 15-30
M-g/dl PbB, or perhaps, somewhat lower (CD, p. 12-157).

     The CDA supplement concludes that "a blood lead
concentration of 10-15 ng/dl, and possibly lower, remains the
level of concern for impaired neurobehavioral development in
infants and children.  Given the fact that such effects have been
associated with blood lead measures in pregnant women, umbilical
cords, and infants up to at least 2 years of age, there is no
apparent distinction at present as to whether this level of
concern applies to only fetuses or infants or preschool-age
children.  Thus, a blood lead level of 10-15 jjig/dl,  and possibly
lower, ought to be avoided in pregnant women, fetuses, infants,
and young children, although it is recognized that pregnant women
per se are not necessarily a population at risk" (EPA, 1990, p.
55).

     3.   Effects on Reproduction and Physical Development
          Lead compounds have been used as an abortifacient and
severe lead poisoning has been shown to be accompanied by
miscarriages, stillbirths, and reduced fertility (Oliver, 1911).
In female animals, relatively low-level lead exposure has been
shown to affect pubertal progression and hypothalamic-pituitary-
ovarian-uterine functions, as evidenced by ovarian abnormalities
(Hilderbrand et al.,  1973; Der et al., 1974), and delays in
vaginal opening (Grant et al., 1980; Kimmel et al.,  1980) and
first conception (Maker et al.,  1975).  In addition, the ability

-------
                             111-40
of the placenta to support fetuses is compromised in mice exposed
to relatively low lead levels (Maisin et al., 1975; Jacquet et
al., 1976).  Newborn rodents and monkeys whose mothers were
exposed to lead during pregnancy showed compromised growth
(Reiter et al., 1975), congenital malformations in the spinal
cord (Carpenter and Perm, 1977; Jacquet and Gerber, 1979) and
delayed neurological development (see previous section).

     Pregnant women who lived in homes with excessive drinking
water lead concentrations (>800 ppm) bore a significantly higher
proportion of retarded infants (Beattie et al., 1975).  Premature
births, lower birth weight, and premature rupture of membranes
have been associated with maternal PbB of 30-40 ug/dl and above
in women who worked in or lived near lead smelters (Fahim et al.,
1976; Nordstrom et al., 1978).  Women in another smelter
community, all with PbB at 14-20 weeks gestation below 32 ng/dl,
also had increased risk of pre-term delivery (<37th week) as well
as late fetal death (beyond 20th week of pregnancy) (McMichael et
al., 1986).  Mothers whose pregnancies terminated actually had
lower PbB levels than average suggesting the possibility of
greater lead transfer to the fetus in those cases, consistent
with earlier findings (Wibberly et al., 1977).
     In newborn children with umbilical cord PbB levels >6.3
an increased incidence in minor (but not major) congenital anomalies
(e.g., benign cysts and minor skin defects) was reported after
covariate control, although no single anatomic defect was
individually associated with lead (Needleman et al., 1984).  The
longitudinal study of Ernhart et al. (1986), involving a smaller
group, failed to find such an association, with average maternal and
cord PbB levels of 5.8 and 6.5 p.g/dl, respectively.

     Significant reductions in gestational age and birth weight
have been found to be related to increased maternal or cord PbB
in some prospective studies (Moore et al., 1982 — mean PbB
12-14 [ng/dl; Rothenberg et al., 1989 — mean PbB = 15 |o,g/dl;

-------
                            111-41
Dietrich et al., 1984—apparent threshold  at  about 13
whereas other studies have reported non-significant, or
inconsistent effects (Bellinger et al.,  1986a;  Ernhart et al.,
1986; McMichael et al., 1986).  Differences in  the age of the
mothers, racial make-up, sample sizes, and lead exposure  levels,
as well as analytical approaches, could  underlie the varying
results of these different studies (EPA, 1990,  p.  57).

     As discussed earlier, Dietrich et al. (1984)  concluded that
the neurobehavioral deficits associated  with  fetal lead exposure
were in part mediated by the observed reductions in gestation and
birth weight.  Based on subsequent, preliminary analyses  of this
cohort, these investigators suggest that high prenatal  lead
exposure (>8 pig/dl) interacts with high  postnatal  exposure to
yield lower than expected growth rates during the  first 15 months
(Shukla et al., 1987; Bornschein et al., 1989).  Although
preliminary, these findings lend support to cross-sectional
analyses finding small but significant decreases in stature with
increased PbB.  Schwartz et al. (1986) found  that  at 59 months,
the mean PbB of children surveyed in NHANES II  (»  16.0  jig/dl) was
associated with about a 1.5% reduction in  height,  weight,  and
chest circumference, with no apparent threshold across  the
measured PbB.range (5-35 fig/dl).  Dentine  lead  was significantly
associated with growth in Danish children  between  6 and 10 years
of age with low level exposure (Lyngbye  et al.,  1987).  Lauwers
et al. (1986) studied children with higher exposures who  lived in
a lead smelter area and found reduced growth  at PbB levels above
40 |j.g/dl.  Despite the uncertainties regarding  dose-response
relationships, these findings on childhood growth  are highly
plausible given lead's interactions with heme-dependent enzymes,
calcium metabolism, bone formation, and hormonal control  (e.g.,
Rosen et al.,  1980; Rosen,  1983; Sandstead et al.,  1969).
     Male reproductive function is also affected by lead.   Sperm
abnormalities, reduced fertility,  and altered testicular  function have
been observed in lead-exposed animals and  in some  industrial  workers
with PbB levels above 40-50 ng/dl (EPA,  1986a,  pp. 12-219).

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                            IiI-42
     Although there are inconsistencies, available data suggest
that low level exposure to mothers and fathers, may increase the
risk of early developmental delays and deficits and reproductive
abnormalities.  OSHA concluded in 1978 that men and women
planning to have children should maintain PbB at or below 30
|ig/dl.  The 1990 CDA Supplement concludes that "it is difficult,
however, to derive a definitive dose-response relationship foif
fetal outcomes from the available data, although some indications
point to a level of concern starting in the region of 10-15
M-g/dl.  The average maternal blood lead levels in the studies
where the pre-term delivery effect was clearest (Port Pirie and
Glasgow) were in the 10-15 nqj/cll range, in contrast to somewhat
mixed findings in the Cincinnati, Boston, and Cleveland studies
where the maternal or cord blood lead levels averaged below 10
ng/dl.  A similar pattern seems to hold for birth weight as well.
The strongest evidence of a birthweight effect comes from the
Cincinnati study, with some of their analyses suggesting that
this effect could start in the region of 12-13 |ig/dl, but
possibly extending from 7 to 18 ng/cil.  However, other studies
provide no support for this conclusion, and so it is considered
an open issue awaiting more definitive resolution" (EPA, 1990,
pp. 57-58).

     4.   Effects on the Kidney
          Excessive exposure to lead can cause renal disease (see
CD, Section 12.5).  At low dosages, lead disturbs heme-mediated
generation in the kidney of the hormonal metabolite of vitamin D,
critical to calcium metabolism (see Section III.D.I).  Lead also
affects renal mitochondrial structure (e.g., swelling) and other
functions (e.g., altered respiratory rates, oxidative
phosphorylation and synthesis of proteins and nucleic acids)
(Goyer, 1968; Fowler et al., 1980, 1981 a,b; Silbergeld et al.,
1982).  Lead's interference with these biochemical processes in
the kidney, particularly energy metabolism, might account for the
transient decreases in renal tubular reabsorptive processes, as
indicated by hyperaminoaciduria, glycosuria, and
hyperphosphaturia, at PbB levels ranging from 40 to more than

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                             111-43
100 M-g/dl, and possibly as low as 30 M-g/dl (See CD, Sections
12.5.2 and 12.5.3; p. 12-170).  The effects of chronic, low-level
lead exposure on renal dysfunction in children have not been
adequately studied, mainly because there is no good method to
easily detect an early renal effect of lead.

     There is limited evidence that elevated lead absorption
contributes to renal disease in association with gout and
hypertension (Emmerson, 1973; Batuman et al., 1981; Wedeen,
1982).  The mild hypertension associated with chronic low-level
lead exposure however, may be related to lead's ability to
directly alter vascular reactivity (Webb et al., 1981; see
following section).

     5.   Effects on the Cardiovascular System
          Symptoms consistent with cardiac disease, such as
degenerative changes in heart muscle (Kline, 1960), abnormal
electrocardiograms (ECG) (Silver and Rodriquez-Torres, 1968) and
increased cerebrovascular mortality (Dingwall-Fordyce and Lane,
1963; McMichael and Johnson, 1982; Fanning, 1988) have been
associated with high human lead exposures.  Cardiotoxicity has
been reproduced in experimental animals acutely exposed to high
concentrations of lead.  Effects include depression in
contractility, increased susceptibility to norepinephrine-induced
arrhythmias (exaggerated in neonates), and decreased cardiac
protein phosphorylation (Kopp et al., 1980; Williams et al., 1977
a,b).  It appears that effects may persist in immature rats even
after cessation of- lead exposure (Williams et al., 1977b).

     Chronic administration of lead resulting in PbB levels as
low as 40 M-g/dl caused structural changes in the myocardium of
mice, and ECG abnormalities that are likely due to nerve
conduction disturbances (Khan et al., 1977, Kopp et al., 1980).
Besides affecting cardiac output, low levels of lead exposure
have produced increased vascular responsiveness to contractile
agents such as noradrenaline, and sustained elevations in

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                             111-44
systolic blood pressure in rats with PbB levels around 40 ng/dl
(and possibly lower) (Webb et al., 1981; Victery et al., 1982;
Perry and Erlanger, 1979; Aviv et al., 1980; Kopp, 1980).  These
changes may be linked to depressed energy metabolism (Kopp,
1980), or to altered nerve transmission by increased
intracellular calcium concentrations (mediated by impaired
sodium-potassium cotransport or activation of protein kinase C)
resulting in increased vascular reactivity in arteriolar smooth
muscle to vasoconstrictive agents such as norepinephrine and
angiotensin (Victery et al., 1982; Rasmussen, 1983; Skocynska et
al., 1986; Chai and Webb, 1988; Moreau et al., 1988; Weiler et
al., 1988).  These studies suggest possible mechanisms by which
lead may contribute to hypertension in humans.

     Excessive amounts of mobilizable lead have been measured in
patients with hypertension (Batuman et al . , 1983) and evidence of
increased hypertension has been found among men occupationally
exposed to high levels of lead (> 50-60 ng/dl) (Inglis et al.,
1978; Lilis et al., 1977; Kirkby and Gyntelberg, 1985; de Kort et
al., 1987; Cooper, 1988), although there have been contrasting
findings in similar populations (Richet et al . , 1966; Cramer and
Dahlberg, 1966; Parkinson et al., 1987; Selevan et al., 1988).
After covariate adjustment, lead exposure has been associated
with hypertension prevalence (Beevers et al., 1976; Kromhout and
Coulande, 1984) and small increases in blood pressure in some
community studies (Moreau et al., 1982; Pocock et al., 1984;
Pirkle et al., 1985; Weiss et al., 1988; Neri et al . , 1988; Sharp
et al., 1988; Schwartz, 1989), but not in others (Staessen et
al., 1984; Elwood et al., 1988; Grand jean et al . , 1989).
Rabinowitz et al. (1984b) reported that umbilical cord PbB was
significantly associated with both mother's blood pressure at
delivery and the presence of pregnancy hypertension in a sample
of 3200 live births in Boston with a mean cord PbB of 6.9
     Weiss et al .  (1988) followed changes in blood pressure among
89 Boston policeman over 5 years.  Despite the small sample, the

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                             111-45
longitudinal nature of the data overcomes many limitations
associated with cross-sectional studies and provides  a  sensitive
measure to detect a subtle effect.  Time-series and bootstrap
analysis indicated a significant association between  PbB  above  30
M-g/dl (but not below) and subsequent elevation in systolic  (but
not diastolic) pressure.  Another longitudinal study  of lead
.foundry workers also found a significant association  but  results
are confounded by cadmium exposures (Neri et al., 1988).

     Some of the largest cross-sectional studies, involving as
many as 7300 adult men (Pocock et al., 1984; Pirkle et  al., 1985;
Schwartz, 1985a,b; 1986a,b; E.I. Dupont de Nemours, 1986a,b) and
subsequent reanalyses, are focused on in the 1986 CDA (pp. A-10
to A-18) and 1990 CDA Supplement.  The quantitative results of
these studies are summarized in Table A-3 of the CDA  and  Table  1
of the CDA Supplement.

     Although the investigators in these studies originally
published divergent conclusions, reassessment using comparable
statistical approaches (comparing covariate-adjusted  regression
coefficients) on these, as well as 2 other "negative  studies" on
over 1700 Welsh men and women (Elwood et al., 1988),  revealed
substantially overlapping confidence intervals and a  consistent
indication of at least a weak positive association (Pocock et
al., 1988; Figure l, CDA Supplement).  Based on the their
analysis, Pocock et al. concluded that a mean increase  of 1.45  mm
Hg in systolic blood pressure appears to occur for every doubling
of PbB concentration.  This supports the earlier conclusion in
the 1986 CDA (p. A-17) that the analyses in Table A-3 (Table 1  in
the CDA Supplement) represented the best estimates of the
association (i.e., generally in the range of 2.0-5.0  mm Hg/log
PbB for systolic and 1.4-2.7 mm Hg/log PbB for diastolic blood
pressure).  The consensus among leading experts at the  1987
International Symposium on Blood Lead-Blood Pressure
Relationships was similar:  that a doubling of PbB was  associated
with about a 1-2 mm change in blood pressure, on average  (Victery
et al.,  1988).

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                           111-46
     The NHANES II analyses initially focused on white males aged
40 to 59 years to avoid the collinearity between blood pressure
and blood lead evident at lower ages, and because data relating
cardiovascular disease to blood pressure are less extensive for
non-whites (Pirkle et al., 1985).  Lead was found to be a
significant, but weaker, predictor of blood pressure in
additional analyses on all men ages 20-74, both black and white
(Schwartz, 1988), and in adult women ages 20-74.  A threshold
below which blood lead was not significantly related to blood
pressure could not be found in that study across a range of
adjusted PbB levels between 7 and 34 |j.g/dl.  It is of interest to
note that the dose-response relationships found by Pirkle et al.
(1985) suggest a large initial effect, leveling off at higher PbB
levels, which is consistent with the biphasic blood pressure
response to PbB levels found in rats (Victery et al., 1982) and
with the saturable, lead-induced accumulation of calcium in cells
(Pounds et al., 1982).  This may account for the inconsistent
epidemiologic findings in persons with mild to moderate
elevations of blood lead.

     Because of the complex inter-relationships among the
multiple environmental, dietary, medical, socio-economic, and
genetic factors that influence blood pressure, all of which may
not be measurable, results from even the recent large studies
must be interpreted cautiously.  Nevertheless, the CDA Supplement
concludes that the new information emerging since 1986
substantiates the main conclusions stated in the CDA at that
time:
     "Sufficient evidence exists from both the four large-
     scale general population studies discussed above
     (NHANES II, BRHS, and the two Welsh studies) and
     numerous other smaller-scale studies to conclude that a
     small but positive association exists between blood
     lead levels and increases in blood pressure.
     Quantitatively, the relationship appears to hold across
     a wide range of PbB values, extending possibly down to
     as low as 7 [ig/dl for middle-aged men, and furthermore,
     an estimated mean increase of about 1.5-3.0 mm Hg in
     systolic blood pressure appears to occur for every
     doubling of blood lead concentration in adult males and

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                          111-47


     something less than 1.0-2.0 mm Hg for adult females.  The
     plausibility of these relationships observed in
     epidemiologic studies of human populations being of a causal
     nature is supported by controlled experimental animal
     studies demonstrating increased blood pressure effects
     clearly attributable to lead, with an apparent biphasic
     dose-response relationship being involved." (EPA, 1990, pp.
     22-23)

     As noted by Tyroler (1988) and other discussants at the 1987

Symposium mentioned above, despite the seemingly small elevations
in blood pressure when viewed from the clinical perspective of

each individual, any increase in blood pressure carries with it

increased risk (albeit very small) for stroke, heart attack,

and/or associated mortality.  Projections of potential lead
effects on such outcomes were modeled by Pirkle et al. (1985).

The CDA Supplement concludes that:
     "projections of potential lead effects on such
     outcomes, as were modelled by Pirkle et al. (1985) and
     discussed in the 1986 Addendum, are not unreasonable in
     view of the potentially very large public health
     impacts; however, much caution must be exercised in
     accepting the validity of any specific quantitative
     estimates derived from such projections in view of the
     uncertainties associated with the selection of the
     specific coefficients used for (1) blood-lead-blood
     pressure relationships and (2) relationships between
     blood pressure increases and more serious
     cardiovascular outcomes."  (EPA, 1990, p. 23)

     Recent reanalyses of NHANES II data help to illustrate the

possibility of detecting indications of small increased risks in
the general population.  Schwartz (1989) found a direct

relationship between PbB levels and electrocardiogram (EGG)
abnormalities, indicative of left ventricular hypertrophy.   Such

EGG abnormalities represent an early indicator of cardiovascular
disease that is much more common than frank myocardial

infarctions.  It remains to be determined to what extent these
observations are due to a lead-induced increase in blood pressure

or to some other lead-related pathogenic mechanism (EPA,  1990; p.
19).

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                             111-48
     6.    Possible Genotoxicity/Carcinogenicity
     Dose-related increases in renal tumors (Azar et al., 1973;
van Esch et al., 1962; Hass et al., 1967) and tumors in endocrine
organs (Zawirska and Medras, 1968) have been reported in rats
administered dietary lead acetate or lead subacetate.  Other
studies have found no indication of tumors at either low doses or
short duration exposures in rats and mice (Kanisawa and
Schroeder, 1969; Stoner et al., 1976; Koller et al., 1985) or
high doses in hamsters (van Esch and Kroes, 1969).  Data on other
chemical forms of lead are either lacking (e.g., lead chloride),
or are limited, but suggestive of carcinogenic potential (lead
phosphate via injection, Roe et al., 1965; lead oxide via
tracheal instillation with benzo[a]pyrene, Kobayashi and Okamato,
1974; lead napthenate via skin painting, Baldwin et al., 1964).
Evidence for tumors at other sites other than kidneys is
uncertain (Hass et al., 1967; Blakely et al., 1987).

     Since lead is capable of transforming cells directly in
culture (DiPaolo et al., 1978; Casto et al., 1979) and affecting
DNA-to-DNA and DNA-to-RNA transcription (Sirover and Loeb, 1976;
Robinson et al., 1984), lead may serve as an initiator of
carcinogenic activity.  Lead's potential to induce chromosomal
aberrations (CD, Table 12-21) may be indicative of its ability to
initiate carcinogenic activity but contradictory results have
been reported (EPA, 1986a, Table 12-22).  In addition, lead may
be a promoter of carcinogenesis, as indicated by its ability to
increase DMA, RNA, and protein synthesis (Choie and Richter,
1974, a,b), and to enhance the development of renal tumors in
rats previously treated with a known carcinogenic initiator
(Hiasa et al., 1983; Shirai et al., 1984).  Lead's sequestration
in the form of "inclusion bodies" in kidney cell nuclei may be
linked to its carcinogenic effects (EPA, 1986a, p. 12-244).

     An evaluation of these results by EPA (1989b) concludes
that:  (a) the evidence for carcinogenicity of lead in animals is
adequate, although positive responses were generally seen only at

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                             111-49
high doses (above a cumulative dose of 1 gram); (b) because
several different lead compounds including organic and inorganic
ones have been shown to be capable of inducing kidney cancer, and
all lead compounds tested are capable of increasing the body
burden of lead, from a qualitative weight of evidence
perspective, all lead compounds are considered to be potentially
carcinogenic; (c) most experiments administered lead in the food,
although positive results were reported using other routes.
Although no inhalation cancer bioassays are available, there is
ample evidence for the bioavailability of lead via inhalation.
Lead is therefore considered to be potentially carcinogenic by
any route.

     Epidemiological studies of lead-exposed workers and children
suggest lead may induce chromosomal aberrations that may be
associated with certain forms of cancer (Grandjean et al., 1983;
Dalpra et al., 1983).  Little can be reliably concluded from the
conflicting occupational findings on kidney tumor incidence and
excess cancer mortality (e.g., Cooper and Gaffey, 1975; Cooper,
1985; McMichael and Johnson, 1982; Sheffet et al., 1982; Selevan
et al., 1988; cantor et al., 1986), although the significant
elevations in respiratory and digestive tract cancer in workers
exposed to lead and other agents warrant concern (EPA, 1986a, p.
12-225).  These latter findings should not be over-interpreted
given differences in age distributions among the populations
studied and inadequate controls for factors such as smoking,
diet, ethnicity, geographical location, and simultaneous
exposures to other heavy metals such as arsenic and chromium,
which are proven carcinogens.  Furthermore, these studies provide
no specific information on the long-term lead exposure levels or
the lead compounds to which workers were exposed.
     The criteria document concludes that:
     "Since lead acetate can produce renal  tumors in some
     experimental animals, it seems reasonable to conclude that
     at least that particular lead compound should be regarded
     and treated as a human carcinogen (as  per recommendations of
     the International Agency for Research  on Carcinogenicity).
     However, this statement is qualified by noting that lead has

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                           11-L-OU
     been seen to increase tumorigenesis rates in animals only at
     relatively high concentrations, and therefore does not seem
     a potent carcinogen.  In vitro studies further support the
     genotoxic and carcinogenic role of lead, but also indicate
     that lead is not potent in these systems" (EPA, 1986a, p.
     12-289).
     Since the IARC recommendations were published in 1980, an
EPA assessment (EPA, 1990) recommends that lead be classified as
a probable human carcinogen in a tentative weight-of-evidence
"Group B2".  Evidence on potential carcinogenicity from human
studies is considered "inadequate" and the evidence from animal
studies is considered "sufficient" according to EPA's guidelines
for Carcinogen Risk Assessment (EPA, 1990).  This classification
includes all lead compounds since all can be absorbed from both
the respiratory and gastro-intestinal tracts, and in some cases,
from the skin.  Although the mechanism through which lead induces
chromosomal aberrations and mutations is unknown, the pattern of
responses suggests that lead compounds may not directly damage
the genetic material, but rather may act through an indirect
mechanism, such as activation of cellular transformation or tumor
promotion (EPA, I989b).

     Although there are animal dose-response data that could be
used to describe the carcinogenic potency of lead, the Agency
staff feels that any such calculation would be highly uncertain.
A variety of complicating factors influence lead-induced cancer,
such as the route of exposure, nutrition, and bioavailability of
different chemical forms.  The preliminary evaluation of lead
carcinogenicity concludes that while pharmacokinetic models have
been developed to assess non-cancer health effects in humans,
comparative models across species would be needed to extrapolate
from high-dose animal studies to project human cancer risks at
low-level environmental exposures, and that sufficient
information is not available to incorporate many of the factors
into a credible exposure-response model for humans (EPA, 1989b).
.Based  on qualitative characterization, this assessment placed
lead in potency Group 3 ("low"), as defined in EPA guidelines for
evaluating potential carcinogenicity (EPA, 1986b).  Combining the

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                             111-51

weight of evidence (B2) and the potency ranking, lead receives  a
"hazard" ranking of "low" relative to other potential
carcinogens .

     The potential carcinogenicity of lead raises concern;
available data, however, do not indicate substantial risks  that
can be anticipated at current exposure levels.  It is recommended
that for purposes of revising the lead NAAQS, attention be
focused on the non-cancer effects of lead which represent
significant risks at relatively low exposure levels.
However, the staff believes that the potential carcinogenicity  of
lead should be considered in determining an adequate margin of
safety.

E.   Summary of Health Risks Associated with Different Blood Lead
     Levels of Concern

     This section presents a brief staff assessment of how  the
dose-response information summarized previously may be applied  in
determining PbB levels of concern for sensitive populations in
assessing the relative protectiveness of alternative lead NAAQS.

     Lead exposure across a broad range of exposure, levels has
been associated with a continuum of effects ranging from subtle
molecular changes to clear pathological effects.  The critical
findings at low PbB levels are as follows:

     (1)  Inhibition of ALA-D and Py-5-N activity at 10-15
and possibly below, with no evident threshold;
     (2) Elevated EP levels at 12-23 ng/dl in children, depending
on their iron status.  Elevated EP indicates interference with
heme or hemoprotein synthesis in many tissues, which can result
in reductions in oxygen transport, changes in cellular
energetics, interference with neurotransmitter synthesis and

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function, reduced detoxification in the liver, and impaired
vitamin D metabolism;

      (3) Interference with vitamin D hormone synthesis  in
children with no apparent threshold down to the lowest levels
measured (12
     (4) Reduced auditory function in children with no apparent
threshold down to the lowest measured levels  (4-6 n-g/dl);

     (5) Altered electrical brain wave activity with no evident
threshold down to 15 ng/dl, and possibly lower;

     (6) Deficits in IQ and other measures of cognitive function
(e.g., attention span) in children at PbB levels above 30 (ig/dl ,
and small deficits as low as 15 M-9/cll (or possibly lower) in
socially disadvantaged children;

      (7) Slowed peripheral nerve conduction at PbB as low as  20-
30 ng/dl in children;

      (8) Deficits in mental developmental indices in infants
with maternal or umbilical cord PbB levels . as low as 10-15 jig/dl.
The CDA Supplement concludes that a PbB concentration of 10-15
M-g/dl, and possibly lower, remains the level of concern for
impaired neurobehavioral development in infants and children
(EPA, 1990, p. 55);

     (9) Low birth weight and decreased gestational age, which
may influence early neurological development, at maternal PbB
levels above 12-14 jig/dl;

     (10) Reduction in early childhood growth with no apparent
threshold in one study across the range of 5-35 jig/dl; a
threshold at 40 \ig/dl was identified in another study;

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                              111-53
      (11) Small increases in blood pressure in adult men with no
apparent threshold from cross-sectional data down possibly, to 7
     Evidence that lead is a potential, weak carcinogen is also
of concern although the focus here will remain on the non-cancer
effects at low exposure levels.

     The lack of an apparent PbB threshold in several studies is
supported by the fact that many of the biochemical changes, or
mechanisms, that appear to underlie lead toxicity (e.g., altered
enzyme activity, membrane receptors, calcium homeostasis) have
been observed at the lowest experimental dosages administered,
often with no discernible threshold.  There is a great deal of
uncertainty regarding the point at which subtle molecular changes
individually or collectively, become significant enough that they
should be regarded as constituting "adverse" effects for purposes
of standard setting under the Clean Air Act.  However, such
effects clearly become more pronounced (and likely) , and broaden
to cause more severe disruptions of the normal functioning of
many organ systems, as PbB levels increase.  This continuum of
effects, from biochemical responses, cellular dysfunction and
morphological changes, to organ system alterations and clinical
toxicity, makes it difficult to identify clearly what PbB level
constitutes an appropriate "threshold", if any, below which there
are no significant risks of adverse effects.

     One approach would be to simply state, as the American
Academy of Pediatrics does, that since lead has no biologic
value, the "ideal" PbB level is 0 ng/dl (AAP, 1987).  This may be
a correct public health goal, and adopting it as the basis for
revising the lead NAAQS would avoid the problems inherent in
addressing the kinds of uncertainties discussed above.  However,
the Clean Air Act does not instruct the Administrator to
eliminate all conceivable health risks that might result from
atmospheric lead, regardless of their likelihood, extent,  or

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                              111-54
significance, simply because there are uncertainties in the
relevant scientific data.  Instead, it requires him to weigh the
available evidence, including the uncertainties, and set NAAQS
which, in his judgment, will protect public health against
"adverse" effects with an adequate margin of safety.
Accordingly, the staff believes it is appropriate to assess the
implications for public health of potential effects at PbB levels
above zero and to examine the degree of protection that would be
afforded by alternative NAAQS.
     The approach taken here is to identify those effects that
individually or collectively represent an adverse pattern that
should be avoided.  For children, the collective impact of the
effects at PbB levels above 15 ng/dl can be seen as representing
a clear pattern of adverse effects worthy of avoidance.  Such
levels provide relatively little margin from those currently
defined by CDC as requiring environmental or medical intervention
(> 25 jig/dl along with elevated EP levels).  At levels of 10-15
M-g/dl, there appears to be a convergence of evidence of lead-
induced interference with a diverse set of physiological
functions and processes, particularly evident in several
independent studies showing impaired neurobehavioral function and
development.  While the available data do not indicate a clear
threshold at 10-15 ng/dl, but rather suggest a continuum of
health risks down to the lowest levels measured, the effects of
lead below this range become increasingly difficult to detect and
their significance more difficult to determine.  For purposes of
comparing the relative protectiveness of alternative lead NAAQS,
the staff has estimated the percentages of children with PbB
levels above 10 and above 15 (J-g/dl (see Section IV.C) .

     While the dose-response information on blood pressure
changes in men is less clear than the information on children,
the same approximate range of PbB levels can also be considered
for assessing risks among adult men.  Percentages of middle-aged
men with PbB levels above 10 and 12 ng/dl are estimated to
compare relative protection afforded by alternative NAAQS.

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                             111-55
Quantitative analyses of differences in prenatal lead exposures
under alternative lead NAAQS are not done in this review  (see
Section III.A).  Although fetal sensitivity to lead is high, it
appears that young children are significantly more responsive to
a lead NAAQS; therefore, the analyses that focus on young
children likely provide appropriate estimates of relative risks
among alternative standards.  Risks associated with fetal lead
exposures will be considered in determining an appropriate margin
of safety.

     To further focus the evaluation of alternative lead NAAQS in
Section IV.C., the following factors should be considered:  (1)
young children are most exposed and absorb a greater proportion
of lead; (2) lead accumulates and persists not only in the
skeleton but in target organs such as the immature brain; (3)
peak exposure generally occurs during the period of maximal
neurological growth and differentiation such that any effects on
the "hardwiring" of neural networks in the brain may be
irreversible.  Given these considerations, the staff recommends
that of the different sensitive populations and PbB levels of
concern, greatest attention be placed on the percentages of young
children with PbB levels above 10 ng/dl.

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IV.  FACTORS TO BE CONSIDERED IN SELECTING A PRIMARY STANDARD  FOR
     LEAD

     This section, drawing upon the previous evaluation of
scientific information from the criteria document and other
information sources, outlines the key factors that should be
considered by the Administrator in designating appropriate
criteria for averaging time, sampling frequency, monitoring
options, and in establishing the level of the lead primary
standard.  Preliminary staff conclusions and recommendations
regarding the most appropriate policy options in each of these
areas are presented.

     A.   Averaging Time
     When the lead standard was proposed in 1977, the averaging
time for the primary lead NAAQS was specified as a calendar month
due to studies which showed an equilibration period of
approximately 60 days before steady state PbB levels in adults
adjust to changes in air lead concentration (Rabinowitz et al.,
1973; Griffin et al., 1975).  A month averaging time was
considered appropriate because of the greater risk of exposure of
young children (FR Vol. 42, No. 240, 1977).  Subsequently, EPA
promulgated the current NAAQS with a calendar quarter averaging
time based on the conclusion that an air lead level of 1.5 v^g/m3
as a ceiling would be safe for indefinite exposure of young
children, and that the slightly greater possibility of elevated
air lead levels within the quarterly period was not significant
for health (FR Vol..43, No. 194, 1978).   The risk of shorter term
exposures to air lead concentrations elevated above a quarterly-
averaged standard that might go undetected was considered in the
1978 standard decision to be minimized because 1) based on the
ambient air quality data available at that time,  the
possibilities for significant,  sustained excursions were
considered small, and 2)  it was determined that direct inhalation
of air lead is a relatively small component of total airborne
lead exposure (FR Vol. 43,  No.  194,  1978).

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                            IV-2
      Since promulgation of the lead NAAQS in 1978, the air lead
problem has changed in scope from a nationwide, primarily auto
emission problem to one related to point source emissions.  Point
source emissions accounted for 63 percent of total lead emissions
in 1987 (EPA, 1989c) and will reach an even higher fraction as
gasoline lead emissions continue to decline.  Therefore, the 1978
standard decision rationale is no longer as directly relevant to
the remaining issues surrounding air lead emissions.  The
following assessment of additional health and exposure
information available since 1978 and other evidence suggests that
a monthly averaging time would be more appropriate than a
calendar quarter.

1.   Biological Kinetics of Lead and Potential Health Impacts
     Associated with Short-Term (Days-Weeks^ Exposures
     Lead is absorbed from the environment through the lungs
(direct inhalation) and through the gastro-intestinal tract
(ingestion).  See Chapter 10 of the CD and exposure report (EPA,
1989a) for complete discussions of lead biokinetics and multi-
media exposure. Once lead is absorbed into blood plasma through
the alveoli or through the gut lumen, it is quickly ionized and
is distributed from plasma to the red blood cells, kidney, liver,
skeleton, brain, and other tissues.  The following discussion
summarizes the most relevant information from studies on adults
and on children.

     a)   Adult Data
     The initial uptake of lead from plasma to the red blood
cells is very rapid, occurring within a few minutes to tens of
minutes (Campbell et al.; 1984; Chamberlain, et al., 1983; De
Silva, 1981).  Ingested lead appears in urine in less than one
hour (Chamberlain et al., 1978).  Analysis of data from studies
on exposure to lead isotope tracers (Rabinowitz et al., 1973,
1976; Griffin et al., 1975; De Silva, 1981) show that lead is
absorbed into peripheral tissues in adults within a few days
(Marcus, 1985a,b,c; Chamberlain, 1985).

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                            IV-3

     The relevance of the rapid transfer of lead via blood  plasma
into target tissues is difficult to assess.  Most animal  and
human studies of lead toxicity use measures of lead exposure
which reflect accumulations over time  (such as blood and  tooth
lead), and thus do not readily allow effects of different
exposure patterns to be distinguished.  It is generally accepted,
however,-that acute exposures to very high lead levels (i.e.  from
ingestion of paint chips) can result in immediate changes in
blood lead and overt toxicity.  Data are available on the effects
of intense inhalation exposures on a direct precursor of  lead
toxicity, impaired heme synthesis.  PbB levels and ALA-D  activity
in workers experiencing occupational lead exposure (e.g., as  high
as 2-4 mg/ra3  air  lead)  for the first  time were  significantly
altered after only a few days of exposure (e.g., from 12  to 40
M-g/dl PbB in 3 weeks), and concentrations of urinary lead and
urinary ALA changed significantly after about two weeks (Tola et
al., 1973).  Hemoglobin and heraatocrit levels were significantly
lower in the workers at the end of the observation period (about
3 months).  After a brief massive exposure of a British worker,
zinc EP became highly elevated within one week.   Similar results
were seen under controlled conditions in which single
experimental lead exposures were followed by a rapid (10-20 days)
and significant elevation in EP in adult men and women (Stuik,
1974; Cools et al., 1976; Schlegel and Kufner,  1979).

     While lead uptake and the onset of potential toxicity may
occur rapidly during increased exposure, there is long-term
retention of lead in tissues,  and reductions in exposure do not
cause an egually rapid reduction in either body burden or
toxicity.  Accumulation of mobilizable pools of lead in the
skeleton and other tissues create an endogenous source of lead
that is only slowly eliminated.   Even soft tissues such as
kidney, liver,  and the brain retain lead on the order of months,
and lead in bone may be retained for many years.   Thus,  the rapid
intake of lead during periods  of increased exposure is of

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                            IV-4

critical concern in determining an averaging time for the lead
NAAQS.

     b)   Data on Children
     The experimental data cited above are all based on adults,
mostly males, and while valuable, should not be directly
extrapolated to children.  Children are kinetically different
from adults, with a proportionally larger volume of blood and a
much smaller but rapidly developing skeleton (especially dense
cortical bone which retains most of the adult body burden of
lead).  Children also absorb lead from the environment at a
greater rate, as they have greater gastrointestinal absorption of
ingested lead and a more rapid ventilation rate than do adults.
Blood lead concentrations change substantially during childhood
(Rabinowitz et al., 1984a).  These changes reflect the washout of
in utero lead and the exposure of the child to changing patterns
of food and water consumption, and changes in exposure to leaded
soil and dust in his or her environment.  Thus, an important
consideration in determining an averaging time for the lead NAAQS
is how quickly a child responds to changes in exposure.

     As noted earlier, clinical studies with adult male
volunteers showed that PbB changed to a new equilibrium level
after 2 or 3 months of exposure,  with a half-life of lead in
blood of 18-28 days (Rabinowitz et al., 1973, 1976; Griffin et
al., 1975).  Few direct measurements have been made on the
equilibration period for blood lead in children, although the
higher metabolic rates in children would be expected to produce a
more rapid turnover rate of red blood cells, along with lead, in
their blood compared to adults (Chamberlain, et al., 1978) and
would thus be more sensitive to changes in lead exposure.
Limited, but informative, data on lead biokinetics in children
are available:
     (1) • Ryu et al. (1983) measured lead balance in infants
exposed to controlled concentrations of lead in formula and in
milk.  Blood lead and lead content of food were measured at 28-

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                            IV-5
day intervals.  Blood lead levels in these  infants  appeared to
equilibrate so fast that no estimate of the kinetic parameters
was possible.
      (2)  A preliminary estimate by Duggan  (1983),  based  on
earlier input-output studies in infants (Ziegler  et al.,  1978)
gave  a PbB half-life (= mean life * log(2)) of 4  to 6 days.
Duggan's method has many assumptions and uncertainties.   An
alternative method, allometric scaling based on surface area,
suggests that if a 70 kg adult male has a blood lead mean life  of
30 days, then a 7 kg infant should have a blood lead mean life  of
about 8 days.
      (3)  A biomathematical model has been  developed by Harley
and Kneip (1985) and modified for use by OAQPS (EPA, 1989a).
This  biokinetic model is based on controlled lead exposure
studies on infant and juvenile baboons, believed  to constitute  a
valid animal model for human growth and development.  Data  on
human growth patterns were subsequently used to calibrate the
model.  Validation and application of the model is  discussed in
the staff exposure report (EPA, 1989a) and  in Section IV.C.
Annual changes of kinetic parameters such as the transfer rates
for blood-to-bone, blood-to-liver, liver-to-gastrointestinal
tract, and growth of blood, tissue, and skeleton are included.
The model predicts a mean residence time for lead in blood  of 2-
year-old children as 8 days.
      (4)  A population of poor, urban children with pretreatment
PbB concentrations greater than 50 |ig/dl received chelation
therapy and were than followed prospectively for the next 2 to  2
1/2 years (Chisolm et al., 1985).   Following therapy, blood lead
levels increased within one month to varying degrees, depending
on the housing conditions the children returned to, and
stabilized after three months.   Individual records showed that
PbB levels usually increased in 3  months by approximately 10
M-g/dl in children who moved from lead-free or renovated housing
to old housing with some lead-paint hazards and that PbB  levels
decreased in a similar fashion in  those who moved in the opposite
way.   The authors conclude that such observations suggest that

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                                IV-6
PbB is "quite sensitive to changes in exposures to lead" (Chisolm
et al., 1985).
     (5)  A more rapid equilibration rate for blood lead in
children is indicated by regression analyses of NHANES II data in
which individual children's PbB levels most closely correlated
with the previous month's gasoline lead consumption compared to
the current month and second previous month's gasoline lead use
(the third previous month's gasoline lead coefficients were not
significant) (Schwartz, 1985).  A one month-lagged gasoline lead
also best fit blood lead in regression analyses of New York and
Chicago screening data (Schwartz, 1985) and of cord blood lead in
Boston (Rabinowitz et al., 1984b).  In addition, for the
prevalence of children then reported (1976-1980) to have lead
toxicity (PbB > 30 (ig/dl) in CDC quarterly screening reports and
in NHANES II, a greater portion of the variance was explained by
one month-lagged gasoline lead, compared to concurrent or
previous gasoline lead use (Schwartz 1985).

     Based on the above data, it appears that increased lead
exposure may produce increases in steady state PbB levels in
children much sooner than the 60 days observed in adults, and
that such changes may not reflect those occurring in the levels
of toxicologically active, or mobile, lead throughout the body,
particularly if exposure is in the form of intermittent pulses.
Although it is difficult to specify a precise temporal pattern of
lead exposure most critical in determining health risks, there is
some cause for concern regarding the current 3-month averaging
time.  This concern is based on the following findings:  1) based
on limited occupational and experimental studies, exposures < 2
weeks to high levels of lead result in significant changes in
heme biosynthesis; effects' on other physiological processes
associated with similar short-term exposures, and effects of
short-term exposures more typical of ambient conditions remain to
be studied; 2) lead accumulates in the body and is only slowly
removed, therefore repeated exposures to small amounts over many
months may produce elevated PbB levels (CDC, 1985); 3) the

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                             IV-7

mean-life of lead in blood in adults is approximately  30  days  and
the toxicologically active fraction of blood  lead appears to
respond quickly to changes in exposure; 4) the rate of
equilibration in children is expected to be much faster than in
adults due to their overall higher metabolic  rate.  This  would
result in children being more responsive to short-term exposures;
and 5) based on NHANES II and gasoline lead data, children's PbB,
levels and the number of children with elevated lead levels,
appear to respond to monthly variations in air lead emissions.

     In summary, it appears that a monthly standard would be a
more appropriate averaging time than the current quarterly
standard, especially around point sources where emissions may
vary significantly from day to day (see section II and section
IV.B.).  Not only would a monthly standard, when compared to a
quarterly standard set at the same level, better capture
significant excursions in lead exposure, it would also reduce
average long-term air lead levels and deposition since controls
would be necessary to meet the standard in months with increased
emissions, and would thereby reduce the number of children with
long-term elevated blood lead levels.

B.   Form of the Standard and Sampling Frequency

     1*.   Form of the Standard
     Any ambient standard is defined not only by its averaging
time and level,  but by the characteristic way attainment  of that
standard is determined,  i.e., its form.   The method of judging
attainment of the current lead NAAQS is deterministic—the
maximum arithmetic mean average over a calendar quarter is not to
exceed 1.5 M-g/m3.  Although other NAAQS have adopted statistical
forms to determine compliance,  the staff recommends maintaining a
deterministic form for the lead NAAQS due to the unique
properties of lead contamination and exposure around point
sources.

     Several alternative forms  of a revised NAAQS for lead have
been examined,  all of which emphasize peak monthly average

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                           IV-8

concentrations (Frank and Faoro, 1989).  The analyses were
conducted independent of a specific concentration level for the
standard over a computed three calendar year attainment period.
This procedure is consistent with the multi-year formats adopted
for the ozone and particulate matter NAAQS.  The forms considered
are presented in Table 4.1.  Associated with these forms are
rules by which attainment is judged.-  For example, with the
second highest monthly average form, at most one monthly value in
a 3-year period would be permitted to exceed the stated level of
the NAAQS.

     In order to evaluate the statistical characteristics of each
form, two types of analyses were conducted.  First, a computer
simulation was performed using generated daily lead
concentrations over a three-year period.  This permitted the
examination of a wide range of possible data sets with identical,
known characteristics.  The second type of analysis involved the
examination of actual lead data observed at point source-oriented
sites.  This provided additional perspective for currently
monitored situations.

     All of the comparisons were based on a design value,  also
referred to as the design concentration.  This design value
reflects the amount of air pollution control necessary to attain
a standard.  As used in this evaluation, as the design value
increases, the stringency of the form being evaluated increases.
The results were presented as relative values normalized to the
expected maximum monthly average concentration (option 3).  Using
a reference indicator, the. conclusions are independent of the
concentration level selected for the standard.

     Lead concentration distributions derived from actual point
source-oriented monitoring sites were used as generating models
for the simulation.  Daily air quality data in the vicinity of an
ASARCO refinery in Omaha and a lead oxide manufacturer in
Philadelphia were used to estimate the underlying distributions.

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IV-9
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-------
                            IV-10

The simulation analyses based on 100 sets of 1080 values, each
set representing 3 years of simulated lead data, were used to
examine the relative stringency among the alternative forms and
the potential effects of incomplete sampling (Frank & Faoro,
1989).

     The first simulation analysis examined the relative
stringency of each potential form of the standard in terms of
average design values.  The average design values produced for
the alternative 3-year forms ranged from 2.97 to 3.89 ng/m3,  (see
Table 4-1) with the maximum monthly average yielding the highest
value (most stringent) and the expected maximum calendar month
yielding the lowest value (least stringent).  The maximum second
highest monthly average per year produces a relatively low value
of 3.09 M.g/m3.  The  other three  alternatives  yielded  similar
values which were each within 3% of the reference indicator.
Among these three "middle" indicators, the simplest form is the
second maximum month in three years.  This standard allows a
single exceedance of a monthly average lead level in a three year
period.

     In order to confirm the stringency findings from the first
simulation analysis, actual lead data from point source
monitoring sites which had violations of the present lead
standard during the 1985-1987 time period were analyzed for
comparisons among the six alternative forms of a revised lead
NAAQS.  Ten sites from 7 different states were used.  These sites
included the ASARCO refinery and the Philadelphia lead oxide
manufacturer, along with other primary and secondary lead
smelters.  In order to compute the design value statistics from
available data, two out of the three years had to be available.
The empirical results from the 10 sites confirmed the relative
stringency findings developed from the computer simulation.
The average design values for these 10 lead sites ranged from
5.34 ng/ra3 for  the maximum monthly  average  (Option  l)  to  2.96
M-g/m3  for the expected maximum calendar month (Option 2).   The

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                          IV-11

design value for the 2nd highest monthly average of 4.13 (ig/m3
(Option 5) was again only 1% greater than the expected maximum
monthly average of 4.08 M-g/ro3 (Option 3).
     Among the alternative forms examined, the form based on  the
second highest monthly average in three years (Option 5) is
recommended for a revised lead NAAQS.  It is easy to comprehend,
does not involve any complex statistical calculations, and
produces design values comparable to the expected maximum monthly
average.  As stated previously, with the second highest monthly
average form, at most one monthly value in a three year period
would be permitted to exceed the stated level of the NAAQS.   The
exceedances could occur in adjacent months or in separate years.
While this form is obviously less stringent than the form which
does not permit any exceedances in a three year period (Option
1), it allows for explicit discounting of one "bad" month which
may be caused, for example, by unusual meteorology.  This
approach is more stringent than the alternative maximum second
highest month per year form (Option 6) in which one monthly
exceedance is allowed each year.  The staff therefore recommends
that the standard be stated deterministically, in terms of a
three-year period with no more than one monthly average
exceedance.

     2.   Sampling Frequency and Monitoring Options
     In reaching a decision on the standard, the averaging
period, form, method of collection, and frequency with which
ambient air lead samples are collected should be considered.
Given the normal operation of the current one-in-six day lead
sampling schedule, even with suggested 75% data capture, it is
clear that 4-6 samples collected in the course of a month would
not provide a statistically valid estimate of the actual air
quality for the period (Thrall et al., 1984; Frank and Faoro,
1989).  Consequently, in changing to a monthly average lead
NAAQS, it would be necessary to increase the frequency of ambient
air lead sampling, especially during periods and in areas of
relatively high, variable air quality.

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                           IV-12
     Because attainment is recommended to be based on peak
monthly averages, (i.e., second highest monthly average in three
years) the precision of the monthly average lead concentrations
is critical.  This is because,  with imprecision, peak values
selected from a set of data tend to be overestimated.  One source
of imprecision is measurement error.  Another source is
incomplete sampling.  Although, averages of measurement
concentrations have less measurement error than individual 24-
hour samples, these errors still persist with small sample sizes.
With one in six day (1/6) or even every other day (1/2) sampling
(coupled with the inevitable missing samples), monthly averages
would be based on few values.  For example, there would be at
most 5-6 values with 1/6 sampling.  Consequently, such averages
would be highly variable (imprecise), causing the potential for
misleading monthly average concentrations.  The peak values
selected from these highly variable monthly averages could
therefore yield overestimates of the true peak average
concentrations.

     Data from the ASARCO refinery based simulations, used to
test the stringency of the alternative sample forms presented
earlier, were also used to examine the effects of incomplete
sampling on design values (Frank and Faoro, 1989).  This analysis
revealed a design value bias.  Design values for each of the
alternative forms 'considered increased with less than complete
sampling.  For example, evaluating option 1 (maximum monthly
average), using every day sampling, produced a design
concentration value of 3.89 ng/m3.   This  same  option  evaluated
with 1/2 and 1/6 sampling produced average design values of 4.64
|ig/m3  and  6.46  M-g/m3 respectively.  This resultant bias could
cause true attainment sites, which are close to the level of the
standard and exhibit large variability in daily concentrations,
to appear to be in nonattainment.

     A striking example of the  expression of this bias is seen in
a simple evaluation of air lead data from the ASARCO refinery

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                              IV-13
presented in Table 4.2 below.  The  1/6  day  average for the month

presented is 5.07 ng/m3 a value based on 5 samples.  However, the

average of the 31 available daily values  is 2.44  |o.g/m3.  Other
months within this year demonstrated the  same bias.


       TABLE 4.2   DAILY AIR LEAD DATA FROM A LEAD REFINERY
                            (MAY 1984)


DATE      AIR LEAD fug/m3)  •    DATE         AIR LEAD  faa/mM

 1             1.22              21                6.45
 2             0.21              22                0.46
 3             0.19         .    23                5.82
 4             1.03              24                8.44*
 5             0.60              25                0.12
 6             1.03*             26                0.58
 7             0.24              27                0.07
 8             0.21              28                0.05
 9             0.70              29                0.24
 10            1.25              30                8.24*
 11            0.34              31               14.71
 12            6.54*
 13            0.36
 14            0.35
 15            0.32
 16            6.99
 17            6.15
 18            1.11*
 19            0.58
 20            1.18


*denotes the normal 1/6 day sample


     Further simulation analyses using  a variety  of lead

concentration distributions confirmed this  bias and showed  that
large overestimates in design concentrations are  possible with

1/6 sampling, and that moderate overestimates are  still possible
even with 1/2 sampling.  It should be noted that  this  bias  occurs
in general,  but not always.


     Nevertheless, since attainment is  judged on the highest  •
monthly averages, it is imperative that these values be as

precise as possible.   Therefore, complete data sampling is

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                              IV-14
recommended in order to judge attainment/nonattainment for a
revised monthly lead NAAQS when a site's maximum monthly readings
approach the standard level.  This is especially a concern around
point sources which can have high daily variability in lead
concentrations (see Figure 2-5).  Analyses suggest that complete
data sampling and highest data capture would only be. needed when
the design value is within a factor of 2 of the NAAQS level; this
will maintain errors of attainment/nonattaininent
misclassification below 5 percent (Frank and Faoro, 1989).  To
maximize precision of the monthly average concentrations, general
minimum data completeness criteria (e.g.,  75 percent) would also
be needed and should be explicitly stated in the NAAQS.
Nevertheless, attainment or nonattainment could still be
determined with less precise estimates for those cases in which
the true'peak averages were sufficiently far from the level of
the NAAQS.  At non-point source sites, such as roadside and non-
industrial neighborhood sites where lead concentrations are below
the current standard, incomplete sampling (i.e., 1/6) would be
sufficient to show the long-term aggregate national trends.

     The current reference method for the determination of lead
in ambient air is based on the collection of suspended
particulate matter on a glass fiber filter using a high-volume
air sampler, and subseguent analysis of the collected sample for
lead uses atomic absorption spectrometry.  Samples are collected
over 24-hour sample periods and analyzed, either individually or
after compositing over a calendar month or quarter, to determine
the average lead concentration for the calendar quarter.  Several
equivalent methods for lead have also been approved for use by
state and local agencies under the provisions of FR Vol. 52 No.
126 July 1987; however, all use the high-volume sampler (hi-vol)
for sample collection.

     During the recent reviews of the air quality criteria for
particulate matter and lead, attention was focused on the
limitations of the high-volume sampler.  Characterization of the

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                            IV-15

sampler by Wedding et al.  (1977), McFarland and Rodes  (1979)  has
demonstrated that the sampler flowrate and shelter  geometry favor
collection of particles up to 25-50 \J.VL (aerodynamic diameter) ,
depending on wind speed and direction.  The sampling
effectiveness for large particles is also substantially  affected
by wind speed and monitor inlet orientation.

     The extent to which the hi-vol sampler will efficiently
collect lead in ambient air may be estimated if the sampling
characteristics of the sampling device and the size distribution
of lead in the air are known.  Available data characterizing  the
size distribution of lead in the atmosphere are somewhat limited
and suspect due to inadequate sampling methodology.  The large
wind-generated lead particles, which are of most concern from a
sampling viewpoint, and their contribution to the total  size
distribution of lead in the atmosphere have not been studied to
any extent.  Nevertheless, the hi-vol's ability to  collect
particles suspended in air can be reasonably estimated if some
assumptions are made concerning the distribution of  lead
particles in the atmosphere.

     Using the particle size distribution specified  in the  PM10
methodology requirements (FR Vol. 52 No.  126 July 1987), one can
demonstrate that the hi-vol sampler should provide an
"acceptable" measure of lead in ambient air.  A hypothetical
particle size distribution can be characterized by a fine mode
mass median diameter of 0.5 \j.m,  a coarse mode mass median
diameter of 14 p.m, fine and coarse mode geometric standard
deviations of 2.0, a coarse to fine mass ratio of 3.0, and  a
total concentration of 300 ng/m3.  This distribution is believed
to be an extreme case and somewhat representative of particle
size distributions in the western states where frequent  high
winds and wind gusts are common.   By assuming that lead  is
distributed everywhere in an identical fashion, the collection
efficiency for lead can be estimated by integrating the  product
of the hi-vol's sampling effectiveness and the size distribution.  In
such an analysis (Purdue,  1988),  of three wind speed scenarios,
scenarios, the sampler was estimated to collect 85-90% of the total

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                              IV-16
mass of lead particles in the distribution.  Even for a worst-
case scenario, 80 percent collection was demonstrated.
     The effectiveness of the hi-vol as compared with the
sampler has been evaluated in the field.  A study at the East
Helena lead smelter used co-located PM10 and hi-vol samplers
(Sternberg, 1988).  Analysis of 22 sampling days showed the hi-
vol captured, on average, twice as much lead (mass) than the PM10
sampler (Brion, 1988).  The average percentage of lead of the
total particulate weight for both samplers was comparable.

     The reason for this observed phenomenon is clear.  The PM10
sampler, by design, excludes particles larger than respirable
size that the hi-vol collects.  Given that exposure to lead
occurs not only via direct inhalation, but via ingestion of
deposited particles as well, especially among young children, the
hi-vol provides a more complete measure of the total impact of
ambient air lead.

     Despite its shortcomings, the staff believes the high-volume
sampler will provide a reasonable indicator for determination of
compliance with a monthly lead standard.  The measurement
technology is in place, the monitor is relatively simple and
inexpensive to operate, and it's continued use for compliance
monitoring will result in historical continuity in the lead air
quality data base.

C.   Level of the Standard
     This section presents a staff assessment of the degree of
health protection that would be provided by alternative air lead
scenarios and how this information may be used in decision-making
on the level of the lead NAAQS.  The presentation also outlines a
qualitative assessment of the key factors that affect the margin
of safety associated with alternative standards.

-------
                            IV-17

1.   Evaluation of Alternative Lead NAAOS from Case-Study Results

     a)   Approach
     As discussed earlier, blood lead (PbB) has been the common
measure used in evaluating health risks associated with lead
exposure.  To assess the degree of protection provided by
alternative lead NAAQS, the chosen approach is to predict
distributions of PbB levels in sensitive populations living near
lead point sources under different air lead scenarios.  As
discussed in Section III.E., it is difficult to specify a
threshold PbB level below which there are no significant risks of
any adverse effects; percentages of children with PbB levels
above 10-15 |ig/dl will be examined to evaluate alternative
standards (see Section III.E).

     Exposure results of 3 case-studies are presented below.
Children with excessive exposures to paint lead hazards are
excluded (see Section III.A).  The methodologies used for the
case-studies are fully described in the supplemental staff
exposure report (EPA, 1989a).

     For children, an uptake/biokinetic model.is used; for adult
men, a hybrid model of two other methodologies ("aggregate" and
"disaggregate" models) that accounts for long-term resorption of
bone lead is used.   All of the exposure methodologies account
for the fact that air lead contributes both directly (via
inhalation) and indirectly (via ingestion of deposited particles
onto.soils, dusts, and crops) to total exposure, along with
several other sources (e.g., solder in plumbing and food cans,
historically-contaminated soils, old paint).  Adjustment is made
for recent and continuing downward trends in gasoline, canned
foods, and drinking water.  The .aggregate and disaggregate models
require an assumption that dust and soil lead concentrations are
approximately in equilibrium with air lead levels, and that
current air lead exposures reflect historical levels.  These
latter two approaches were also developed for young children.

-------
                            IV-18

However, these models present "snapshot" PbB estimates which are
not likely to provide accurate predictions for children, whose
exposure patterns, metabolism, and physiology change rapidly (as
evidenced by the age-dependent variability seen in PbB
measurements).

     The uptake/biokinetic model incorporates age-specific
differences in exposure and biokinetics, and is used to model
cohorts of children born in 1990 up until their seventh
birthdays.  The model allows explicit projections of future lead
concentrations in various media (including possible changes in
dust lead levels due to changes in air quality) and in turn can
estimate impacts of these different changes on different age
groups of children.  The flexibility of the uptake/biokinetic
model in reflecting "non-equilibrium" lead exposures in children
allows it to better estimate PbB changes over time in response to
changes in environmental lead in rapidly developing young
children compared to the other models.  For this reason, it was
the focus of validation exercises described in the staff exposure
report (EPA, 1989a) and chosen to predict PbB distributions in
the case-study analyses.  A CASAC subcommittee that reviewed the
different exposure methodologies in the report supported this
decision (see Appendix D of EPA, 1989a).

     Because most of the available data input to the exposure
models are generally average values, all of these models are
designed to predict population mean response and not individual
levels.  Individuals with greater than average responses in the
upper tail of the distribution .of exposures comprise the
population of concern, however.  Since these models cannot be
expected to capture the significant behavioral and biological
variability within populations, percentages of individuals above
PbB levels of concern (e.g., 10 jxg/dl) will be estimated in the
case-study analyses by calculating the distributions around
predicted mean PbB levels using empirically-derived estimates of
PbB variance (Section III.B, EPA, 1989a).  Blood lead

-------
                              IV-19

distributions are consistently lognormal and can be calculated
using geometric standard deviations (GSDs) from point source and
other population surveys.  A range of GSD values (1.30-1.53) is
derived from available data on children living near lead point
sources (EPA 1989a); results calculated from the lower and upper
bound GSD values are presented to reflect the uncertainty in this
parameter.  The midpoint value of 1.42 is considered to.be a
reasonable best estimate (EPA 1989a) and emphasis is placed on
results using this GSD.  A GSD value of 1.37 derived from the
NHANES II survey is used for adults (EPA, 1989a).

     As noted earlier, no attempt is made here to specifically
assess exposures to lead in children with excessive "pica"
behavior ( i.e., abnormal tendency to repeatedly ingest non-food
items) because of an absence of data that could quantify such
highly variable intakes, or who are excessively exposed to lead
in paint from deteriorating housing conditions.  Such children
cannot be effectively protected from the hazards of lead in their
environment by a lead NAAQS (see Section III.A).  Nevertheless,
the data used for the exposure analyses implicitly include high
exposure conditions.

     The uptake/biokinetic model uses data on indoor and outdoor
dust and soil lead concentrations measured in various locations
where children were exposed.  As best that can be determined from
the studies, these data do not include measurements from in and
around homes where peeling paint,  holes in the walls, or other
unsound conditions were reported.   However, to the extent that
the studies appeared to have sampled populations and dwellings
representative of the study areas, a heterogeneous mix of homes
including older homes with lead-based paint (but no overt
hazards) are represented and appear suitable to represent average
or "typical" lead exposures.  [Data from homes with identified
lead paint hazards are excluded from analysis; see Appendix A,
EPA, 1989a],  in addition,  where applicable,  available data was
used on the full range of "typical" rates of dirt ingestion

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                               IV-20
through inadvertent hand-to-mouth activity in children.  Finally,
the uptake/biokinetic model uses GSD values derived from blood
lead distributions measured in a variety of childhood populations
living near different lead point sources to capture the range of
exposure variability to the fullest extent possible.  Given these
factors, the staff believes that the exposure analyses presented
below reflect a wide range of biological, sociodemographic, and
behavioral variability among children who live near point sources
including, in part, those living in lead-painted homes (but
without overt hazards such as chipping or flaking walls), and
those who ingest higher than average amounts of soil and dust.

     b)   Case-Study Analyses
     Populations living near a secondary smelter in Dallas, a
secondary smelter and a battery recycling plant in Tampa, and a
primary lead smelter in East Helena, Montana comprise the case-
study groups.  PbB levels in children living near the East Helena
smelter were measured in 1983, along with lead in household dust,
yard soil, drinking water, and ambient air.  These data were used
in a successful validation of the uptake/biokinetic model
(Section VI, EPA, 1989a).

     Air lead concentrations around the point sources were
estimated by the Industrial Source Complex Model (ISC) that
accounts for source sampling data on emissions, dry atmospheric
deposition, background lead concentrations (i.e., mobile sources,
re-entrained soil, local minor point sources), and site-specific
meteorological data.  Air lead levels generated by ISC were found
to reliably predict average concentrations in the East Helena
validation study.  Modeled air quality was used to determine the
geographic ranges for analysis; only those people living within
an area that the source(s) impacted air lead by a concentration
above 0.4 M-9/m3 were included (roughly 1-3 km radius depending on
the source).  Predicted air lead concentrations and populations
were assigned by block group (or in the case of East Helena,
enumeration district), as defined by census data.  Soil and

-------
                               IV-21

household dust lead concentrations were estimated for the
uptake/biokinetic model using  relationships derived  from
available data collected near  a wide range of point  sources
(Appendix B, EPA, 1989a).  This approach allows estimation of
effects, if any, of historical or possible future changes in air
lead levels on soil and dust lead concentrations.  Dietary lead
intake estimates were derived  from historical and current -data
and future projections of the  Multiple Source Food Model,
originally developed in the 1986 CD, and updated to  include more
recent information (Appendix A, EPA, 1989a).

     Additional considerations related to the uptake/biokinetic
modeling results presented in  this section are:

     (1)  Several parameters in the model were assigned lower and
upper bound values defined by  the ranges of available data of
comparable reliability and relevance.  These parameters include
time spent outdoors, volume of air respired, absorption
efficiency of dietary lead in  the gastrointestinal tract, soil
and dust lead levels associated with different air lead
concentrations, and the amount of dirt typically ingested by
children (Appendix A; EPA, 1989a).  Midpoint estimates of these
parameters are considered best estimates and are incorporated
into analyses presented here. Results using the full range of
values are presented in Appendix B.

     (2)  As noted above, the midpoint GSD value of  1.42 is
considered a best estimate for point source PbB distributions.
Results based on lower and upper bound GSD values of 1.30 and
1.53 are also presented.

     (3)  Two alternative assumptions were made regarding the
response of soil lead levels to future changes in air lead
standards:   a)  that soil  lead levels equilibrate to changing air
lead levels within a few  years.  Under this assumption,  a
different soil  lead level would exist for each air lead

-------
                              IV-22

concentration in the model between 1990 and 1996.  Each soil lead
level could be specified by the equilibrated air lead:soil lead
relationships derived from mainly cross-sectional data summarized
in Appendix B of the staff exposure report (EPA, I989a) or; b)
baseline soil lead levels in 1990, which are the result of long-
term deposition, will remain constant for at least six years
after a new standard is implemented.  The staff,'with concurrence
from the CASAC Subcommittee that reviewed the lead NAAQS exposure
analysis, believes that the latter assumption is more realistic
and results presented here reflect a "fixed soil lead" scenario
(with varying house dust lead levels).  For a given standard, PbB
levels are predicted higher under this scenario than under a
variable soil lead scenario, although relative differences
between standard alternatives are less using this approach.

     Blood lead distributions are predicted for non-
occupational ly exposed middle-aged men assuming a blood
lead:inhaled air lead slope of 1.8 pg/dl per A*0.4 /ng/m3) near point
sources in East Helena, Dallas, and Tampa under alternative lead
NAAQS.  Percentages above selected PbB levels within the
estimated distributions are presented.  Other points of the
distribution can be calculated; for example, percentages of
children above 25 /jg/dl, the CDC definition of undue lead
absorption for medical intervention.  Because children with pica
and with exposures to lead paint hazards are excluded from the

-------
                                   IV-2 3
        TABLE 4-3.   ESTIMATED CHILDREN'S (0-6 YRS.)  PbB LEVELS UNDER
         ALTERNATIVE LEAD NAAQS IN 3 CASE STUDY  ANALYSES:  1990-1996*
Case Study
(# Children) /
PbB Level"
          Lead NAAQS Level (|ig/m3)
           1.5               Monthly43
Baseline10  Quarterly0  1.5   1.25   1.0
                   0.75
        0.5
Dallas f2411

Mean PbB (ng/dl)
% > 10 ng/dl
% > 15 ng/dl

East Helena (217

Mean PbB (p-g/dl)
% > 10 ng/dl
% > 15 ng/dl

Tampa (10)
                    6.9
                   14.2
                    1.3
                    6.2
                    8.3
                    0.6
             4.9
             2.2
            0.08
             5.2
             2.9
             0.1
 4.8   4.8
 1.9   1.7
0.06  0.05
5.1   4.9
2.6   2.1
0.1   0.07
 4.7
 1.5
0.04
 4.6
 1.4
0.04
 4.8   4.6
 1.7   1.4
 0.05  0.04
                          4.5
                          1.2
                         0.03
        4.4
        1.0
        0.02
Mean PbB (ng/dl) 10
% > 10
% > 15
ng/dl
M-g/dl
50
12
.1
.9
.9
8
29
4
.3
.7
.6
7
23
3
.8
.4
.0
7.4
19.4
2.2
7.0
15.6
1.5
6.6
12.1
1.0
6.3
9.2
0.6
* Assumes soil Pb remains at baseline levels (see text)
a PbB distributions calculated assuming GSD = 1.42
13 Baseline scenario represents current conditions for air quality, as well
  as soil and dust Pb.  Dietary intake assumed to be at 1990-1996 levels
05 Current NAAQS level and averaging time (calendar quarter)
d Alternative NAAQS levels with monthly averaging time

-------
                            IV-24
analysis, very few, and in most cases no children, were estimated
to have such high levels.

     The results for Tampa should not be extrapolated since the
secondary smelter and battery plant modeled there were surrounded
by mainly non-residential areas.  According to the overlay of air
dispersion estimates onto block group census data, only 10
children and 20 men live close enough to those point sources to
be significantly affected by changes in emissions.  Further
analyses are necessary to determine whether these results for
Tampa are applicable to other point source areas with small
populations living nearby.

     The results indicate that significant reductions in exposure
in all 3 case-study areas could be achieved through attainment of
the current NAAQS.  Progressive but smaller improvements are
indicated for alternative monthly standards, beginning with the
current level down to 0.5 |ig/m3.

     The level of protection that should be provided by a lead
NAAQS is difficult to specify.  The current standard was set in
1978 so that 99.5% of all children (including those with pica)
would have PbB levels below 30 p,g/dl, which at that time was
CDC's definition of lead toxicity for screening programs, and
which was considered to provide an adequate margin of safety from
clearly adverse effects (e.g., anemia).  Since then, a PbB of 15
M-g/dl has been associated with risks of several health effects in
children, including newborns (see Section III.D), and may provide
a small margin of safety from adverse effects.  According to the
analyses using the best estimate GSD value, a monthly NAAQS
between 0.5 and 1.5 iig/m3 would keep more than 99.9% of the non-
pica children, living without lead-paint hazards near the Dallas
and E. Helena smelters, below a PbB of 15 (ig/dl.

     A NAAQS at 0.5 ng/m3, according to the best estimate Dallas
and E. Helena case-studies, would protect 99.97% of affected

-------
                           IV-25

children from 15 jug/dl PbB and keep 98.8 - 99.0% below 10 jug/dl
PbB.  A PbB of 10 A*g/dl obviously provides a relatively greater
margin of safety than 15 A*g/dl, although it cannot be considered
devoid of any risks of some health effect, however uncertain  in
terms of functional or "clinical" significance (see Section
III.D).  No NAAQS can adequately protect all children, even non-
pica children living without lead paint hazards, from PbB levels
above 10 ^g/dl.  EPA's exposure analysis estimated that by 1990,
non-air contributions to children's total lead exposure
(excluding excessive paint lead) would result in a range of PbBs
from 4.2 to 5.2.  The lower bound was used in their analyses
(EPA, 1990).  Assuming a GSD of 1.42, this mean increment
attributable to non-air lead sources alone would be associated
with 0.7% of children above 10 /ig/dl, (and 0.02% above 15 /ig/dl).
Reducing the NAAQS would reduce the estimated proportion of
children with PbB levels above 10 jig/dl.  For the East Helena and
Dallas case studies, an estimated  8.3-14.2% of children
currently exceed 10 /zg/dl, whereas a monthly NAAQS of 1.5 Mg/m3
would reduce this fraction to 1.9-2.6%, and a monthly NAAQS of
0.5 Mg/n»3 would reduce it to 1.0-1.2%.  Given that a lead NAAQS
of 0.5 M9/ro3 would appear to minimize the number of additional
children with PbB levels over 10 /ng/dl compared to a "zero air
lead" scenario (an additional 0.3-0.5%), and would keep more than
99.97% below 15 A*g/dl, it can be considered as a reasonable lower
bound for a revised lead NAAQS.

     According to the best estimate analyses using a  GSD of
1.42, intermediate NAAQS levels (0.75, 1.0, 1.25 ^tg/rn3) would be
associated with an additional 0.7-1.4% of children above 10 jug/dl
over what would be expected with zero air lead emissions, and a
total of 99.95-99.96% below 15 M9/dl (0.063-0.066% increase over
"zero air lead" scenario).

     Interpretation of the above results must consider that
although the differences among standard alternatives appear
small, they are in fact, significant in terms of population

-------
                              IV-26
risks.  For example, approximately 60,000 children between the
ages of 0 and 7 years live near major U.S. lead point sources.
Therefore, even a 1% difference in the proportion of children
above 10 jig/dl corresponds to about 600 children.  Also,
recognition of the limitations of any exposure modeling effort to
fully and correctly simulate reality is important.  The staff
believes, however, that the uptake/biokinetic model does provide
plausible and useful results for several reasons, including: a)
The model's mathematical assumptions and numerical parameters
combine plausible biological hypotheses with the full range of
available and reliable animal experimental data, results of human
experimental studies, and environmental lead data; b) Results of
different validations of the model indicate good concordance
between observed and predicted PbB levels in children living near
lead point sources; and c) Of the 3 modeling approaches developed
in EPA (1989a), it is not only the most flexible but the most
conservative in terms of public health protection.  To
illustrate, using the midpoint estimates (for air and non-air
exposures) of the 3 models, and a constant air lead exposure to
1.0 M-g/m3 results in a PbB level in a 2-year child in 1990 of:
10.9 |ig/dl (uptake/biokinetic model); 8.7 p-g/dl (aggregate
model); 7.2 |ig/dl (disaggregate model).

     An effects threshold for increased blood pressure in men has
not been defined; several studies have failed to find one while
one longitudinal study suggests a threshold of 30 M.g/dl (Section
III.D.5).  For analytical purposes of comparing alternative lead
NAAQS, PbB levels of 10 and 12 p.g/dl will be used to compare
relative effects of alternative NAAQS on adult men.  While the
basis for a decision on the lead NAAQS should be on the most
sensitive population (young children), the results in Table 4-4
indicate substantial reductions in PbB levels in men through
attainment of the current NAAQS, and that the range of monthly
lead NAAQS analyzed for-children (0.5-1.5 p,g/m3) would be
associated with corresponding improvements in adult men exposures
compared to baseline conditions.

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            TABLE 4-4.   ESTIMATED MEN'S (40-59 YRS.) PbB LEVELS
           UNDER ALTERNATIVE LEAD NAAQS IN 3  CASE  STUDY  ANALYSES*
Case Study
(# Men) /
PbB Level*
          Lead NAAQS Level (|j.g/m3)
           1.5               Monthly4*
Baseline**  Quarterly0  1.5
1.25
1.0
0.75
0.5
Dallas (1311
Mean PbB (ng/dl)
% > 10 ng/dl
% > 12 M-g/dl
East Helena (1731
Mean PbB (ng/dl)
% > 10 M-g/dl
% > 12 M-g/dl
Tampa (171
Mean PbB (ng/dl)
% > 10 M-g/dl
% > 12 (ig/dl
6.3
7.2
2.1
6.9
12.1
4.0
6.6
9.2
2.8
5.5
2.8
0.7
5.8
4.2
1.0
5.8
4.2
1.0
5.4
2.5
0.5
5.7
3.5
0.9
5.6
3.3
0.7
5.3
2.1
0.4
5.6
3.3
0.7
5.4
2.3
0.5
5.2
1.9
0.4
5.5
2.8
0.7
5.2
1.9
0.4
5.1
1.5
0.3
5.4
2.5
0.5
5.1
1.5
0.3
5.0
1.4
0.3
5.3
2.1
0.4
4.8
1.0
0.2
* Weighted averages of white and non-white men.
a PbB distributions calculated by assuming GSD = 1.37
to Baseline scenario represents current air quality; non-air contributions
 assumed to be at 1996 levels
0 Current NAAQS level and averaging time (calendar quarter)
<* Alternative NAAQS levels with monthly averaging time

-------
                           IV-28
     According to the case-study analyses, a monthly NAAQS
between 0.5 and 1.5 Mg/m3 would result in between 1.4 - 3.5% of
non-occupationally exposed middle-aged men with PbB levels above
10 ng/dl (compared to 7.2 - 12.1% at current baseline air and
1990 non-air exposures); percentages above 12 ng/dl would be 0.3-
0.9%.

     As seen for children, even with zero air lead emissions,
average PbB in adult men is expected to be about 4.5 Mg/dl in
1990; with 0.6% above 10 pg/dl and 0.1% above 12 jjg/dl.  In other
words, a NAAQS of 0.5 /jg/m3 would increase the number of men in
these analyses above 10 fig/31 by only 0.4-0.5%; a 1.5 A*g/m3 NAAQS
would increase this fraction by 1.9-2.9%.

     No estimates are derived for pregnant women.  Although the
fetus is highly sensitive to lead, direct and indirect
contributions from atmospheric lead via the mother is limited
compared to young children.  The staff recommends that the
analytic focus remain on young children as the most "sensitive"
in terms of the present standard review.  As discussed in the
staff exposure report, approximately 95% of adult body lead
burden is sequestered in bone.  Fetal exposures in most cases can
therefore be expected to be dominated by maternal bone lead
stores from past, higher-level exposures compared to current ones
(EPA, 1989a).  Given this and the fact that children are exposed
to, absorb, and retain proportionally more lead from the
environment than women, it can be concluded that a lead NAAQS
will influence children's exposures more than fetal exposures.

     As discussed earlier, the effects of mobilization of
skeletal lead sequestered from past exposures, during pregnancy,
on transplacental transfer1 of lead to the fetus cannot be
quantified at this time.  It is possible, however, to gain some
insight into what might be expected in the future under
alternative standards.  The available data indicate that any PbB:
air slope used for adult women would be similar to that used for

-------
                            IV-29
adult men.  Furthermore, the non-air background contributions to
PbB are estimated to be lower in adult women compared to men
(EPA, 1989a; Section V.A. and Appendix C).

     Given this, the case study results for adult men would be
expected to be reasonable upper bound surrogates for those that
would be derived for adult women.  This suggests that the small
improvements in PbB levels between future lead NAAQS in the range
of 0.5-1.5 M-g/m3 estimated for adult men could also be expected
for adult women.  Thus, it can be anticipated that in the future,
changes in atmospheric lead will have a relatively small impact
on maternal bone lead stores, and consequently on fetal
exposures.  In contrast, young children are much more responsive,
indirectly and directly, to changes in atmospheric lead emissions
and provide the most sensitive indications of the relative
protection afforded by alternative NAAQS.

     While the fetus may not be the most responsive or
"sensitive" subgroup of the population in assessing the future
impacts of alternative lead NAAQS, the fact remains that there
are now approximately 140,000 women of childbearing age living
near major lead point sources whose offspring may be at risk from
past lead exposures.  A conservative approach to the decision on
the lead NAAQS would benefit the future generation born to women
who are children today.

2.   Factors to Con^sidejr in Evaluating Margin of Safety for the
     Lead NAAOS

     a)   The Significance and Persistence of Observed or
          Anticipated Health Effects
     Little controversy exists that high-level lead exposures are
associated with adverse health effects.  There is substantial
concern regarding several health effects associated with low-
level lead exposure as well:

-------
                            IV-30
     (1) The significance of alterations in the heme synthetic
pathway may be questioned given the physiological reserve
capacity of ALA-D activity, for example, and that effects on EP
elevation are reversible.  Given that disturbances in herae
formation can extend throughout multiple organ systems and
physiological functions (e.g., neurotransmission, vitamin D
metabolism), however, even low-level disturbances have
potentially long-term effects;

     (2) The relatively small effect on children's IQ
attributable to lead at low-moderate exposures, compared to other
socio-hereditary influences, (» 4 IQ point deficit at 30-50
ng/dl; 1-2 points at 15-30 ng/dl) indicates nevertheless,
potentially large population impacts.  For example, Needleman et
al. (1982) calculated that a 4 point decrement in the mean IQ of
a normal population distribution would be associated with a
three-fold increase in the number of children with severe
deficits (IQ < 80), along with a 5% reduction in the number of
children who attain superior function (IQ > 125).  Although there
is some evidence that low-level lead (<30 ng/dl) effects on IQ
may be reversible (Hawk et al., 1986), follow-up investigation of
a subset of the children initially evaluated by Needleman et al.
indicated that grade retention was significantly associated with
past lead exposure (Bellinger et al., 1984);

     (3) The small but significant impacts of lead on auditory
function may have long-lasting consequences in some children by
interacting with lead-induced effects on, or resulting in, delays
or deficits in language acquisition and processing, attention,
and learning;

     (4) Definitive conclusions about the persistence and
ultimate impact of low-level effects on infant mental and
physical development, due to prenatal and neonatal exposures,
must await further results of ongoing longitudinal studies.  Some
data suggest that children with early neurobehavioral deficits

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                              17-31
are able to catch up later on in childhood  (Dietrich et al.,
1989b), and that natural over-production of neural cells pre-and
post-natally may compensate for structural perturbations.
However, as stated in the ATSDR (1988; page IV-23) report,
"research in developmental and physiological psychology has shown
that the actualization of behavioral capabilities requires
appropriate periods of functional neural activity for proper
development. Thus, even transient, or in themselves, reversible
deficits during early development may have potentially serious
and long-lasting sequelae.  Given the complex interactions that
figure into the psychosocial development of children, attempts to
compensate for lead-induced deficits in one area of a child's
development may affect other areas of development";

     (5) Linkages have been drawn from animal experiments between
the persistence of lead-induced effects on neurobehavior and
neurological biochemistry and morphology, and the accumulation
and retention of lead in the brain.  This illustrates that, even
if effects appear to be reversible, as long as absorbed lead
remains in soft tissues or is available from long-term storage,
continuing risk of lead toxicity remains.

     b)   Persistence of Lead in the Environment
     Atmospheric lead deposits on soils, crops, and street and
playground surfaces.   Soil lead, which serves as a continuous
source of outdoor and indoor (household) dusts as well as a
direct exposure route for young children, is relatively insoluble
and immobile and can continue to accumulate indefinitely.   The
persistence of lead in soil,  and its movement into accessible
dusts has been taken into account in the uptake/biokinetic model.
Nevertheless,  the long-term presence of atmospheric lead in the
environment, once deposited,  beyond the time-frame addressed in
the exposure analyses,  should be considered in evaluating the
margin of safety of alternative NAAQS.

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                              IV-32
     c)   gensitivity of Exposure Results
     The full range of available and reliable data were used to
estimate PbB distributions of populations exposed under
alternative lead NAAQS.  Wherever possible, best estimates were
derived from the data to use for various input parameters.  Where
lower and upper bound parameter values could not be distinguished
in terms of reliability or relevance, midpoint estimates were
chosen.  As with any modeling exercise, the results are sensitive
to the required assumptions.  Appendix B presents results of the
analyses on children with either all upper bound assumptions or
all lower bound assumptions.  The upper bound results indicate
much higher percentages of children above PbB cutoffs (e.g., 10
and 15 jig/dl) for a given standard.  While the case-study results
presented in this section should not be considered as precise and
absolute predictions, the staff believes they adequately
represent the relative impacts associated with alternative lead
NAAQS.  Further refinements can be made as additional data become
available.

     d)   Groups Not Evaluated
     Young children have the highest rates of lead exposure and
absorption and any lead standard derived to protect them should
also protect other sensitive groups evaluated quantitatively
(adult men) or qualitatively (pregnant women/fetus).  The
analyses summarized in this section omit young children who
cannot be substantially affected by any changes in atmospheric
lead emissions under different standards.  These children (e.g.,
those with pica and/or living in deteriorated lead-paint homes)
total several million and require direct parental and public
health intervention to reduce their high-level exposures (see
Section III.A).  Nevertheless, any reduction in air lead levels
can be expected to have at least a small beneficial effect on
these children and should be considered in establishing the lead
NAAQS.  Similarly, adult women whose blood pressure is affected
by ongoing lead exposure, and women experiencing bone

-------
                            IV-33
demineralization during osteoporosis (as well as during
pregnancy) and increased lead mobilization, will also benefit,
however slightly, from any reduction in ambient air lead levels.

D.   Summary of Staff Conclusions and Recommendations

     The major staff conclusions and .recommendations made in
Sections IV.A-C are briefly summarized below:

     1)   A monthly averaging period would better capture short-
term increases in lead exposure and would more fully protect
children's health than the current quarterly average.

     2)  The most appropriate form of the standard appears to be
based on the second highest monthly average.  This form would be
nearly as stringent as a form that does not permit any
exceedances and allows for discounting of one "bad" month in 3
years which may be caused, for example, by unusual meteorology.

     3)   With a revision to a monthly averaging time, complete
data is needed, except in areas, like roadways remote from lead
point sources, where the standard is not expected to be violated.
In those situations, the current l-in-6 day sampling schedule
would sufficiently reflect air quality and trends.
                                         «•
     4)   Because exposure to atmospheric lead particles occurs
not only via direct inhalation, but ingestion of deposited
particles as well, especially among young children, the hi-volume
sampler provides a reasonable indicator for determination of
compliance with a monthly lead standard and should be retained as
the instrument to monitor compliance with the lead NAAQS.

-------
                             IV-34

     5)   Because young children are exposed to, absorb, and
retain proportionally more environmental lead than other
populations, they are most responsive to changes in atmospheric
lead emissions and provide the most sensitive indications of
relative protection afforded by alternative NAAQS.  Case-study
analyses of children populations living near Dallas and East
Helena smelters indicate that substantial reductions in lead
exposure could be achieved through attainment of the current  lead
NAAQS.  Progressively smaller improvements are estimated for  the
alternative monthly lead NAAQS levels evaluated, ranging from 1.5
jig/m3 to 0.5 M,g/ra3.

     A PbB concentration in the range of 10-15 ng/dl is
considered the level of concern for infants and children, and is
used to compare the relative protection provided by alternative
standards.  According to the best estimate analyses, over 99.9%
of children living in areas significantly affected by the
smelters would have PbB levels below 15 |j.g/dl.  The staff
believes that evaluation of alternative standards based on
children's PbB levels above 10 ng/dl is more appropriate given
the health risks associated with lead.  Reducing the NAAQS levels
would reduce the estimated proportion of children with PbB levels
above 10 jig/dl.  For the Dallas and East Helena case studies, an
estimated 8.3-14.2% of children currently exceed 10 jig/dl,
whereas a monthly lead NAAQS of 1.5 ng/ro3 would reduce this
fraction to 1.9-2.6%, and a monthly NAAQS of 0.5 |Ag/m3 would
reduce it to 1.0-1.2%.  Because of unavoidable background
exposures to lead in the diet, historically-contaminated soils
and dusts, and maternal bone lead stores in utero, no standard
can keep all children below a PbB of 10 p.g/dl.   It is estimated
that even at zero air lead emissions, 0.7% of children would  have
PbB levels above 10 (ig/dl.  For example, Dallas and East Helena
results indicate that a monthly lead NAAQS of 1.5 M-g/m3 would
result in an additional 1.2-1.9% of children with PbB levels
above 10 M-g/dl over what would be expected with zero air lead
emissions.  A NAAQS of 0.5 (j.g/m3 would appear to minimize the

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                           IV-35
number of additional children with PbB levels above 10 M-g/dl
compared to a zero air lead scenario and appears to be a
reasonable lower bound for consideration of a revised lead
standard.  Intermediate increments are indicated for lead NAAQS
levels of 0.75, 1.0 and 1.25 |ig/m3.

     6)   While the basis for a decision on the lead standard
should be the most sensitive population, i.e., young children,
the case-study results on adult men indicated small PbB
reductions with progressively lower monthly lead NAAQS levels
evaluated, beginning with 1.5 [ig/ro3 down to 0.5 ng/m3.  A PbB
threshold for blood pressure effects in men has not been defined.
Two PbB levels, 10 and 12 ng/dl, are selected to compare the
relative protectiveness of alternative lead NAAQS.  The results
indicate that a monthly NAAQS between 0.5 and 1.5 ng/m3 would
result in between 1.0 - 3.5% of non-occupationally exposed men
with PbB levels above 10 iig/dl, compared to 7.2-12.1% at current
baseline exposures and 0.6% above 10 jig/dl simply because of non-
air background exposure.  The percentages above 12 |ig/dl for this
range of standards are estimated to be 0.3-0.9%, compared to 0.1%
due to background exposures.

     7)  Fetal exposures are not evaluated quantitatively in the
case-study exposure analyses.  While young children are the most
responsive population in terms of the lead NAAQS, and represent
the appropriate group to focus on in the exposure analyses, the
sensitivity of the developing nervous system in the fetus, and
uncertainties regarding other possible fetal effects, require
consideration in determining the appropriate margin of safety
that should be provided by a lead NAAQS.

     8)   Other factors that should be considered in evaluating
the margin of safety are the significance and persistence of
observed or potential health effects,  the persistence of lead in
the body and in accessible environmental reservoirs (i.e., soil),

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                              IV-36
the sensitivity of the exposure analyses to alternative
assumptions, the potential carcinogenicity of lead, and groups
beside the fetus that have not been evaluated quantitatively
because any lead NAAQS, no matter how stringent, could not remedy
their excessive background exposures (e.g., children with pica or
living with lead-paint hazards), or because there-are
insufficient data to quantify their risks at this time (e.g.,
post-menopausal women).

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V.   CRITICAL ELEMENTS IN THE REVIEW OF THE SECONDARY
     STANDARD

     This section includes a discussion of information drawn from
the criteria document that appears most relevant to the review
and possible revision of the current secondary NAAQS for lead.
It focuses on field and laboratory studies that have identified
potential effects of lead in terrestrial and aquatic ecosystems.

A.   Effects in Terrestrial Ecosystems
     Anthropogenic emissions of lead deposit on terrestrial
ecosystems via wet and dry deposition.  After initial deposition
on vegetation and other surfaces, the migration and distribution
of lead in the soil reservoir depends on a number of
environmental factors including precipitation, surface
adsorption, and ion exchange reactions (Zimdahl and Skogerboe,
1977; Miller & McFee, 1983; Camerlynck & Kiekens, 1982).  Once in
the soil reservoir, lead is relatively insoluble and immobile
(NAS, 1980; Nriagu, 1978) and is not readily removed by such
mechanisms as leaching and stream run-off (EPA 1986a, pp. 6-29,
8-8).  As a result, lead accumulates in the soil reservoir even
when the deposition rate is relatively low.

     When examining the potential impact of lead on terrestrial
ecosystems, a distinction must be made between total soil lead
content and the available or potentially available fractions.
The fraction of soil lead that may be biologically available
includes the potentially available lead (exchangeable forms
determined by chemical extraction) and the actually available
water soluble forms (lead in soil moisture) (EPA, 1986a, p. 6-
29).  The generally low solubility of lead and the apparently
small percentage (1-12%)  of total soil lead that is exchangeable
(Camerlynck and Kiekens,  1982; Miller and McFee, 1983;  Hughes,
1981; Atkins et al., 1982)  suggest that the bioavailability of
lead for plants is quite limited.  The potential effect of acid
precipitation to increase the relative mobility of lead in soil

-------
                           V-2

(Tyler, 1978; Hutchinson, 1980) is of clear concern as a
mechanism that may increase the bioavailability of this heavy
metal.

     Given the varying capacity of different soil types to
immobilize lead under different environmental conditions (Zimdahl
and Skogerboe, 1977), and the limited usefulness of chemical ,
extraction studies to provide reliable estimates of exchangeable
soil lead fractions, it is difficult to determine the percentage
of total soil lead that is biologically available (actual or
potential).

     The major concern regarding deposition of atmospheric lead
onto plant surfaces is its eventual entry into the human food
chain.   Effects on plants may also occur directly through foliar
uptake or indirectly via root uptake from the nutrient medium
(soil moisture) (Facchetti and Geiss, 1982; Lindberg and Harriss,
1981).   Although 90% or more of lead taken up via the roots may
remain tightly bound in the roots (Koeppe, 1981), field and
laboratory studies provide evidence that some lead is
translocated to physiologically active tissues in vascular plants
(CD, pp. 8-18 to 8-19).  While the relative significance of
foliar uptake has not been clearly determined, it is potentially
high since surface deposition of lead is estimated to account for
90% of total plant lead (CD, p. 8-42).  Elevated lead burdens in
plants near smelters and along roadsides, for example, have been
attributed primarily to surface deposition (Getz et al., 1977;
Nriagu, 1978; Smith, 1976).

     Experimental data on lead-induced effects in plants indicate
that:  (1) at relatively low concentrations, ranging from 2-10 M.g
Pb/g hydroponic solution, inhibition of photosynthesis,
alteration in enzyme activity, and reduction in growth can occur.
Factors such as length of treatment (exposure), chemical form of
lead, level of nutrients in solution, and age and species of
plant can influence the experimental results (Koeppe, 1981;

-------
                            V-3

Paivoke, 1979); (2)  high concentrations of total soil  lead  are
necessary before physiological effects in plants are observed.
For example, Khan and Frankland (1983) report significant growth
reduction in radish plants with exposure to 1000 p.g Pb/g soil and
complete growth inhibition at 5000 ug Pb/g soil; and (3)  lead
tolerant plant communities appear near roadsides and stationary
source emissions (Antonovics et al., 1971; Atkins et al., 1982).
Potential changes in species composition in these areas have
implications for the long-term effect of lead on ecosystem
function and stability.  Atkins et al. (1982) suggest that
selection pressure due to even low total soil lead concentrations
(112 ng Pb/g soil), resulted in the evolution of lead tolerance
in a roadside grass.

     Available data suggest that the impact of lead in
terrestrial ecosystems may be evident first in the components of
the soil and litter microcosm  (e.g., fungi and bacteria) that
play a critical role in the decomposition of organic matter  and
in nutrient cycling (Tyler, 1972; Doelman and Haanstra, 1979a;
Babich and Stotgky, 1979).  In the presence of lead (1500 jig Pb/g
soil), the composition of microbe communities may shift to more
lead-tolerant populations (Doelman and Haanstra, 1979b) and, at
soil lead concentrations found near roadways and stationary
sources (750-2000 |j.g Pb/g soil), soil microbial activity may be
sufficiently reduced to inhibit the decomposition and
nitrification processes (Smith, 1981; Doelman and Haanstra,
1979a; Liang and Tabatabai, 1978).  However, Crist et al. (1985)
reported no inhibition during the early stages of leaf-litter
decomposition for the range of lead concentrations evaluated,
i.e., 0 to 1000 M-g Pb/g leaf added as lead sulfate.     Subtle
changes in ecosystem structure and function have been attributed
to lead contamination.  Friedland et al.  (1984) suggest that the
increase in percent organic matter in a New England forest may
have resulted from the accumulation of lead and other trace
metals that inhibited decomposition.  In other more heavily
contaminated areas, reduced abundance and altered composition of

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                            V-4
microflora populations have been observed accompanied by
accumulation of litter and alterations in soil parameters
(Jackson and Watson, 1977; Bisessar, 1982; Williams et al.,
1977C).

     Although these field observations suggest inhibitory effects
of lead on microbial activity in certain heavily contaminated
areas, quantitative assessment is limited by the lack of adequate
controls for confounding effects of other stationary source
emissions (including other metals) and of environmental
influences (e.g., temperature, moisture).  Further, the long-term
significance of lead-induced changes in soil microbial
populations is unclear and depends on whether the ecosystem has
the ability to compensate for such perturbations.  Nevertheless,
the critical role of soil microbes in terrestrial ecosystem
processes (decomposition and nutrient cycling) indicates the need
for additional research to more clearly define the potentially
serious effects of lead on microbial activity.

     Decreased soil invertebrate abundance has also been observed
in lead-contaminated soils (Watson et al., 1976; Williams et al.,
1977c; Bisessar, 1.982).

     Very few field studies reporting lead exposures, body
burdens and associated effects in wildlife are available.  With
the exception of cattle and waterfowl, incidence rates of lead
poisoning in terrestrial fauna are generally unavailable (Forbes
and Sanderson, 1978; Botts, 1977) and difficult to verify.
Sources of these exposures have typically included lead wastes,
paint and spent lead shot (unrelated to airborne lead emissions),
and contaminated forage near lead smelters (NAS, 1980; Forbes and
Sanderson, 1978).

     Lead burdens in animals are elevated relative to natural
background levels (EPA, 1986a, pp. 8-33, 8-34), and have been
correlated with proximity to roadways and lead point sources

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                             V-5
(e.g., mining sites, smelters) (Williamson and Evans, 1972;
Quarles et al., 1974; NAS, 1980; Clark, 1979; Beresford et al.,
1981; Kisseberth et al., 1984).

     When assessing the effects of lead on domestic animals and
wildlife, it is important to consider the more subtle effects
that are not readily discernible in-field observational studies,
but found on laboratory experiments such as alterations in
neurobehavior and reproduction and development.  Because of
species differences in susceptibility (Forbes and Sanderson,
1978) and a lack of sufficient quantitative exposure/uptake/
response data in natural habitats, results from controlled animal
studies have not been extrapolated to animals in natural
environments.  Nevertheless, the available data indicate that
domestic animals and wildlife are at least as sensitive to lead
as those studied in laboratories.

B.   Effects in Aquatic Ecosystems
     Although lead is readily complexed in natural water systems
(EPA, 1986a, p. 6-34), concentrations exceeding 100 |ig Pb/1 (lead
in solution) have been reported for surface waters receiving
urban runoff and sewage and industrial effluents (NAS, 1980).
Freshwater ecosystems function as potential sinks for lead
loading (McNurney et al., 1977; Getz et al., 1977), with the
sediment as the primary collection site (Rickard and Nriagu,
1978).  As a result, the soluble fraction comprises only a small
percentage of the total lead burden (Rickard and Nriagu, 1978;
Wershaw, 1976).  The solubility and sedimentation of lead depends
on a number of physical, chemical and biological factors (EPA,
1986a, p. 8-14), and the retention of lead within the sediment is
influenced by the substrate type (McNurney et al., 1977; Wershaw,
1976; Newman and Mclntosh,  1982).  Over the past century,  a trend
of increasing deposition of lead in the sediments of freshwater
systems has been observed (EPA, 1986a,  p.  5-1, Figure 5-1), with
elevated lead concentrations observed in sediments draining urban
areas relative to rural areas (McNurney et al.,  1977; Getz et al.,

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                           V-6

1977).  Some reversal of this trend has been observed in river
and ocean sediments in and around the U.S., likely a result of
recent, significant reductions in atmospheric lead emissions
(Alexander and Smith, 1988; Rabinowitz, 1989).  For example,
Trefry et al. (1985) reported a 40% decrease in lead transport by
the Mississippi River in the decade since the regulation of lead
additives in gasoline.                •              .

     Lead in the sediment can become a source of soluble lead
even after the discontinuation of lead inputs (Wershaw, 1976).
Increased availability of waterborne lead to aquatic biota is
most pronounced in water bodies in which complexed lead in the
sediment remains at the water-sediment interface (Getz et al.,
1977).

     Water lead concentrations as low as 19-30 ng/L have been
associated with increased mortality and impaired reproduction) in
aquatic invertebrates (Borgmann et al., 1978; Biesinger and
Christensen, 1972).  Vertebrates (fish) appear even more
sensitive.  Hematological and neurological changes have been
observed in fish exposed under laboratory conditions to
concentrations between 8-12 ng Pb/1.  The neurological effects
include black tails, an early indicator of spinal deformity, and
spinal curvature, which increases mortality and prevents
successful reproduction (Hodson et al., 1978a,b).  Effects
observed at these lower levels may have been enhanced by the
relatively soft water conditions used in the experiments (Hodson,
1979).    In 1985, the U.S. EPA Office of Water Regulations and
Standards published new ambient water quality criteria for lead
to protect aquatic life.  These criteria concentrations are
expressed as a function of water hardness and indicate the need
to consider the influence of this chemical water quality
parameter on the bioavailability and toxicity of lead.  For
example, at hardnesses of 50, 100, and 200 mg/1 as CaCO3  the  4-
day average criteria concentrations of lead for freshwater
systems are 1.3, 3.2, and 7.7 ng/1, respectively, and the one-

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                                  V-7

hour average concentrations are 34, 83, and 200 |j.g/l  (50 FR
30791) .

C.   Staff Conclusions and Recommendations
     The available laboratory and field data indicate that at
high concentrations, lead can: 1) affect certain plants (e.g.,
inhibition of photosynthesis, reduced growth, changes in species
composition), and fish (e.g., neurological changes); and 2) alter
the composition of soil microbial communities and inhibit
invertebrate activity resulting in delayed decomposition, reduced
nutrient supply, and altered soil properties (e.g., lower organic
content).  A qualitative assessment of the available field
studies and animal toxicological data suggests that domestic
animals and wildlife are as susceptible to the effects of lead as
laboratory animals used to investigate human lead toxicity risks.

     The available data also raise concerns about the continued.
accumulation of lead in soil and sediment reservoirs.  Due to the
persistence of lead in the environment, such accumulations are
expected to continue as long as inputs exceed outputs.  Thus,
even at relatively low deposition rates, lead could affect the
ecosystem over time.  This concern is primarily directed to urban
and stationary source areas that may already be approaching or
have exceeded their soil capacity to bind lead.

     In summary, while the available data are limited and do not
provide clear quantitative relationships, they generally support
the need for limiting lead emissions to protect against potential
ecosystem effects.  Indications are that the emission reductions
achieved since promulgation of the current standards in 1978,
particularly when coupled with reductions achieved by the
phasedown of lead in gasoline (gasoline combustion in the early
1980's accounted for 85-90% of total airborne lead emissions),
may have mitigated or delayed the potential risk of lead-induced
ecosystem effects occurring in many areas of the country.   In
urban centers, along roadsides,  and in the immediate vicinity of

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                            V-8
major stationary sources that have experienced a long-term,
historical accumulation of lead, and where the natural soil sinks
for lead may be approaching or have exceeded their capacity to
bind lead, the more sensitive components of the ecosystem  (e.g.,
soil microbes) may remain at some risk that is difficult to
quantify at present.

     Until a stronger data base is developed that more accurately
quantifies ecological effects of different lead concentrations,
the staff recommends that consideration be given to retaining a
secondary standard at or below the level of the current secondary
standard of 1.5 (ig/m3.   If the  level,  averaging  time,  or  form  is
changed for the primary standard, consideration should be given
to making a similar change for the secondary standard to
facilitate implementation.

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   APPENDIX A.   SUMMARY OF  PROBABILITY ENCODING ON LEAD-INDUCED
                         HEALTH EFFECTS

     The scientific information describing dose-response
relationships for lead, as with most environmental pollutants, is
generally limited and incomplete. . There is a large variation in
people's susceptibility to air pollution-induced health effects,
and scientific evidence is rarely conclusive in establishing a
causal relationship for health effects resulting from pollutant
exposure, especially if these effects involve a latency period or
other contributing factors.  Given the precautionary nature of
the Clean Air Act and the need to protect public health with an
adequate margin of safety,  it is important to characterize, as
explicitly as possible, the range and implications of
uncertainties in the data base as part of the ambient standard
review.  One way to address uncertainties in the scientific
knowledge about a particular health effect is to obtain
probability distributions based on expert judgments.  Obtaining,
or encoding these judgments involves interviewing experts to
assess their judgments concerning the probability that a certain
fraction of the sensitive population would suffer a particular
adverse health effect at a given exposure level.  Probability
judgments can be used to describe an individual's assessment of
the likelihood of an event based on the current state of
information, which includes both his or her judgments or
interpretations of existing studies and theories and the
quantitative data available.  Because different experts will have
different judgments, it is also important not to merge these
judgments into a single average, but rather to present to the
decision makers the range of risks based on the range of
judgments, and thereby also identify the range and form of
disagreement among experts.

     In 1984-1985, probability distributions representing the
judgments of experts on two health effects were formally and
directly assessed using the technique of probability encoding.

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                              A-2

Detailed results of the encoded judgments and their application
to compute health risks in children living near representative
lead point sources are provided in Wallsten and Whitfield  (1986).
The report also describes the methods used to elicit the
judgments.  These methods were reviewed in 1985 by CASAC who
found them to be sound.

     Of the numerous health effects of lead, reductions in
hemoglobin levels and IQ decrements were chosen for probability
encoding.  It must be emphasized that although there is
considerable uncertainty regarding the dose-response functions
for these two effects, particularly at low lead levels, these
endpoints are not the most sensitive indicators of lead toxicity,
nor are they necessarily the most critical in terms of public
health.  Because this exercise was EPA's first application of
formal risk assessment procedures in reviewing a NAAQS, it was
important to select health endpoints:  a) that could be readily
quantifiable in common measurement units (in contrast to
classroom behavior, for example); b) that could be readily
understood in terms of their medical significance (in contrast to
changes in ALA or nerve conduction velocity, for example); and
c) for which exist a sufficient number of qualified experts who
span the range of respected opinion and interpretation (unlike
for example,lead-induced changes in vitamin D metabolism for
which few experts can be identified).

     Since only a finite number of PbB levels can be presented
for encoding,it is necessary to interpolate between levels in
order to use the judgments in risk assessments.  Such
interpolations were made by fitting suitable probability
distributions to the encoded values for both hemoglobin and IQ
effects (see Wallsten and Whitfield, 1986, for a detailed
description).  The present discussion utilizes the functions fit
to each individual's probabilistic judgments to present a summary
of the quantitative results for both hemoglobin and IQ.  The
functions provide an accurate representation of the underlying
encoded values, both because goodness of fit was excellent and

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                           A-3
because each expert endorsed the output of the respective
functions as representing his or her judgments.

A.  Encoding Judgments on Lead-Induced Hemoglobin Decrements

     Of five experts selected, probability judgments of four were
encoded with respect to the frequency of lead-induced hemoglobin
levels below either 9.5 or 11.0 grams per deciliter (g/dl) in
homogeneously exposed populations of young children.  The fifth
expert (Expert B) felt uncomfortable with the notion of
judgmental probability encoding and declined to have his
judgments encoded.  The experts were given the option of
considering separately the population of children in the age
groups 0-3 and 4-6 years, because of the age-related differences
in iron deficiency.

     It is generally agreed that for children a hemoglobin level
of about 12 g/dl is normal and about 9 g/dl is anemic.  Thus, of
the two levels specified, a hemoglobin concentration of 9.5 g/dl
would be much more likely to be considered as an adverse health
effect.  Although both hemoglobin levels are sufficiently low to
warrant concern, there would likely be extensive debate over
whether a hemoglobin level of 11 g/dl would necessitate
preventative measures in terms of a lead air quality standard.
In the interests of brevity and of focusing in on the more
critical effects, results are summarized here only for the
judgments regarding 0-3 year olds (the more sensitive age group),
and for the dose-response function for hemoglobin levels less
than or equal to 9.5 g/dl (See Figure A-l). [Expert C, believes
that a single dose-response function applies to children in the
0-6 year age range; with his concurrence, his judgments were
reproduced in both the 0-3 and 4-6 year age groups.]

     The following discussion regarding Figures A-l and A-2 is
extracted directly from Wallsten and Whitfield (1986):

-------
                                A-4
                           t   Expert C
                         10-
                     in  6_
                     en
                      VI
                         4-
                         2-
                                                ,0.95
                           5   15   25  35   45  55
         Expert D
     15   25    35   45    55
                               I   Expert E
                                          50-

                                          40-
                                       O)

                                      ^  30-
                                       VI  20-
                                          10-
                                      CL
                                    I     I    I    I     I
                                5    15   25   35  45   55
Figure A-l.
Probabilistic Judgments of Experts Regarding Lead-Induced
Hemoglobin Levels < 9.5 g/dl in children aged 0-3 years.
Blood lead (L) is on abscissa (in ug/dl) (from Wallsten
and Whitfield, 1986).

-------
                            A-5

     The graphs are analogous to the usual dose-response
     functions found in the literature, except, of course,
     they are based on probabilistic judgments rather than
     on direct data.  The dark, central curve in each panel
     shows the median judged dose-response curve for each
     expert.  In other words, for a given panel, according
     to that expert, at each blood lead level there is a
     0.50 probability that the true response rate is above
     the indicated value and a 0.50 probability that the
     true response rate is below it.

     The two lighter lines on either side of the median
     curve contain the central 50% credible interval.  Thus,
     according to the expert in a particular panel, at each
     blood lead level there is a 0.25 probability that the
     true response rate is below the lower light curve, a
     0.50 probability that it is between the two light
     curves, and a 0.25 probability that it is above the
     upper one.  In a similar manner, the dashed curve
     contains the 90% credible interval.

     The more tightly packed are a family of functions in a
     panel, the less uncertainty does an expert indicate in
     his judgments.  Thus, Figure A-l gives a rather
     complete representation of each expert's probabilistic
     judgments.

     Figure A-2 is less complete, but provides a convenient
     means of comparing judgments across experts.  The axes
     are the same as in Figure A-l.  The vertical bars at
     each lead level represent each expert's central 90%
     credible interval for response rate, and the symbol
     within each bar indicates the median judgment at that
     lead level.
     It must be borne in mind that these judgments are with

respect to lead-induced response rates over and above any base

response rate due to iron deficiency and other factors.  Thus,

levels of uncertainty, as well as differences or similarities of

opinion reflected here, are focused solely on the effects of lead

on hemoglobin.


     Note first that expert A did not feel that there was a

measurable lead-induced hemoglobin effect at PbB levels below 45-

55 M-g/dl, and therefore judgments at 9.5 g/dl are not shown for

him; indeed, his median judgment for the percentage of children


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                           A-7

age 0-3 years with hemoglobin levels below 11 g/dl  at  PbB  =  45
M-g/dl is 3%, and this rises to a most likely rate of 17% at  PbB
75
     There is overlap in the judgments of experts C, D,  and  E,
although not to the degree as for their  judgments regarding
hemoglobin levels below 11.0 g/dl which  are not displayed here.
For example, these experts judged with a probability of  0.9  that
the following fraction of children 0-3 years old which would have
hemoglobin levels below 9.5 g/dl with PbB of 35 M-g/dl were within
the following ranges: 3-8% (Expert C); 4-13% (Expert D); 3-41%
(Expert E) .   At a PbB of 25 p-g/dl, the  corresponding range  of
the fraction of children affected with a probability of  0.9
are:3-6% (Expert C) ; 1-4% (Expert D) ; 2-29%  (Expert E) .  For a
PbB of 15 |ig/dl, these 0.9 credible intervals are:  2-5% (Expert
C); 1-2% (Expert D);l-23% (Expert E) .  For a PbB of 5 ng/dl, the
following range of fractions of children 0-3 years would have
hemoglobin levels below 9.5 g/dl with 0.9 probability:   1-3%
(Expert C); 0 (Expert D) ; 0-10% (Expert  E) .

     Considering the median judgments (i.e., the response rate
for which there is a 0.5 probability that the actual rate is
either above or below the indicated value), C and E agree in
estimating the most likely response rate at 5 M-g/dl to be 2%,
while D is most certain that the response rate is 0.  Expert C's
median response rate judgment increases  relatively slowly with
increased PbB, while that of expert D increases relatively
quickly.  As a result, at PbB = 55 M-g/dl, D and E agree that the
most likely response rate is 20%, while  C considers it to be 7%.

     Of these 3 experts, expert E expresses considerable
uncertainty in his judgment about the dose-response function,
while experts C and D express much less.  Note also that the
judgment of expert D suggests a slight threshold between PbB
levels 25 and 35 [ig/dl, but that the judgments of the other  two

-------
                             A-8
do not suggest a threshold for hemoglobin levels below 9.5 g/dl
in 0-3 year olds.

     The corresponding judgments for lead-induced hemoglobin
levels at or below 11.0 g/dl, and for children 4-6 years old, are
not displayed here.  Expert A judged that blood lead below 45
ng/dl would not cause hemoglobin levels to drop as low as 11.0
g/dl.  As with 9.5 g/dl, the judgments of experts C, D, and E for
11.0 g/dl tend to overlap, but the degree of similarity displayed
is greater than at the low hemoglobin level.

     None of these 3 experts' judgments suggest a threshold above
which blood lead would result in a hemoglobin level below 11.0
g/dl.  According to their median judgments, the best estimate of
response rate for 0--3 year olds, hemoglobin < 11.0 g/dl, is
between 2% and 7% at PbB = 5 y.g/dl, rising to between 14% and 26%
at PbB = 55 ng/dl.  The judgments for children 4-6 years of age
followed the same patterns, as for children 0-3 years, with all
the experts judging smaller probabilities of effects in the older
group.  Detailed results can be found in Wallsten and Whitfield
(1986).

B.   Encoding Judgments on Lead-Induced IQ Decrements

     It should be noted again that IQ was chosen not because it
is the only,nor necessarily the best, measure of cognitive
ability, nor is it being considered as a surrogate for other
suspected lead-related central nervous system and behavioral
effects that have been explored (e.g., brain wave activity,
sensory motor, perceptual and attentional deficits, negative
classroom behaviors).  Rather, IQ decrement emerged as most
appropriate to consider because of its acknowledged functional
significance, its easy specification, and the amount of data
on its relationship to lead exposure.

-------
                           A-9

     It must also be emphasized that the encodings were conducted
prior to publication of several important studies or IQ effects
in children (e.g., Schroeder et al., 1985; Hawk et al., 1986;
Fulton et al., 1987; see section III.D.2.C).  Although these
recent studies tend to support earlier data, interpretation of
the encoded judgments here must recognize their time context.

     The probability judgments of six experts were encoded with
respect to the outcomes of a hypothetical, ideal experiment in
which a very large number of subjects were randomly assigned at
conception to various exposure groups and were exposed to (or
sheltered from) lead until their seventh birthdays.  Although
each child's lead uptake would not be constant due to changes
with age, .physiology and behavior, the hypothetical experimental
conditions were specified such that at their third birthdays, all
children in each group have the same measured PbB level.
Environmental lead levels necessary to yield a given PbB level at
age 3 in a particular child were specified as remaining constant
through the seventh birthday,  at which time the WISC-R IQ test
was administered.  The very large numbers of subjects per group
eliminated any concern about sampling error, and the random
assignment of subjects to conditions eliminated any concern about
complex analyses of covariance.  Each group was assumed to differ
only in terms of exposure to lead.

     Probabilistic judgments were encoded regarding:  (a) the
mean IQ decrement for each exposure group (5, 15, 25, 35, 45, and
55 p.g/dl on their 3rd birthday) relative to a lead-free control
group;  (b) the mean IQ of the control group; and (c) the within-
group IQ standard deviation.  Judgments about control group mean
IQ values and within-group standard deviations were necessary to
derive probabilistic estimates about the lead-induced increase in
percent of children at each lead level whose IQ scores are below
a specified IQ value of interest.  Detailed results, including
the encoded judgments, mathematical functions fit to those
judgments, goodness of fit measures, and derived subjective

-------
                           A-10

probabilities about dose-response functions, are given in
Wallsten and Whitfield (1986).  For brevity, summaries of results

for IQ decrements only are presented here.


     The experts were given the option of considering possible

interactive effects of socio-economic status and lead on IQ

(based on findings from several studies discussed in the CD and

this staff paper) by considering low SES children living in

households with incomes in the lowest 15th percentile separate
from the remainder of the population.  All the experts, except F,

believe that at the doses under consideration, lead interacts

with variables that contribute to SES level.  Therefore, all

except Expert F provided separate judgments for the two SES
levels.


     Figure A-3 summarizes the judgments of all six experts

regarding mean IQ decrements for the low SES group.  The
following discussion regarding the figure is extracted directly

from Wallsten and Whitfield (1986).


     Each person's judgments are shown in a separate panel.
     Blood lead is on the abscissa and mean IQ decrement
     (mean control group IQ minus mean exposed group IQ) is
     on the ordinate.

     The dark, central curve in each panel shows the median
     judged IQ decrement for each lead level.  In other
     words, for a given panel, according to that expert
     there is a 0.50 probability that the actual mean IQ
     decrement would be greater than the indicated value,
     and a 0.50 probability that it would be less.  The
     successively lighter pairs of curves that bracket the
     median curve represent central 50%, 90%, and 95%
     credible intervals.

     Figure A-4 allows a comparison of judgments across the
     experts.  The axes are the same as in Figure A-3.  The
     vertical bars at each lead level represent each
     expert's central 90% credible interval, and the symbols
     are his or her median judgments.

     Expert F consistently judged the IQ effects of lead to
     be less than did the other experts, and evidenced
     considerably less uncertainty about the magnitude of

-------
                           A-ll
                                           Expert G
                                            5   15   25   35  45   55
   25    35   45    55   65
        Expert H
                                   Afn
                                          3/  .• ^^  .•   ,*
                                      I  s    ^.••
         5   15   25   35  45   55
                                       15    25   35    45   55
A|Q A   Expert J

  15-
  10-
                                                Expert K
    I     I    I    [
                                      15   25   35  45   55  65
          '    *    i     i    i     i     i_
          5   15   25   35  45   55           u   ^3   jj   to  j^   03
Figure A-3.  Probabilistic Judgments of Experts Regarding  Mean, Lead-Induced
             IQ Decrements for Low SES Group.  Blood lead  (L)  is  on abscissa
             (in ug/dl) and mean IQ decrement  (mean  control  group IQ minus
             exposed group IQ) is on the ordinate of each  panel  (from
             Wallsten and Whitfield, 1986).

-------
    A-12
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-------
                           A-13


     these effects than did the others.  F was certain that
     there is no IQ effect of lead up to at least  15 ng/dl.
     At 25 ng/dl, the median judged IQ decrement is about  a
     0.25 point, and this increases to a median judged IQ
     decrement of just under 2 points at 65 ng/dl.
     According to F, at 25 |4.g/dl, the IQ decrement exceeds
     approximately 0.5 point with probability 0.05, while  at
     65 M-g/dl, it exceeds 3.7 points with the same
     probability.

     There are overriding similarities in the judgments of
     the other experts, although there are also small,
     consistent differences among them.  Thus, only G, H,
     and J give any credibility to there being IQ  effects  as
     low as 5 ng/dl, while I does so at 15 j^g/dl,  and K does
     at 25 M-g/dl.  The judgments of H and J are consistently
     very close, as are those of G, I, and K, which as a
     group are somewhat lower than those of and H  and J.
     Considering the five sets of judgments, the median
     judged IQ decrement at 5 ng/dl ranges from 0  to 2.4
     points.  The median judged IQ decrement at 55 ng/dl is
     from about 7 to 11 points;  According to the  judgments
     of G, H, and J, with probability 0.05, the IQ decrement
     exceeds 1.8 to 4.5 points at 5 ng/dl, while according
     to all 5 experts, it exceeds 9.9 to 15.1 points at 55
           with the same probability.
     Considering intermediate PbB levels, Expert F judged a

probability of 0.5 that the mean IQ decrement at a PbB level of

35 M-g/dl in low SES children would be 0.5 points.  Corresponding

median judged IQ decrements at 35 ng/dl for the other experts

are:  1.5 (Expert G); 8.4 (Expert H); 3.6 (Expert I); 7.0 (Expert

J); 4.0 (Expert K).  The median judged IQ decrements at 25 jxg/dl
for low SES children are:  0.25 (Expert F); 2.7 (Expert G); 4.9

(Expert H); 2.3 (Expert I); 4.8 (Expert J); 2.9(Expert K).  At a
PbB level of 15 p.g/dl, the median judged IQ decrements for low

SES children are according to these experts:  0 (Expert F);
1.4 (Expert G); 3.5 (Expert H); 0.7 (Expert I); 3.5 (Expert J);

1.3 (Expert K).


     As with hemoglobin, credible intervals were calculated for

each expert's judgments.  For example, the 0.9 credible interval

is a set of mean IQ decrement values such that there is a 0.9

probability of the true value falling within it.  The 0.9

-------
                            A-14

credible intervals concerning mean IQ decrements for the low SES
children for different PbB levels are as follows:

     45 ng/dl:  0.45-2.07 (Expert F); 3.5-9.3 (Expert G); 6.4-
13.9 (Expert H);3.3-9.1 (Expert I); 6.3-11.4 (Expert J); 4.4-8.4
(Expert K) .

     35 Jig/dl:  0.23-1.05 (Expert F); 2.1-7.3 (Expert G); 4.6-
12.7 (Expert H);2.2-6.5 (Expert I); 4.4-9.3 (Expert J); 2.0-5.5
(Expert K).

     25 M-g/dl:  0.11-0.52 (Expert F); 1.1-6.3 (Expert G); 2.6-9.0
(Expert H);1.2-4.6 (Expert I); 2.3-7.2 (Expert J); 1.1-4.7
(Expert K).

     15 ng/dl:  0 (Expert F); 0.6-3.5 (Expert G); 1.8-6.7 (Expert
H);0.3-1.7 (Expert I); 1.5-5.4 (Expert J); 0.5-1.8 (Expert K).

     5 |ig/dl:  0 (Expert F); 0.2-1.8 (Expert G); 1.2-4.5 (Expert
H);  0 (Expert I); 0.9-3.9 (Expert J); 0 (Expert K).

     Judgments about mean IQ decrement for the high SES group are
not displayed here, although all the experts, except F, felt that
the risks of lead effects on IQ would be smaller in the high SES
children.  Also, as with the low SES population, F consistently
judged the IQ effect to be less than did the other experts.  From
25 ng/dl on, the judgments of the others overlap, with, as
before, those of H and J being very similar and somewhat greater
than those of G, K, and I, which themselves are similar.  Only H
gave any credibility to the existence of an IQ effect at 5 |ig/dl,
G, I,and J did so at 15 ng/dl, and F and K concur at 25 p.g/dl
(Wallsten and Whitfield, 1986).

     Considering all the experts simultaneously, the median
judged IQ decrement at 15 ng/dl in the high SES group ranges from
0 to 2.4 points;at 55 p.g/dl, it ranges from 1.4 to 7.9 points.

-------
                            A-15

According to G, H, I, and J, with probability  0.05  it exceeds 1
to 7 points at 15 v.q/dl, while according  to  all  the experts it
exceeds 4 to 11.5 points at 55 M-g/dl with probability 0.05.

     C.  DISCUSSION
     Considering the scientific debate that  has  prevailed  about
the IQ effects of lead, the degree of consensus  reflected  in the
results is notable.  This is particularly so,  since the  experts
were selected so as to span the credible  range of opinion.   For
both health endpoints, encoding subjective probabilities from the
scientific experts about specific, well-defined  scientific
outcomes eliminated or minimized disagreements about definitions,
policy, and other matters.  The remaining differences, evidenced
in the preceding results, are mainly due  to  differing
interpretations of, and extrapolations from, the scientific
evidence.

     As discussed previously, the health  endpoints  that  were
assessed using probability encoding should not be considered  the
individual effects most crucial to a determination  of the
appropriate maximum acceptable PbB level.  Further,  the  encodings
were conducted in 1985-86 prior to publication of several
important studies on IQ effects in children; these  studies  tend
to support earlier data.  Several of the  experts assigned  fairly
high probabilities that potentially important  hemoglobin and  IQ
decrements could occur in children with PbB  levels  starting at  25
M-g/dl.  Judgments of some of the experts  suggest that effects on
IQ and hemoglobin could occur at and below 15 |o,g/dl. In  general
the judgments tend to support that the range of  10-15 p-g/dl is
appropriate for evaluating in Section IV.C the health protection
provided by alternative lead NAAQS.

-------
    APPENDIX B.  EXPOSURE CASE STUDIES:  SENSITIVITY ANALYSES

     This appendix presents results of sensitivity analyses of
the three case studies on children described in Section IV.D.2.
Populations of children living near a Dallas secondary smelter,
the East Helena primary smelter, and a.secondary smelter and
battery plant in Tampa were modeled from birth up to their
seventh birthdays, 1990-1996.  Blood lead distributions under
alternative lead NAAQS are estimated using the uptake/biokinetic
model which accounts for age-specific differences in exposure,
absorption, and physiological distribution of lead from food,
water, soil and housedusts, as well as air; behavioral and
biological variability not captured by the model parameters is
accounted for through use of empirically-derived measures of
blood lead variance (GSDs).  Several parameters were assigned
lower and upper bound values that span the range of credible
estimates derived from available data.  These include time spent
outdoors per day, volume of air respired per day, percent
absorption in the gastrointestinal tract of ingested lead in
diet, concentrations of lead in soil and housedust associated
with different air lead concentrations, the amount of dirt
typically ingested by children daily, and the GSD value that best
represents variability in childhood lead exposure around lead
point sources.
     The results presented for children in Section IV.D.2
incorporate midpoint estimates of those parameter values with
lower and upper bounds.  Tables B.I and B.2 summarize blood lead
distributions estimated by the uptake/biokinetic model using
either all lower bound values or all upper bound values.  While
the staff believes that the results in Section IV.D.2 are better
representations of future scenarios, the results shown here
illustrate the extremes in possibilities.  Sensitivity analyses
that focus on altering only one or two parameters at a time are
possible but are not shown here in the interest of space.
Results of any such analysis, using the same range of estimates,
would be intermediate to the results in the following two tables.

-------
                                     B-2
                   TABLE  B-l.   LOWER BOUND SENSITIVITY ANALYSIS:
                    CHILDREN'S PbB LEVELS IN 3 CASE STUDIES*
Case Study
(# Children) /
PbB Level
          Lead NAAQS Level (|j.g/m3)
           1.5               Monthly0*
Baseline*3  Quarterly0  1.5   1.25   1.0
0.75
0.5
Dallas (241)
Mean PbB (ng/dl")
% > 10 M-g/dl
% > 15 M-g/dl
East Helena (217}
Mean PbB (ng/dl)
% > 10 M-g/dl
% > 15 ng/dl
Tampa (10)
Mean PbB (p.g/dl)
% > 10 M-g/dl
% > 15 M-g/dl

4
0
0

4
0


6
5
0

.9
.3
.001

.0
.03
0

.5
.3
.08

3.
0.
0

3.
0.
0

5.
1.
0.

8
01


6
004


6
4
009

3
0


3
0


5
0
0

.8
.01
0

.5
.003
0

.4
.9
.005

3.7
0.01
0

3.4
0.002
0

5.2
0.6
0.003

3.7
0.01
0

3.4
0.002
0

5.0
0.4
0.001

3
0


3
0


4
0
0

.6
.005
0

.3
.001
0

.8
.3
.001
•
3.6
0.004
0

3.2
0.001
0

4.7
0.2
0
* Assumes lower bound values for parameters specified in text.
a PbB distributions calculated by assuming GSD = 1.30.
13 Baseline scenario represents current conditions for air quality, as well
  as soil and dust.  Dietary intake assumed to be at 1990-1996 levels.
G Current NAAQS and averaging time (calendar quarter).
d Alternative NAAQS levels with monthly averaging time.

-------
                                    B-3
                   TABLE  B-2.   UPPER BOUND SENSITIVITY ANALYSIS:
                    CHILDREN'S PbB LEVELS IN 3 CASE STUDIES*
Case Study
(# Children) /
PbB Level"
          Lead NAAQS Level
           1 . 5
Baseline*3  Quarterly"  i . 5
Monthly*3
1 . 25   1.0
0.75
0.5
Dallas r24H
Mean PbB (ptg/dl)
% > 10 M-g/dl
% > 15 p-g/dl
East Helena (217)
Mean PbB (ng/dl)
% > 10 ng/dl
% > 15 ng/dl
Tampa (101
Mean PbB (p-g/dl)
% > 10 ng/dl
% > 15 ng/dl

8
38
10

8
32
8

13
76
41

.9
.8
.8

.3
.7
.1

.6
.6
.0

6
12
1

6
17
3

11
58
23

.1
.0
.7

.7
.7
.0

.0
.7
.1

5
10
"l

6
16
2

10
51
17

.9
.8
.4

.6
.6
.7

.1
.3
.9

5.8
10.1
1.3

6.4
14.5
2.2

9.6
46.1
14.7

5.7
9.3
1.1

6.1
12.6
1.8

9.0
40.3
11.6

5
8
1

5
10
1

8
34
8

.6
.6
.0

.9
.9
.4

.4
.4
.8

5.5
7.9
0.9

5.6
8.6
1.0

7.9
28.7
6.5
* Assumes upper bound values for parameters specified in text.
* PbB distributions calculated by assuming GSD = 1.53.
to Baseline scenario represents current conditions for. air quality, as well
  as soil and dust.  Dietary intake assumed to be at 1990-1996 levels.
G Current NAAQS and averaging time (calendar quarter).
<* Alternative NAAQS levels with monthly averaging time.

-------
APPENDIX C:  CASAC CLOSURE REPORT

-------
     pp A        U-S. Environmental       Washington, OC
     fc* **        Protection Agency       EPA-SA8-CASAC-90-002
      Report of the Clean Air Scientific
      Advisory Committee (CASAC)
      Review of the OAQPS Lead Staff Paper
      and the FCAO Air Quality Criteria
      Document Supplement
A SCIENCE ADVISORY BOARD REPORT                  JANUARY 1990

-------
           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON, D.C. 20460
                                                         OFFICE OF
                                                      THE ADMINISTRATOR
                          January 3,  1990
Honorable William K. Reilly
Administrator
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC  20460
                                   RE:  National Ambient Air
                                   Quality Standards for Lead

Dear Mr. Reilly:

     I  am  pleased  to  transmit  the  advice  of  the  Clean  Air
Scientific  Advisory Committee  (CASAC)  concerning  the  National
Ambient Air Quality Standards  (NAAQS)  for Lead.   The CASAC has
reviewed and offered comments directly to EPA Staff on  the EPA Air
Criteria Document update, "Supplement to the 1986 EPA Air Quality
Criteria for Lead  -  Volume  I  Addendum (Pages Al - A67)w, and the
Office of Air Quality Planning and Standards (OAQPS)  staff position
paper "Review  of  the National Ambient  Air Quality Standards for
Lead: Assessment  of Scientific and  Technical Information", both
dated March 1989.

     The Committee previously  reached closure  on the  1986  Air
Quality Criteria Document and Criteria Document Supplement.  At a
meeting held on April 27,  1989,  CASAC reviewed and was prepared to
close on the 1989 Criteria Document Addendum  and  the  1989 Staff
Position   Paper,   but   withheld  closure   pending  receipt  and
consideration of  additional public  comments.   The public comment
period, scheduled  to close 30 days following the CASAC meeting, was
extended through  June  12, 1989, providing the interested public
further time to prepare comments.  The additional comments received
as a result of the extended comment period  were provided to the
Committee  and  taken into consideration  before reaching closure.
The Committee concludes that  these  EPA documents,  along with the
1986 documents  previously closed upon,  provide a scientifically
balanced and defensible  summary of our  current knowledge of the

-------
effects of this pollutant, providing an adequate scientific basis
for  EPA to  retain  or  revise  primary and  secondary NAAQS  for
airborne lead.

     As part of this review process, the Committee considered and
approved the CASAC Exposure Subcommittee review of the August 1988
EPA document "Review of  the National Ambient Air Quality Standards
for  Lead:  Exposure Analysis Methodology  and Validation".   That
approval is formally contained in the CASAC report transmitted to
you in April 1989 (EPA-SAB-CASAC-89-018, April 1989).

     In November 1988, the CASAC formed an ad hoc Joint Study Group
with the Science Advisory Board  (SAB).  The broad charge to this
Study  Group  included  assessment  of  the  weight  of.  evidence
classification of lead  and lead compounds as carcinogens; review
of lead-related health effects and exposure issues which cut across
EPA organizational lines; and an assessment of how the scientific
information concerning  lead is  applied to standard  setting and
other regulatory decisions in the Agency.  The report of that Joint
Study Group,  based on  their  March 30, 1989  and April  28,  1989
meetings, is contained in their report  (EPA-SAB-EC-90-001, December
1989), transmitted to you separately.

     A key point of the Joint Study Group Report is the contrasting
nature  of  the  data base for central  nervous  system  versus
carcinogenic effects.   The carcinogenic risk assessment is based
primarily  on  induction  of kidney tumors  in rodents  administered
large  quantities of  lead.   Use of  these data  for human  risk
assessment involves two  extrapolations: from rodents to people, and
from high doses to the low doses encountered in ambient exposures
of lead.  In contrast, central  nervous system effects are observed
directly  in people  and at exposures at or  near the  levels of
exposure relevant to setting the standard. Thus, and unless, more
quantifiable and relevant scientific  evidence is available on the
carcinogenicity of lead, the Committee feels it appropriate to give
primary  consideration  to  nervous  system  effects in  setting the
national ambient air quality standard for lead.

     During the course of the GASAC meeting several recommendations
were made  to  the EPA Staff as to actions that  can be taken that
will  provide  an improved  basis  for setting the  NAAQS  for lead.
These include calculation of the distribution of blood lead levels
estimated  to  result from achieving an  air  lead concentration of

-------
0.25   ug/m3.   In  addition,  it was  suggested that  it would be
appropriate to evaluate the  estimated  distribution of effects on
childrens intelligence at a given level of lead exposure.

     While the Committee is  willing  to further advise you on the
lead standard, we  see no need,  in view of the extensive comments
provided, to review any proposed changes prior to their publication
in the Federal Register.    The public comment period following
publication will provide sufficient opportunity for the Committee
to provide any additional comment or review, if needed.

     The  attached  report  contains  the  detailed  analysis  and
recommendations of the CASAC  concerning its closure on the Criteria
Document Addendum  and the  EPA Staff Position  Paper  for airborne
lead.   In considering the CASAC's recommendations for the lead
NAAQS it is important to recognize that air is just one source of
exposure to lead; reducing the total population risk from lead will
require a concerted effort  to reduce  lead  intake from all sources'.

     We  appreciate the  opportunity to provide  advice on  this
important  issue  and  look  forward  to  your  response  to  our
recommendations.
                                   Sincerely,
                                   Roger O. McClellan, D.V.M.
                                   Chairman, Clean Air Scientific
                                     Advisory Committee

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               U.S.  Environmental  Protection Agency
                      Science Advisory Board

  Clean Air Scientific Advisory Committee Lead Review Committee
Chairman

Dr. Roger O. McClellan*, Chemical Industry Institute of Toxicology,
     Research Triangle Park, North Carolina

Co-chairman

Dr. Arthur Upton, New York University Medical Center, Department
     of Environmental Medicine, New York, New York

Members

Dr. Gary Carlson, Department of Pharmacology and Toxicology,
     School of Pharmacy, Purdue University, West Lafayette,
     Indiana

Dr. J. Julian Chisolm, Jr., Johns Hopkins School of Medicine,
     Francis Scott Key Medical Center, Baltimore, Maryland

Dr. Robert Frank, The Johns Hopkins School of Hygiene and Public
     Health, Baltimore, Maryland

Dr. Paul B. Hammond, Department of Environmental Health,
     University of Cincinnati Medical Center, Kettering
     Laboratory, Cincinnati, Ohio

Dr. Timothy Larson*, Environmental Engineering and Science
     Program, Department of civil Engineering, University of
     Washington, Seattle, Washington

Dr. Ian von Lindern, President, Terragrahics Environmental
     Engineering, Moscow, Idaho

Dr. Morton Lippmann, Institute of Environmental Medicine, New
     York University Medical Center, Tuxedo, New York

Dr. Kathryn R. Mahaffey, National Institute of Environmental
     Health Sciences, University of Cincinnati Medical
     Center, Cincinnati, Ohio

Dr. Paul Mushak, Consultant and Adjunct Professor, University
     of North Carolina, Chapel Hill, North Carolina

Dr. Gilbert S. Omenn*, School of Public Health and Community
     Medicine, University of Washington, Seattle, Washington

-------
Dr. Michael B. Rabinowitz, Marine Biological Laboratory, Wood's
     Hole, Massachusetts

Dr. Marc B.  Schenker*,  Occupational and Environmental Health Unit,
     University of California, Davis, California

Dr. Ellen Silbergeld, Environmental Defense Fund, Washington, DC

Dr. Mark J. Utell*, Pulmonary Disease Unit, University of Rochester
     School of Medicine, Rochester, New York

Dr. Bernard Weiss, Division of Toxicology, Department of EHSC,
     School of Medicine, University of Rochester, Rochester, New
     York

Dr. Jerome J. Wesolowski*, Air and Industrial Hygiene Laboratory,
     California Department of Health, Berkeley, California

Dr. George T. Wolff*, General Motors Research Laboratories,
     Environmental Science Department, Warren, Michigan

     * Statutory CASAC Members

Science Advisory Board Staff

Mr. A. Robert Flaak,  Designated Federal Official, Science Advisory
     Board (A-101F), U.S. Environmental Protection Agency,
     Washington, D.C.  20460

Ms. Carolyn Osborne, Staff Secretary, Science Advisory Board
      (A-101F), U.S.  Environmental  Protection Agency,  Washington,
     DC   20460

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
 EPA-A50/2-89-022
                                                           3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
 Review  of  the National Ambient  Air Quality Standards
 for  Lead:   Assessment of  Scientific and Technical
 Information  OAQPS Staff  Paper
                                                           5. REPORT DATE
                                                            December  1990
                                                           6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                           8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
 Office  of Air and Radiation
 Office  of Air Quality Planning  and Standards
 U.S.  Environmental Protection Agency
 Research  Triangle Park, NC   27711
                                                            10. PROGRAM ELEMENT NO.
                                                           11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD COVERED
                                                               Final
                                                            14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NQTES
16. ABSTRACT
 This paper evaluates and interprets the updated  scientific and technical information
 that EPA staff believes is most  relevant to the  review of the primary  (health) and
 secondary (welfare) national  ambient air quality standards for lead.   This assessment
 is intended to bridge the gap between the scientific  review in the EPA criteria docu-
 ment and the judgements required of the Administrator in setting the ambient air
 quality  standards for lead.
 The major  recommendations of  the  staff paper are:
 consideration should be from  0.5  to 1.5 ug/m
                                                      (1)  the range of standards under
                                                 (2)  a monthly averaging period would
better reflect children's responsiveness to lead exposures than a quarterly averaging
period;  (3)  the most appropriate  form of the standard  is  the second highest monthly
average  in a 3 year span; (4) with  a monthly averaging period, more frequent sampling
is needed in areas with point sources;  and (5) the  hi-volume sampler should be re-
tained to monitor compliance with the lead NAAQS.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lOENTIFIERS/OPEN ENO'ED TERMS
                                                                         c.  COSATI Field/Group
 Lead
 Air Pollution
                                              Air Quality  Standards
18. DISTRIBUTION STATEMENT
 Release to Public
                                              19. SECURITY CLASS (This Report)
                                              Unclassified
21. NO. OF PAGES

      200
                                               20. SECURITY CLASS (This page)
                                                                          22. PRICE
EPA Form 2220-1 (R«y. 4-77)   PREVIOUS EDITION is OBSOLETE

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U.S. Environmental Protection
Region 5, Library (PL-12J)
77 West Jackson Boulevarjd. 12th Floor
Chicago, IL  60604-3590

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