U.S. ENVIRONMENTAL PROTECTION AGENCY




            STRATEGY FOR




       REDUCING LEAD EXPOSURES
        *  February 21,  1991

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              U S  ENVIRONMENTAL PROTECTION AGENCY
                          STRATEGY FOR
                     REDUCING  LEAD EXPOSURES

                        TABLE  OF CONTENTS
                                                            Page

                                     	    1
Executive Summary	

I.   statement of Problem	 '

          Health Effects	'.'.I    4
          Environmental Exposures	"."."....    5
          Sources of Lead. .  	
                                                	    8
II.  overview of Strategy	
                                                      .  .    8
          Goal	I*.'.'...-    8
          Objectives	:	        .  .    9
          Major Action  Elements	I*.'.'....     H
          Coordination	
                                          	     13
 III. Research  Program	

 TV  Abatement Program  	
                                  '                    .  .     15
           Lead-Based Paint Exposures	"...."   19
           Urban Soil	1 '. ".'...-•    21
           Superfund Sites	

 .v.   Regulatory and Pollution Prevention Program	«

           Office of Drinking Water	' ; ;    25
           Office of Solid Waste	'.!*.!••      27

           Office of Air Quality  Planning and S  an^  ^      32


           Office of' Enforcement	
  Appendices:
            I.
            II.
                                                              35
                                                              36

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                       EXECUTIVE SUMMARY
INTRODUCTION
     This document presents  the  coordinated  strategy of  the  U.S
Environmental Protection  Agency  to  address the  significant heal
and environmental problems our society  is facing as a result of
?ead pollution.   Lead is  a multi-media  pollutant;  accordingly,
the Agency plans to address  lead contamination  by coordinating
its authorities across programs.

     Because the strategy includes  research,  regulatory,  •
enforcement, educational  and training activities,  we envision
?his document will be a living document, and that it will evolve
as we begin to implement  its various components.  Several aspects
of the strategy will entail  continued coordination with other
branches of government while others, such  as regulations, will
require full compliance with the Agency's  rulemaking
requirements.

THE PROBLEM

     Lead is a highly toxic metal,  producing a range of adverse
health effects, particularly in children and fetuses.  Effects
include nervous and reproductive system disorders, delays ,in
neurological and physical development,  cognitive «f ^JJ0"1
changes! and hypertension.   Adverse effects have been found at
lower and lower blood lead levels,  and the Centers  for  Disease
control  (CDC) anticipate lowering its level of  concern  from 25
ug/dl to a  level within the range of 10 to 15 /ig/dl.
     Elemental lead is indestructible, and ubiguitous  « «je
environment.  Although the percentage of children J1^ JJJ^JJ
blood lead has declined substantially over thfclast_t^y  y^r
with average blood lead levels dropping from 15 to  5 jig/dl, an
estimated 15% of children still have blood lead levels over 10
ug/dl.  The three major sources of elevated blood lead are  leaa
blsed paint  urban soil and dust  (contaminated mainly  by lead-
based paint'and gasoline), and lead in drinking water  (moderate
exposures in large populations).  Other sources include
stationary point sources, Superfund sites, municipal waste  and
sewage  sludge  incinerators, and use of lead in products.
 FPA'S STRATEGY
      The gra-  of the strategy is to  reduce  lead exposures to the
 fullest ex-rt practicable,  with particular int.r..t in reducing
 account the associated costs and benefits,  and 2) to

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significantly reduce, through voluntary and regulatory actions,
unacceptable lead exposures that are anticipated to pose risks to
children, the general public, or the environment.   These
objectives will necessarily evolve as we better understand the
risks posed by lead.

     The strategy includes several major action elements:

          develop methods to identify geographic "hot spots",
          implement a lead pollution prevention program,
          strengthen existing environmental standards,
          develop and transfer cost-effective abatement
          technology,
          encourage availability of environmentally sound

          develop and implement a public information program,., and
          aggressively* enforce environmental standards.

     EPA'S research program, with other Federal agencies,  will
define, encourage, and/or conduct research needed to 1) locate
and assess,  in terms of both geography and media,  serious lead
risks, and 2) develop methods and tools to reduce those risks.
EPA's Lead Research Sub-Committee will continue to define and
rank lead research program objectives and activities.
                              >
     EPA'S abatement program focuses on in-place lead, and        ';
addresses lead-based paint exposures, urban soil and dust, and
Superfund sites.  Lead-based paint is the most serious source of
children's exposures.  Although the Department of Housing and
Urban Development (HUD) has primary responsibility for the lead-
based paint portion of this program, EPA is providing HUD with
technical and administrative assistance.  HUD's Lead-Based Paint
Task Force,  with representation from EPA, CDC, the National
Institute of Standards and Technology  (NIST) and other Federal
agencies, is providing a mechanism for the exchange of
information on Federal lead-based paint activities among the
various agencies.  EPA is funding a number of initiatives in
support of reducing risk from in-place lead, and will continue to
serve as the focal point and overall manager of technical support
to HUD.

     Lead-contaminated urban soil is believed to be the next most
important source of lead exposure, but relatively little is known -
about it.  Under the Superfund Amendments and Reauthorization Act
(SARA), EPA is conducting a pilot program to evaluate effects of
removing lead-contaminated soil and dust on children's blood
lead.

     More than 400 National .Priority ..List sites iiave lead as an
important contaminant.  EPA has issued interim guidance on lead
soil clean-up levels at Superfund sites, and is working to
provide methods for determining site-specific soil levels.

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     EPA-s  r«Ti1«frnrv  an* petition rrrYfnt-
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                       STATEMENT OF PROBLEM
HEALTH EFFECTS

     Lead is a highly toxic heavy metal. It produces a spectrum
of effects, both acute  and chronic.  Adverse effects include
peripheral and central  nervous system dysfunction, anemia, and in
extreme cases, mental retardation and death.  It has no
beneficial biologic effect, and current data do not permit
establishing a clear threshold for adverse effects.

     Fetuses and young  children are particularly susceptible to
lead.  Considerable data suggest a correlation between elevated -
blood lead (EBL) and delays in early neurological and physical
development, cognitive  and behavioral alterations, alterations in
red blood cell metabolism and vitamin D synthesis, and kidney
impairment.

      Adults also  face  health risks.  A positive association has
been found in adult males between EBL and hypertension.  Lead has
also been associated with increased risk of cardiovascular
disease.  Since lead is stored in bone, it may be mobilized
during periods of  stress, "during pregnancy, and among people
suffering from osteoporosis.  Lead exposures also may play a role
in miscarriages and in  damage to the male reproductive system.

     Blood lead (PbB) is a surrogate for estimating recent
exposure.  There has been increasing concern about PbB at lower
and lower levels over the past 15 years, as adverse effects have
been identified at levels not previously recognized as harmful.
The Centers for Disease Control (CDC) has repeatedly lowered the
PbB level of concern, from 40 M9/dl in 1978 to 25 Mg/dl
currently, and anticipates lowering this to a level within the
range of 10 to 15  ng/dl in the near future.
ENVIRONMENTAL EXPOSURES

     As an element, lead is essentially indestructible, and is
ubiquitous in the environment.  However, there have been large
reductions in ambient air lead and food lead concentrations since
the late 1970 's, primarily due to the phase-down of the use of
lead in gasoline and the removal of lead-soldered food cans from
domestic production.  While no longitudinal or prospective data
are available on soil lead, it is likely that reductions in soil
deposition have occurred as air emissions declined.  This, in
conjunction with other factors, has dramatically lowered
population PbB.  While there .has been no .recent. national survey
of human PbB, it is estimated that mean PbB in U.S. children has
declined by a factor of three or four, from about 15-20 /xg/dl in
1976-80 to approximately five ng/dl today. As the next table

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shows,  there have  been comparable declines  in the estimated
percent of U.S.  children with EBL.1
                            TABLE 1:     -       -   jLJiii*LJ*L

                                  ^976-80         1990
                                  (percent)      (percent)
               >25
 population exposures as well.
                           «

 SOURCES OF LEAD

      The  three major sources of lead  contributing  to  PbB above  10
        in descending order of importance,  are:

          Lead-based paint (LBP):  Most PbB levels in U.S.
          "ildren  above  CDC's current level of J0""™^
          Mg/dl)  are due  primarily to exposures to deteriorating
          TRP causina very  high  PbB  in relatively large
          populations9 L£  fof residential use was banned by the
          EoSsumer  Product Safety Commission  CPSC) in 1978.  The
           control of existing LBP in  residential units is
           D?im!rily the responsibility of the homeowners    .
           alt£oughythe Depa?tment of  Housing and Urban Affair.
           ?HUD)  is  responsible  for  public housing.  Pr°f™^ *L
           assist homeowners and property owners in the abatement
           of residential  LBP is the responsibility of HUD, with
           EPA and several other agencies providing technical
           support .
      1 The estimates in this and the following[table ^ere



  ?he^ost  recent available information on lead occurrence  in
  various exposure media.

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      2.    Urban soil and dust:   These were contaminated  In  the
           past mainly by LBP and lead in gasoline.  The  extent
           and severity of exposures  are  not well  characterized,
           but both are believed to be large.

      3.    Driuhing vater:  Drinking  water generally contributes
           low to moderate exposures  to relatively large
           populations.  Lead contamination is due mainly to lead
           solder joining water  pipes in  housing,  the past use of
           lead service lines to connect  homes to  public  water
           supplies,  and the continuing use of lead in brass
           plumbing fixtures.  Lead use in pipes and solder  was
           banned in 1986; however, EPA enforcement of this  ban is
           extremely limited.  Revisions  to Safe Drinking Water  -•
           Act (SDWA)  regulations will gradually minimize
           exposures from these  sources.

      Thus,  the major sources of EBL  today largely are regional
exposures  to  lead deposited when lead was extensively used  in
gasoline and  paint,  and to previously installed lead and lead-
soldered pipes conveying drinking water.   The next table
describes  the extent of these exposures.
                             TABLE 2: .
   Estimated Number of Children under 6 Exposed to Lead Sources

                                             Number and percent
                                             with PbB  >10 uo/dl

                         Total exposed       Number    Percent
     LBP, plus
     urban background     12,000,000      2,000,000       17

     Urban soil/dust      12,000,000        ?              ?

     Drinking water       30,000,000        950,000        3.5


      Although most EBL  in the U.S. today is attributable to one
or more of the above sources, -there are additional contributions..
from other sources that  add to total lead body burden.  The
severity of lead exposures from other sources is unclear,
although these sources may contribute to very high exposures in
smaller populations.  These other sources include food and
continuing auto emissions, as well as the following sources:

     *    Stationary point >ouro««:  Mainly smelters, which cause
          high PbB in relatively small and local populations.
          Exposures are  due in part to current emissions, and in

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                    part to resuspension of  dusts  and soil  contaminated  by
                    past emissions.

               *    Superfund National Priority List  (NPL)  »ites:
                    ADDroximately 400 of these sites have lead identified
•                    as one of the major contaminants, and may have very
; '                   high soil lead levels.

               *    Municipal waste conbustors (Mire's):  Presently about
                    200  with many more planned or under construction.
                    Stack emissions from these sources will be reduced by
                    recently promulgated regulations.

                    continued us* of l«ad in products or for purposes that
                    could result in high wposure:  For  example, the use of
                    lead solder to seal food cans or (illegally) to join
                    pipes conveying drinking water; use  in brass plumbing
                    fixtures; use in products  (such as paints and solder)
                    used intensively by hobbyists or "do-it-yourselfers";
                    use in industrial paints, and use in ceramic glazes.

                    Mining sites:  Sites exist where significant residual
                    mine wastes remain.  Many of these sites have ongoing
                    activities to remove or remill much of the existing
                    mine waste.  The bioavailability of such  lead is under
:    "                investigation.

                *    sewage sludge disposal:   Primarily a problem  if the
>                    sludge is  incinerated without proper controls.

                *    Occupational  exposures:   This would include secondary
i                    exposure of  children whose parents are occupationally
f                    exposed  to lead.

'                EPA, recognizing  the  varied  sources of lead and the  multiple
           pathways  of exposure which are possible, has developed  this
           strategy  document  to limit lead exposure.

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                       OVERVIEW OF STRATEGY
      This section provides a summary  of the goal, objectives, ar.d
 major action elements of EPA's lead strategy.
 GOAL

      The goal of this strategy is  to r«duc« lead exposures to the
 fullest extent practicable,  with particular uphaai* on reducing
 the  risk to children.  This  strategy document describes the
 extensive set of actions underway  or planned within EPA or other
 Federal agencies to reduce lead exposure.  As appropriate within
 the  context of the various statutes which EPA implements,
 benefits to society of reducing exposures to lead will be weighed
 against the costs of achieving those reductions before taking
 action.
OBJECTIVES

     To achieve  this broad goal, EPA has set two objectives as a
means of setting program  priorities and gauging success.  These
objectives will  necessarily  evolve over time as we better
understand the risk posed by lead exposure.  These program goals
include:

1.   Significantly reduce the incidence of blood lead levels
     (PbB) above 10 M9/dl (subject to revision in light of the
     forthcoming CDC report)  in children, while taking into
     account the associated  coata and benefits.

     This objective places EPA's priority on the highest
exposures and on the most sensitive population, the 15 percent of
U.S. children estimated to be at higher blood lead levels.  This
target is consistent with the recommendation of EPA's Clean Air
Science Advisory Committee (CASAC) and the anticipated guidelines
of the Centers for Disease Control (CDC).  Among these children
at risk, EPA will continue to work in close coordination with CDC
efforts to identify, through additional surveillance programs,
individual children with  PbB above 25 /jg/dl.  These children
should have their sources of lead exposure abated on a priority
basis.   All of the various initiatives will take into account •
costs and benefits to the extent allowed by statute.

2.   significantly reduce, through voluntary and regulatory
     actions, unacceptable lead •xposur** that arc anticipated to
     pose risks  to children/  th« ganaral population/ or the
     environment.

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     imdAr this obiective,  priority attention will be given to
voluntary anS regulatory actions,  including pollution prevention
activities? to reduce risks.   This includes reducing or
and costs.
flft.TQR ACTIOM ELEMENTS

     To achieve the above objectives, EPA activities will proceed

along several basic lines of action:
  the dissemination of materials,  »•  «•"  training.   Many other

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including performance  criteria.  The ease of following
.directions,  and  the  ruggedness of the test procedure to
departures  from  instructions, is also being evaluated for         ' i
commercially available test  kits.                                  '

Implement Lead Pollution  Prevention Program:  while the major
tasks  in reducing  risks from lead are to abate or control lead
that is already  deposited in the environment, the lead pollution
prevention  program will seek to reduce future exposures      —
associated  with  the  continued use of lead.  This program will
include:

          exploring  market-based incentives to limit or eliminate
          lead use and exposure;

          using  regulatory mechanisms (such as the Toxic
          Substances Control Act (TSCA)) to reduce the use of
          lead in  current and future products where risks
          outweigh the benefits; and

    . -    identifying  and encouraging cleaner technologies for
          mining,  smelting and processing lead.

     In addition,  the  Administrator has stated a goal of reducing
lead releases (along with releases of selected other chemicals)
by one-third by  October 1992, using voluntary means; and reducing1
lead releases by 50% by 1995.  The Administrator intends that
this goal be reached primarily through pollution prevention,
using toxics use reduction as the preferred approach.  This goal
applies to  reductions  which  go beyond any existing regulatory
requirements.

Minimize Human and Environmental Exposures through Traditional
Control Mechanisms:  This activity includes controlling lead
contamination in water, air,  and other media by setting
performance  standards  and other regulatory approaches.  Because
lead presents risks  through  a wide range of media, the Agency has
clustered together the current and prospective rules and policies
addressing  risks from  lead from these various media.  This will
allow the Agency and the  public to review the regulatory programs j
of each of  EPA's program  offices as a cohesive whole, and will    -
help prevent the human and environmental risks of lead pollution
from being  simply  transferred from one medium to another.   -  —

Encourage the Availability of Environmentally Sound Recycling:
This activity is unique in that it highlights the inherent
conflicts which  are  possible as individual offices strive to
minimize lead emissions to their particular media.  In order to
reduce .risks to  populations .and ecosystems from-J.ead, And to
provide safe disposition  of  spent lead products, the Agency seeks
to encourage environmentally sound recycling capacity.
Activities  rec.ently  completed or under consideration by a number

                                10

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reductions in human and environmental exposure.


Develop and Implement a Public Information and •""•"•» Program:






































 with lead issues in general.

 coordinate »....r=h.Prc!r».:  A wide range oferesear=heis£n.eaed
                                                 s
                   agenda is directly supp         effort,  which

                        n
                                                  set the research
                          ^i  1*1*^*1 »**•*  •—• ——  - ~     -


 agenda  for coining years.



 ronpntNATION
                                  11

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highly  interdependent.   The EPA Office Director Lead Committee
 (ODLC)  is  responsible for ensuring this coordination.  The ODLC
will monitor and report on lead-related activities to the Deputy
Administrator on a continuing basis.
     Specific Agency  lead-related activities recently completed,
underway or planned are described.in the following sections.
This document summarizes EPA's.strategy for addressing lead
exposures as envisioned by the Agency at the time of its
publication.  However, EPA's plans will be dynamic and evolving,   £
and will be subject to change as new research and our ongoing      s
programs indicate new priorities.  Nevertheless, this strategy is  i
meant to convey the Agency's deep concern about lead exposure,     |
and its commitment to reducing associated risks to human health    \
and the environment in the most efficient and cost-effective ways  ,
possible.
                               12

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                         RESEARCH PROGRAM
Background

     A focused research program is critical not only to develop
sound regulations, but also to inform other Federal agencies and.
I?a?e and local governments on matters relating to abatement.

     EPA will, in conjunction with CDC, HUD, and the Department
redceoser.   In th   way, -EPA =.n ^
and  an  intonation resource to  local abatement  efforts.


Needs

     While  the  toxicity of  lead is  well recognized,  the





 needed:

                       of  methods for identifying *nd
           sources (geographic "hot spots");
           loading;

           development and evaluation of cost-effective abatement

           tools and methods;
                                                             ln
                      Actions
       The Office Director's
                                          e
                                  13

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likely to effectively address major sources of elevated blood
lead levels.

     The Lead Research  Sub-Committee will report back to the ODj_c
at least annually, with a ranked list of research objectives.
Upon concurrence, the ODLC will include this list in their
periodic reports to the Deputy Administrator.

     EPA's research program will also be coordinate' with the
research activities of  other government entities, including CDC
and HUD, through periodic meetings.  Development of the methods
for identifying and mapping geographic "hot spots", for example,
must involve CDC, HUD,  public drinking water suppliers, and State
and local governments.
                               14

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              ABATEMENT PROGRAM FOR "IN-PLACE"  LEAD
LBP EXPOSURES

Background                                                   . •. •

     LBP is the most serious source of children's  exposure.   The
ATSDR estimates that 12 million children  are  exposed to lead-
painted homes,  and that almost six million are  exposed to the
highest concentrations, in homes built before 1940.

     In 1971, under the Lead-Based Paint  Poisoning Prevention Act
(LBPPPA),  HUD began restricting FHA mortgages for  new dwellings
to those with paint that did not contain  more than one percent
lead   In 1973, amendments to the LBPPPA  reduced this level to
0.5 percent, and designated HUD as the principal Federal agency
to eliminate the hazard of LBP in housing.

     In 1987, Congress enacted the Housing and Community
Development Act, which among other things required HUD to prepare
plans for the abatement of lead-based paint hazards in housing.
A plan, comprehensive and Workable Plan for the Abatement of
Lead-Based Paint in Privately Owned Housing,  was released in
December 1990.   Another plan addressing lead-based paint
abatement in public housing is scheduled  for completion by late
1991.

     In 1988, Congress directed EPA and HUD to effect a
Memorandum of Understanding (MOU), under which EPA would provide
technical and program development support to HUD.   EPA and HUD
signed the MOU in April of 1989, identifying the following areas
of technical and managerial assistance:

          accreditation of abatement personnel,
          establishment of training and information centers,
          intergovernmental relations,
          identification of gaps in existing technical standards,
          new technical standard-setting, and
          public outreach and education.

     EPA's  current work is in two major areas:

          assistance  in developing technical information
          necessary to effectively administer abatement programs,
          and                                            .
          program assistance to help HUD  and public housing
          personnel administer the program, and ensure that
          .contractor/designer personnel do their.work well.

     CDC  has historically directed the targeted lead  screening
program that identified lead-poisoned children, and has  long

                                15

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  advocated  intervention to lower EBL  in children resulting from
  LBP.  Recently,  the Assistant  Secretary for Health asked CDC to
  design  a program to eliminate  the childhood lead problem,
  including  abating lead paint in deteriorated housing.  EPA
  provided assistance to CDC in  performing a detailed cost/benefit
  analysis o£  the  program.   CDC  is expected to further lower the
  PbB level  of concern from 25 /ig/dl,  significantly increasing the
  number  of  children above  the action  level.

      Other agencies also  play  a role in LBP abatement-related
  programs,  in 1978,  the CPSC limited all residential paint to
  0.06 percent lead.   OSHA  is actively pursuing a reassessment of
  the worker protection  issue.   NIST is currently under contract to
 HUD on  a number  of research issues related to measurement
 techniques and procedures  for  lead in paint-films and dust.

      LBP accounts  for  the  largest single share of EBL.   The LBP
 problem is both  large  and  complex; the magnitude of these
 exposures adds to  the  difficulty and expense involved in finding
 and implementing solutions.  This is exacerbated because,  while
 EPA and other Federal  agencies can plan and otherwise assist
 activities, these  agencies are not equipped to perform most
 actual  abatement work.  This field work will likely be performed
 by property owners under State and local government programs..
      It is essential to achieving the first of this strategy's
 objectives that exposure to LBP be significantly reduced.   There
 is  a  clear need to coordinate the various strategic plans  that
 EPA,  HUD and CDC are developing for dealing with LBP.   State  and
 local governments must also become involved.   Given the magnitude
 of  the problem, these jurisdictions will  work  with  property
 owners who will conduct most of the actual  abatement work.

      Guidance is needed on acceptable lead  levels in dust
 resulting from LBP to enable programs to  set goals  to reduce
 these exposures.   The relative contribution to dust from LBP  and
 soil  needs to be established; and improved  measurement  methods
 for soil,  paint and dust need to be developed  to reduce abatement
 costs.   More cost-effective LBP abatement and  management
 approaches have to be developed.

      Responsibilities fall into three broad categories:  direct
 abatement;  technical support and research;  and  operational
 support.   Abatement involves planning and implementing  abatement
 projects;  technical support and research  involves providing
 consultation and  information;  and operational support involves
managing  the infrastructure needed to support abatement  programs.
Examples  of  the third category include PbB  screening, training
and lab accreditation programs.


                                16

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pi a^ped/Pegommended
     in EPA  both OTS and ORD will be  involved in Provid"??.ties



closely to ongoing  abatement efforts.
NIST      oe       ene
  Sil^^^^
Congressional appropriation provided resources for these
initiatives.
 issues.
 LBP testing  and abatement.
      OTS is  currently pursuing the following specific
 initiatives:
                         of one or two Dining  centers  which
                                                            in
           1991.
                                17

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 Provide worker training grants to  major  groups  after
 the model course materials are completed.   This will be
 funded during late 1991.

 Initiate a flagship lead center at a  leading
 university,  to serve as a focal point for  information
 transfer and to stimulate quality  training by other
 organizations.  This center will be established during
 FY 1991.

 Promote state lead training programs  with  seed  grants
 to at least  two states.   It is expected  that this
 program will be funded  in late FY  1991.

 Develop a risk communication strategy to inform the
 public,  industry,  labor,  environmentalists, etc. on
 health risks associated with LBP exposure.  This will
 be prepared  in 1991.

 Study of low-cost  repair  and maintenance activities
 (management  in place).  The pilot  study  will be
 completed in spring 1991;  the  study will continue
 through 1993.

 Study of the long-term  effectiveness  of  abatement
 methodologies.   A  pilot study  is expected  to be
 completed in FY 1991; field work is expected to begin
 in FY 1991 and continue through FY  1993.

 Preparation  of a Report to  Congress on the
 applicability  of RCRA to wastes  generated  from  LBP
 abatement.   This will be submitted  to OMB  in 1991.

 Continuation of support to  HUD  on the Guidelines for
 LBP abatement  in public and Native  American housing.
 This  includes  analysis  of data  collected by HUD in a
 national  study and demonstration project.  This will
 occur throughout 1991.

 Development  of a test protocol to evaluate the
 effectiveness  and  durability of  LBP encapsulants.  This
 will  be  completed  in 1991.

 Evaluation of  LBP  test kits for commercial and home use
 (with NIST and ORD), throughout  1991.

 Development  of key components of a laboratory
 accreditation  program (with NIST and ORD),  including
the development .of-protocols -and standard reference
materials  for  various analytical methods, throughout
 1991.
                      18

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         1992.


     SOIL
Background
                     urban soil - soil .contaminated bjMD
                     of lead
                 «.«, ,,»-,j.r.
non-iSssssrssu   s   a          ^iiaSSiiraSc...
household wastes (e.g , used oil) . «nd '?! •JJJllng sltes,  and
(e'?;' Y^iSf coSribite  «£?£? II mSch asSo percent of
ssi ;          ? s    -i    -             c^iS1
                  coribte
                   ? s £   e
soil being tracked into residences.
     Although EPA-s Office of                      o
 (OERR)  currently h.s.n^er of progr^enj.yd
 soil, the focus is primarily upon "ix              Study.  Under
 sources.   An exception to this is °™  J Thr*     y    ^^ ^
 Section lll(b)(6) of SARA, OERR, with advice    conducting a $15
           of Agriculture  (USDA) and °««s; d cincinnati to
                                                 soil and dust
 on  children's PbB.
                  -, ~+*A 
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 Needs

     Although believed to be one of  the two most serious sources
 of lead exposure,  far less is known  about urban soil than about
 either paint or drinking water.   Data are limited on the location
 and severity of the problem,  on  the  extent to which abatement is
 required,  and on the best procedures for achieving abatement.
 More information is needed to better characterize the problem, to
 determine  pathways of exposure,  and  to determine effective
 remediation methods, as well as  to developing methods to identify
 geographic "hot spots".

 Planned/Recommended Actions

     EPA's Office  of Solid Haste and Emergency Response  (OSWER)
 is responsible for actions involving lead abatement at NPL sites.
 Given  the  current  lack of knowledge  regarding urban soil,
 priority will be given to develop information about, the problem
 and on methods of  remediation.    EPA will seek to establish a
 joint  effort with  HUD,  CDC arid ATSDR to promote and assist a
 national effort to identify the  locations, extent,
 bioavailability and severity of  lead-contaminated soil.

     EPA's Region  5 has initiated a  multi-year (1991 to 1993),
 $1.1 million project called the-Lead Education/Abatement Program,
 or Project LEAP, to address exposures from contaminated soil and
 paint.   This project,  which is the result of an OPPE/Region 5
 Comparative Risk Project,  includes education, intervention,
 abatement  of public and private  areas, waste minimization, sourci
 controls,  and pilot clean-up.

     In  1991,  Region 5 will develop  a database of exposure
 (various media and pathways)  to  be used in a geographic
 information system application.   They will then map the data and
 prioritize geographic areas on which to concentrate efforts
 (education,  pollution prevention, and abatement activities).
 The Region will also initiate pollution prevention discussions
 with air sources of Pb.   They will coordinate the development of
 education  and training activities with OTS, and request
 assistance from the States in the Region.  Finally, they will
 determine  the compliance status  of major sources of Pb, and
 initiate enforcement action as appropriate.

     Region 5 will refine and update the exposure database in
 1992.  They will also initiate pollution prevention discussions
with sources of Pb in targeted areas, with the goal of achieving
even greater multi-media reductions  in Pb releases than included
 in EPA's Industrial Toxics Program.  They will begin
 implementation of  the education  program (developing and
distributing brochures,  stickers, coloring books, etc.), and will
begin  intervention efforts (distribution of calcium supplements,
etc.) .    Finally, they will perform an abatement pilot project in

                                20

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communicated.
          SITES
Act (CERCLA) §104 (i) (2).



          than 400 NPL sites have lead designated as a
                                                                 t
mining and milling sites.  }"?"*"*"•'   involve large volumes  and






not  routinely measured at Superfund sites.









 to 1000  ppm.
 sites^
 developed is a biokinetic uptake model  for lead


      in June 1990, OERR recommended a cleanup level of  15 ppbjor

      in groundwater near Superfund sites if      water
                                           using a  10  ,g/dl  P.B



 criterion.



               an
                                 21

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            REGULATORY AND POLLUTION.PREVENTION PROGRAM
      EBL today is largely due to exposures to "in-place".lead
 previously deposited.  Therefore, the highest public health     ;
 priority is to abate exposures to this "in-place" lead — with
 particular emphasis on LBP and lead-contaminated urban soil.

      There are, however, some continuing sources of new lead  —
 particularly lead smelters and drinking water — that warrant
 attention by EPA.  These exposures,  in contrast to those from
 "in-place" lead, are amenable to regulatory control.   While EPA
 has limited regulatory authority to address "in-place" lead,  it
 has ample authority under several statutes to restrict current
 and future consumption of lead which might add to new exposures.
 This may include both traditional emission control restrictions
 as well as pollution prevention measures that could,  for example,
 result in the use of new smelting technologies to reduce the
 amount of lead waste generated.  In addition, EPA may encourage
 pollution prevention measures to reduce the amount of lead in
 products.

      This section summarises the roles of the various EPA Offices
 in controlling new or ongoing lead pollution.  All of these
 activities  are under consideration,  but a final decision has  yet
 to be made  regarding some of them.   It is important to note that
 the activities summarized here, while significant and importan*-
 in reducing lead contamination for specific localized populati
 as well as  ecosystems,  are not sufficient in themselves to
 adequately  achieve the goal of significantly reducing the  blood
 lead levels of children at highest risk.   Achieving this
 objective  is dependent upon significantly reducing risks due  to
 LBP and urban soil.
OFFICE  OF DRINKING WATER (ODW)

Background

      Lead occurs  in drinking water primarily due to corrosion of
lead-bearing  materials in water supply distribution systems
(e.g.,  service  lines,  goosenecks, water meters) and in household
plumbing  (e.g., lead-soldered copper pipes, brass faucets, and_.
brass fixtures).  The highest levels are found in areas with
corrosive waters,  especially in older urban areas with lead
service lines and mains,  in homes with newly-installed lead
solder  (though  now illegal) and brass faucets, and in buildings
with drinking water coolers containing lead-lined tanks.  Nearly
everyone  is exposed, to lead .in drinking water at some ..level.
Concentrations  vary widely from city to city, house to house, and
even at the same  tap depending on standing time of the water and
temperature.  There are very few data to make reliable nationwide

                                22

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projections of current exposure.   In 1986,  EPA estimated that
approximately 20 percent of the population  was exposed to lead
levels over 20 ppb in first-flush water.  These data are being
used to estimate baseline risks as part of  the current reviews of
the drinking water regulation and.the lead  National Ambient Air —
Quality Standard (NAAQS).

     Assuming the highest PbB to water lead relationships
available in the literature, steady exposure to 20 ppb in
drinking water would  contribute between 2.5-3.5 jig/dl to a
child's PbB.  Most people are probably exposed to lower levels of
lead in drinking water, and only a snail fraction is exposed to
much higher levels.  Therefore, drinking water actually
contributes a smaller amount for most of the population.  On
average, this is estimated at between one and two ng/dl.

     EPA currently estimates that among U.S. children not living
in deteriorating lead-painted housing, and  not exposed to highly
contaminated soils, approximately 3.5 percent have PbB above 10
Mg/dl.  Even if lead in drinking water could be completely
eliminated, the percentage of children with PbB above 10 »ig/dl
would be reduced to 1.4 percent,  although this shift would be
relatively small — from about 11 to 9 fig/dl on average.

Final Drinking Water Regulations

     In 1988,  EPA proposed revisions to the National Primary
Drinking Water Regulation for lead under the SDWA.  The major
provisions of the proposal were for water suppliers to monitor
lead levels in first-flush, standing water  in high-risk homes,
and to install and improve corrosion control and conduct public
education if lead levels were above various targets.  The current
standard is a Maximum Contaminant Level (MCL) of 50 ppb measured
at free-flowing taps located throughout the distribution system.
The Agency is considering reducing this 50  ppb MCL to a 15 ppb
first flush "Action Level" at the tap.  The Agency is also
considering requiring corrosion control, public education, source
water monitoring and possible treatment, and lead service line
replacement if the 15 ppb "Action Level" is exceeded in more than
10% of samples from high-risk homes  (90th percentile).  Further,
EPA is considering whether to reguire all large systems (those
serving more than 50,000 people)  to optimize corrosion control
for lead without jeopardizing overall water quality.  ODW plans
to promulgate the rule  in April 1991.

     ODW estimates that the final rule will result in the average
PbB among children not  exposed to paint or soil contamination
hazards dropping from 5.3 to approximately 4.7 Mg/dl-  EPA
estimates that actions  by water systems to comply with the
revised rule will reduce exposures for millions of Americans.
Approximately half a million children will  have their blood  lead
levels reduced to below 10 ng/dl.  Although the average shift

                                23

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will be relatively small, some children vill have very
significant decreases in blood lead.

 level of 15 ppb.










 systems that •^••^^^"Xres from household plumbing can
 customers  of easy "ays that ££°S£rst £lush water after long






                              ££ ,y vatL supplier.
 suppliers.

 planned Actions

      Several ongoing |«~^^

      s^tJr^ £ ^^^^ijs^^SiKSi
 systems,  and from plumbing in resident 1JJ J     The use of pipes
 facilities connected to  a P^c.Y;J?rp;£cent lead was also
 or faucets containing »ore than eight PJ^JJ  tlon comes from
 banned.   Given that much of ^h«1"Jc^r plunbing, effective
 water standing in J*«««J» •"? ."ni^SS pElorlty! Although

                    ^
                             24

-------
fixtures.   ""•  1      «6 (a) to ton the. sale of lead .solder .to

^er".ndUp-i!SbIn™supPli house.-, to further ensure

compliance.




















names of certified  analytical  laboratories.
 of  lead  in  drinking water.
 resource Conse:



      Land Ban


      m resnonse to the 1984 Hazardous and Solid
      In response to "•       ,,-r>,<^ third" rule i
  sr
  rather than meet the new requirements
                                  25

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     Toxicitv Characteristic Leaching Procedure  fTCLP)

     OSW published a final  rule  in March 1990, under Subtitle c
 of  RCRA,  replacing the Extraction Procedure  (EP) leach test with
 the TCLP. ..Under the EP,  if a wastt.was a solid, homogeneous
 material,  a sample of the waste  could be tested using the
 structural  integrity procedure  (SIP), and did not have to be
 ground  to pass through a  9.5 mm  sieve the way all other wastes
 did.  The TCLP no longer  allows  the use of the SIP for any
 wastes,  although alternatives to the grinding requirement are
 being evaluated.

     In addition, the final rule has a regulatory limit of 5 ppm
 for lead in the TCLP leachate, based on the  current drinking
 water standard of 50 ppb.  OSW will evaluate whether to change
 the regulatory limit once the revised drinking water standard,
 currently under development, is  promulgated.

     Both of these actions  could cause additional secondary
 smelter slag to be considered hazardous waste, although other
 modifications to the standard setting procedure under
 consideration could offset  the effect of the revised drinking
 water standard.

     If additional slag is  therefore characterized as hazardous
 waste,  more secondary smelters will be required to comply with
 Subtitle  C  requirements.  If, for example, a smelter is disposing
 of  hazardous slag at its  own on-site landfill, the smelter will
 have to  comply with Subtitle C hazardous waste management
 requirements,  including corrective action for all solid waste
 management  units.at'the facility.  These costs may cause some
 secondary  smelters to choose to  close.

 Regulatory  Determination  on Mineral Processing Wastes

     Lead  slag from primary lead smelting is one of twenty
 mineral  processing wastes currently excluded from regulation
 under RCRA  Subtitle C.  OSW is currently evaluating whether any
 of  these  twenty wastes should be regulated under Subtitle C,
 which would include permitting,  manifesting, and on-site and off-
 site waste  management activities.  Subtitle  C regulation may be
 warranted  for lead slag because  of its toxicity, documentation of
 damages,  and widespread distribution of waste off-site.  However,
 Subtitle  C  regulation could also contribute  to economic
 disruption  of the primary smelting industry; this is discussed
 further under the "Battery  Cluster" section  of this document.
 OSW plans to make its Regulatory Determination by June 1991.

 Source  Separation

     OSW  is considering issuing  an Advance Notice of Proposed
Rulemaking  (ANPR)  to solicit comments on a number of options to

                                26

-------
encourage recycling,   osw is also studying current  State battery
recycling programs,  and will develop  and distribute information
on the proper implementation of cost-effective, environmentally
sound lead-acid battery recycling.


OFFICE OF TOXIC SUBSTANCES (OTS)

Toxic Substances Control Act (TSCAi

     TSCA Lead Pollution Prevention Plan

     The use of lead in products presents two  types of exposures:

          exposures that occur from specific lead products during
          or immediately following production  or  use;  and
          potential exposures that might occur from any lead-
          bearing product at some time in the  future after
          disposal.

     OTS has two regulatory objectives with  respect to each type
of exposure if they present unreasonable risks.   In the first
instance, OTS intends to (1) prevent  new uses  of  lead, and (2)
limit or, if appropriate ban, current uses of  lead, if they
present an unreasonable risk of injury to human health or the
environment due to exposures generated during  production or use.

     For the second type of exposure, OTS plans to  (1) encourage
environmentally sound recycling of essential products which
contain lead as essential component   (e.g.,  lead acid storage
batteries), and (2) explore the desirability and  feasibility of
discouraging overall consumption of  lead  in  general.

     Traditional pollution control rules,  as well as pollution
prevention efforts to reduce the amount of  lead generated
(including economic incentive or market-based approaches) may be
suitable ways of addressing these exposures.  OTS will examine
both benefits and costs of possible actions, including an
analysis of materials which would be substituted for lead in
specific products.  OPPE is working closely with OTS to evaluate
these alternative approaches.

     Prevention of new uses of lead nosing unreasonable risks

     While new lead uses continue to be developed,  they are not
subject  to EPA scrutiny prior to commercial production.  OTS  is
considering rulemaking to require advance notice from anyone
intending to manufacture or process  lead for a new use, in order
to ensure that these uses do not pose unreasonable risks.  Tnls
would afford EPA an opportunity to review the intended  new use
and, where risks are unreasonable, to either limit or ban it.


                                27

-------
     Phase-out  of  current uses of lead posing unreasonable risks

     Several uses  of  lead that generate risk during use may be
candidates  for  bans or restrictions under several Federal
statutory authorities.   OTS will perform a regulatory
investigation on these uses, considering the benefits of each
product relative to the risks, in order to determine if the risk
is  "unreasonable"  and should be regulated under TSCA.  Uses
currently under consideration for a ban or restriction under TSCA
include:

          brass and bronze plumbing fittings and fixtures
           (scheduled  proposal January 1992),
          lead  solder used to join water pipes (scheduled
          proposal January 1992), and
          lead  in  non-residential paint.

This list may be expanded in the future.

     Battery recycling

     In 1989, 1,012,155 metric tons of lead, approximately 80
percent of  total domestic consumption, went into batteries.
Because of  the  amount of lead involved, EPA is considering a rule
to  increase and maintain the rate of battery recycling, in order
to  reduce risks due to lead discarded in the environment and to
primary lead mined.

     Somewhere  between 80 to 95 percent of spent batteries are
currently recycled; however, lead acid batteries still comprised
65% of all  lead in municipal solid waste in 1988.  In addition,
if  the price of lead  again falls, the market may not support even
the current recycling rate.  OTS is considering a rule to
encourage battery  recycling in an environmentally sound manner,
and to sustain  high recycling rates through world market price
fluctuations.   This rule is scheduled to be proposed in October
1991.  EPA  is involved in a regulatory negotiation, scheduled to
run through April  1991,  to determine the best methods to
encourage maximum  recycling.

     The regulatory negotiation is considering a variety of
approaches, including requiring battery manufacturers to include
some specified  fraction of recycled lead in the total amount of
lead they need  to  produce new batteries; require the battery
distribution chain to accept any spent batteries returned for
recycling; a combination of both approaches, or another
mechanism.  This rule is particularly amenable to a market-based
approach using  economic incentives,  and this option is being
jointly explored by OPPE and OTS.
                                28

-------
     Additional potential restrictions of lead

     OTS plans to publish an ANPR in 1991 under TSCA which will
begin the process of examining the feasibility  and desirability
of additional restrictions on lead—If OTS determines that the
risks of lead use are unreasonable,  this will be followed by a
Notice of Proposed Rulemaking (NPR)  with proposed regulatory
remedies.  A variety of TSCA §6(a) rules are possible,  including
rules that would restrict general consumption of lead or provide
economic incentives for reducing lead use, based on a balancing
of the benefits to society of such reductions against their
associated costs.

     Final risk management decisions regarding  the entire TSCA
lead regulatory program will be made after consideration of
comments received on the ANPR, status of other  rules, and
evaluation of an economic incentives analysis.


OFFICE OF AIR QUALITY PLANNING AND STANDARDS fOAOPSl

Background
     The current lead NAAQS was set in 1978 at 1.5
quarterly average.  EPA's 'primary mechanism for attaining the
NAAQS has been the reduction of lead in gasoline.  In addition,
lead emissions from industrial sources have been substantially
reduced by State Implementation Plans (SIP's) designed to attain
the particulate matter and lead NAAQS.  Further reductions have
also resulted from the New Source Performance Standard (NSPS) for
smelters.  In combination, these control programs have resulted
in major reductions in air lead and in children's PbB.  Available
data indicate that the lead NAAQS is being attained in all areas
except those near lead smelters, refineries and remelters.  In
these areas, exposures are due both to current emissions and to
resuspension of soil contaminated by past emissions.  OAQPS has
developed a compliance strategy to bring these areas into
attainment.

Strategy for achieving attainment of the current lead NAAQS

     Twenty-nine sources  (four primary smelters, 23 secondary
smelters, one lead refinery and one lead remelter) have been
identified under OAR's attainment strategy.  Monitoring data from
the sources with monitors indicate that 10 of the 11 do not
attain the current NAAQS.  Fifteen other smelters had modelled
violations.

     Non-attainment is due ..either -to non-compliance with SIP
emission limits, or to insufficient SIP emission limits which
would not result in attainment of the NAAQS even with full
compliance.  Bringing an area into attainment with the NAAQS
                                29

-------
typically involves three steps: (a) monitoring air quality,  (b)
developing control plans (SIP requirements),  and (c)  enforcing
those regulations.  However, in developing SIP requirements,  a
series of estimates must be made to determine the emission
reduction needed to attain the NAAQS.  Because of uncertainties
in such estimates, some areas might not attain the_NAAQS even
when all sources in the areas are in compliance with their SIP
requirements.  When this occurs, EPA can initiate a SIP revision.

     Because the 42 facilities in the OAQPS Extended Exposure
Analysis affect only their immediate vicinity, the number of
children at risk is small compared to the number of children at
risk from LBP, contaminated urban soil or drinking water.
However, non-attainment of the NAAQS adds significantly to the
PbB level of these children.  OAQPS estimates that the number of
children near these facilities with PbB greater than 10 Mg/dl
would be reduced about 50 percent, from approximately 800 to 400,
if the current NAAQS was attained in all areas of the country.

     OAQPS's lead NAAQS attainment strategy, approved by the
Deputy Administrator, contains four activities:

1.   Expand monitoring to all 29 large lead sources.

    . An expanded ambient monitoring initiative is underway to
     provide the necessary ambient monitoring database near
     stationary lead sources.  Ambient monitoring networks will
     be initiated near each of the sources, and initial ambient
     air data analyses should be complete by June 30 > 1991.

2.   Conduct Federal inspections of all 29 sources.

     As scheduled, the Regions completed  inspections of each of
     the 29 sources by December 31,  1990.  Approximately six of
     these sources were  found  to be  in violation.

3.   Implement  "leveraged  enforcement" by  coordinating with other
     program offices  (multi-media  approach).

     OAQPS has  asked the Regions to develop enforcement actions
     by January 31,  1991;  negotiate multi-media consent
     agreements by October 30,  1991;  and  achieve emission
     reductions expeditiously  thereafter.

4    Designate, or  require States  to  designate, non-attainment
     areas with respect  to the lead  NAAQS, and to require SIP
    . revisions  for  these areas.

     EPA began  the  designation process, in October 1990;  States
     must  respond by February  1991,  and designations will be
     final by June  1992.   Revised  SIP's will  be due  by  the  end of
     1993, and  attainment of  the NAAQS  is expected by mid-1997.
                                30

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     NAAOS review
     The Clean Air Act (CAA)  requires  that  EPA review the NAAQS
every five years and make any appropriate revisions.   The
scientific and technical assessment -portion of the lead NAAQS
review was completed in January 1990,  when  the Clean  Air
Scientific Advisory Committee gave final  closure on the lead
Staff Paper and the supplement to the  Addendum to the Criteria
Document.  CASAC concluded that: (a) EPA  should set a NAAQS that
minimizes the number of children with  PbB greater than 10 fig/dl,
(b) a NAAQS at the upper end of the range under consideration
(l o to 1.5 ng/m3)  offers little if any margin of  safety,  and (c)
populations not quantitatively analyzed in  EPA exposure modelling
should be considered for setting a margin of safety on the NAAQS.
CASAC also asked EPA to examine a NAAQS of  0.25 Mg/m3,  if only to
provide perspective on the higher alternatives.

     OAQPS has analyzed the effect of NAAQS revisions by
reviewing 42 lead point sources — the 29 sources identified  for
the NAAQS attainment strategy, and 13 other sources that are  not
currently being pursued under the attainment strategy, but which
may 'be in non-attainment if the NAAQS is lowered.  OAQPS has
estimated the number of children living near these sources who
would have PbB greater than 10 fig/dl at each of the alternative
NAAQS levels, and at background air lead concentrations.  .
Approximately 126,000 children  live near these sources.  The
results shown on the following  table should not be interpreted  as
the absolute number of children at risk of elevated PbB  from
point source emissions because  (1) they are based on  a sample of
sources, and  (2) they do not specifically  reflect the  exposure
characteristics of children living in homes with  deteriorating
LBP or children with an unusually  strong tendency to  ingest  non-
food  items.   In addition,  the  results do not -represent the  risks
faced by other  sensitive groups such  as pregnant  women (for
fetuses) and  adult men.  However,  the results are useful for
comparing the relative  protection  afforded by alternative
standard levels.


         Estimated Number of Children Exceeding 10 /ig/dl
                  nndar Alternative NAAOS Situations
            alternatives            No.  children with PbB
                                           than 10 tiq/dl*
 1.5 Mg/m?  quarterly,  today                    JOO
 1.5 Mg/m3  quarterly,  enforced                 «°°
 0.75 »q/-n? monthly                            •""
 0.25 yg/m3 monthly                            ""
 Background (0.10 jig/m*)                       ««   i-v«n
      (Assuming water level = 8 ng/1,  constant soil level)
      (* - rounded to the nearest 50)
                                 31

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As the table shows, enforcing the current NAAQS would provide a
greater incremental public health benefit than any of the
contemplated NAAQS revisions.  Most of the public health
improvements would be near primary and secondary smelters.

     While cost and technological feasibility are not to be
considered in setting NAAQS, impacts on both primary and
secondary smelters have implications for the broader integrated
lead strategy.  If none of the operating primary smelters could
attain the NAAQS level selected during the Agency's review with
readily available control technologies, the domestic primary
smelting industry may simply shut down.  This could result in
increased importation of primary lead from countries with less
stringent standards.  Should such smelters close, they could be
potential Superfund sites due to past contamination.  In
addition, impacts on secondary smelter capacity have implications
for EPA's efforts to promote environmentally sound battery
recycling, and are discussed in the following section on that
topic.

Secondary Smelter NSPS                                           '
                        *                                          «!
     As part of the lead Pollution Prevention Program, OAQPS is
initiating work on a revised NSPS for secondary smelters to
ensure that new or reconstructed secondary smelters continue to
apply best demonstrated control technology.  New sources also
must demonstrate compliance with the lead NAAQS.  The analysis
for this revision will consider the feasibility of performance
standards based on alternative smelting technologies that would
reduce lead discharges to other media as well as air.


OFFICE OF PESTICIDE PROGRAMS  fOPP^

     The last known use of  lead as a pesticide active ingredient
(lead arsenate for use on grapefruit) was voluntarily cancelled
in  1989, generally due to concerns about the arsenate.  EPA is
currently revoking the associated tolerance levels.

     OPP found lead as an inert ingredient in 13 pesticide
products.  As a result of this discovery, OPP issued data call-in_
notices to all of the registrants of these products.  Out of the
13  products,  11 have been cancelled, one has been reformulated
without lead, and one is pending cancellation, since the
registrant has not responded to OPP's request.

     OPP believes these actions have removed lead from pesticide
products.  There is, however, one possible area, for additional
action, and that involves active ingredients registered before
1984.  OPP is undertaking a review of pesticides registered prior
to  1984, in order to discover if any contain lead as an active

                                32

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ingredient.  If OPP finds lead as an active ingredient,  it will
initiate appropriate regulatory action.


DfFICE OF WATER REPUTATIONS AND STANDARDS fQWRS)

ri^p Water Act

     EPA estimates that sewage sludge contributes less than 0.05
percent to total high hazard lead exposures, and virtually all of
this occurs with incineration of sludge.

     Section  §405(d) of the Clean Water Act (CWA) requires EPA to
propose and promulgate regulations establishing numeric limits
?nd management practices regarding sludge that are adequate to
protec? public health and the environment from any reasonably
anticipated adverse  effects of each pollutant.  Currently, EPA
?AO CFR Part  257)  regulates the  land disposal of sewage sludge
from publicly and  privately owned treatment works.  EPA has:also
proposed a rule  under the Resource Conservation and Recovery Act
P(lc^) and the CWA which would establish standards for the co-
disposal of  sewage sludge  in  municipal  solid waste landfills.

     Because  Part  257  covers  only a  limited number of pollutants
    use  and  disposal practices  (land application and

                                                   r
 ,ir,Hor 40 CFR Parts 501 (issued in nay i»o»;  «mu  ->«-'  \~	















 control  of  the  POTW.
         Of FNFQRCEM^NT fOE)

                                  33

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     OE is assisting in coordinating inspections and analysis of
data collected from major sources of lead emissions.  One focus
will be the use of the CAA to reduce air emissions of lead from
primary and secondary lead smelters, with an emphasis on
compliance with SIP lead emission.limits.  This is discussed
further in the section on OAQPS activities.  OE will also focus
on violations of lead limits in NPDES permits for industrial and
municipal vastewater discharges and pretreatment requirements for
industrial users of municipal vastewater treatment systems.  Some
RCRA actions likely will be brought against primary and secondary
lead smelters.  Other offices are also exploring the possibility
of developing lead cases in other media.  A national filing of
enforcement actions against sources of lead emissions is expected
in early July 1991.

     The publicity surrounding this effort will highlight the
significance of this cluster filing and also to underscore the
Agency's commitment to improving regulatory compliance and
dealing with lead problems.          .
                                34

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                           APPENDIX I
                      GLOSSARY OF ACRONYMS
ANPR      Advance Notice of Proposed Rulemaking
ATSDR     Agency for Toxic substance and Disease Registry
CAA       Clean Air Act                  ._,.
CASAC     Clean Air Science Advisory Committee
CDC       centers for Disease Control
CERCLA    Comprehensive Environmental Response,  Compensation, ana
               Liability.Act
CPSC      consumer Product Safety Commission
CWA       Clean Water Act
EBL       Elevated Blood Lead
HUD       Department of Housing and Urban Development
LBP       Lead-Based Paint
LBPPPA    Lead-Based Paint Poisoning Prevention Act
LCCA      Lead Contamination Control Act
LEAP      Lead Education/Abatement Program
MCL       Maximum Contaminant Level
NAAQS     National Ambient Air Quality Standard
NIST      National Institute of Standards and Technology
NPL       National Priority List
NPRM      Notice of Proposed Rulemaking
NSPS      New Source Performance Standard
OAQPS     Office of Air  Quality Planning and Standards
ODLC      Office Directors Lead Committee
ODW       Office of Drinking Water
OE        Office of Enforcement
OERR      Office of Emergency and Remedial Response
OPP       Office of Pesticide Programs
OPPE      Office of Policy,  Planning and Evaluation
ORD       Office of Research and Development
osw       Office of Solid Waste
OSWER     Office of Solid Waste  and Emergency Response
OTS       Office of Toxic Substances
OWRS      Office of Water Regulations and  Standards
PbB       Blood Lead
RCRA      Resource Conservation  and Recovery  Act
SARA      Superfund Amendments and Reauthorization Act
SDWA       Safe Drinking Water Act
SIP       State implementation Plan (OAQPS issues)
                            or
           Structural Integrity  Procedure (OSW issues)
 SNUR      Significant New Use Rule
 TCLP      Toxic Characteristic  Leaching Procedure
 TSCA      Toxic substances Control Act
 USDA      U.S. Department of Agriculture
 jig/dl     Micrograms per Deciliter
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                           APPENDIX  II
         CASE STUDY IN COORDINATION:  THE  BATTERY  CLUSTER


     Maintenance of environmentally-sound lead  recycling capacity
— to prevent batteries from being discarded in the environment,
to reduce the need to mine and smelt new  lead,  and to reduce lead
concentrations near smelters to an acceptable level ~ is an
important part of this lead strategy.   A  number of regulations
have been identified in this document which could affect the
recycling of lead acid batteries.

     The secondary smelting industry is essential to the
continued availability of domestic battery recycling.  The
increased costs of pollution control associated with safe
recycling could result in a significant part of this industry
choosing to close rather than to install  necessary equipment.
Losses of this domestic recycling capacity could  result in a net
increase in risks to human health and the environment due to
lead,-because of the increased need  to  introduce  primary lead
into the domestic market, and other  consequences  based on the
international market.

     To avoid this outcome, the group of  regulations affecting
battery recycling (and smelter operation) were  clustered so that
they could be considered in a cohesive  EPA plan to address lead
exposures and encourage environmentally sound battery recycling.

Background

     In 1989, approximately 80 percent  of total domestic
consumption of lead went into batteries.   Although 80 to 95
percent of spent batteries are currently recycled, batteries
still comprised 65 percent of all lead  in municipal solid waste
in 1988.  EPA wants to encourage increases in the recycling rate.
Further, the price of lead has fluctuated over  time.  If the
price falls again, the market may not support even the current
recycling rate.            .                                    .

     Several regulations, policy determinations,  and programs
have been grouped together as the "Battery Cluster":

     *    Municipal Solid Waste Landfill Materials Separation
          ANPR  (under consideration), possibly  addressing
          batteries  (OSW);

     *    Lead Acid Battery Recycling Proposed  Rule, considering
          alternative battery recycling strategies  (OTS);

     *    Proposed Revision of National Ambient Air Quality
          Standard (NAAQS) for lead, possibly requiring  smelters


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          to meet more stringent air emission requirements
          (OAQPS);

     *    Proposed Revision to NSPS for Secondary .Smelters
          (OAQPS);

     *    Regulatory Determination on Mineral Processing Wastes
          for Lead Slag, possibly requiring primary smelters to
          meet RCRA Subtitle C requirements (OSW);

     *    Land Disposal Restrictions ("Land Ban"): the "third-
          third" rule, including lead disposal and storage
          requirements for smelters (OSW - promulgated June 2,
          1990) ;

     *    Revisions to Toxicity Characteristics for Hazardous
          wastes (TCLP) (OSW - promulgated March 29, 1990}; and

     *    Lead NAAQS Attainment Strategy/Smelter Compliance Plan,
          forcing smelters to meet lead air emission requirements
          of the current NAAQS (OAQPS - ongoing).

     An ad hoc Task Force, chaired by OTS, assessed and made
recommendations regarding the appropriate sequence and collective
impact of the several impending decisions that could adversely
affect secondary smelting capacity.  The task force consists of a
subset of offices which have been directly involved in
development of this strategy.  The workgroup developed a
regulatory plan,  described below, outlining their
recommendations.

Effects of Regulations

     Many of these programs could affect the economic viability
of smelters.  The Land Ban, the TCLP, and downward revision of
the lead NAAQS are all factors which could reduce the
profitability of secondary smelters, causing owners to close the
facilities or cut back production.  Even enforcing the existing
NAAQS could affect existing recycling capacity.  Secondary
smelters, however, are also recyclers of batteries and other lead
scrap — a very important component of the lead strategy.  In
addition,  due to the international nature of the smelting
industry, there are a number of other potential consequences that
must be considered, including a reduction in domestic lead
production and increased foreign production.

     The Agency is considering all of the various linkages among
potential actions affecting battery recycling.  The regulatory
investigations now.planned or underway may or may not result in
rules, but EPA wants to be sure that it considers in advance the
consequences of each possible rule on the others,  and on the lead
industry as a whole.

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      From the list of actions  outlined above, several could have
particularly important effects on  the industry.  For example,
OAQPS analyses indicate that a revised NAAQS, if adopted, would
have  an  impact on domestic secondary smelting, or recycling,
capacity.   A TSCA rule addressing  battery recycling could provide
an  incentive to continue smelter operation.  If the Agency were
to  pursue restrictions on battery  disposal, that also may
encourage recycling.   Another  important action under review is a
Regulatory Determination that  may  require primary smelters to
comply with RCRA Subtitle C for lead slag.  If EPA decides
Subtitle C is applicable,  it could have significant effects on
the economic viability of the  domestic primary smelting industry.
If  less  primary lead  were available, recycling would become more
economically viable.

      Other policies and actions outside the Agency, such as some
State requirements for battery recycling, could either promote or
counteract the effects of actions  EPA is investigating.

      This cluster of  recent and impending regulatory decisions —
if  carefully considered and coupled with a pollution prevention
policy — could conceivably encourage the smelting industry to
adopt new technologies that ..would  provide more efficient and
cost-effective means  of complying  with the set of regulations.

Description of Cluster Product

      Agency offices are working on a consolidated plan which is
designed  to meet virtually all of  the program-specific goals of
each  regulation to address lead releases into a particular medium
and at the same time  address the unacceptable risks from lead
across Agency programs.

      The  rules and programs included in the Battery Cluster are
listed above and are  being coordinated among program offices.
Coordinating the goals,  programs,  and schedules of the
participating offices will (1)  improve the potential
effectiveness of individual programs by reinforcing their goals
through  language in rules developed by other offices, and (2)
help  achieve the Agency's goals in encouraging the continued
availability of environmentally sound recycling capacity for lead
acid  batteries.   Specifically,  the following coordination will
occur between program offices,  and is an example of the type of
coordination necessary when dealing with a ubiquitous pollutant.
Obviously,  plans and  schedules for specific rules may change as
the Agency analyzes regulatory alternatives and applicable costs
and benefits.

      There are several linkages that EPA has identified.  For
example,  the third potential regulation on the list is the lead
NAAQS  revision.   If EPA lowers the NAAQS for lead, the new
standards  will  not be in place until well after decisions are

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made on the other actions in the cluster.   However,  the
date of any NAAQS revision would signal the ««lting


 and ensure safe recycling
             offices will continue coordination as ••=*» °* th*
cSnslidated Agenc  action to reduce risks
                                                 lead.
                                                         - -
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