UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


REGION 10 


1200 Sixth Avenue, Suite 900 

Seattle, Washington 98101-3140 

OFFICE OF THE 

REGIONAL ADMINISTRATOR 

JUN 13 2011 

The Honorable Christine Gregoire 

Governor ofthe State ofWashington 

Post Office Box 40002 

Olympia, Washington 98504-0002 

Dear Governor Gregoire: 

Thank you for your recommendations on air quality designations for the revised National 

Ambient Air Quality Standards for lead throughout Washington. This letter is to notify you of 

the U.S. Environmental Protection Agency's preliminary decision to designate all of Washington 

as unclassifiable/attainment and to inform you of our approach for completing the designations 

for the revised lead standards. Reducing levels oflead pollution is an important part ofthe EPA's 

commitment to a clean, healthy environment. Lead exposure can cause a range of adverse health 

effects, most notably in children. Exposures to low levels oflead early in life have been linked to 

effects on IQ, learning, memory, and behavior. 

On October 15,2008, the EPA substantially strengthened the health-based or "primary" National 

Ambient Air Quality Standard by lowerinf it from 1.5 micrograms per cubic meter (llg/m3) - a 

level set in 1978 - to a level of0.15 Ilg/m . This stronger standard provides increased protection 

against adverse health effects associated with exposure to lead in at-risk groups, including 

children. To provide increased protection against lead-related environmental and other welfare 

effects, the EPA revised the secondary National Ambient Air Quality Standard to be identical in 

all respects to the revised primary standard. The EPA also determined that the pre-existing 

ambient lead monitoring network was inadequate for determining whether many areas are 

meeting the revised lead standards and established new criteria for siting ambient lead monitors 

and new data collection requirements. Monitors meeting the new network siting requirements 

were to begin operation January 1, 2010. 

Within two years ofpromulgating new or revised National Ambient Air Quality Standards, the 

Clean Air Act requires the EPA to complete the initial process ofidentifying or designating areas 

that meet or do not meet an air quality standard. If the Administrator has insufficient information 

to make these designations, the EPA has the authority to extend the designation process by up to 

one year. In light of the new monitoring network, the EPA is completing the lead designations in 

two rounds. In the first round, published on November 16, 201 0, the EPA designated as 

"nonattainment" 16 areas as violating the 2008 Lead National Ambient Air Quality Standards 

based on data from the pre-201 0 monitoring network. For all other areas, the EPA extended the 

deadline for designations by up to one year so that data from the newly deployed monitors can be 

considered in making appropriate designation decisions. States were given an opportunity to 

update their recommendation letters for those remaining areas for our consideration in the second 
round of designations by December 15, 2010. The EPA intends to complete the second round of 

lead designations by no later than October 14, 2011. 

Consistent with the Clean Air Act, and after carefully considering Washington's October 16, 

2009, recommendation letter and all the associated technical information for the 2008 Lead 

National Ambient Air Quality Standards, including the most recent air quality data from 2008­

2010, the EPA is proposing to adopt Washington's recommended designation and boundary. 

We look forward to a continued dialogue with you and your staff as we work together to 

implement the 2008 Lead National Ambient Air Quality Standards. Should you have any 

questions, please do not hesitate to call me, or have your staff contact Mr. Steve Body at (206) 

553-0782 

q~,~ Dennis J. McLerran 

Regional Administrator 

cc: 	 Ted Sturdevant 

Director, Washington State Department ofEcology 

Stu Clark 

Air Program Director, Washington State Department of Ecology 

Gina McCarthy 

Assistant Administrator for Air and Radiation, EP A 

Steve D. Page 

Director, Office ofAir Quality Planning and Standards, EPA