UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8 1595WYNKOOP STREET DENVER, CO 80202-1129 Phone 800-227-8917 http://www.epa.gov/region08

8P-AR 

# :JUN 14 2011

Richard Opper, Environmental Director Montana Department ofEnvironmental Quality PO Box 200901 Helena, Montana 59620-0901

DearMr. Opper:

Thankyou for your recommendations on airquality designations for the revised National Ambient Air Quality Standards for lead throughout Montana. This letter is to notify you ofthe U.S. Environmental Protection Agency's (EPA's) preliminary decision to designate all of Montana as attainmentlunclassifiable, and to inform you ofour approach for completing the designations for the revised lead standards. Reducing levels oflead pollution is an important part ofthe EPA's commitmentto a clean, healthy environment. Lead exposure cancause 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 AmbientAir Quality Standardby**lowerin~** it from 1.5 micrograms per cubic meter (flg/m3) - a level set in 1978

- to a level of0.15 flg/m

.This stronger standard provides increasedprotection against adverse health effects associated with exposure to lead in at-risk groups, including children. To provide increased protection against lead-related environmental and otherwelfare effects, the EPA revised the secondaryNational 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 whethermany areas are meeting the revised lead standard and established newcriteria for siting ambient lead monitors and newdata collectionrequirements. Monitors meeting the newnetwork siting requirements
were to begin operation January 1,2010.

Within two years ofpromulgating new orrevised National Ambient Air Quality Standards, the Clean AirActrequires the EPA to complete the initial process ofidentifying ordesignating areas that meet ordo not meet an air quality standard. Ifthe 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 ofthe new monitoring network, the EPA is completing the lead designations in two rounds. In the first round, published onNovember 16, 2010, the EPA designated as "nonattainment" 16 areas as violating the 2008 LeadNational Ambient Air Quality Standards based on data from the pre-201O monitoring network. For all otherareas, the EPA extendedthedeadline for designations by up to one year so that datafrom the newly deployed monitors can be considered in making appropriate designation decisions. States were given an opportunity to update theirrecommendation letters for those remaining areas for our consideration in the second round ofdesignations by December 15,2010. The EPA intends to complete the second round of lead designations by no laterthan October 14, 2011.

Consistent withthe Clean Air Act, and after carefully considering Montana's September 30, 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 proposingto designate Montana as unclassifiable/attainment. The EPA uses this designation for initial designations to identify areas that have data indicating attainment, or where there is no evidence ofa violation.

Ifyour state has additional information that the EPA should consider withrespect to our proposed modification to your designation recommendation, please submit it to us by August 15, 2011. The EPA'spreliminary designation decisions and supporting documentation will be made available to the general public for review. We will be accepting comments through August 15, 2011. We will review any informationwe receive from the state ofMontana and the general public by this date, and we planto promulgate the second round offinal designations by October 14, 2011.

We look forward to a continued dialogue withyou and your staffas we work together to implement the 2008 LeadNational Ambient Air Quality Standards. Should you have any questions, please do not hesitate to call me, orhave your staffcontact Carl Daly ofmy staffat (303) 312-6416.

Sincerely,

cc: Dave Klemp, Bureau Chief Air and Waste Management Bureau

Gina McCarthy, Assistant Administrator for Air and Radiation Steven D. Page, Director, Office ofAir Quality Planning and Standards