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STATE OF UTAH t~/'(/$ !J,r.L"rf.."" 

GARY R. HERBERT OFFICE OF THE GOVERNOR GREG BELL 

GOVERNOR SALT LAKE CITY, UTAH LIEUTENANT GOVERNOR 

84114-2220 

October 12, 2009 

Carol Rushin, Acting Regional Administrator 

U. S. Environmental Protection Agency, Region 8 

1595 Wynkoop Street 

Denver, CO 80202-1129 

Dear Ms. Rushin: 

The revised national ambient air quality standards (NAAQS) for lead promulgated 

in October 2008 require that by October 15,2009, states make recon1n1endations to the 

Environmental Protection Agency for areas to be designated attainment, nonattainment, 

or unclassifiable based on ambient lead monitoring data collected between 2006-2008. 

The State of Utah recommends that all 29 counties in Utah be designated 

unclassifiable for the primary and secondary lead standards. With approval from EPA 

Region 8, the State has not monitored for lead in the an1bient air since September 2005. 

Lead monitoring was halted because measured levels of lead were extremely low relative 

to the former primary and secondary lead standards (1.5 ~g/m3 quarterly average). 

Consequently, insufficient information is available to determine the current attainment 

status of each area of Utah. If a violation ofthe lead standard is measured at any lead 

monitoring site before EPA issues its final designations, the State will submit a revised 

recommendation to the Agency as expeditiously as possible. 

We look forward to working with you and your staff to implement the revised 

lead standards in Utah. Should you have questions, please contact Cheryl Heying, 

Director, Utah Division of Air Quality, (801) 536-4022. 

RECEIVED 

U.S. EPA Region 8 ,.(; A ",,' RA's OffIce 

\; ...,.' ~.<7 'f '. e, ~;:>- ;/ '... s-ti5'·"·'~l Gary R. Herbert 

Governor OCT 132009 

Enclosure 
Overview of Lead Monitoring Data in Utah 

The EPA has revised the level of both the primary and secondary lead NAAQS to 0.15Ilg/m3 to 

improve health protection for at-risk groups, especially children. An area is considered in 

compliance with the revised lead standard if measured lead concentrations do not exceed 

0.15Ilg/m3 during a rolling three-month averaging period evaluated over three years. Table 1 

shows lead values averaged over rolling three-month periods at the Magna site (AIRS code: 49­

035-1001) for the most recent three-year monitoring period (2002-2005). Each lead sample was 

collected over a 24-hour sampling period (from midnight to midnight) every sixth day at the site. 

On average, 15 samples were collected during each three-month averaging period. Magna is the 

only site where ambient lead concentrations were measured in the State's air monitoring network 

during the past five years. No additional lead monitoring data have been collected in the State by 

the EPA, local, or tribal agencies during this period and submitted to EPA's national database, 

AQS. 

Table 1: Rolling Three-Month Averaged Lead Concentrations Measured at Magna Site from 

October 2002 to September 2005, in Jlg/m3 

Period Pb 

Conc.* 

Period Pb 

Conc.* 

Period Pb 

Conc.* 

Aug-Oct 02 .03 Aug-Oct 03 .04 Aug-Oct 04 .02 

Sep-Nov 02 .04 Sep-Nov 03 .04 Sep-Nov 04 .04 

Oct-Dec 02 .04 Oct-Dec 03 .06 Oct-Dec 04 .06 

Nov 02-Jan 03 .07 Nov 03-Jan 04 .07 Nov 04-Jan 05 .09 

Dec 02-Feb 03 .07 Dec 03-Feb 04 .08 Dec 04-Feb 05 .10 

Jan-Mar 03 .06 Jan-Mar 04 .07 Jan-Mar 05 .08 

Feb-Apr 03 .03 Feb-Apr 04 .04 Feb-Apr 05 .05 

Mar-May 03 .02 Mar-May 043. .04 Mar-May 05 .02 

Apr-Jun 03 .02 Apr-Jun 04 .02 Apr-Jun 05 .02 

May-Jul03 .02 May-Jul04 .02 May-Jul05 .02 

Jun-Aug 03 .02 Jun-Aug 04 .02 Jun-Aug 05 .02 

Jul-Sep 03 .02 Jul-Sep 04 .02 Jul-Sep 05 .02 

* Three-month rolling averages are rounded to two decimal places as required by federal regulations. 

None of these three-month rolling averages exceeds the revised lead standard. The highest threemonth average occurred between December 2004 and February 2005 when the 15 collected 

samples averaged 0.1 OJlg/m3

• 1989 was the last time an average lead level of 0.15 Jlg/m3 

was 

measured at the site during any three-month period. The lead monitors were removed from 

Magna at the end of September 2005 because ambient concentrations of the pollutant were 

consistently low relative to the existing primary and secondary lead standards. Monthly lead 

concentrations had averaged less than one-tenth ofNAAQS over a IS-year monitoring period at 

the site (1990-2005). Nationally and locally, lead levels in the ambient air have been reduced 

dramatically in the past three decades. UDAQ's former monitoring station in downtown Salt 

Lake City showed a 970/0 decrease in ambient air lead measured over an I8-year monitoring 

period (1982-1999), mirroring national trends. These dramatic reductions are attributable to 

EPA's lengthy regulatory efforts to remove lead from gasoline (1973-1996).