Comment submitted by J. Morian

U.S. Environmental Protection Agency Air and Radiation Docket and Information Center Mail Code 2822T 1200 Pennsylvania Ave., NW Washington, DC 20460 Attn: Docket ID No. EPA-HQ-OAR-2006-0735 E-mail: a-and-r-Docket@epa.gov Re: EPA-HQ-OAR-2006-0735, Proposed Rule Concerning Revisions to Lead Ambient Air Monitoring Requirements 74 Fed. Reg. 69,050. I live in Missouri, the leading state for lead mining and home to North America's largest primary lead smelter. I am concerned about the air quality of our residents, particularly in light of increasing evidence that exposure to certain pollutants like lead may contribute to dementia in older individuals. The Clean Air Act requires the EPA to protect the public health by setting National Ambient Air Quality Standards for lead. These standards accomplish nothing unless there is sufficient monitoring for compliance with the NAAQS. Without sufficient monitoring, children and pregnant women, who are particularly sensitive to lead, are not protected with an adequate margin of safety. I support EPA's proposed half-ton per year threshold for monitoring. The EPA’s final rule on lead NAAQS indicated that an ambient standard of 0.15 µg/m3 of lead is required to protect public health with an adequate margin of safety. Only a monitoring threshold of 0.5 tons per year will enable the agency to ensure compliance and the technical data supports this. A one ton per year standard is arbitrary and the figure is not rationally supported by the technical data underlying the .5 ton standard. There is no safe level of lead exposure for children, and children will not be protected without adequately monitoring and enforcing the NAAQS. I also ask that the EPA be required to attach specific conditions to any waivers of the source-oriented monitoring requirements for lead, and that these be sufficiently strict to limit their use. Thank you, Julie Morian, 2112 Del Norte Ave. Richmond Heights, MO 63117