EPA-450/5--88-003
NATIONAL AIR TOXICS
INFORMATION CLEARINGHOUSE
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
State and Territorial Air Pollution Program Administrators
Association of Local Air Pollution Control Officials
Case Studies in
Risk Communication
June 1988
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DON No. 88-239-001-38-11
EPA Contract No. 68-02-4330
Work Assignment No. 38
EPA-450/5-88-003
NATIONAL AIR TOXICS INFORMATION CLEARINGHOUSE:
CASE STUDIES IN RISK COMMUNICATION
FINAL REPORT
Prepared for:
Karen L. Blanchard
Work Assignment Manager
Emission Standards Division
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Prepared by:
Radian Corporation
3200 Progress Center
Post Office Box 13000
Research Triangle Park, North Carolina 27709
June 1988
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DISCLAIMER
This report has been reviewed by the Office of Air Quality Planning and
Standards, U. S. Environmental Protection Agency, and approved for
publication as received from Radian Corporation. Approval does not signify
that the contents reflect the views and policies of the U. S. Environmental
Protection Agency, nor does mention of trade names or commercial products
constitute endorsement or recommendation for use.
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PREFACE
The EPA is supporting State and local agency air toxics control efforts
by organizing and operating an information dissemination center, known as
the National Air Toxics Information Clearinghouse. The EPA established the
Clearinghouse in response to requests for assistance from State and local
agencies concerned about control of toxic air emissions. The Clearinghouse
is composed of a computerized data base which contains indexed information
on toxic and potentially toxic air pollutants, "hard copy" reports of
information from the data base, several special reports such as this one,
and a bimonthly newsletter. The Clearinghouse has been designed and is
being operated in close coordination with the State and Territorial Air
Pollution Program Administrators (STAPPA) and the Association of Local Air
Pollution Control Officials (ALAPCO).
This report documents the risk communication experience of three
agencies. Case studies are presented describing the experience of the Puget
Sound (Washington) Air Pollution Control Agency and the San Diego County
(California) Air Pollution Control District in communicating the results of
source-specific cancer risk assessments. Routine risk communication
practices rather than a specific case study are presented for Maryland's
Department of the Environment. This report is intended to be most useful to
State and local agencies just beginning to do quantitative cancer risk
assessments, and seeking to benefit from the risk communication experience
of others.
Shortly before this report went to press, the EPA project officer
became aware of a relevant paper entitled "Seven Cardinal Rules of Risk
Communication," by Vincent Covello (Director of the Center of Risk
Communication at Columbia University) and Fredrick W. Allen (Associate
Director of EPA's Office of Policy Analysis). This information may be
useful to State and local air pollution control agencies interested in risk
communication, and therefore was added to this report as an appendix. It
will soon be published as a pamphlet by EPA's Office of Policy Analysis
within the Office of Policy, Planning, and Evaluation.
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Other Clearinghouse publications include:
National Air Toxics Information Clearinghouse: Rationale for Air
Toxics Control in Seven State and Local Agencies,
EPA-450/5-86-005, NTIS: PB86-181179/AS, August 1985;
National Air Toxics Information Clearinghouse: How The
Clearinghouse Can Help to Answer Your Air Toxics Questions,
EPA-450/5-86-009, NTIS: PB88-157813/AS, July 1986;
National Air Toxics Information Clearinghouse: Methods for
Pollutant Selection and Prioritization, EPA-450/5-86-010,
NTIS: PB87-124079/AS, July 1986;
National Air Toxics Information Clearinghouse: NATICH Database
Users Guide for Data Entry and Editing, EPA-450/5-87-002,
NTIS: PB87-175576/AS, February 1987;
National Air Toxics Information Clearinghouse: Qualitative and
Quantitative Cancer Risk Assessment, EPA-450/5-87-003,
NTIS: PB88-113188/AS, June 1987;
National Air Toxics Information Clearinghouse: Ongoing Research
and Regulatory Development Projects, EPA-450/5-87-004,
NTIS: PB88-113196/AS, June 1987;
National Air Toxics Information Clearinghouse: Bibliography of
Selected Reports and Federal Register Notices Related to Air
Toxics, Two Volumes, EPA-450/5-87-005, NTIS: PB88-13660/AS
(Volume 1) and NTIS: PB88-136593/AS (Volume 2), July 1987;
National Air Toxics Information Clearinghouse: NATICH Data Base
Report on State, Local, and EPA Air Toxics Activities,
EPA-450/5-87-006, NTIS: PB88-113428/AS, July 1987;
National Air Toxics Information Clearinghouse: NATICH Data Base
Users Guide for Data Viewing, EPA-450/5-88-002, NTIS: Not
available yet, February 1988; and
National Air Toxics Information Clearinghouse Newsletter, A
Periodical, 20 issues to date, December 1983 - March 1988.
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ABSTRACT
The National Air Toxics Information Clearinghouse has been established
by the EPA Office of Air Quality Planning and Standards (OAQPS) in
coordination with the State and Territorial Air Pollution Program
Administrators (STAPPA) and the Association of Local Air Pollution Control
Officials (ALAPCO) for the purpose of aiding information transfer among
Federal, State, and local air quality management agencies. This report has
been published as part of that effort. The purpose of this report is to
provide information on risk communication to State and local agencies that
are beginning to undertake quantitative cancer risk assessments. The report
presents case studies on risk communication efforts undertaken by Puget
Sound (Washington) Air Pollution Control Agency and the San Diego County
(California) Air Pollution Control District, as well as the risk
communication procedures of Maryland's Department of the Environment. The
case studies briefly describe the source, the risk assessment approach, and
results of the risk assessment. The report also discusses the
characterization of risk assessment results, the process for communicating
risk, and an evaluation of the risk communication effort conducted by each
of the three agencies.
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TABLE OF CONTENTS
Section
Page
1.0 Executive Summary 1-1
1.1 Methodology and Organization 1-1
1.2 Summary and Conclusions 1-2
1.2.1 Preparing to Communicate Risk 1-3
1.2.2 Characterization of Risk Assessment
Results 1-4
1.2.3 Risk Communication Procedures 1-4
1.2.4 Evaluation 1-5
1.3 Suggestions for Risk Communication from the
Literature 1-5
2.0 Puget Sound Air Pollution Control Agency 2-1
2.1 Preparing to Communicate Risk 2-2
2.2 Characterization of Risk Assessment Results 2-3
2.3 Risk Communication Procedures 2-8
2.3.1 News Conference 2-8
2.3.2 Workshops 2-9
2.3.3 Press Coverage 2-10
2.4 Evaluation 2-12
3.0 San Diego County Air Pollution Control District 3-1
3.1 Planning to Communicate Risk 3-2
3.2 Characterization of Risk Assessment Results 3-3
3.3 Risk Communication Procedures 3-7
3.4 Evaluation 3-10
4.0 Maryland Department of the Environment 4-1
4.1 Preparing to Communicate Risk 4-2
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Section Page
4.2 Characterizing the Risk Assessment Results 4-2
4.3 Risk Communication Procedures 4-4
4.4 Evaluation 4-5
Appendix A - Seven Cardinal Rules of Risk Communication
by Vincent T. Covello and Fredrick W. Allen A-l
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LIST OF TABLES
Table Page
3-1 North County Project (San Diego, California) - Results
of Population Risk and Excess Cancer Burden (for
One of Several Emission Scenarios) 3-6
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1.0 EXECUTIVE SUMMARY
More and more frequently, the staffs of air pollution control agencies
are being called upon to present to the public results of technical studies
about exposure to various toxic substances and to describe any potential
risks associated with that exposure. The process of transmitting such
information is termed "risk communication." This report was prepared to
offer examples of how State and local air pollution control agencies have
used risk communication procedures to convey information to the public.
Three air pollution control agencies participated in this project:
Puget Sound (Washington) Air Pollution Control Agency,
San Diego County (California) Air Pollution Control District, and
Maryland Department of the Environment.
1.1 METHODOLOGY AND ORGANIZATION
This report consists of two specific case studies and one more general
discussion of risk communication efforts undertaken by the three air
pollution control agencies. The information presented here was compiled
from telephone interviews with staff members of the three agencies. In each
interview, the agency representatives were asked a series of questions about
the risk communication process including: (1) activities prior to the
release of risk assessment results, (2) methods used to characterize risk,
(3) process used for communicating risk, and (4) evaluation of risk
communication efforts. The three examples are organized around the
responses to these four topic areas. Supplemental information such as press
releases, fact sheets, risk assessment summaries, and news clippings were
provided by the three agencies. This additional information was used to
give more details about the events or actions that led up to and that
transpired during the risk communication processes discussed here.
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The result of the telephone discussions and the information review are
the two case histories of specific risk communication projects and a general
discussion of one agency's plans and procedures for communicating risk. The
two case histories describe the actions and discussions concerning specific
industrial sources of toxic air pollutants.
The case history for the ASARCO copper smelter in Tacoma, Washington,
describes plans and actions taken by the Puget Sound Air Pollution Control
Agency, the Environmental Protection Agency's (EPA) Office of Air Quality
Planning and Standards, and EPA's Region X office. One highlight of the
Tacoma discussion is how these three groups worked together on a local
project that came to receive national attention.
The second case history involves the North County Recycling and Energy
Recovery Center ("San Marcos incinerator"), a municipal waste-to-energy
facility in San Diego County, California. At the time of the project, a
risk assessment had never been requested by San Diego County as part of a
permit application. Therefore, the local air pollution control agency was
placed in a new role as risk communicator.
The third segment of this report discusses, in a more general fashion
than the case studies, the effects of recent legislation in the State of
Maryland. The new legislation requires that, for certain sources of
pollutants that are requesting construction permits, the Department of the
Environment offer the opportunity for a public hearing. Thus, the State
agency is required to prepare for and conduct public hearings for a variety
of air pollution sources and to present information about emissions and
risks of toxic pollutants.
Each case study and the general discussion were reviewed by and
approved by staff members of the participating agencies.
1.2 SUMMARY AND CONCLUSIONS
There are many similarities in the risk communication process and the
experiences of all three agencies, but the scope, degree of public interest,
and level of staff effort involved in risk communication differ among these
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three cases. To put the level of effort for the three cases into
perspective, the approximate staff requirements for each risk communication
effort are:
t ASARCO/Tacoma Smelter - EPA Region X - 5 person years
(12 full-time staff members for the public comment period from
July to November); Puget Sound Air Pollution Control District -
1.25 person years (3 full-time staff members for 5 months); and
EPA's Office of Air Quality Planning and Standards - additional
staff time for preparing and attending public meetings.
San Marcos Incinerator - 0.3 to 0.4 person years (done by 6 staff
members over a 18-month period who were involved in permit review
and risk communication).
Maryland Department of the Environment - Averages 30 person hours
per source, but can go as high as 60 hours.
In general, all three agencies that were interviewed for this report
used similar techniques for communicating risks. They also reported similar
evaluations of their risk communication efforts (i.e., that some techniques
worked better than others). The results of the risk communication efforts
for the three agencies are summarized below. After the summary, some
guidelines drawn from the risk communication literature are presented.
While other issues such as noise and traffic control, changes in
property values and aesthetics often accompany discussions of proposed new
facilities, the risk communications efforts in this report focus on the
health risk issues only.
1.2.1 Preparing to Communicate Risk
All three agencies conducted planning meetings to prepare for
communication efforts, although none of the three documented this in a
written plan. Since the Puget Sound Air Pollution Control Agency and
San Diego APCD projects involved sources of great public interest, press
coverage was extensive and groups interested in the air pollution sources
were easily identifiable through the agencies' existing lists and through
contacts individuals and groups made with the agencies in response to press
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coverage. In Maryland, on the other hand, consideration of proposed new
sources or facilities is simply announced in local newspapers. The
responsibility for becoming aware of potential new permits and requesting or
participating public meetings or hearings is placed on the public.
1.2.2 Characterization of Risk Assessment Results
All three agencies have dealt with sources of air pollution that
involve a wide range of community issues. The public was not only
interested in air quality, but also topics including jobs, the source's
impact on the local economy, noise abatement, and traffic control. The
three air agencies, however, were focusing risk communication efforts only
on potential risks posed by air emissions. In all three cases, and
especially for the Tacoma smelter because it was an existing source, the
agencies presented the public with background on facility operation and
emission control measures, emission dispersion characteristics, population
statistics, the nonthreshold theory of carcinogenesis, and carcinogenic risk
estimation techniques.
All three agencies have presented risk estimates to the public in terms
of both lifetime cancer risk to the most exposed individual and the
potential number of cancers. All three also have tried to put estimated
risks into perspective by comparing them to risks people encounter in
everyday life. This comparison technique met with varying degrees of
success. Most groups concerned about the Tacoma smelter objected to this
approach because of the comparisons made between voluntary and involuntary
risk. The risk assessment for the North County waste-to-enerqv far;i **
, ** *" ' i ' '-' j
included the same types of comparisons, but th* purpose Of tne comparisons
was to show that the risks posed by the proposed facility were so low as to
be considered insignificant.
1-2.3 Risk Communication Procedures
All three agencies used public meetings to inform interested members of
the public about the proposed actions prior to a formal public hearing. In
addition, workshops for individual interest gr°uPs were held in Tacoma and
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San Diego. All three agencies used specially prepared fact sheets to
explain risk estimates to participants at the public meetings. The Puget
Sound Agency noted that the public workshops seemed to make the comments
given at the public hearing more focused and useful.
The Tacoma smelter and the San Marcos incinerator generated extensive
press coverage. In both cases, the press contacted the agencies almost
daily during the public comment periods. The presentation of risk estimates
in news articles was accurate, but the press highlighted disagreements among
groups on issues such as the estimates that went into the risk calculations.
News articles also tended to personalize the estimates of cancer incidence
by portraying incidence statistics as having human qualities and
personalities. In dealing with the press, Puget Sound emphasized the
importance of communicating facts to the press understandably and accurately
as well as in a timely way.
1.2.4 Evaluation
Each case study includes the agencies' assessments of what was done
well, what could have been done better, and what advice they would offer to
other agencies undertaking a risk communication program. All three agencies
responded that it was very important to be open and straightforward with all
interested parties, being willing to answer questions and to investigate all
issues.
Advice for other agencies includes putting risk estimates into
perspective for the public, thoroughly evaluating the facility in question,
anticipating the public's questions in order to present technical
information clearly, and being sure of the facts and being confident of
explanations of agency policy before going to the public.
1.3 SUGGESTIONS FOR RISK COMMUNICATION FROM THE LITERATURE
Risk communication is fast becoming a necessary part of air pollution
control agencies' daily tasks. Conferences on risk communication,
scientific journals, and research by academia and the private sector are
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sources of information about the nature of risk communication and how it can
be accomplished.
Shortly before this report went to press, the EPA project officer
became aware of a relevant paper entitled "Seven Cardinal Rules of Risk
Communication," by Vincent Covello (Director of the Center of Risk
Communication at Columbia University) and Fredrick W. Allen (Associate
Director of EPA's Office of Policy Analysis). This information may be
useful to State and local air pollution control agencies interested in risk
communication, and therefore was added to this report as an appendix. It
will soon be published as a pamphlet by EPA's Office of Policy Analysis
within the Office of Policy, Planning, and Evaluation.
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2.0 PUGET SOUND AIR POLLUTION CONTROL AGENCY
In July 1983, the EPA proposed a national emission standard for
hazardous air pollutants under Section 112 of the Clean Air Act (NESHAP) for
inorganic arsenic. A major source of inorganic arsenic emissions was the
ASARCO copper smelter in Tacoma, Washington, the only copper smelter in the
United States that processed high-arsenic feed ore. Since this significant
source of arsenic emissions was located in Tacoma, the Puget Sound Air
Pollution Control Agency (APCA) and EPA's Region X staff were closely
involved with EPA's Office of Air Quality Planning and Standards (OAQPS) in
communicating risks of arsenic exposure to the public.
In developing the inorganic arsenic standard, OAQPS performed a
quantitative cancer risk assessment using EPA's Human Exposure Model. The
proposed standard would have required the ASARCO smelter to install best
available control technology on fugitive emissions of arsenic from the
converter. This control requirement would have reduced total inorganic
arsenic emissions from the ASARCO/Tacoma smelter by 39 percent, or from
282 Mg per year to 172 Mg per year. The EPA estimated that without the
NESHAP control requirements, the estimated risk of contracting lung cancer
for the most exposed person would be about 9 chances in 100. After control,
the estimated lifetime risk of lung cancer to the most exposed person would
be reduced to approximately 2 chances in 100. This represented a reduction
in estimated lung cancer incidence in the Tacoma area from these emissions
from about four cases per year without the proposed controls to one case per
year after control.
The residents of the Tacoma area were already aware of the potential
adverse health effects posed by smelter emissions when EPA began the
standards development process. For over 10 years prior to the NESHAP
proposal, EPA and the local county health departments had issued health
advisory pamphlets to local residents concerning arsenic emissions from the
smelter. The ASARCO/Tacoma smelter had been in place since the 1890's and
was an important source of jobs in the local economy. Thus, the factors
which later played a large role in public discussion -- age of the smelter,
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importance to the local economy, and potential for smelter emissions to
cause adverse health effects -- were all part of the public consciousness
prior to presentation of the NESHAP risk assessment results.
2.1 PREPARING TO COMMUNICATE RISK
Preparation for communicating the results of a risk assessment to the
public included planning for public involvement, identifying the target
audiences and their concerns, and deciding on the most appropriate
communication techniques to use. The objectives of the risk communication
effort were, first, to inform the public of the risk assessment results and,
second, to get public comments on whether the reduction in health risks
attributable to the proposed NESHAP were acceptable to the citizens in the
Tacoma area.
The OAQPS, EPA Region X, and the Puget Sound APCA had many planning
discussions prior to announcing public information meetings or public
hearings. Although the groups did not write a formal public involvement
plan, the three agencies did develop a methodology to announce the contents
of the EPA NESHAP proposal to the public.
To identify interested groups, Puget Sound APCA used routine agency
mailing lists as a starting point. Since the ASARCO/Tacoma smelter had been
a concern in the area for some time, the agency had a list of people who had
testified at previous public hearings on the smelter. In addition, the
agency identified smelter workers, their union, and residents of Vashon
Island (an area near the smelter shown through dispersion modeling to be
particularly affected by smelter emissions) as interested groups. In
addition, some ad hoc coalitions were formed seeking to influence decisions
about the smelter. Such coalitions included a group of Vashon Island
residents who banded together to oppose continued operation of the smelter.
Another coalition was made up of Washington Fair Share, smelter workers, and
the Sierra Club. The three groups formed an informal alliance that sought
to have ASARCO modernize the plant with new smelting technology, thereby
reducing health risk but maintaining jobs.
While EPA and Puget Sound APCA expected considerable local interest in
the effect of the proposed NESHAP on the ASARCO/Tacoma smelter, they did not
anticipate the strong national interest aroused by the proposal. National
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interest was sparked because the inorganic arsenic NESHAP represented the
first application of the risk assessment/risk management approach to NESHAP
development as proposed by then EPA Administrator William Ruckelshaus.
As the main channels for communication with the public, OAQPS, EPA
Region X, and Puget Sound APCA planned a news conference, several public
workshops, and a public hearing. The news conference was held the day the
proposed NESHAP for inorganic arsenic was published in the Federal
Register. The public workshops were aimed at informing members of the
public who were interested in participating in the formal public hearing.
Special workshops were also held with smelter workers and their union
representatives.
Press releases were prepared by OAQPS and EPA Region X and coincided
with the news conference. They announced the proposal of the NESHAP,
described the standard setting procedures, announced public workshops, gave
emission estimates, highlighted potential health effects, and posed the
question of whether the reduced health risks resulting from proposed control
requirements were acceptable to the citizens of the Tacoma area. Besides
these press releases, additional releases announced workshops and the public
hearing. The intense public interest in the fate of the ASARCO/Tacoma
smelter led to extensive, indeed almost daily, coverage in the five area
newspapers.
2.2 CHARACTERIZATION OF RISK ASSESSMENT RESULTS
The EPA and Puget Sound APCA were faced with explaining a range of
issues to the public concerned with the ASARCO/Tacoma smelter. In order to
understand health risk and the risk reduction achievable, the agencies had
to give the public some background in smelter operation and emission control
measures and emission dispersion characteristics, as well as cancer risk
estimation techniques. In the initial press releases prepared when the
standard was proposed in the Federal Register, EPA noted that
"epidemiological studies linking inorganic arsenic to human lung and skin
cancer" gave a "high probability that inorganic arsenic is carcinogenic to
humans" and "that there is significant public exposure to the pollutant."
The initial EPA Region X press release explained the nonthreshold concept of
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risk from exposure to carcinogens noting that since "inorganic arsenic is a
probable carcinogen, ... [it] can be assumed to present risks at any level
of exposure. There is no defined threshold at which risks begin to occur."
In the initial press release, EPA encouraged people living near the smelter
to help decide what was an "acceptable" or "reasonable" health risk. The
initial press releases did not attempt to quantify cancer risk.
Risk estimates were quantified in the fact sheet prepared by Puget
Sound APCA and presented to people at the public workshops, as well as being
included in the NESHAP proposal documents and orally at the public
workshops. The fact sheet explained how cancer risks were calculated,
presented the risks, and gave a characterization of the uncertainties
involved in estimating risk. The following is an excerpt from the Puget
Sound APCA fact sheet on risk to public health:
To calculate this remaining risk [after control], EPA
combined data from two different types of analyses. The first
analysis provides what is known as the unit risk number. This
number is defined as the lifetime lung cancer risk that would
occur in a population which is exposed throughout their lifetime
to 1 microgram per cubic meter of arsenic in the air they breathe.
(A microgram is equal to about 1/28 millionth of an ounce and a
cubic meter is about the same as a cubic yard. Therefore,
1 microgram per cubic meter is about 1/28 millionth of an ounce of
arsenic a cubic yard of air.) This unit risk number is calculated
by using data from studies of workers who were exposed to arsenic
in smelters and at a pesticide manufacturing plant.
The second analysis estimates the exposure for residents
living near the smelter. This is done with mathematical models.
Utilizing data on emissions of arsenic from ASARCO smelter as well
as information on weather and geographic conditions, a dispersion
model is used to calculate the concentration of arsenic expected
at over 100 locations within approximately 12 miles of the
smelter. Combining these exposure estimates with population data
from the Bureau of Census gives an estimate of the number of
people exposed to various concentrations of arsenic within about
12 miles of the smelter. This 12-mile distance was chosen because
the mathematical models used tend not to be as accurate at a
greater distance. (While our analysis stops at about 12 miles, it
must be realized that risk from exposure to arsenic emissions
extends beyond this distance, though at a reduced level.)
By multiplying the unit risk number and the estimated
exposure for people living around the smelter, it is possible to
make an estimate of the cancer risks expected in the ASARCO
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community as a result of arsenic exposure. For those people
living within 1 mile of the smelter, the lifetime cancer risk
remaining after controls have been installed would be about
0.2 percent. This is in addition to the normal lifetime cancer
risk of about 20 percent that would be expected without arsenic
exposure. Within the 12-mile area, this excess lifetime cancer
risk, after controls are installed, would be 0.004 percent.
Another way of expressing this risk is by using lung cancer
incidence numbers. Lung cancer incidence is the expected number
of lung cancer cases that would result each year from arsenic
exposure within 12 miles of the smelter. Without additional
controls, the estimated lung cancer cases are approximately four
per year. After the proposed controls were installed, the
estimated number would drop to approximately one per year. To
keep this in perspective, these numbers should be compared to the
several hundred lung cancer deaths that are normally expected each
year in a population the size of that found within this 12 mile
radius. [Note: The estimate of several hundred is based on
national lung cancer rates, as applied to the size of the
population in the Tacoma area.]
The process of calculating these risks for the population
around the smelter involves many assumptions and uncertainties.
So while these estimates of risk are a useful tool in the
decision-making process, MUCH CAUTION SHOULD BE EXERCISED TO AVOID
RELYING TOO HEAVILY ON THE NUMBERS PRESENTED ABOVE. These numbers
have considerable uncertainty for the following reasons:
(1) Modeling Assumptions - Measurements of air
concentrations of arsenic around the ASARCO plant have not been
done thoroughly; however, the measurements that have been obtained
indicate lower concentrations than those predicted by the
dispersion model. Arsenic emissions data from the smelter used in
the dispersion model are not precise. In many cases, these
emission rates were based on assumptions rather than actual
emission tests. This is especially true for fugitive emissions
which are very important in calculating concentration yet are very
difficult to measure. Also, estimates of how these arsenic
emissions mix with the ambient air are hard to determine because
of the complex geography and lack of specific weather data for the
area around the smelter. These problems may explain why the
ambient monitoring around the smelter shows lower concentrations
of arsenic than EPA's dispersion model predicts.
(2) Exposure Assumptions - A principal assumption is that
all persons living within the 12-mile radius of the smelter will
remain the same location of a 70-year lifetime and are exposed to
a constant, average concentration of airborne arsenic. This
assumption could result in large overestimates of arsenic exposure
for those who spend a lot of time away from their residences and
in underestimates for workers employed at the smelter.
Additionally, exposure to arsenic from resuspension of arsenic
bearing dusts from city streets, empty lots, and playgrounds has
not been taken into consideration.
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(3) Unit Risk Number - Because arsenic is a carcinogen, it
was assumed that a linear relationship exists between exposure and
risk. Simply stated, this means that person who inhales
1 microgram of arsenic per cubic meter of air is one-tenth as
likely to get cancer as a person who inhales 10 micrograms per
cubic meter. If the relationship between exposure and risk is not
linear, a different unit risk number could result which would in
turn change the lung cancer risk estimates made for the population
around the smelter. It is unlikely that the actual cancer risks
would be higher than those predicted by EPA, but they could be
substantially lower.
The executive summary of the NESHAP regulatory document which was also
available to the public similarly presented risk estimates and
characterization of uncertainties. In addition, this document outlined two
goals of EPA's risk management procedure, "(1) to limit the risk of the most
exposed individuals around sources of hazardous air pollutants, even though
these individuals may be small in number ('maximum lifetime risk'); and
(2) to limit the risk across the entire exposed populat.-,: as reflected in
the number of lung cancers expected per year over and above those normally
expected (xlung cancer incidence')."
The executive summary described health effects this way:
Using the conservative assumption on health effects and
exposure described above, EPA estimated the health risks of both
current and recommended control lc-'els. The EPA estimated that
under current conditions, the est:,;,ated risk of contracting lung
cancer for a hypothetical most exposed person is about 9 chances
in 100 if,the person were to be exposed to the same level over a
lifetime. As a larger section of the population is brought into
the analysis, the estimated risks drop significantly. For
instance, the model estimates that the risk for the 1000 most
exposed people is 1 in 100. The lifetime risk (assuming lifetime
exposure) of the population of Tacoma is about 0.02 percent, which
is an increase of about l/1000th the average expectation of dying
of cancer (20 percent). The estimated lung cancer incidence in
Maximum Lifetime Risk is the risk to the individual or
individuals who are exposed to the highest average exposure, as
estimated by a dispersion model, for a lifetime (70 years).
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the Tacoma metropolitan area from these emissions is approximately
four per year. This is in relation to the 71 to 94 people who
die from lung cancer in Tacoma each year from all causes.
After controls, the estimated lifetime risk would be reduced
four to five times for all exposed individuals. Specifically, the
estimated lifetime risk of lung cancer to the most exposed person
would be reduced by this proposed regulation to approximately
2 chances in 100. The risk to the 1000 most exposed people living
closest to the plant would be reduced to approximately 0.2 chances
in 100. The exposure and risk for typical residents would be far
less: four thousandths of a percent. The estimated lung cancer
incidence in the Tacoma metropolitan area from these emissions
would be approximately one per year above what would normally be
expected. The greatest risk is from the fugitive emissions
because they are emitted at a relatively low altitude and are not
dispersed easily to the atmosphere. Therefore, those people who
live close to the smelter are at greater risk than those who live
farther away.
Through the fact sheets and public workshops, the public came to
understand that the emissions from the smelter posed some increased cancer
risk compared to cancer risks if there were no smelter, and that
quantification of this risk was difficult. This was the intent of the Puget
Sound APCA and EPA staff. People living near the smelter had been informed
of potential health risks for a number of years by pamphlets issued by
county health departments.
When asked what the most difficult risk communication issues were, the
Puget Sound APCA and EPA Region X staff members identified two items.
First, the public initially expected that health risks posed by exposure to
smelter emissions would be precisely quantified and it was difficult for the
agency and EPA to explain how all the uncertainties made it impossible for
them to present a precise numerical estimate of risk.
2
Cancer Incidence is the number of additional estimated cancer
deaths per year in all people exposed within 20 km (12 miles).
During the 1970's, the number of lung cancer deaths in Tacoma
ranged from 71 to 94 per year. In order to compare these figures
to nationwide rates, it is necessary to adjust the data to
reflect the age distribution of the population. This has not
been done for Tacoma. However, the age-weighted data for Pierce
County in which Tacoma is located are not significantly different
from national rates.
MCH/002 2-7
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The second difficult issue the agencies faced in trying to communicate
the potential health risks was the preexisting attitudes of many local
people which affected their perception of whether the smelter indeed posed a
serious health hazard. Since the smelter had existed in the community for a
long time, and many local residents were economically dependent on the jobs
it provided, some people tended to discount the health warnings. On the
other hand, the residents of Vashon Island, downwind of the smelter, were
less economically dependent on the smelter, and consequently were less
accepting of the health risks posed by the smelter emissions.
2.3 RISK COMMUNICATION PROCEDURES
As mentioned above, the program for risk communication established by
OAQPS, Region X, and Puget Sound APCA consisted of an initial news
conference timed to coincide with the proposal of the inorganic arsenic
NESHAP in the Federal Register. The news conference was followed by
workshops aimed at informing interested groups and individuals in
preparation for the public hearing. Throughout this series of meetings,
which occurred from July 12, 1983 (date of proposal) through
November 2, 1983 (date of public hearing), press coverage was quite
extensive. This section discusses each major activity in the risk
communication process in more detail, highlighting the groups involved and
their perceptions.
2.3.1 News Conference
The news conference was held in Tacoma on the same day the EPA standard
for inorganic arsenic emissions was proposed. Press releases were prepared
by both OAQPS and EPA Region X. At the news conference, EPA's two main
speakers were Ernesta Barnes, EPA Regional Administrator for EPA Region X,
and Dr. Roy Albert, Deputy Director of the Institute of Environmental
Medicine, New York University. Ms. Barnes explained the standard setting
process and highlighted the issues on which EPA was seeking public comment,
most notably the "ample margin of safety" necessary to protect public
health. The Region X press release quoted Ms. Barnes,
MCH/002 2-8
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That phrase -- "an ample margin of safety" -- is the critical
issue in the upcoming public comment period on the EPA proposal.
In making the proposal, EPA is openly acknowledging that our
proposed controls for ASARCO will not eliminate risks to health,
but will only reduce them. The question facing citizens affected
by the ASARCO arsenic emissions is whether the reduced health risk
is acceptable.
Results of the cancer risk assessment conducted to support development of
the NESHAP were presented.
2.3.2 Workshops
Three main workshops were held after the news conference. The
workshops were carefully planned so that participants would gain a good
overall sense of what was said. The workshops were led by experts in
workshop facilitation. All participants gathered initially for an OAQPS
presentation on its risk assessment. Workshop participants then attended
small group sessions on specific topics of interest to them. Led by EPA
experts in each field, small group sessions included risk assessment and
control technology.
In addition to the three main workshops, EPA and Puget Sound APCA also
held similar information sessions for the smelter's union workers. One of
these sessions was held on Saturday to enable the smelter workers to attend
during nonworking hours.
EPA and Puget Sound APCA found that the workshops they conducted indeed
helped to make the comments received at the public hearing more focused and
useful than would have been the case without the sessions. By having the
workshops, EPA and Puget Sound APCA did not rely solely on the news media to
inform the public, but rather were able to distribute fact sheets and give
presentations at the workshops. Both agencies took a very open and
forthright approach at the workshops and throughout the public comment
period.
MCH/002 2-9
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2.3.3 Press Coverage
During the public comment period from July to November, EPA and Puget
Sound APCA had almost daily contact with the press. By taking frequent
telephone calls from the press, both agencies felt they were able to build a
good relationship with reporters.
During the comment period, coverage on the smelter issues appeared in
at least 13 publications, including both news and editorial coverage in
local as well as national publications. While articles covered a wide range
of issues of concern to the public including EPA's standard setting process,
the reactions of various groups, costs of additional pollution control, and
potential effects on property values, this section focuses on press coverage
of risk assessment issues.
The primary risk estimates used in the newspaper articles were the
estimated increases in lung cancer incidence (attributable to the smelter)
in the Tacoma area before and after the proposed control requirements. (The
estimated incidence from smelter emissions before control was four per year,
and after, one per year.) Several articles that opposed the risk level
after control tended to personalize the statistical estimate of one cancer
case per year with statements such as, "Who will teach his children to
fish?" Another article drew an analogy between this risk of one cancer case
and a ritual of human sacrifice where one life is sacrificed each year to
prosperity.
Other measures of risk cited in news articles included the estimate
that the average American has a 20 percent chance of dying of cancer, while
a person living within a mile of the smelter could have a 21 percent chance
and the comparison of the average American's 3 percent chance of contracting
fatal lung cancer with a 4 percent chance for residents within one mile of
the smelter.
Uncertainties inherent in the risk assessment process were
characterized in some articles as they were reported in the Federal Register
notice proposing the inorganic arsenic standard. However, some articles
chose to cast doubt on EPA competence by the way the article characterized
uncertainties. For instance, articles said that EPA "...has admitted its
mathematics for its cancer death statistical model may be wrong," and "the
EPA says that for all it knows, any amount of arsenic is harmful to health."
MCH/002 2-10
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In a lengthy article on the smelter, one weekly magazine summarized the
risk assessment in the following way:
The EPA calculated that the smelter was dumping 311 tons of
arsenic a year into the environment. With hooding, it said, the
figure would drop to 189 tons a year. Then, the EPA calculated
the effects of those emissions on human health. It started with
the fact that arsenic is a recognized carcinogen. Then it made
two assumptions -- assumptions that are widely accepted in the
scientific community, but assumptions nonetheless. First, because
arsenic is a carcinogen, there is no "threshold" level below which
exposure is harmless. Second, the response to given amounts of
arsenic is "linear" -- that is, if X amount of arsenic causes Y
amount of cancer, then 0.1 X will cause 0.1 Y, 0.01 X will cause
0.01 Y, and so on. Even when the numbers are very small, if you
expose a large enough number of people over a long enough period
of time, somebody's going to die. The EPA's actual data on
arsenic-caused cancer came from people exposed to high doses. At
the low doses reaching the general population around the smelter,
the agency calculated that up to four people a year could get
cancer from the current emissions. If the converters were all
hooded, up to one person a year would still be getting cancer
courtesy of ASARCO.
The article went on to say:
One case of lung cancer does not sound like much of an "ample
margin of safety." No exposure to a carcinogen is "safe." If the
EPA really believes arsenic is a carcinogen with no threshold,
then the only way it can satisfy the letter of the law is to
require absolutely no emission of arsenic. The only way to do
that is to shut the smelter down period.
However, the article went on to point out the discrepancy between ASARCO's
arsenic emission estimates and the EPA estimates, noting that "...EPA has
publicly conceded that its own figures are wrong." The article went on to
further examine uncertainties saying:
Under the circumstances, that is a rather striking
concession. If EPA cannot get those basic numbers right, what can
it get right? The questions may be unfair, but it is natural.
It certainly spills over onto the EPA's assessment of risks.
If the emission figures are up to three-and-one-half times too
high, the maximum number of cancer cases per year with secondary
hooding drops to less than one. Does that mean it is effectively
MCH/002 2-11
-------
zero? That all depends on which scientific assumption you choose
to believe, and how you interpret the epidemiological data.
ASARCO's national director of environmental sciences,
Michael Varner, says flatly that the company believes arsenic does
have a threshold. He says the "no threshold" assumption is valid
for ionizing radiation, but there is no reason to think it is
valid for everything else.
The article continued to compare opinions of ASARCO's Varner with other
experts. It explained that Varner cited medical studies that showed no
excess cancer deaths that correlate in any way to distance from the Tacoma
smelter or any other smelter. The article also noted that Varner did not
think any workers were suffering from the levels of arsenic exposure. In
response, a university professor responded, "They [ASARCO] are lying,"
adding support to the no threshold assumption.
2.4 EVALUATION
When asked about what was especially successful in the ASARCO/Tacoma
risk communication work, EPA Region X and Puget Sound APCA agreed that one
item was the agencies' openness. Both agencies demonstrated that they could
work together with all groups involved, showing that everyone had a stake in
the issues. Both agencies were willing and available to talk with all
groups, and demonstrated their understanding of the concerns of all
involved.
The risk information that was communicated to the public left many
people somewhat confused and eager for EPA to make the decision defining
ample margin of safety. However, others wanted to see a specific change in
technology at the smelter and were not concerned about evaluating
technological changes in terms of changes in cancer risk. In general,
people were searching for more certainty than they found in the risk
assessment.
One technique used in communicating risk estimates that did not prove
useful was that of comparing risks posed by smelter emissions to risks
encountered in everyday life. Most groups involved in the ASARCO case
objected to this approach because of the comparisons made between voluntary
and involuntary risks. One EPA Region X representative felt that it would
MCH/002 2-12
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be useful to express cancer risk in terms of changes in cumulative cancer
burden, noting the increase in total cancer risk resulting from smelter
emissions.
As for staff resources devoted to the ASARCO/Tacoma risk communication
work, EPA Region X had approximately 12 people working full-time on the
project from the time the NESHAP was proposed in July through the end of the
public comment period in November. In addition, Puget Sound APCA had three
people devoted to the project during the same time period. Staff at OAQPS
were also involved on the public hearings and workshops.
EPA Region X and Puget Sound APCA had one main piece of advice for
other agencies in communicating risks to the public and that was that risk
estimates need to be put into perspective to help the public to understand
how risk can be minimized. The EPA and Puget Sound APCA agreed such
comparisons as the relationship to total cancer burden were useful for
assigning a priority to a particular risk, ranking it against other risks.
Puget Sound APCA also felt the agency learned some important techniques
for dealing with the press. They found that the main concern among the
newspapers covering the smelter story was to be first to publish a
particular item, regardless of accuracy. For this reason, Puget Sound APCA
learned the importance of communicating facts to the press understandably
and accurately. The agency found that the press was interested in covering
events rather than explaining the process to be used in decision-making-or
explaining a control alternative. When the technical staff from Puget Sound
APCA and the news reporters came to understand each others' concerns, they
were able to help each other and work well together.
A final evaluation of the results of risk communication efforts for the
Tacoma smelter was not possible since the plant announced in June 1984 that
it would shutdown by mid-1985. Because of the shutdown, the proposed
arsenic NESHAP never went into effect at the ASARCO smelter. When faced
with requirements for control of sulfur dioxide and arsenic, ASARCO decided
for many reasons to redirect its assets and close the Tacoma smelter. The
smelter faced a variety of business problems including excessive smelting
capacity worldwide and competition from Japan for purchasing United States
ore.
MCH/002 2-13
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3.0 SAN DIEGO COUNTY AIR POLLUTION CONTROL DISTRICT
In 1984, the San Diego County Air Pollution Control District (the
District) reviewed an application for a construction permit for a recycling
and energy recovery project, the North County Recycling and Energy Recovery
Center, to be located at the San Marcos landfill in San Diego County. The
facility would be processing 1,200 tons of municipal waste per day, creating
1,040 tons of refuse derived fuel per day for boiler fuel. In addition to
concern over particulate emissions, carbon monoxide, NO , and SO , the
A .A
District was concerned about emissions of specific toxic pollutants. The
public health implications of these toxic pollutants were evaluated by
performing a risk assessment. At that time, the District had never
requested a risk assessment from a permit applicant.
The risk assessment for the North County facility was prepared by a
contractor hired by the permit applicant and was reviewed by the California
Department of Health Services (CDHS). In the risk assessment, two measures
of risk were calculated: (1) the incremental cancer risk associated with
the project, and (2) the excess cancer burden. Incremental cancer risk is
the probability that an individual will contract cancer as a result of
facility emissions. Excess cancer burden is the additional number of
persons in the study area predicted to contract cancer as a result of the
project (above the background level of cases or the number who would
contract cancer from all other sources).
Risk and cancer burden were calculated for both residential exposure
and work-related exposure. Population and employment were projected to the
year 2000. Concentrations of nine substances were calculated at the
centroids of discrete population and employment units. The nine substances
addressed were: arsenic, beryllium, cadmium, chromium, nickel, polynuclear
aromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs),
polychlorinated dibenzo-p-dioxins (PCDDs), and polychlorinated dibenzofurans
(PCDFs). Emission assumptions were based on data from existing
waste-to-energy facilities. The low dose cancer potency slopes used for the
MCH/002 3-1
-------
various substances were those developed by EPA's Carcinogen Assessment
Group. The results of the quantitative risk assessment indicated that, in
the opinion of the District, a well-designed and operated waste-to-energy
facility would not represent a significant health risk.
Press coverage of the proposed North County Recycling and Energy
Recovery Center began well before the completion of the risk assessment for
the facility. It is clear from these articles that some groups who noted
potential adverse health effects opposed the proposed facility. Additional
reasons for opposition included the potential for decline in property
values, increased noise, and increased traffic volume. Press coverage prior
to the development of cancer risk estimates also presented the need for
additional garbage disposal capacity as well as the advantages offered by
energy production.
Local issues other than air quality also came to public attention after
the proposal of the North County facility. For example, before
construction, the facility needed to obtain a special use permit from the
San Marcos City Council and the San Marcos Planning Commission. A general
land use amendment was also required. For these reasons, the City Council
and Planning Commission were soliciting public comments and holding hearings
at the same time as the Air Pollution Control District. The District served
as a technical resource to the City Council and Planning Commission for
air-related matters. The District reviewed the conditions set forth in the
special use permit.
3.1 PLANNING TO COMMUNICATE RISK
In planning how best to inform the public about potential health risks
and the risk reduction achievable, the District found that the
constituencies that needed to be involved identified themselves. Several
environmental groups were interested in the North County project. The
groups most interested in this facility, however, were not those groups
generally involved in District air issues. The people directly affected by
the facility's emissions showed the greatest interest. Churches that had
retreat centers located near the proposed project actively opposed its
construction.
MCH/002 3-2
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The District prepared one formal press release announcing the public
hearing, which was held two months after the Department of Health Services
finalized comments on risk assessment. Several local newspapers frequently
published articles during the public review of the District's recommended
approval of the facility.
3.2 CHARACTERIZATION OF RISK ASSESSMENT RESULTS
The risk assessment for the North County project was prepared by the
permit applicant, and the methodology and results were reviewed by the CDHS.
After the permit applicant completed the risk assessment, the District took
the role of risk manager in deciding to approve the permit application.
Although the District had not developed the risk assessment and was not
responsible for characterizing uncertainties as they were presented in the
risk assessment, the District was the main source of risk information for
the public.
The District's work on review of the permit application, the
applicant's risk assessment, and the results of the CDHS's review of the
risk assessment were all presented to the public. The applicant's risk
assessment report actually served two purposes: it documented the risk
analysis procedures and the risk estimates for the CDHS's review and it
presented risk estimates to the public. Because the report was prepared for
the CDHS review, it presented detailed scientific information. This
information was also available to the public. The risk assessment gave
detailed descriptions of how emissions, population at risk, emission
concentration estimates from dispersion modeling, and risk estimates were
determined. The District found that some local residents read this material
very carefully and prepared very technical comments as a result. Some
citizen groups were assisted in reviewing the risk assessment by people with
technical backgrounds. Several people who prepared comments were
knowledgeable about risk assessment from the context of the nuclear
industry.
With regard to emissions from the proposed facility, the risk
assessment report presented a table of trace metals emissions and organics
used in risk calculations. The report also listed the source of the
emission rate data, which were based on other resource recovery facilities.
MCH/002 3-3
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With regard to population, the report noted that population projections
were based on census tract forecasts for population and employment in the
year 2000, noting that the year 2000 was selected because it would best
represent the average population exposed to the facility combustion
emissions over the lifetime of the facility. By identifying the census
tracts that would be affected by emissions and apportioning population
estimates in smaller units, the population within the 10-mile radius study
area was estimated. Employment and school population were also estimated on
a sub-census tract level.
The report explained how air quality modeling was used to predict
annual average concentrations. It noted the dispersion model used to
estimate concentrations, its assumptions with regard to plume dispersion
options, the effect of terrain in the model's estimates, and the model's
associated tendency to overestimate concentrations. The report also
discussed selection of meteorological data, stack parameters, the facility's
operating schedule, and receptor sites. One discrete receptor was located
in each of the population units defined by the census data. In addition,
eight special receptors were modeled that corresponded to the location of
the eight houses nearest to the proposed facility.
The determination of risk consisted of the calculation of two
quantities: (1) the incremental cancer risk associated with the project and
(2) the excess cancer burden. The report defined both terms, noting that
the incremental cancer risk is the probability that an individual will
contract cancer as a result of facility emissions, and that the excess
cancer burden is the additional number of individuals in the study area who
can be expected to contract cancer as a result of the facility's emissions.
The report presented derivation of potency data for the nine substances
addressed in the risk assessment. The report also presented two
calculations of risk and excess cancer burden; one was based on the waste
combustion facility operating for 30 years and the other assumed the
facility would operate for 70 years. The report summed up by saying, "the
assumptions used in calculating risk associated with a given exposure are
consistently conservative, with the intention of establishing an upper limit
on potential risk."
MCH/002 3-4
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The report presented tables summarizing maximum risk and excess cancer
burden for each of the nine substances and the total risk and excess cancer
burden estimated to result from the proposed facility. Table 3-1 summarizes
these results for one emission scenario. The risk assessment results showed
that chlorinated dibenzo-p-dioxins and dibenzofurans were responsible for
more than 99 percent of the calculated risk, and because of this, the report
focused interpretation of health risks exclusively on dioxins and furans.
Features of the North County project (such as removal of hazardous waste,
waste processing to remove substances contributing to trace metal emissions,
and the use of emission control devices) that minimize risk were listed, but
the report explained that most were not used in the initial risk assessment
calculations. Therefore, the report noted, actual risk would be
considerably less than the calculated risk estimates presented. Based on
use of the special features at the proposed facility, additional risk
estimates were calculated showing that actual incremental cancer risk posed
by the facility would likely be less than one in a million for all
emissions.
To place the risk estimates in perspective, the applicant's report
presented a table listing risks that individuals might encounter in everyday
life to increase the risk of death by one in a million. Some of these
included:
Activity
Smoking 1.4 cigarettes
Travelling 6 miles by canoe
One chest X-ray
Eating 40 tablespoons of
peanut butter
Living in southern California
for 7 months
Cause of Death
Cancer, heart disease
Accident
Cancer caused by radiation
Cancer from acrylonitrile
monomer
Earthquake
The report concluded,
It is obvious people are routinely exposed to risks which
greatly exceed a lifetime risk of one in a million. Despite
the apparent low risk associated with the North County
MCH/002
3-5
-------
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MCH/002
3-6
-------
facility, many individuals resent any amount of risk, however
small, that is imposed on them. Their feeling is that risks
such as those listed [above] are risks that individuals chose
to take on their own free will. However, public officials
are constantly making risk/benefit decisions for the public
on projects or actions that have social benefit such as power
plants, airports, and dams. The important factor is not
whether there is zero risk associated with a project,
but whether the risk is acceptably low (i.e., so low
that it can be considered to be insignificant).
Based on contact with the public, the District reported three difficult
risk communication issues. First, some people responded to the proposed
facility very emotionally and did not make use of the risk information
offered to them. Their minds were made up to oppose the proposed project
and, although the District attempted to communicate risk information, they
did not accept the information. These people feared adverse health effects,
increased traffic and noise levels, and decreased property values for areas
around the facility. Many of these people felt uncomfortable with the
uncertainties in emission and health projections.
Second, the District found the concept of atmospheric pollutant
dispersion was difficult to communicate. The public did not understand that
air dispersion patterns made ground level concentrations different from
stack concentrations. Third, some thought that gaseous pollutants emitted
from the facility would reach a receptor site and that concentrations would
continue to increase with time rather than vary with the meteorological
conditions. Finally, the District found that it was difficult to
communicate the variation in risk estimates and the conservative nature of
the assumptions used in estimating risk.
3.3 RISK COMMUNICATION PROCEDURES
During the 30-day public comment period following the District's
preliminary approval of the North County project's permit, the District held
two formal public hearings as well as several meetings with various groups
interested in the project. As mentioned above, the City of San Marcos also
undertook public involvement efforts because the proposed facility required
a special land use permit and a general amendment to the City's land use
plan.
MCH/002 3-7
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Public hearings by the District dealt with air issues only. At each
hearing, the project and the risk assessment results were summarized
verbally followed by attendees' comments. At the public hearings, the
District staff explained the proposed facility and a CDHS physician with a
Master's degree in public health spoke on the risk assessment.
The only press release prepared by the District was an announcement of
the public hearings. However, because there was so much public interest in
the facility, press coverage was extensive. In fact, the District was
contacted frequently by the press. In comparing the perception of those who
had direct agency contact with those who learned of risk results through the
media, the District felt that the former had more information, but that the
additional information was unlikely to change initial perception of the
proposed facility.
The District felt that the press was accurate in reporting risk
assessment results. However, the facility's initial risk assessment was
reported in various articles, but was later revised based on CDHS comments.
The reporting of a second batch of risk estimates led to some public
confusion.
Press coverage of the proposed project continued for 6 months before
the final (i.e., the revised) risk assessment was released in June 1984.
Coverage prior to the release of the risk assessment did not address the
potential cancer risk posed by emissions except in an occasional qualitative
reference such as the facility would possibly release "cancer-causing
chemicals." Even after the release of the facility's risk assessment,
little of the press coverage addressed the risk estimates. Most articles
relied on quotations from those on opposing sides of the facility
development issue. One of the more extensive articles on the risk
assessment noted that, according to the North County's risk assessment
report, "The chances of getting cancer or any other disease -- from the
emissions of a proposed $120 million trash-to-energy plant ... are less than
one in a million, according to a study." Quoting the managing director of
the project, the article said,
The proposed North County Resource Recovery Center, even before
taking into account its unique features designed to protect air
quality, will not be a significant health risk according to the
MCH/002 3-8
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evaluation prepared for county and State environmental agencies.
This risk assessment calculates not the actual risk, but the
ceiling below which any actual risk lies.
The article went on to quote the North County project managing
director: "not even one additional case of cancer will result over the
center's 30-year operating life." The article then cited the North County
report's figures on daily activities that have "mill ion-to-one odds."
Other news articles quoted opponents of the plant who emphasized risk
from dioxin emissions. One such article quoted a member of the North County
Concerned Citizens (NCCC) who reported that one EPA report on dioxins said,
"one trillionth of a gram per cubic meter could cause nine additional cases
of cancer per year in a population of 100,000." Another article quoted a
local resident and member of NCCC who said, "smoke from the plant would
contain the cancer causing agent dioxin in amounts 100 times the Federal
safety limit."
At one planning commission hearing, a PTA spokesman made referred to
the Union Carbide accident in Bhopal, India, which had occurred shortly
before the hearing date. The article quoted the speaker as saying, "God
forbid such an accident could happen in San Marcos."
The NCCC published a one-page flier encouraging people to contribute to
the group's legal and educational fund. The flier addressed several issues,
but with regard to cancer risk information, mentioned only dioxin emissions,
saying that "dioxin, according to scientists, may be just the most deadly
cancer-causing substance yet discovered."
During the comment period, the District staff had almost daily contact
with the public interested in the North County project, in addition to press
contacts. In the District office, six staff members worked on this permit
application and review for about 18 months. This included three staff
members who communicated regularly with the press or the public. Total
staff involvement on this project was 1.5 to 2 person-years of staff time.
Of this staff time, 80 percent was used in permit review work and 20 percent
in risk communication.
MCH/002 3-9
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3.4 EVALUATION
When asked what risk communication techniques were especially
successful, the District brought up several points. The District staff
prepared a thorough and extensive review of the proposed project and
required the permit applicant to do a thorough risk assessment. In fact,
the District felt that it had investigated all significant issues raised by
the public and had not glossed over anything. The public apparently agreed.
The CDHS review of the risk assessment helped to improve the final product.
The District also noted that presenting a comparison of risks so that the
public could place the estimated cancer risk posed by the proposed facility
into perspective was useful. Finally, the District added that visual
presentations, such as maps showing estimated impacts, were well received.
The District had no plan to measure how well their message was received
by the public, since the District's main concern was the facility's
compliance with air regulations. However, one measure of effectiveness was
that both the San Marcos City Council and the Planning Commission approved
the North County project, based in part on the District's analysis. Also,
when a local referendum was held based on a challenge to the City Council's
decision, facility construction was approved by the voters.
Public response to this risk communication effort showed a tremendous
variation in opinion. However, the District felt material was presented so
that both lay and technical people could understand. Approval in the local
referendum confirmed that the public had concluded that risks posed by the
project were acceptable.
When asked about an assessment of their risk communication effort, the
District felt they did a good job in their new role as risk communicators
since their principal duty is to ensure compliance with air rules. One
change suggested that has since been implemented was to speed up the process
for CDHS review of a facility's risk assessment.
The District had several pieces of advice to offer other agencies
undertaking the task of communicating risk about a facility. First, prepare
a thorough evaluation of the proposed project before presenting it to the
public. Next, try to anticipate how the public will perceive information
presented. Determine how technical information can be explained most
MCH/002 3-10
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clearly before communicating it. Also, expect a wide range of public
responses, from very emotional to quite technical. Finally, the District
stressed the importance of being responsive to every concern raised by the
pub!ic.
MCH/002 3-11
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4.0 MARYLAND DEPARTMENT OF THE ENVIRONMENT
In the State of Maryland, the Air Management Administration (the AMA)
within the Department of the Environment is responsible for issuing
construction permits and operating permits for sources of air pollution.
Recent legislation in the State requires that citizens be given an
opportunity to request a public hearing for certain air pollution sources
applying for a construction permit. The AMA has received more requests for
these public hearings than they anticipated. Of tne permit applications for
Wiiicfi public hearings may be requested, about half result in a hearing.
Recognizing the need to discuss the applications and air pollution
issues with the public in a more casual atmosphere than a hearing, the AMA
usually holds a less formal public informational meeting first, followed by
the formal public hearing. In a few instances the AMA has found that a
brief discussion of the source/permit application with the public has been
sufficient to allay concerns and little opposition has been expressed at the
formal public hearings. In most cases, both the informal meetings and
formal public hearings have been well attended.
The public meetings have helped to focus attention on air pollution
control issues. The AMA reported that people want to discuss traffic,
impact on property values and zoning changes, issues over which the AMA has
no jurisdiction. The public meetings helped people to understand that the
purpose of the meetings and hearings sponsored by the AMA was to discuss air
polluting £Qp,trol issues only. The AMA also felt that the informal meetings
provided a bett!r fon- -" CCHCe^ C.V,l*nl co ask questions and for ^e
AMA to respond to those questions. TtiG ^formal meetings also produce a
more knowledgeable public that is better prepared for the public hearing.
The AMA is using their proposed air toxics regulations to examine the
impacts of toxic air pollutants to be discharged from sources applying for
permits to construct. Because the regulations use the concepts of risk
assessment to evaluate carcinogens, these topics are sometimes discussed at
the public meetings. (The proposed regulations and the methodology for risk
MCH/002 4-1
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assessment used by the AMA is discussed in a September 1987 National Air
Toxics Information Clearinghouse Newsletter article.)
Unlike the previous two sections, which focused on the history of a
well-defined risk communication effort for a particular source, this section
describes the AMA's experiences in preparing for and participating in public
meetings and hearings and in communicating risk for a variety of sources,
all within the AMA's limited budget.
4.1 PREPARING TO COMMUNICATE RISK
The AMA uses an informal planning process to prepare for public
meetings and hearings. The AMA has also learned that meetings and hearings
for certain kinds of sources, such as incinerators, require more detailed
preparation. Staff involved in risk communication anticipate what questions
the public is likely to ask for a given source and they prepare accordingly.
If necessary, the AMA can call on the Department's Assistant Secretary
for Toxics, Environmental Science and Health, to describe risks to the
public. Because of a limited budget, the AMA does not usually seek outside
assistance to prepare for the meetings.
The opportunity to request a public hearing is announced in newspapers.
Although the AMA contacts citizens' groups in the affected area, the
responsibility for becoming aware of potential hearings lies with any
interested parties, such as citizens' groups, elected officials, business
and industry representatives, and trade organizations. Although the AMA
maintains a positive relationship with the local press, press releases are
not usually prepared for any meetings or hearings.
4.2 CHARACTERIZING THE RISK ASSESSMENT RESULTS
The AMA has found that simple, straightforward verbal and written
presentations are the most effective. The AMA feels that the public is
pleased that toxic emissions have been evaluated and that efforts have
been made to ameliorate any problems. In some cases, more technical
discussions of risk, risk assessment, and carcinogens have taken place at
MCH/002 4-2
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hearings. In these types of discussions, the AMA stresses the importance of
emphasizing the conservative assumptions used in their proposed air toxics
regulations to assess risk. For example, the estimates of cancer risk are
based on a hypothetical continuous exposure to the highest concentration
resulting from a source's emissions for 70 years. This is a very
conservative approach.
The AMA begins their presentations with relatively simple materials,
such as descriptions of the source and results of their evaluations. More
detailed information is also available to the public on request. Fact
sheets have been prepared and are distributed to people as they enter the
public meetings and hearings. The fact sheets contain a description, in
plain English, of the facility or plant, the products it manufactures, and
the processes it uses. The fact sheet also contains a list of pollutants
that will be emitted and modeling results showing the concentrations
predicted for each of the pollutants. The fact sheet also lists an
acceptable ambient level for each of the pollutants. This information is
presented in a table for easy comparison. The fact sheet may also contain
other air quality information that does not directly pertain to toxics.
For example, a corporation proposed to construct a facility to
manufacture molded fiberglass petroleum storage tanks. The fact sheet
prepared by the AMA for distribution at the public meeting for the proposed
facility included a description of the process and the emissions expected
and a list of applicable air pollution regulations. The process description
defined the products of the proposed plant (fiberglass petroleum storage
tanks), the raw materials needed {solvents, polyester resin, and chopped
fiberglass), and the equipment used (spray guns, molds). Furthermore, the
fact sheet identified the emissions from the process and how they would be
released into the air.
In this case, the pollutants of concern were noncarcinogens (except for
one pollutant). The emissions of the pollutants were modeled to derive
estimated off-site concentrations. The fact sheet listed each pollutant,
its estimated off-site concentration, and its proposed screening level. A
comparison of the modeled concentrations to the proposed screening level
concentrations showed that none of the estimated concentrations were likely
to result in adverse health effects for any potentially exposed population.
MCH/002 4-3
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Fact sheets help educate people concerning the purpose of the hearings
and the AMA's actions. They also help to focus discussions on air pollution
issues. The AMA has prepared a pamphlet on the air quality permitting
process. The pamphlet is organized in a question and answer format. The
questions include:
"Why hold a public hearing?"
"What happens at a public hearing?"
"What happens after construction?"
The answers clearly indicate the purpose of a public hearing, the procedures
to be followed at the public hearing, and the purpose of permits to operate.
The AMA anticipates preparing similar pamphlets to explain risk assessment
and control of toxic air pollutants.
The AMA has used various ways of presenting risk information. Showing
that concentrations resulting from a plant's emissions are below levels
considered to be protective is often sufficient. However, if risk estimates
are presented, the AMA has found that comparing increases in risk from air
emissions to risks from everyday activities puts things in perspective for
the public. Cancer risks from passive cigarette smoking, X-rays, and
natural radiation have been used for comparison. The AMA also emphasizes
that carcinogens are not always exotic, unfamiliar substances. Many
carcinogens may be found in motor vehicle exhaust, fireplace smoke, and
drinking water. Having information on concentrations of substances at other
locations in the State or elsewhere in the country is also helpful,
according to the AMA.
The AMA used comparative risks for an ambient monitoring survey. The
study involved ambient monitoring for 25 substances, including four
carcinogens. This excerpt from the fact sheet for the survey is an example
of the use of comparative risks to help the public understand risk
assessment:
Carcinogens Monitored
Four out of the 25 substances monitored are considered
carcinogens under the draft regulations. These are benzene,
carbon tetrachloride, chloroform, and ethylene dichloride
(1,2-dichloroethane).
MCH/002 4-4
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Most scientists believe that any exposure to a carcinogen
results in some risk of cancer. Almost everyone is exposed to
some carcinogens everyday. Common exposures to carcinogens
include benzene in air (from gasoline) and chloroform (from
chlorination) in water. Many foods and consumer products contain
trace quantities of carcinogens.
The four carcinogens monitored are commonly found in ambient
air across the United States. The levels of benzene and carbon
tetrachloride are close to or slightly higher than typical
background concentrations. Ethylene dichloride and chloroform
concentrations are below levels found in heavily industrialized
areas, although higher than background concentrations.
Comparative Risks
Risk can be estimated using a process called risk assessment.
For example, it has been estimated that the following activities
increaseAan individual's risk by about one chance in a million
(1 x 10~b).
1. Smoking two cigarettes (cancer or heart disease).
2. Eating 40 tablespoons of peanut butter (cancer).
3. Living in a stone or brick home for 2 months (cancer
from natural radioactivity).
Potential Cancer Risks
There is a lot of uncertainty involved in cancer risk
assessment and estimates of the risk of cancer caused by air
pollution are not perfect. However, risk assessment is the best
scientific tool available. Risk estimates can give us at least a
rough idea of a worst-case or "upper bound" cancer risk.
Using risk assessment, AMA estimated the upper bound risk of
cancer from breathing air containing the four carcinogens at the
levels monitored. A continuous 2-year exposure would increase an
individual's overall risk of cancer by no more than 6 chances in a
million (6 x 10" ). This is about the same amount of increased
risk as from smoking 12 cigarettes. A continuous lifetime
exposure (70 years) would increase an individual's risk by up to
about two chances in ten thousand (2 x 10" ). EPA estimates of
lifetime risks resulting.from emissions at similar facilities are
generally around the 10 range, and often in the 10" range.
This fact sheet clearly and concisely presents the risk assessment results,
and provides data for comparison to help put risks in perspective.
MCH/002 4-5
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The most troublesome issue the AMA reported, in terms of risk
communication, involved hospital incinerators and concern over biological
hazards such as the AIDS virus. At one hearing, the Department requested
help from health experts in explaining the destruction capability of an
incinerator and the inhalation route of exposure, as related to biological
hazards. The public still had strong reservations about the measure of
control afforded by the incinerator, because of the uncertainty and fear
associated with biological hazards.
4.3 RISK COMMUNICATION PROCEDURES
As described above, actual risk communication is done verbally at
meetings and hearings, and in writing, through fact sheets and pamphlets
prepared by the AMA. The public meeting involves one representative from
the AMA making a presentation. Then, the representative answers questions
from the public. In some cases, when the AMA anticipates that there is
strong public concern about the proposed plant, several AMA representatives
and personnel from the Assistant Secretary for Toxics, Environmental
Science and Health have made presentations. The person(s) presenting the
risk information need to be perceived as trustworthy, objective, and
straightforward.
The AMA does not routinely notify the press about proposed sources and
the opportunity for public hearings. Communicating with the press and other
news media is done on a case-by-case basis.
However, during the development of the air toxics regulations, the AMA
held a seminar designed to inform the press and the general public about
risk assessment issues. The seminar included presentations about Maryland's
proposed air toxics program, principles of risk assessment, risk management,
and a case history of an EPA risk management decision in Philadelphia. The
symposium was designed for a selected list of participants including
community interest groups, environmental groups, and the press. The AMA
feels that media coverage of permit hearings and risk assessment issues has
been fairly accurate. The AMA attributes this accuracy to open
communications with the press.
MCH/002 4-6
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4.4 EVALUATION
The Air Management Administration feels that the public meetings and
hearings have accomplished their intended goal of informing the public and
communicating risk. The public has been pleased that the AMA has identified
and evaluated pollutants, taken steps to correct any potential problems, and
informed the public of its actions. The AMA credits their use of public
meetings before public hearings in the success of their efforts. The AMA is
not required by law to hold information meetings before the formal public
meetings. However, they feel that giving people an opportunity to learn
more about a particular case or permit application helps direct and focus
public hearings. Sometimes, the information presented at the public
meetings answers the citizens' questions and the formal public hearing is
uneventful.
Being able to state that predicted ambient concentrations are below
levels considered protective is the most effective communication approach
the AMA uses. Keeping risk information simple and straightforward is
beneficial, according to the AMA. In a few cases when very detailed risk
assessment data were presented, the message on risk was not clearly
understood. The AMA found that the public was not interested in hearing the
details of the risk assessment process. Instead, they wanted to know if a
potential problem existed and what the AMA had done to correct the problem.
The pamphlets and fact sheets prepared by the AMA to distribute at
meetings and hearings helped educate the public that air issues were to be
discussed. This helped make meetings and hearings more effective. The AMA
has estimated that about 30 hours of staff time are needed to prepare for
each permit hearing. This includes time to attend the public meetings. In
cases where more formal, detailed presentations have been made, the AMA
estimates about 60 hours of staff time are needed.
Finally, the AMA recommends anticipating the questions the public will
ask and preparing general responses to those questions. It is also
important to be prepared for the worst-case scenario. The AMA stresses
that, in the communication process, it is very important for the
communicators to understand that people are truly concerned about their
well-being and the health of their children.
MCH/002 4-7
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APPENDIX A
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SEVEN CARDINAL RULES OF RISK COMMUNICATION
by Vincent T. Covello and Frederick W. Allen
There are no easy prescriptions for successful risk
communication. However, those who have studied and participated
in recent debates about risk generally agree on seven cardinal
rules. These rules apply equally well to the public and private
sectors. Although many of the rules may seem obvious, they are
continually and consistently violated in practice.
RULE 1. ACCEPT AND INVOLVE THE PUBLIC AS A LEGITIMATE PARTNER.
A basic tenet of risk communication in a democracy is that people
and communities have a right to participate in decisions that
affect their lives, their property, and the things they value.
Guidelines; Demonstrate your respect for the public and
sincerity by involving the community early, before important
decisions are made. Involve all parties that have an interest or
a stake in the issue under consideration. If you are a
government employee, remember that you work for the public. If
you do not work for the government, the public still holds you
accountable.
Point to Consider;
o The goal of risk communication in a democracy should
not be to diffuse public concerns or replace action;
rather, it should be to produce an informed public that
is involved, interested, reasonable, thoughtful,
solution-oriented, and collaborative.
RULE 2. PLAN CAREFULLY AND EVALUATE YOUR EFFORTS.
Risk communication will be successful only if carefully planned.
Guidelines: Begin with clear, explicit risk communication
objectives such as providing information to the public,
motivating individuals to act, stimulating response to
emergencies, or contributing to the resolution of conflict.
Determine if you have sufficient information to discuss the
risks. Classify and segment the various groups among your
audience. Aim your communications at specific subgroups in your
audience. Recruit spokespeople who are good at presentation and
interaction. Train your staffincluding technical staffin
communication skills; reward outstanding performance. Whenever
possible, pretest your messages. Carefully evaluate your efforts
and learn from your mistakes.
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Points to Consider;
o There is no such entity as "the public;" instead, there
are many publics, each with its own interests, needs,
concerns, priorities, and preferences.
o Different risk communication goals, audiences, and
media require different risk communication strategies.
RULE 3. LISTEN TO THE PUBLIC'S SPECIFIC CONCERNS.
If you do not listen to people, you cannot expect them to listen
to you. Communication is a two-way activity.
Guidelines; Do not make assumptions about what people know,
think, or want done about risks. Take the time to find out what
people are thinking; use techniques such as interviews, focus
groups, and surveys. Let all parties that have an interest or a
stake in the issue be heard. Identify with your audience and try
to put yourself in their place. Recognize people's emotions.
Let people know that you understand what they said, addressing
their concerns as well as yours. Recognize the "hidden agendas,"
symbolic meanings, and broader economic or political
considerations that often underlie and complicate the task of
risk communication.
Point to Consider;
o People in the community are often more concerned about
such issues as trust, credibility, competence, control,
voluntariness, fairness, caring, and compassion than
about mortality statistics and the details of
quantitative risk assessment.
RULE 4. BE HONEST. FRANK. AND OPEN.
In communicating risk information, trust and credibility are your
most precious assets.
Guidelines; State your credentials; but do not ask or expect to
be trusted by the public. If you do not know an answer or are
uncertain, say so. Get back to people with answers. Admit
mistakes. Disclose risk information as soon as possible
(emphasizing any reservations about reliability). Do not
minimize or exaggerate the level of risk. Speculate only with
great caution. If in doubt, lean toward sharing more
information, not lessor people may think you are hiding
something. Discuss data uncertainties, strengths and weaknesses-
-including the ones identified by other credible sources.
Identify worst-case estimates as such, and cite ranges of risk
estimates when appropriate.
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Point to Consider:
o Trust and credibility are difficult to obtain. Once
lost they are almost impossible to regain completely.
RULE 5. COORDINATE AND COLLABORATE WITH OTHER CREDIBLE SOURCES.
Allies can be effective in helping you communicate risk
information.
Guidelines; Closely coordinate all inter-organizational and
intra-organizational communications. Devote effort and resources
to the slow, hard work of building bridges with other
organizations. Use credible intermediaries. Consult with others
to determine if you or someone else are best able to answer
questions about risk. Try to issue communications jointly with
other trustworthy sources (for example, credible university
scientists, physicians, or trusted local officials).
Point to Consider;
o Few things make risk communication more difficult than
conflicts or public disagreements with other credible
sources.
RULE 6. MEET THE NEEDS OF THE MEDIA.
The media are a prime transmitter of information on risks; they
play a critical role in setting agendas and in determining
outcomes.
Guidelines; Be open with and accessible to reporters. Respect
their deadlines. Provide risk information tailored to the needs
of each type of media (for example, graphics and other visual
aids for television). Prepare in advance and provide background
material on complex risk issues. Do not hesitate to follow up
on stories with praise or criticism, as warranted. Try to
establish long-term relationships of trust with specific editors
and reporters.
Point to Consider;
o The media are frequently more interested in politics
than in risk; more interested in simplicity than in
complexity; more interested in danger than in safety.
RULE 7. SPEAK CLEARLY AND WITH COMPASSION.
Technical language and jargon are useful as professional
shorthand. But they are barriers to successful communication
with the public.
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Guidelines; Use simple, non-technical language. Be sensitive to
local norms, such as speech and dress. Use vivid, concrete
images that communicate on a personal level. Use examples and
anecdotes take make technical risk data come alive. Avoid
distant, abstract, unfeeling language about deaths, injuries, and
illnesses. Acknowledge and respond (both in words and with
actions) to emotions that people express-anxiety, fear, anger,
outrage, helplessness. Acknowledge and respond to the
distinctions that the public views as important in evaluating
risks, e.g., voluntariness, controllability, familiarity, dread,
origin (natural or man-made), benefits, fairness, and
catastrophic potential. Use risk comparisons to help put risks
in perspective; but avoid comparisons that ignore distinctions
that people consider important. Always try to include a
discussion of actions that are under way or can be taken. Tell
people what you cannot do. Promise only what you can do, and be
sure to do what you promise.
Points to Consider:
o Regardless of how well you communicate risk
information, some people will not be satisfied.
o Never let your efforts to inform people about risks
prevent you from acknowledgingand sayingthat any
illness, injury, or death is a tragedy.
o If people are sufficiently motivated, they are quite
capable of understanding complex risk information, even
if they may not agree with you.
Vincent T. Covello is Director of the Center for Risk
Communication at Columbia University and is currently President
of the Society for Risk Analysis. Frederick W. Allen is
Associate Director of the Office of Policy Analysis at the
Environmental Protection Agency. Both direct risk communication
projects for their organizations. The views expressed here are
solely those of the authors and do not necessarily represent the
views of their organizations. The authors invite your comments.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/5-88-003
4. TITLE AND SUBTITLE
National Air Toxics Information Clearinghouse:
Studies in Risk Communication
Case
3. RECIPIENT'S ACCESSION NO.
5 RFP^RT DATE
June 1988
6. PERFORMING ORGANIZATION CODE
7. AUTHOR (S)
Radian Corporation
3200 Progress Center. P- 0. Box 13000
- Park, NP. 9770Q
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Radian Corporation
3200 Progress Center
Research Triangle Park, NC 27709
1O. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-4330
12. SPONSORING AGENCY NAME AND ADDRESS
US Environmental Protection Agency
Office of Air Quality Planning & Standards, ESD
Pollutant Assessment Branch, MD-13
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This report provides guidance on risk communication to State and local agencies
that are beginning to undertake quantitative cancer risk assessments. The report
presents case studies on risk communication efforts undertaken by Puget Sound
(Washington) Air Pollution Control Agency and the San Diego County (California)
Air Pollution Control District, as well as the risk communication procedures of
Maryland's Department of the Environment. The case studies briefly describe the
course, the risk assessment approach, and results of the risk assessment. The
report also discusses the characterization of risk assessment results, the process
for communicating risk, and an evaluation of the risk communication effort conducted
by each of the three agencies.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS.'OPEN ENDED TERMS C. COSATI FieW/GtOUp
Risk Communication
Risk Characterization
Risk Assessment
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report!
Unclassified
21. NO. OF PAGES
61
20. SECURITY CLASS (Thi
Unclassified
22. PRICE
EPA Form 2220-1 (R«r. 4-77) PREVIOUS EDITION is OBSOLETE
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