Review of the National Ambient Air Quality
    Standards for Ozone:


    Policy Assessment of Scientific
    and Technical Information

    OAQPS Staff Paper - First Draft
                                     U S EPA Headquarters Library
                                        Mail code 3404T
                                     1200 Pennsylvania Avenue NW
                                      Washington, DC 20460
                                         202-566-0556
D

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                                              EPA-452/D-05-002
                                                November 2005
Review of the National Ambient Air Quality
Standards for Ozone:

Policy Assessment of Scientific
and Technical Information

OAQPS Staff Paper - First Draft
                 U.S. Environmental Protection Agency
               Office of Air Quality Planning and Standards
                 Research Triangle Park, North Carolina

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                                  DISCLAIMER

      This document has been reviewed by the Office of Air Quality Planning and Standards
(OAQPS), U.S. Environmental Protection Agency (EPA), and approved for publication. This
first draft OAQPS Staff Paper contains the preliminary draft conclusions of the staff of the
OAQPS and does not necessarily represent those of the EPA.  Mention of trade names or
commercial products is not intended to constitute endorsement or recommendation for use.

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                         TABLE OF CONTENTS


List of Tables	viii
.List of Figures	x

1.    INTRODUCTION	1-1
   1.1   PURPOSE	1-1
   1,2   BACKGROUND	'.	1-2
      1.2.1    Legislative Requirements	1-2
      1.2.2    History of Ozone NAAQS Reviews	1-3
      1.2.3    Litigation Related to the 1997 Ozone Standards	1-5
      1.2.4    Current Ozone NAAQS Review	'.	1-6
   1.3   GENERAL APPROACH AND ORGANIZATION OF THE DOCUMENT	1-7
   REFERENCES	..:	1-9


2.    AIR QUALITY CHARACTERIZATION	2-1
   2.1   INTRODUCTION	':	2-1
   2.2   CHEMICAL AND PHYSICAL PROPERTIES, FORMATION, AND
         TRANSPORT	2-1
      2.2.1    Chemical and Physical Properties	2-1
      2.2.2    Formation	2-2
      2.2.3    Transport	2-2
      2.2.4    Precursors, Sources and Emissions	2-3
      2.2.5    Tropospheric vs. Stratospheric Ozone	2-3
   2.3   DATA SOURCES	2-8
      2.3.1    Air Quality System (AQS)	2-8
      2.3.2    CASTNET	2-10
   2.4   OZONE MONITORING METHODS AND ISSUES	2-10
   2.5   CHARACTERIZATION OF GROUND-LEVEL OZONE
         CONCENTRATIONS	2-11
      2.5.1    Metrics	2-11
      2.5:2    Spatial Variability	2-12
         2.5.2.1  8-hour and 1-hour Statistics	2-12
         2,5.2.2  Cumulative Seasonal Statistics	2-12
      2.5.3    Temporal Variability	2-15
         2.5.3.1  Long Term Variability - Trends	2-15
         2.5.3.2  Seasonal Variability	2-24
         2.5.3.3  Short Term Variability-Diurnal	2-24
   2.6   CHARACTERIZATION OF OZONE EPISODES	2-29
   '2.7   BACKGROUND LEVELS	2-36
   REFERENCES	2-43


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3.    POLICY-RELEVANT ASSESSMENT OF HEALTH EFFECTS EVIDENCE	3-1
   3.1    INTRODUCTION	3,1
   3.2    MECHANISMS	3-3
      3.2.1     Direct Pulmonaiy Effects	3-3
          3.2.1.1   Breathing Pattern Changes	3-4
          3.2.1.2   Symptoms and Lung Function Changes	3-4
          3.2.1.3   Airway Hyperresponsiveness	3-4
      3.2.2     Extrapulmonary Effects	3-5
   3.3    NATURE OF EFFECTS	3-6
      3.3.1     Morbidity	3-6
          3.3.1.1   Emergency Department Visits/Hospital Admissions for Respiratory
                  Causes	3-7
          3.3.1.2   Effects on the Respiratory System from Short-term Exposures	3-8
             3.3.1.2.1  Pulmonary Function Decrements, Respiratory Symptoms,
                      and Asthma Medication Use	3-9
             3.3.1.2.2  Airway Responsiveness	3-12
             3.3.1.2.3  Respiratory Inflammation and Permeability	3-13
             3.3.1.2.4  Changes in Host Defense Capability	3-15
             3.3.1.2.5  Morphological Effects	3-16
             3.3.1.2.6  Effects on Exercise Performance	3-17
             3.3.1.2.7  Increased School Absences	3-17
          3.3.1.3   Effects on the Respiratory System from Long-term Exposures	3-18
             3.3.1.3.1  Seasonal Ozone Effects on Lung Function	3-18
             3.3.1.3.2  Reduced Baseline Lung Function and Respiratory Symptoms	3-19
             3.3.1.3.3  Long-term Oa Exposure and Respiratory Inflammation	3-21
             3.3.1.3.4  Risk of Asthma Development	3-22
             3.3.1.3.5  Morphological Effects	:	3-23
             3.3.1.3.6  Summary	3-23
          3.3.1.4   Effects on the Cardiovascular System	3-23
      3.3.2     Premature Mortality	3-25
          3.3.2.1   Mortality and Short-term O3 Exposure	3-25
          3.3.2.2   Mortality and Long-term O3 Exposure	3-28
      3.3.3     Summary	3-30
   3.4    INTEGRATIVE ASSESSMENT OF EVIDENCE FROM EPIDEMIOLOGICAL
          STUDIES	3-31
      3.4.1     Strength of Associations	3-32
      3.4.2     Robustness of Associations	3-33
          3.4.2.1   Exposure Error	3-33
          3.4.2.2   Confounding by Copollutants	3-34
          3.4.2.3   Model Specification	-.	3-35
      3.4.3     Consistency	.-	3-36
      3.4.4     Temporality	3-37
      3.4.5     Lag Structure in Short-term Exposure Studies	3-37
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      3.4.6     Concentration-Response Relationships and Potential Thresholds	3-39
   3.5   BIOLOGICAL PLAUSIBILITY AND COHERENCE OF EVIDENCE	3-40
      3.5.1     Coherence and Plausibility of Short-term Effects on the Respiratory System	
                	3-41
      3.5.2     Coherence and Plausibility of Effects on the Cardiovascular System	3-48
      3.5.3     Coherence and Plausibility of Effects Related to Long-Term O3
               Exposure	3-49
      3.5.4     Coherence and Plausibility of Mortality-Related Health Endpoints	3-50
   3.6   OZONE-RELATED IMPACTS ON PUBLIC HEALTH	3-51
      3.6.1     Factors which Modify Responsiveness to Ozone	3-51
      3.6.2     Susceptible Population Groups	:	3-53
         3.6.2.1  Active People	3-53
         3.6.2.2  People with Lung Disease	3-53
         3.6.2.3  Children and Older Adults	3-54
         3.6.2.4  People with Increased Responsiveness to Ozone	3-56
         3.6.2.5  Other Population Groups	3-57
      3.6.3     What Constitutes an Adverse Health Impact from Ozone Exposure?	3-57
   3.7   SUMMARY AND CONCLUSIONS FOR OZONE HEALTH EFFECTS	3-63
     1 3.7.1     Morbidity Health Effects of Acute (Short-term) Exposures to Ozone	3-63
      3.7.2     Mortality-Related Health Effects of Short-term Exposures to Ozone	3-67
      3.7.3     Heallh Effects of Repeated Short-term Exposures to Ozone	3-67
      3.7.4     Health Effects of Long-term Exposures to Ozone	3-68
      3.7.5     Health Effects of Binary Pollutant Mixtures Containing Ozone	3-68
      3.7.6     Populations At Risk and Susceptibility Factors Associated With Ozone
               Exposure	3-69
      REFERENCES	3-71

4.    CHARACTERIZATION OF HUMAN EXPOSURE TO OZONE	4-1
   4.1   INTRODUCTION	4-1
   4.2   OZONE EXPOSURE STUDIES	4-2
      4.2.1     Exposure Concepts and Definitions	4-2
      4.2.2     Monitoring Equipment Considerations	4-3
      4.2.3     Personal Ozone Exposure Assessment Studies	4-4
      4.2.4     Microenvironmental Studies	4-5
   4.3   EXPOSURE MODELING	4-5
      4.3.1     The APEX Model	4-6
      4.3.2     Key Algorithms	4-7
      4.3.3     Model Output	4-11
      4.3.4     Limitations of the Model	4-13
         4.3.4.1  Estimation of Ambient Air Quality	4-13
         4.3.4.2  Estimation of Concentrations in Indoor Microenvironments	4-14
                 4.3.4.2.1 Air Exchange Processes	4-14
                 4.3.4.2.2 Deposition Processes...	4-15
                 4.3.4.2.3 Chemical Reaction Processes	4-15
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         4.3.4.3  Characterization of Population Demographics and Activity Patterns	4-15
         4.3.4.4  Modeling Physiological Processes	4-16
   4.4   SCOPE OF EXPOSURE ASSESSMENTY	4-16
      4.4.1     Selection of Urban Areas to be Modeled	4-16
      4.4.2     Time Periods Modeled	4-16
      4.4.3     Populations Modeled	'.	4-17
   4.5   INPUTS TO THE EXPOSURE MODEL	4-18
      4.5.1     Population Demographics	4-18
      4.5.2     Population Commuting Patterns	4-19
      4.5.3     Human Activity Data	4-19
      4.5.4     Physiological Data	4-20
      4.5.5     Microenvironments Modeled	4-23
      4.5.6     Ambient Ozone Concentrations	4-23
      4.5.7     Meteorological Data	4-25
   4.6   EXPOSURE ASSESSMENT RESULTS	4-25
   REFERENCES	4-33
5.    CHARACTERIZATION OF  HEALTH RISKS	5-1
   5.1   INTRODUCTION	5-1
      5.1.1     Overview of Risk Assessment From Last Review	5-1
      5.1.2     Development of Approach for Current Risk Assessment	5-2
   5.2   SCOPE OF OZONE HEALTH RISK ASSESSMENT	5-4
      5.2.1     Selection of Health Endpoint Categories	5-5
      5.2.2     Selection of Study Areas..	5-7
      5.2.3     Air Quality Considerations	5-8
   5.3   COMPONENTS OF THE RISK MODEL	5-9
      5.3.1     Assessment of Risk Based on Controlled Human Exposure Studies	5-9
         5.3.1.1  General Approach	5-9
         5.3.1.2  Exposure Estimates	5-13
         5.3.1.3  Exposure Response Functions	5-13
         5.3.1.4  Characterizing Uncertainty and Variability	5-14
      5.3.2     Assessment of Risk Based on Epidemiological Studies.:	5-16
         5.3.2.1  General Approach	5-16
         5.3.2.2  Air Quality Considerations	5-19
         5.3.2.3  Concentration-Response Functions	5-20
         5.3.2.4  Baseline Health Effects Incidence and Population Estimates	5-23
         5.3.2.5  Characterizing Uncertainty and Variability	5-27
   5.4   OZONE RISK ESTIMATES	5-30
      5.4.1     Recent Air Quality	5-30
      5.4.2     Just Meeting Current Ozone Standards	5-48
      5.4.3     Just Meeting Alternative Ozone Standards [to be included in next draft
               of Staff Paper]	:	5-61
      5.4.4     Key Observations [to be included in next draft of Staff Paper]	5-61
   REFERENCES	5-62


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6.    STAFF CONCLUSIONS AND RECOMMENDATIONS ON PRIMARY O3
      NAAQS	:	6-1
   6.1    INTRODUCTION	6-1
   6.2    APPROACH	6-2
   6.3    PRIMARY O3 STANDARD...:	6-4
      6.3.1    Adequacy of Current O3 Standard	6-4
         6.3.1.1   Evidence-based Considerations	6-5
            6.3.1.1.1  Respiratory Morbidity	:	6-5
            6.3.1,1.2  Cardiovascular Morbidity	6-7
            6.3.1.1.3  Mortality	6-8
         6.3.1.2   Risk-based Considerations	6-8
         6.3.1.3   Summary	6-14
      6.3.2    Indicator	6-14
      6.3.3    Averaging Time	6-15
         6.3.3.1   Short-Term and Prolonged (1 to 8 hours)	:	6-15
         6.3.3.2   Long-Term.....	.'	6-16
      6.3.4    Form	!	6-17
      6.3.5    Level	6-18
      6.3.6    Summary of Alternative Standards to Be Considered in Additional Exposure
      and Risk Analyses	'.	6-22
   6.4    SUMMARY OF KEY UNCERTAINTIES AND RESEARCH
         RECOMMENDATIONS RELATED TO SETTING A PRIMARY 03 STANDARD
         [TO BE INCLUDED IN THE NEXT DRAFT STAFF PAPER].	6-22
   REFERENCES	6-23
7.    POLICY-RELEVANT ASSESSMENT OF WELFARE EFFECTS EVIDENCE.. 7-1
   7.1    INTRODUCTION	7-1
   7.2    EFFECTS ON VEGETATION	7-2
      7.2.1    Exposure Methodologies Used in Vegetation Research	7-3
      7.2.2    Species (Intra-Plant) Response/Mode of Action	7-6
         7.2.2.1   Entry of Ozone into the Leaf	7-6
         7.2.2.2   Reactions of Oa and possible reaction product(s) at cell surfaces	7-8
         7.2.2.3   Movement of an O3 reaction product(s) into the cell with enzymatic or
         chemical transformation of those products in the cell	7-8
         7.2.2.4   Ozone Initiated Wounding and Pathogen Attack Response	7-9
         7.2.2.5   Defense and Compensation Mechanisms	7-10
         7.2.2.6   Changes to Plant Metabolism	7-10
         7.2.2.7   Relationships Between Age and Size and Ozone Response	7-12
      7.2.3    Factors That Modify Functional and Growth Response	7-12
         7.2.3.1   Genetics	7-13
         7.2.3.2   Biological Factors	7-13
         7.2.3.3   Physical Factors	•.	7-14
         7.2.3.4   Chemical Factors	7-15
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      7.2.4    Effects-Based Air Quality Exposure Indices	7-17
          7.2.4.1   Concentration-based Forms	7-18
          7.2.4.2   Flux-based forms	7-20
          7.2.4.3   The Critical Level Approach	7-21
          7.2.4.4   Summary	7-22
      7.2.5    Ozone Exposure-Plant Response Relationships	7-23
   7.3    VEGETATION IMPACT ASSESSMENT	7-27
      7.3.1    Overview	7-27
      7.3.2    Air Quality Analysis	7-29
          7.3.2.1   Monitor coverage	7-29
          7.3.2.2   Modeling tools	7-30
          7.3.2.3   Generation of Potential Ozone Exposure Surfaces	7-33
          7.3.2.4   Alternative Air quality scenarios	7-34
      7.3.3    Crop Risk/Benefits Assessments	7-34
          7.3.3.1   Exposure Assessment	7-36
          7.3.3.2   Crop yield loss Assessment	7-36
          7.3.3.3   Economic Benefits Assessment - AGSIM	7-38
      7.3.4    Tree Seedling/Mature Tree/Forest Species Quantitative/Qualitative Risk
               Assessments	7-38
          7.3.4.1   Selected Species Exposure Assessment	7-39
          7.3.4.2   Selected Tree Seedling Biomass Loss	7-39
          7.3.4.3   Foliar Injury Incidence/Epidemiology - FIA Data	7-39
          7.3.4.4   Ponderosa Pine case study for mature tree	7-44
   7.4    ECOSYSTEM CONDITION, FUNCTION AND SERVICES	7-45
      7.4.1    Evidence Demonstrating the Potential for Ozone to Alter Ecosystem Structure
               and Function	7-48
      7.4.2    Effects on  Ecosystem Products and Services	7-49
          7.4.2.1   Carbon Sequestration	7-49
          7.4.2.2   Water Resources	7-50
      7.4.3    Research needs	7-50
REFERENCES	7-53


APPENDIX 3A:
      Ozone Epidemiological Study Results	3A-1
APPENDIX 4A:
      Microenvironment Modeling Parameters	4A-1

APPENDIX 4B:
      Frequency Distributions of Daily Maximum 8-Hour Average Ozone      Concentrations
      4B-1

APPENDIX 4C:
      Exposures for Exercising Children	4C-1
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APPENDIX 4D:
      Grid Points used for Policy Relevant Background in 12 Cities.
                                   .4D-1
APPENDIX 5A:
      Monitor-Specific Oj Air Quality Information	5A-1

APPENDIX SB:
      Summary of Locations, Concentration-Response Functions, Months Included and
      Counties Included	5B-1

APPENDIX 5C:
      Tables of Study-Specific Information	5C-1
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                                  List of Tables
Number
                     Page
2-1, VOC emission sources, 1970-2004	2-4
2-2. NOX emission sources, 1970-2004	2-6

3-1. Acute Oa-induced Physiological and Biochemical Changes in Humans and Animals	3-42
3-2. Gradation of Individual Responses to Short-Term Ozone Exposure in Healthy Persons. 3-60
3-3. Gradation of Individual Responses to Short-Term Ozone Exposure in Persons with
    Impaired Respiratory Systems	3-61
3-4. Summary of Ozone-Induced Respiratory Health Effects from Clinical Studies	3-65

4-1. Exertion Levels in Terms of Equivalent Ventilation Rates	4-12
4-2. Urban Areas and Time Periods Modeled	4-17
4-3. Population Coverage of Modeled Areas	4-18
4-4. Studies in CHAD	4-21
4-5. Microenvironments Modeled	^	4-23
4-6. 2002-2004 8-Hour Ozone Design Values for the Modeled Areas	4-24
4-7. Numbers of Person-Days Over the Modeled Periods With Daily Maximum 8-Hour Average
    Exposures Above 0.08 ppm Under Moderate Exertion	4-27
4-8. Numbers of Persons With At Least One Daily Maximum 8-Hour Average Exposure Above
    0.08 ppm Under Moderate Exertion Over the Modeled Periods	4-28
4-9. Numbers of Persons With At Least One Daily Maximum 8-Hour Average Exposure Above
    0.08 ppm Under Moderate Exertion Over the Modeled Periods (percent of population
    group)	4-29
4-10. Numbers of Person-Days Over the Modeled Periods with Daily Maximum 8-Hour
     Average Exposures Above 0.07 ppm Under Moderate Exertion	4-30
4-11. Numbers of Persons With at Least One Daily Maximum 8-hour Average Exposure Above
     0.07 ppm Under Moderate Exertion Over the Modeled Period	4-31
4-12. Numbers of Persons With at Least One Daily Maximum 8-hour Average Exposure Above
     0.07 ppm Under Moderate Exertion Over the Modeled Period (percent of population
     group)	4-32

5-1. Locations and Health Endpoints Included in the Ozone Risk Assessment Based on
    Epidemiological Studies	5-22
5-2. Relevant Population Sizes for Ozpme Risk Assessment Locations*	5-24
5-3. Baseline Mortality Rates (per 100,000 Population) for 2002 for Ozone Risk Assessment
    Locations*	5-25
5-4. Baseline Rates for Hospital Admissions	.•	5-26
5-5. Comparison of Number and Percent of School Age Children and Active School Age
    Children Estimated to Experience Lung Function Responses Associated with 8-Hour
    Ozone Exposure While Engaged in Moderate Exertion	5-32
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5-6.  Comparison of Number and Percent of Occurrences of Lung Function Responses
     Associated with 8-Hour Ozone Exposure While Engaged in Moderate Exertion	5-34
5-7.  Estimated Non-Accidental Mortality Associated with Recent Ozone Concentrations (April -
     September, 2004)	5-41
5-8.  Estimated Cardiovascular and Respiratory Mortality Associated with Recent Ozone
     Concentrations (April - September, 2004)	5-44
5-9.  Estimated Hospital Admissions Associated with Recent Ozone Concentrations in New
     York, NY* (April - September, 2004)	5-46
5-10. Estimated Non-Accidental Mortality Associated with Ozone Above Background When the
     Current 8-Hour Standard is Just Met (April - September)	5-54
5-11. Estimated Cardiovascular and Respiratory Mortality Associated with Ozone
     Concentrations: that Just Meet the Current 8-Hour Daily Maximum Standard (April -
     September):	5-57
5-12. Estimated Hospital Admissions Associated with Ozone Above Background In New York,
     NY* When the Current 8-Hour Standard is Just Met (April -  September)	5-59

6-1.  Summary of Estimates of Number of people Exposed and Number of Occurrences
     Associated with 8-Hour Daily Maximum Ozone Concentrations Above 0.08 ppm for 12
     Urban Areas in the U.S. (from Tables 4-7 and 4-8)	6-11
6-2.  Summary of Comparison of Median Number of Children and Median Number of
     Occurrences Associated with 8-Hour Ozone Exposure Among All Children and Among
     Active Children While Engaged in Moderate Exertion in 12 Urban Areas in the U.S. (from
     Tables 5-5  and 5-6)	,	6-12
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                                  List of Figures
Number
                     Page
2-1.  Locations of Monitors from AQS and CASTNET	2-11
2-2.  4th Highest Daily Maximum 8-Hour Values in U.S. Counties, 2002-2004	2-13
2-3 . 2nd Highest Daily Maximum 1-Hour Values in U.S. Counties, 2002-2004	2-14
2-4.  Highest 3-month SUM06 Exposure Index in US. Counties, 2001 AQS Data	2-16
2-5.  Highest 3-month W126 Exposure Index in U.S. Counties, 2001 AQS Data	2-17
2-6.  Highest 3-month SUM06 Exposure Index in U.S. Counties, 2001
     CASTNET Data.	2-18
2-7.  Highest 3-month W126 Exposure Index in U.S. Counties, 2001
     CASTNET Data	2-19
2-8.  4th highest daily maximum 8-hour ozone values 1990-2004 (Urban)	2-20
2-9.  4th highest daily maximum 8-hour ozone values 1990-2004 (Rural)	2-21
2-10. 2nd highest daily maximum 1-hour ozone values 1990-2004 (Urban)	2-22
2-11. 2nd highest daily maximum 1-hour ozone values 1990-2004 (Rural)	2-23
2-12. 2nd highest daily maximum 1 -hour ozone values from 2004 by month	'.	2-25
2-13. 4th highest daily maximum 8-hour ozone values from 2004 by month	2-26
2-14. 1-Hour Diurnal Week Day Pattern for Urban Sites, May through September 2004	2-27
2-15. 8-Hour Diurnal Week Day Pattern for Urban Sites, May through
      September 2004	2-28
2-16. 1-Hour Week Day Diurnal Pattern for Rural Sites, May through
     September 2004	'.	2-30
2-17. 1-Hour Week End Diurnal Pattern for Rural Sites, May through
     September 2004	2-31
2-18. 8-Hour Week Day Diurnal Pattern for Rural Sites, May through
     September 2004	2-32
2-19. 8-Hour Week End Diurnal Pattern for Rural Sites, May through
     September 2004	2-33
2-20. Length of Episodes over 0.12 ppm by Year for 1-hour O3 Data	2-34
2-21. Length of Episodes over 0.08 ppm by Year for 8-hour 63 Data.	2-35
2-22. Length of Episodes over Levels for 1-hour O3 Data (2000-2004)	2-37
2-23. Length of Episodes over Levels for 8-hour O3 Data (2000-2004)	2-38
2-24. Length of Gaps in Days Between  Episodes over O.OSppm for 8-hour O3
      Data (2000-2004)	2-39
2-25. Length of Gaps in Days Between  Episodes over 0.12ppm for 8-hour O3
      Data (2000-2004)	2-40

3-1.  Resolution Time-Line for Acute Ozone-Induced Physiological and Biochemical
     Responses in Humans	3-43
3-2.  Postulated Cellular and Molecular Changes in Human Airway Epithelial Cells on Acute
     Exposure to Ozone.....	3-44
3-3.  Effect Estimates from U.S. and Canadian Studies	3-46
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4-1 APEX Diagram	4-8

5-1.  Major Components of Ozone Health Risk Assessment Based on Controlled Human
     Exposure Studies	5-11
5-2.  Major Components of Ozone Health Risk Assessment Based on Epidemiological
     Studies	;	5-17
5-3.  Estimated (Non-Accidental) Mortality Associated with Short-Term Exposure to Ozone
     Above Background:  Single-Pollutant, Single-City Models                ,
     (April - September, 2004)	5-37
5-4.  Estimated (Non-Accidental) Mortality Associated with Short-Term Exposure to Ozone
     Above Background (April — September, 2004):  Single-City Model (left bar) vs.
     Multi-City Model (right bar)	^	5-38
5-5.  Estimated Cardiovascular and Respiratory Mortality Associated with Short-Term
     Exposure to Ozone Above Background (April - September, 2004):  Single-City Model
     (left bar) vs. Multi-City Model (right bar) - Based on Huang et al. (2004)	.'	5-39
5-6.  Estimated Cardiovascular and Respiratory Mortality Associated with Short-Term Exposure
     to Ozone Above Background (April - September, 2004):  Single-Pollutant vs. Multi-
     Pollutant Models [Huang et al. (2004), additional pollutants, from left to right: none,
     PM10,NO2,SO2,CO].:	".	5-40
5-7.  Estimated (Unscheduled) Hospital Admissions in Detroit Associated with Short-Term
     Exposure to Ozone Above Background (April - September, 2004):  Different Lag Models
     - Based on Ito (2003) [bars from left to right are 0-day, 1-day, 2-day, and 3-day lag
     models]	*	5-50
5-8.  Estimated (Non-Accidental) Mortality Associated with Short-Term Exposure to Ozone
     Above Background When the Current 8-Hour Standard is Just Met (April - September):
     Single-City Model (left bar) vs. Multi-City Model (right bar)..:.	5-51
5-9.  Estimated Cardiovascular and Respiratory Mortality Associated with Short-Term Exposure
     to Ozone Above Background When the Current 8-Hour Standard is Just Met (April -
     September):  Single-City Model (left bar) vs. Multi-City Model (right bar) - Based on
     Huang et al. (2004)	;	5-52
5-10. Estimated Cardiovascular and Respiratory Mortality Associated with Short-Term Exposure
     to Ozone Above Background When the Current 8-Hour Standard is Just Met (April -
     September):  Single-Pollutant vs. Multi-Pollutant Models [Huang et al. (2004), additional
     pollutants, from left to'right:  none,PM10,NO2, SO2, CO]	5-53

6-1.  Odds ratios for associations between Os and respiratory symptoms; and effect estimates for
     associations between'Os and hospitalization for respiratory diseases	6-21

7-l(a-c).  Major  Components of Planned Environmental Assessment	7-28
7-2.  Locations of AQS monitors (top) .and CASTNET monitoring stations	7-32
7-3.  Range of planted soybean for the year 2001	7-37
7-4.  County-level 4ht highest maximum 8-hour averages for 2001	7-42
7-5.  County-level max 3month 12-hour SUM06 for 2001	7-43
7-6.  Common anthropogenic stressors and the essential ecological attributes they affect.
     Modified from Young and Sanzone (2002)	7-47
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 1                                  1.   INTRODUCTION

 2    1.1   PURPOSE
 3          This draft Staff Paper, prepared by staff in the U.S. Environmental Protection Agency's
 4    (EPA) Office of Air Quality Planning and Standards (OAQPS), evaluates the policy implications
 5    of the key studies and scientific information contained in the draft document, Air Qualify
 6    Criteria for Ozone and Related Photochemical Oxidants: T* External Review Draft (USEPA,
 7    2005b; henceforth referred to as the draft CD), prepared by EPA's National Center for
 8    Environmental Assessment (NCEA).  This draft Staff Paper also presents and interprets initial
 9    results from several staff analyses (e.g., air quality analyses, human exposure analyses, and
10    human health risk assessments) and discusses plans for a staff environmental assessment of
11    vegetation-related impacts. Staff believes that these analyses should be considered in EPA's
12    current review of the national ambient air quality standards (NAAQS) for ozone (63). This draft
13    Staff Paper identifies alternative standard options for purposes of conducting additional exposure
14    and risk analyses but does not present staff conclusions and recommendations as to potential
15    revisions of the primary (health-based) and secondary (welfare-based) Oa NAAQS.
16          The policy assessment to be presented in the final version of this Staff Paper is intended
17    to help "bridge the gap" between the scientific review contained in the draft CD and the
18    judgments required of the EPA Administrator in determining whether it is appropriate to revise
19    the NAAQS for Os.  Emphasis will be placed on identifying those conclusions and uncertainties
20    in the available scientific literature that the staff believes should be considered in selecting an
21    indicator, averaging times, forms1, and levels for the primary (health-based) and secondary
22    (welfare-based) standards, which must be considered collectively in evaluating the health and
23    welfare protection afforded by O3 standards.  The final Staff Paper will evaluate the policy
24    implications of the key studies and scientific information contained in the final CD (targeted for
25    completion by February 2006), identify the critical elements  that EPA staff believes should be
26    considered in the current review of the NAAQS for Os, and present factors relevant to the
27    evaluation  of current primary and secondary  Os NAAQS, as  well as staff conclusions and
28    recommendations of options  for the Administrator to consider.
29          This draft Staff Paper is being provided to CASAC and the public for review at a meeting
30    planned for December 2005.  Following that meeting, staff will complete the human exposure
     " -      The "form" of a standard defines the air quality statistic that is to be compared to the level of the standard
     in determining whether an area attains the standard.
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 1    analyses and health risk assessment and conduct an environmental assessment of vegetation-
 2    related impacts. Taking CAS AC and public comments on this first draft Staff Paper into
 3    account, staff will prepare a second draft Staff Paper, to be based on the final CD, and will make
 4    that draft document available for further review and comment by CASAC and the public.
 5           While this document should be of use to all parties interested in the 63 NAAQS review, it
 6    is written for those decision makers; scientists, and staff who have some familiarity with the
 7    technical discussions contained in the draft CD.

 8    1.2   BACKGROUND
 9           1.2.1  Legislative Requirements
10           Two sections of the Clean Air Act (Act) govern the establishment and revision of the
11    NAAQS. Section 108 (42 U.S.C: 7408) directs the Administrator to identify "air pollutants" that
12    "in his judgment, may reasonably be anticipated to endanger public health and welfare" and
13    whose "presence... in the ambient air results from numerous or diverse mobile or stationary
14    sources" and, if listed, to issue air quality criteria for them. These air quality criteria are intended
15    to "accurately reflect the latest scientific knowledge useful in indicating the kind and extent of
16    identifiable effects on public health or welfare which may be expected from the presence of [a]
17    pollutant in ambient air...."
18           Section 109 (42 U.S.C. 7409) directs the Administrator to propose and promulgate
19    "primary" and "secondary" NAAQS for pollutants identified under section 108. Section
20    109(b)(l) defines a primary standard as one "the attainment  and maintenance of which in the
21    judgment of the Administrator, based on such criteria and allowing an adequate margin of safety,
22    are requisite to protect the public health."2 A secondary standard, as defined in Section
23    109(b)(2), must "specify a level of air quality the attainment and maintenance of which, in the
24    judgment of the Administrator, based on such criteria, is requisite to protect the public welfare
25    from any known or anticipated adverse effects associated with the presence of [the] pollutant in
26    the ambient air."3
              The legislative history of section 109 indicates that a primary standard is to be set at "the maximum
      permissible ambient air level... which will protect the health of any [sensitive] group of the population," and that
      for this purpose "reference should be made to a representative sample of persons comprising the sensitive group
      rather than to a single person in such a group" [S. Rep. No. 91-1196, 9l" Cong., 2d Sess. 10 (1970)].

             3 Welfare effects as defined in section 302(h) [42 U.S.C. 7602(h)] include, but are not limited to, "effects
      on soils, water, crops, vegetation, man-made materials, animals, wildlife, weather, visibility and climate, damage to
      and deterioration of property, and hazards to transportation, as well as effects on economic values and on personal
      comfort and well-being."
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 1 .         In setting standards that are "requisite" to protect public health and welfare, as provided
 2    in section 109(b), EPA's task is to establish standards that are neither more nor less stringent
 3    than necessary for these purposes. In so doing, EPA may not consider the costs of implementing
 4    the standards. See generally Whitman v. American Trucking Associations, 531 U.S. 457,464,
 5    475-76(2001).               .                      •              .
 6          The requirement that primary standards include an adequate margin of safety was
 7    intended to address uncertainties associated with inconclusive scientific and technical
 8    information available at the time of standard setting. It was also intended to provide a reasonable
 9    degree of protection against hazards that research has not yet identified. Lead Industries
10    Association v. EPA, 647 F.2d 1130,1154 (D.C. Cir 1980), cert, denied. 101 S. Ct. 621 (1980);
11    American Petroleum Institute v. Costle, 665 F.2d 1176,1186 (D.C. Cir. 1981), cert, denied. 102
12    S.Ct. 1737(1982). Bom kinds of uncertainties are components of the risk associated with
13    pollution at levels below those at which human health effects can be said to occur with
14    reasonable scientific  certainty.  Thus, in selecting primary standards that include an adequate
15    margin of safety, the Administrator is seeking not only to prevent pollution levels that have been
16    demonstrated to be harmful but also to prevent lower pollutant levels that may pose an
17    unacceptable risk of harm, even if the risk is not precisely identified as to nature or degree.
18          In selecting a margin of safety, the EPA considers such factors as the nature and severity
19    of the health effects, the size of the sensitive population(s) at risk, and the kind and degree of the
20    uncertainties that must be addressed.  The selection of any particular approach to providing an
21    adequate margin of safety is a policy choice left specifically to the Administrator's judgment.
22    Lead Industries Association v. EPA, supra. 647 F.2d at 1161 -62.
23          Section 109(d)(l) of the Act requires that "not later than December 31,1980, and at 5-
24    year intervals thereafter, the Administrator shall complete a thorough review of the criteria
25    published under section 108 and the national ambient air quality standards ... and shall make
26    such revisions in such criteria and standards and promulgate such new standards as may be
27    appropriate . ..." Section 109(d)(2) requires that an independent scientific review committee
28    "shall complete a review of the criteria... and the national primary and secondary ambient air
29    quality standards .. . and shall recommend to the Administrator any new'. .. standards and
30    revisions of existing criteria and standards as may be appropriate...." Since the early 1980's,
31    this independent review function has been performed by the Clean Air Scientific Advisory
32    Committee (CAS AC), a standing committee of EPA's Science Advisory Board.
33          1.2.2  History of Ozone NAAQS Reviews
34          Tropospheric (ground-level) Os is formed from biogenic precursor emissions and as a
35    result of anthropogenic precursor emissions. Naturally  occurring Os in the troposphere can result
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 1   from biogenic organic precursors reacting with naturally occurring nitrogen oxides (NOX) and by
 2   stratospheric Os intrusion into the troposphere. Anthropogenic precursors of O3, specifically
 3   NOX and volatile organic compounds (VOC), originate from a wide variety of stationary and
 4   mobile sources. Ambient 63 concentrations produced by these emissions are directly affected by
 5   temperature, solar radiation, wind speed and other meteorological factors.  •
 6          The EPA initially established primary and secondary NAAQS for photochemical
 7   oxidants on April 30,1971 (36 FR 8186). Both primary and secondary standards were set at an
 8   hourly average of 0.08 parts per million (ppm), total photochemical oxidants, not to be exceeded
 9   more than one hour per year.
10          On February 8,1979, EPA completed its first periodic review of the criteria and
11   standards for O3 and other photochemical oxidants (44 FR 8202).  In that action, EPA made
12   significant revisions to the original standard:  the level of the primary and secondary NAAQS
13   was changed to 0.12 ppm; the indicator was changed to O3; and the form of the standards was
14   changed to be based on the expected number of days per calendar year with a maximum hourly
15   average concentration above 0.12 ppm (i.e., attainment of the standard occurs when that number
16   is equal to or less than one).
17          On March 9,1993, EPA concluded its second periodic review of the criteria and
18   standards for O3 by deciding that revisions to the O3 NAAQS were not warranted at that time (58
19   FR 13008).  The timing of this decision was required by a court order issued to resolve a lawsuit
20   filed to compel EPA to complete its  review of the criteria and standards for O3 in accordance
21   with the Act. This decision  reflected EPA's review of relevant scientific information assembled
22   since the last review, as contained in the 1986 03 CD (USEPA, 1986), its Supplement (USEPA,
23   1992) and the 1989 O3 Staff Paper (USEPA, 1989), although it did not take into consideration a
24   large number of studies on the health and welfare effects of O3 published since the literature was
25   last assessed in the O3 Supplement.  The final decision emphasized the Administrator's intention
26   to proceed as rapidly as possible with the next periodic review of the air quality criteria and
27   standards to consider the more recent information.
28          Under a court-ordered schedule and a highly accelerated review process, EPA completed
29   its third review of the O3 NAAQS on July 18,1997, based on the 1996 O3 CD (USEPA, 1996a)
30   and 1996 O3 Staff Paper (USEPA, 1996b). EPA revised the primary and secondary O3 standards
31   on the basis of the then latest scientific evidence linking exposures to ambient O3 to adverse
32   health and welfare effects at levels allowed by the 1-hr average standards (62 FR 38856). The
33   O3 standards were revised by replacing the existing primary 1-hr average standard with an 8-hr
34   average O3 standard set at a level of 0.08 ppm. The form of the primary standard was changed to
35   the annual fourth-highest daily maximum 8-hr average concentration, averaged over three years.
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 1   The secondary O3 standard was changed by making it identical in all respects to the revised
 2   primary standard.
 3          1.2.3   Litigation Related to the 1997 Ozone Standards
 4          Following promulgation of the revised O3 NAAQS, petitions for review were filed
 5   addressing a broad range of issues. On May 14,1999, in response to those challenges to EPA's
 6   1997 decision by industry and others, the U. S. Court of Appeals for the District of Columbia
 7   Circuit (D.C. Circuit) remanded the O3 NAAQS to EPA, finding that section 109 of the Act, as
 8   interpreted by EPA, effected an unconstitutional delegation of legislative authority.5 In addition,
 9   the D.C. Circuit Court directed that, in responding to the remand, EPA should consider the
10   potential beneficial health effects of O3 pollution in shielding the public from the effects of solar
11   ultraviolet (UV) radiation.
12          On January 27, 2000, EPA petitioned the U.S. Supreme Court for certiorari on the
13   constitutional issue (and two other issues) but did not request review of the D.C. Circuit ruling
14   regarding the potential beneficial health effects of 03. On February 27,2001, the U. S. Supreme
15   Court unanimously reversed the judgment of the D.C. Circuit on the constitutional issue, holding
16   that section 109 of the CAA does not delegate legislative power to the EPA in contravention of
17   the Constitution, and remanded the case to the D.C. Circuit Court to consider challenges to the
18   O3 NAAQS that had not been addressed by that Court's earlier decisions.6 On March 26,2002,
19   the D.C. Circuit Court issued its final decision, finding the 1997 O3 NAAQS to be "neither
20   arbitrary nor capricious," and denying the remaining petitions for review.7
21          On November 14,2001, EPA proposed to respond to the D.C. Circuit's remand to
22   consider the potential beneficial health effects of Os pollution in shielding the public from the
23   effects of solar (UV) radiation by leaving the 1997 8-hr NAAQS unchanged (66 FR 52768).
24   Taking into account public comment on the proposed decision, EPA published its final response
25   to this remand on January 6, 2003, reaffirming the 8-hr O3 NAAQS set in 1997 (68 FR 614).
26   Finally, on April 30,2004, EPA announced (69 FR 23966) the decision to make the 1 -hr O3
27   NAAQS no longer applicable to areas one year after the effective date of the designation of those
28   areas for the 8-hr NAAQS. For most areas the date that the 1 -hr NAAQS no longer applied was
29   June 15,2005. (See 40 CFR 50.9 for details.)
            5 American Trucking Associations v. EPA,.l15 F.3d 1027 (D.C. Cir., 1999)

            6 Whitman v. American Trucking Associations, 531 U.S. 457 (2001)

            7 American Trucking Associations v. EPA, 283 F.3d 355, (D.C. Cir. 2002)
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 1          1.2.4  Current Ozone NAAQS Review
 2          EPA initiated the current NAAQS review in September 2000 with a call for information
 3   (65 FR 57810). A project work plan (USEPA, 2002) for the preparation of the CD was released
 4   in November 2002 for CASAC and public review.  EPA held a series of workshops in mid-2003
 5   on several draft chapters of the CD to obtain broad input from the relevant scientific
 6   communities.  These workshops helped to inform the preparation of the first draft CD (EPA,
 7   2005a), which was released for CASAC and public review on January 31,2005.
 8          During the process of preparing the first draft CD, NCEA revised the planned format of
 9   the CD described in the 2002 work plan. These decisions were made as part of a collaborative
10   effort with OAQPS staff to modify the review process so as to enhance the Agency's ability to
11   meet this and future NAAQS review schedules. As described in Chapter 1 of the first draft CD,
12   emphasis is placed on interpretative evaluation and integration of evidence in the main body of
13   the document, with more detailed descriptions of individual studies being provided in a series of
14   accompanying annexes. This change is intended to streamline the document so as to facilitate
15   timely CASAC and public review and to focus more clearly on issues most relevant to the policy
16   assessment to be developed in the Staff Paper. The modified review process envisions that key
17   policy-relevant issues will be identified earlier in the review process through enhanced
18   collaboration between NCEA and OAQPS staff, leading to a more efficient linkage between the
19   CD and the Staff Paper. At the CASAC meeting held on May 4-5,2005, to review the first draft
20   CD, this new format for the CD was met with general approval of CASAC and the public. A
21   second draft CD (EPA, 2005b) was released for CASAC and public review on August 31, 2005.
22          The schedule for completion of this review is governed by a consent decree resolving a
23   lawsuit filed in March 2003 by a group of plaintiffs representing national environmental
24   organizations.  The lawsuit alleged that EPA had failed to perform its mandatory duty, under
25   section 109(d)(l), of completing the current review within the period provided by statute.
26   American Lung Association v. Whitman (No. 1:03CV00778, D.D.C. 2003). An initial consent
27   decree, entered by the court in July 2003, after an opportunity for public comment, was
28   subsequently modified in December 2003 and in April, July, and December 2004.  The modified
29   consent decree that now governs this review, entered by the court on December 16,2004,
30   provides that EPA will sign for publication notices of proposed and final rulemaking concerning
31   its review of the O3 NAAQS no later than March 28, 2007 and December 19,2007, respectively.
32   These dates are premised on the expectation that a series of interim milestones will be met,
33   including the release of a final CD by February 28, 2006, and release of a second draft Staff
34   Paper by April 2006, followed  by CASAC and public review by July 2006, with completion of a
35   final Staff Paper by September 2006.
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 1    13   GENERAL APPROACH AND ORGANIZATION OF THE DOCUMENT
 2          The policy assessment in this draft Staff Paper is based on staff's evaluation of the policy
 3    implications of the scientific evidence contained in the draft CD and initial results of quantitative
 4    analyses based on that evidence. Taken together, this information informs preliminary staff
 5    conclusions and recommendations on certain elements of the Os standards under review.  While
 6    the draft CD focuses on new scientific information available since the last review, it
 7    appropriately integrates that information with scientific criteria from previous reviews. The
 8    quantitative analyses presented in this draft Staff Paper (and described in more detail in technical
 9    support documents) are based on the most recently available air quality information, so as to
10    provide current characterizations of Os air quality patterns and estimated health and
11    environmental risks related to exposure to ambient Os concentrations.
12          Following this introductory chapter, this draft Staff Paper is  organized into three main
13    parts: the characterization of ambient Oj air quality data; Os-related health effects and primary
14    Oa NAAQS; and Os-related welfare effects and secondary Os NAAQS. The content of these
15    parts is discussed more fully below.
16          The characterization of ambient 63 air quality data is presented in Chapter 2 and includes
17    information on Oi properties, current OB air quality patterns, historic trends, and background
18    levels. This chapter provides a frame of reference for subsequent discussion of current and
19    alternative Oj NAAQS and alternative forms of 63 standards.
20          Chapters 3 through 6 comprise the second main part of this draft Staff Paper dealing with
21    human health and primary standards. Chapter 3 presents an overview of key policy-relevant
22    health effects evidence, major health-related conclusions from the draft CD, and an examination
23    of issues related to the quantitative assessment of evidence from controlled human exposure and
24    epidemiological studies. Chapters 4 and 5 describe the scope and methods used in conducting
25    human exposure and health risk assessments  and present initial results from those assessments.
26    Chapter 6 includes a preliminary discussion of the adequacy of the current primary standard and
27    identifies alternative primary standards that staff believes are appropriate to consider in
28    completing the human exposure and health risk assessments.
29          Chapters 7 and 8 will comprise the third main part of this draft Staff Paper. Chapter 7
30    presents a policy-relevant assessment of Os welfare effects evidence and discusses the scope and
31    methods that staff is planning to use in conducting vegetation-related exposure and risk
32    assessments.  Chapter 8 will be added in the second draft Staff Paper, and it will include
33    discussions of the adequacy of the current secondary standard and staff recommendations related
34    to the secondary Os standard.
35          Staff conclusions and recommendations, to be presented in the second draft Staff Paper,
36    will be informed by comments received from CASAC and the public in their reviews of this draft

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 1    Staff Paper. The final Staff Paper will be informed by further comments received from CAS AC
 2    and the public in their review of the second draft Staff Paper. The final Staff Paper will take into
 3    account the scientific evidence reviewed in the final CD and will include: 1) the results of
 4    comparative air quality analyses, human exposure and health risk assessments, and vegetation-
 5    related environmental assessments; 2) the staffs overall evaluation of the adequacy of the
 6    current primary and secondary NAAQS; and 3) staff conclusions and recommendations as to
 7    whether any revisions are appropriate to address public health and welfare effects associated
 8    with exposure to Os. For these purposes, the staff will assess and integrate new scientific and
 9    technical findings with information gained in previous reviews in the context of those critical
10    elements that the staff believes should be considered.
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  1    REFERENCES
  2
  3    Federal Register (1971) National Primary and Secondary Ambient Air Quality Standards for
  4            Photochemical Oxidants; Final rule. 40 CFR 50; Federal Register,36: 8186.
  5
  6    Federal Register (1979) National Primary and Secondary Ambient Air Quality Standards: Revisions to the National
  7            Ambient Air Quality Standards for Photochemical Oxidants, Final Rule, 40 CFR 50; Federal Register
  8            44:8202.
  9                                                                     •                              .
10    Federal Register (1993) National Ambient Air Quality Standards for Ozone, Final rule. 40 CFR 50; Federal Register
11            58:13008.
12                                                                       .   .
13    Federal Register (1997) National Ambient Air Quality Standards for Ozone; Final Rule. 40 CFR 50; Federal
14            Register 62:38856.
15
16    Federal Register (2001) National Ambient Air Quality Standards for Ozone; Proposed Response to Remand;
17            Proposed Rule.  Federal Register 66: 57368.
18
19    Federal Register (2003) National Ambient Air Quality Standards for Ozone; Proposed Response to Remand. Final
20            Rule. Federal Register 68: 614.
21
22    U.S. Environmental Protection Agency. (1986) Air Quality Criteria for Ozone and Other Photochemical Oxidants.
23            Research Triangle Park, NC: Office of Health and Environmental Assessment, Environmental Criteria and
24            Assessment Office; EPA report nos. EPA-600/8-84-020aF-eF. Available from NTIS, Springfield, VA;
25            PB87-142949.
26
27    U.S. Environmental Protection Agency (1992) Summary of selected new information on effects of ozone on health
28            and vegetation: supplement to 1986 air quality criteria for ozone and other photochemical oxidants.
29            Research Triangle Park, NC: Office of Health and Environmental Assessment, Environmental Criteria and
30            Assessment Office; EPA report no. EPA/600/8-88/105F. Available from NTIS, Springfield, VA; PB92-
31            235670.
32
33      U.S. Environmental Protection Agency (1996) Air Quality Criteria for Ozone and Related Photochemical
3 4            Oxidants. Research Triangle Park, NC: Office of Research and Development; report nos. EPA/6001AP-
35            93/004aF-cF. 3v. Available from: NTIS, Springfield, VA; PB96-185582, PB96-185590, and PB96-
36            185608. Available online at: http://cfpub.epa.gQv/ncea/cfnvrecordisplav.cfm7deid~2831.
37
38    U.S. Environmental Protection Agency (2002) Project Work Plan for Revised Air Quality
39            Criteria for Ozone and Related Photochemical Oxidants. Research Triangle Park, NC: National Center for
40            Environmental Assessment-RTP Report no. NCEA-R-1068.
41
42    U.S. Environmental Protection Agency (2005a) Air Quality Criteria for Ozone and Related
43            Photochemical Oxidants (First External Review Draft). Washington, DC, EPA/600/R-05/004aA-cA.
44            Available online at: www.ega.gpy/hceu/
45
46    U.S. Environmental Protection Agency (2005b) Air Quality Criteria for Ozone and  Related
47            Photochemical Oxidants (Second External Review Draft). Washington, DC, EPA/600/R-05/004aB-cB.
48            Available online at:  hijfe//cfpi!b..e^^
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 1                       2.   AIR QUALITY CHARACTERIZATION

 2   2.1  INTRODUCTION
 3          This Chapter summarizes the origin and status of ozone (Oa) concentrations in the
 4   ambient air. Section 2.2 summarizes the physical and chemical properties of 63 including its
 5   formation, transport, and fate. The section also summarizes the differences between tropospheric
 6   and stratospheric 63 and how O3 and ultraviolet radiation interact.  Section 2.3 describes the
 7   various sources of ground level Os data and the monitoring methodology that gives rise to these
 8   data and issues regarding the monitoring methodology. Section 2.4 describes 63 monitoring
 9   methods and issues. Section 2.5 describes the spatial and temporal variation found in ground
10   level Os data Section 2'.6 characterizes Os episodes and Section 2.7 describes background levels
11   of ground level Os-

12   2.2  CHEMICAL AND PHYSICAL PROPERTIES, FORMATION, AND
13          TRANSPORT
14          2.2.1  Chemical and Physical Properties
15          Ozone and other oxidants form in polluted areas mainly by chemical reactions in the
16   atmosphere involving two classes of precursor pollutants, volatile organic compounds or VOCs
17   and nitrogen oxides (NOX).  Ozone is, therefore, a secondary pollutant. Carbon monoxide (CO) is
18   also important for ozone formation in urban areas. The formation of Os, other oxidants and
19   oxidation products from these precursors is a complex process involving many factors: the
20   intensity and spectral distribution of sunlight; atmospheric mixing and processing on cloud and
21   aerosol particles; the concentrations of the precursors in ambient air; and the rates of chemical
22   reactions of the precursors.  A more detailed discussion of these processes can be found in
23   Chapter 2 of Volume 1 of Air Quality Criteria for Ozone and Related Photochemical Oxidants
24   (draft CD, pp.2-1 - 2-27).
25          The effects of sunlight on Os formation, aside from the role of solar radiation in
26   meteorological processes, depend on its intensity and its spectral distribution. Intensity varies
27   diumally, seasonally, and with latitude, but the effect of latitude is strongest in the winter.
28   Ultraviolet radiation from the sun plays a key role in initiating the photochemical processes
29   leading to O? formation and affects individual photolytic reaction steps. However, there is little
30   empirical evidence in the literature, directly linking day-to-day variations in observed surface
31   UV radiation levels with variations in tropospheric O3levels (draft CD, p. AX2-88).
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 1          2.2.2   Formation
 2          The chemical formation of Os in the troposphere results from the oxidation of nitric oxide
 3   (NO) to nitrogen dioxide (NOa) by organic (RO2) or hydro-peroxy (HO2) radicals. Photolysis
 4   (the chemical process of breaking down molecules into smaller units through the absorption of
 5   light) of NO2yields nitric oxide (NO) and a ground-state oxygen atom, O(3P), which then reacts
 6   with molecular oxygen to form Oa (draft CD, p.2-2).
 7          In urban areas, compounds representing all forms of VOCs are important for Os
 8   formation. In non-urban, vegetated areas,  biogenic VOCs emitted from vegetation tend to be the
 9   most important. In the remote troposphere, CH4and CO are the main carbon-containing
10   precursors to Os formation. In coastal environments and other selected environments, atomic Cl
11   and Br radicals can also initiate the oxidation of VOCs (draft CD, p.2-2 and 2-3).
12          Oxidized nitrogen containing compounds are essential to the formation of Os in the air.
13   There are a large number of oxidized nitrogen containing compounds in the atmosphere
14   including NO, NO2, NO3, HNO2, HN03, N2O5, HNO4, PAN and its homologues, other organic
15   nitrates and particulate nitrate. Collectively these species are referred to as NOy. Oxidized
16   nitrogen compounds are emitted to the atmosphere mainly as NO which rapidly interconverts
17   with NO2. Consequently, NO and NO2 are often grouped together into their own family called
18   NOX (draft CD, p. 2-3). NOx is considered  a good surrogate for N0y and is monitored more often
19   and its emissions are more widely reported (see Table 2-2).

20          2.2.3   Transport
21          The transport of OB and other secondary pollutants is determined by meteorological and
22   chemical processes extending typically over spatial scales of several hundred kilometers (e.g.,
23   Civerolo et al., 2003; Rao et al., 2003). An analysis of the output of regional model studies
24   conducted by Kasibhatla and Chameides (2000) suggests that Oa can be transported over a few
25   thousand kilometers in the upper boundary layer of the eastern half of the United States during
26   specific 03 episodes. Convection is capable of transporting Oj and its precursors vertically
27   through the troposphere as shown in Annex AX2.3.2 of the CD. Nocturnal low level jets (LLJs)
28   can also transport pollutants hundreds of kilometers. They are observed over the mid-Atlantic
29   region, the central U.S. and California  Turbulence associated with LLJs can bring these
30   pollutants to the surface and result in secondary Os maxima in the early morning in many
31   locations. However, the presence of mountain barriers limits mixing as in Los Angeles and
32   Mexico City and will result in a higher frequency and  duration of days with high Os
33   concentrations (draft CD, p.2-9).
     November 2005                           2-2               Draft - Do Not Quote or Cite

-------
 1          2.2.4  Precursors, Sources and Emissions
 2   Although there are direct sources of ozone (electrical discharges, lightning), ambient CH
 3   pollution problems are generally acknowledged to result from the secondary formation of 63 via
 4   the processes described in section 2.2.1.
 5          Table 2-1 (see http://w7wvv,epaagov/airtrends/econ-einissions.html) lists the main sources
 6   of VOC emissions from 1970-2004, The categories in the table are self explanatory with the
 7   exception of the fires and miscellaneous categories.  The fires category includes both wild fires
 8   and prescribed burns. The miscellaneous category includes mainly structural fires and sources
 9   from agricultural activities. One category not in either table is biogenic emissions. Biogenic
10   emissions are an important factor on warm to hot days in heavily vegetated areas. As can be
11   seen in the table, highway vehicles have been the single largest source of VOC emissions over
12   the years ranging from about 49% of total emissions in 1970 to about 27% of total emissions in
13   2004.  Starting in 2001, solvent use and highway vehicles were the two main sources of VOCs
14   with roughly equal contributions to the total emissions.
15          Table 2-2 contains the same emission information but for NOx emissions. Again,
16   highway vehicles are the single largest source of NOx emissions over the years ranging from
17   about 47% of total emissions in 1970 to about 37% of total emissions in 2004.

18          2.2.5  Tropospheric vs.  Stratospheric Ozone
19          The atmosphere can be divided into several distinct vertical layers, based primarily on the
20   major mechanisms by which they are heated and cooled. The lowest major layer is the
21   troposphere, which extends from  the earth's surface to about 8 km above the surface in polar
22   regions and to about 16 km above the surface in tropical regions. The planetary boundary layer
23   (PEL) is the lower sub-layer of the troposphere, extending from the surface to about 1 or 2 km,
24   and is most strongly affected by surface conditions. The stratosphere extends from the top of the
25   troposphere, to about 50 km in altitude. The emphasis in this chapter is placed on concentrations
26   of Oa occurring in the troposphere, in particular in the PBL (draft CD, p.2-1).
27          In urban environments the rate of O3 formation is sensitive to the rate of photolysis of
28   several species including H2CO, HjOj, 03, and especially NO2. Monte Carlo calculations suggest
29   that model simulations of photochemical O3 production are most sensitive to uncertainty in the
30   photolysis rate coefficient for NO2  (draft CD, p.AX2-88).
     November 2005
2-3
Draft - Do Not Quote or Cite

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 1   23   DATA SOURCES
 2          Two main sources of data were used for this assessment, the state-supplied data from
 3   various types of monitors housed in the Air Quality System (AQS) data base and the Clean Air
 4   Status and Trends Network (CASTNET). The vegetation exposure/risk analyses (see Chapter 7)
 5   will depend heavily on using the Community Multi-scale Air Quality (CMAQ) modeled data for
 6   2001  in conjunction with 2001 monitor data. Both monitor and model values will be combined
 7   using the spatial interpolation tool in BenMAP to create an interpolated surface to fill in the gaps
 8   left by a sparse rural monitoring network. Air quality models are often used to simulate the
 9   formation, transport, and decay of air pollution/ The CMAQ modeling system is a
10   comprehensive three-dimensional grid-based Eulerian air quality model designed to estimate
11   ozone and particulate concentrations and deposition over large spatial scales (Dennis et al, 1996;
12   Byun and Ching, 1999).  The CMAQ model is a publicly available, widely-used, peer-reviewed,
13   state-of-the-science model consisting of a number of science attributes that are critical for
14   simulating the oxidant precursors and nonlinear organic and inorganic chemical relationships
15   associated with the formation of ozone, as well as sulfate, nitrate, and organic aerosols.

16          2.3.1   Air  Quality System (AQS)
17          The Code of Federal Regulations, Title 40, Part 5 8 (40 CFR Part 58) contains the EPA's
18   ambient air quality surveillance regulations.  Section 58.20 requires States to provide for the
19   establishment of air quality surveillance systems in their State Implementation Plans (SIP). The
20   air quality surveillance system consists  of a network of monitoring stations designated as State
21   and Local Air Monitoring Stations  (SLAMS), which measure ambient concentrations of those
22   pollutants for which standards have been established in 40 CFR Part 50.  SLAMS, National Air
23   Monitoring Stations (NAMS), which are a subset of SLAMS, and Photochemical Assessment
24   Monitoring Stations (PAMS) must meet the requirements of 40 CFR Part 5 8, Appendices A
25   (Quality Assurance Requirements), C (Ambient Air Quality Monitoring Methodology), D
26   (Network Design Criteria), and E (Probe and Path Siting Criteria).
27          The Air Quality System (AQS) is EPA's repository  of ambient air quality data. AQS
28   stores data from over 10,000 monitors; 5000 of which are currently active. Of these, over 3000
29   measure and report Oa concentration data (See Figure 2-1).  These monitors make up the
30   SLAMS, PAMS, NAMS and other special purpose monitors used and operated by the States.
31   AQS  also contains  meteorological data, descriptive information about each monitoring station
32   (including its geographic location and its operator), and data quality assurance/quality control
     November 2005                           2-8               Draft - Do Not Quote or Cite

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 1   information. The Office of Air Quality Planning and Standards (OAQPS) and other AQS users
 2   rely upon the data system to assess air quality, assist in Attainment/Non-Attainment
 3   designations, evaluate State Implementation Plans for Non-Attainment Areas, perform modeling
 4   for permit review analysis, and other air quality management functions. AQS information is also
 5   used to prepare reports for Congress as mandated by the Clean Air Act (see
 6   http;//ww\y,ej^^
 7          The NAMS/PAMS/SLAMS ozone monitor network achieved an overall average bias
 8   (upper bound) of 0.2% and an overall mean precision of 3% for 2002. If special purpose and
 9   other ozone monitors are also included the average upper bounds of bias and precision were
10   0.4% and 2.9% respectively (U.S. EPA 2004a).

11    '      23.2  CASTNET
12          CASTNET is the nation's primary source for data on dry acidic deposition and rural,
13   ground-level ozone. Operating since 1987, GASTNET is used in conjunction with other national
14   monitoring networks to provide information for evaluating the effectiveness of national emission
15   control strategies. CASTNET  consists of over 80 sites across the eastern and western United
16   States (see Figure 2-1) and is cooperatively operated and funded with the National Park Service.
17   In 1986, EPA established the National Dry Deposition Network (NDDN) to obtain field data on
18   rural deposition patterns and trends at different locations throughout the United States. The
19   network consisted of 50 monitoring sites that derived dry deposition based on measured air
20   pollutant concentrations and modeled dry deposition velocities estimated from meteorology, land
21   use, and site characteristic data. In 1990, amendments to the Clean Air Act necessitated a long-
22.  term, national program to monitor the status and trends of air pollutant emissions, ambient air
23   quality, and pollutant deposition. In response, EPA, in cooperation with the National Oceanic
24   Atmospheric Administration (NOAA), created CASTNET from NDDN. In terms of data quality,
25   CASTNET achieved 98% to 99% of all precision and accuracy audits being within the ±10%
26   criteria for both precision and  accuracy.  Overall, CASTNET ozone monitors are stable and show
27   only very small variation (U.S. U.S. EPA 2003, p.22).

28   2.4  OZONE MONITORING METHODS AND ISSUES
29          Ozone monitoring is conducted almost exclusively with UV absorption spectrometry with
30   commercial short path instruments, a method that has been thoroughly evaluated in clean air. The
31   ultimate reference method is a relatively long-path UV absorption instrument maintained under
32   carefully controlled conditions at the National Institute of Standards and Technology (NIST)
33   (draft CD, p.2-21).
     November 2005                          2-10              Draft - Do Not Quote or Cite

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 1          Several reports in the reviewed scientific literature have investigated interferences in 03
 2   detection via UV radiation absorption. These include the effects of water vapor,  VOC's,
 3   aromatic compounds and their oxidation products, and other organic and inorganic compounds
 4   on instruments based on both UV absorption and chemiluminescence. Water vapor had no
 5   significant impact on UV absorption-based instruments, but could cause a positive interference
 6   of up to 9% in chemilurninescence-based detectors at high humidities (dew point of 24 C).
 7   Aromatic compounds and their oxidation products were found to generate a positive but small
 8   interference in the UV absorption instruments. However,  when the results are applied to ambient
 9   concentrations of toluene and NOx, the effect appears to be very minor (about 3 percent under
10   the study conditions). Other organic and inorganic compounds displayed interferences, but not at
11   levels likely to interfere with accurate determination of 03 in an urban environment The
12   possibility for substantive interferences in O3 detection exists, but such interferences have not
13   been observed even in urban plumes (draft CD, p. 2-24).
14          Ozone is also measured by differential optical absorption spectroscopy (DOAS) at a
15   variety of wavelengths in the UV and visible parts of the spectrum. Comparisons of DOAS
16   results to those from a UV absorption instrument showed good agreement, on the order of 10%.
17   Researchers have reported a positive interference due to an unidentified absorber in the 279 to
18   289 nm spectral region used by many commercial short-path DOAS systems for the
19   measurement of O3. Results of that study suggest that compounds from wood burning, used for
20   domestic heating, may be responsible (draft CD, p.AX2-146).
21          New techniques are being developed, but UV absorption remains the method of choice
22   for ambient 0,monitoring near the Earth's surface. These commercial UV absorption detectors
23   are available at a moderate price. They show good absolute accuracy with only minor cross
24   sensitivity in clean to moderately polluted environments;  they are stable, reliable, and sensitive
25   (draftCD,p.AX2-147).

26   2.5  CHARACTERIZATION OF GROUND-LEVEL OZONE CONCENTRATIONS
27          2.5.1  Metrics
28          This section characterizes ground level Os  concentrations based on several  metrics. Two
29   daily maximum statistics, 1-hr and 8-hr, and two seasonal cumulative statistics, SUM06 and
30   W126 are summarized to show how Os varies over space and time. The daily maximum 8-hr  '
31   values are found by first calculating running or moving 8-hr values for all 24 hours in a day (for
32   example averaging the 1-hr concentrations from 1:00am to 8:am, then average the  1-hr values
33   from 2:00am to 9:am, etc.). Then the maximum value for each day is found (note that any 8-hr
34   time period that starts in a day is assigned to that day).  On an annual basis, the fourth highest of

     November 2005                          2-11              Draft - Do Not Quote or Cite

-------
 1   these values is summarized. The daily maximum 1-hr statistic is the maximum value of all 1-hr
 2   values in a day. On an annual basis, the second highest of these values in a year is summarized.
 3   Both die SUM06 and the W126 statistics were calculated using all 1-hr values from 8:00am to
 4   8:00pm and finding the largest 3-month sum of these values in an Os monitoring season
 5   according to the secondary standard proposed in 1996 (FR Dec 13, 61(241) 1996 p. 65750). The
 6   SUM06 cumulative statistic is calculated by summing all 1-hr values that are greater than or
 7   equal to 0.06ppm for every day in a month. The W126 seasonal  cumulative statistic is calculated
 8   similarly to the SUM06 statistic.  The only difference is the weighting function. SUM06 has a
 9   weighting function that is 0 when the concentration is less than 0.06 and is 1.0 when the
10   concentration is greater than or equal to 0.06. The W126 statistic is a continuous, sigmoidal
11   weighting function with an inflection point between 0.06ppm and 0.07ppm (Lefohn and
12   Runeckles, 1987).

13          2.5.2   Spatial Variability
14          This section characterizes the spatial variability of Os based on all the metrics discussed
15   above. Spatial variability is based on maps displaying county levels of the various metrics.  In
16   this way different levels of Oa for different areas of the country are displayed.

17           2.5.2.1    8-Hour and 1-Hour Statistics
18                 High 8-hr average 63 concentrations tend to  occur near larger urban areas in the
19   same patterns as the 8-hr concentrations. Elevated levels occurring in smaller urban and non-
20   urban areas are most likely caused by transport (see Figure 2-2).  These smaller urban and non-
21   urban areas are most obvious at the  end of the northeast corridor (the highly urbanized area
22   running from Washington, DC to Boston, MA), North-central New York, and the Northern coast
23   of Lake Michigan.  Some of the highest levels occur not in California but in Texas, some
24   counties in the Northeast Corridor, and isolated counties in the East (see Figure 2-2) (Fitz-
25   Simons, et al, 2005). High 1-hr Os concentrations levels occur in the same patterns as the 8-hr
26   concentrations (see Figure 2-3).  The highest levels occur in California. (Fitz-Simons, et al,
27   2005).

28           2.5.2.2    Cumulative Seasonal Statistics
29          High SUM06 and Wl 26 levels in 2001 (most of the analyses in Chapter 7 center on 2001
30   data) occurred in most of the agricultural areas of California. When the data were from
31   CASTNET sites more purely rural counties show higher values.  The spatial patterns for SUM06
32   and W126 are very similar (See Figure 2-4,2-5,2-6, 2-7). (Fitz-Simons, et al, 2005).
     November 2005                           2-12              Draft - Do Not Quote or Cite

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 1          2.5.3  Temporal Variability
 2          Temporal variability consists of several time frames when considering characterization of
 3   ground level air quality data. Multi-year trends characterize long term variability or year to year
 4   variability. Trends can usually give evidence as to whether or not a situation is getting better or
 5   worse over time. For the purposes of displaying long term trends, the data from both AQS and
 6   CASTNET are screened  for temporally consistent data (only data from sites that meet a data
 7   completeness criteria of 12 complete years out of 15 and no gaps of more than 3 consecutive
 8   years are included). Seasonal variability characterizes month to month variability to demonstrate
 9   when, in the year the highest concentrations occur. Diurnal variability characterizes hour-to-hr
10   changes demonstrating when, in the day, the highest concentrations occur (Fitz-Simons, et al.,
11   2005).

12           2.5.3.1     Long Term Variability - Trends
13          Long term,  nationwide trends for 8-hr ozone values are presented in Figures 2-8 and 2-9.
14   Figure 2-8 presents data from sites in the AQS that meet trends criteria and have locations
15   described as Urban and Center City. Figure 2-9 presents data from CASTNET which are rural
16   locations.
17          The trends are similar. The urban trends have more data and more variation. The rural
18   means are slightly lower that the urban means; however the largest urban concentrations are
19   much higher than the largest rural concentrations (Fitz-Simons, etal, 2005).
20          Long term trends for 1 -hr ozone values are presented in Figures 2-10 and 2-11. Figure 2-
21   10 presents data from sites in the AQS that meet trends criteria and have locations described as
22   Urban and Center City. Figure 2-11 presents data from CASTNET which are rural locations.
23   The trends are similar. As in the 8-hr data, urban trends have more data and more variation with
24   the means for the urban trends being higher than the means for the rural trends. This difference
25   is more pronounced than in the 8-hr trends (Fitz-Simons, et al., 2005).
26          The long term trends for both 1-brand  8-hr ozone data are similar. The 8-hr
27   concentrations are lower, but the trends are basically parallel. The  highest means occur in
28   1990,1991,1995,1998 and 2002.  The highest  extreme values are clearly in the 1990s.  In many
29   cases, short term variation (3 years or less) is associated with meteorological conditions that are
30   generally more or less conducive to Oa formation in a particular year. One high year between
31   two low years or one low year between two higher years are examples of this short term
32   variation (see Evaluating Ozone Control  Programs in the Eastern United States: NOx P-17, U.S.
33   EPA 2005V).
34

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 1           2.5.3.2     Seasonal Variability
 2          Monthly statistics are the best method to characterize seasonal variation in Oa
 3    concentrations. However in many areas, monitors are not active during cooler months. As a
 4    result, data from May through September are the only universally available data for all monitors.
 5    Although this is a limited characterization of seasonal variability, it is consistent across the entire
 6    national network.
 7          Figure 2-12 shows box-plots of all 2004 data from May through September for the
 8    second highest daily 1-hr maximums.  The center of the distribution shows a slight, steady
 9    increase from May to September while the extreme values show a more pronounced but more
10    variable increase for the same period (Fitz-Simons, et al, 2005).
11          Figure 2-13 shows box-plots of all 2004 data from May through September for the fourth
12    highest daily 8-hr maximums.  The center of the distribution and the extremes show a slight,
13    steady increase from May to July  followed by a slight decrease from July through September
14    (Fitz-Simons, etal.,  2005).

15           2.5.3.3     Short Term  Variability - Diurnal
16          The daily cycles of human activity and the solar phase drive the hour-to-hour daily cycle
17    seen in ground level Os concentrations. The daily 1 -hr peak levels generally occur in the
18    afternoon with the lowest concentration occurring in the early morning.  However, on any given
19    day when conditions are right, this phase can be reversed with the highest values occurring at
20    night or early morning.
21          In order to examine diurnal patterns, box-plots summarize 1-hr values and 8-hr for each
22    hour in the day. The most recently available data, 2004, was used to generate all the box-plots.
23    Figure 2-14 summarizes 1-hr data from AQS that was classified as urban and center city.  The
24    pattern is similar for both weekend and week day data. The pattern of the center of the
25    distribution of values shows a smooth sinusoidal portion of the curve from 6:00AM until  8:OOPM
26    and reaches a peak at 1:00 PM to  3:00 PM.  Then the pattern alters to a gradual decrease from
27    9:00 PM to 6:00AM (Fitz-Simons, et al., 2005).
28          Figure 2-15 shows the same set of summaries for 8-hr data. 8-hr values run from 0 to 23
29    hours. Hourl is the average of 1-hr values from 1 to 8 while hour 2 is the average of hours 2 to 9
30    and so on. The main difference between the 1-hr data and the 8-hr data is that the 8-hr data
31    exhibit a smoother sinusoidal pattern throughout the day with a peak for the center of the
                                               2-24

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 1    distribution occurring at 10:00 AM or 11:00 AM and a minimum at about 12:00 midnight. The
 2    week end pattern is similar to the week day pattern (Fitz-Simons, et al., 2005).
 3          Figures 2-16 through  2-19 summarize 1 -hr and 8-hr data from CASTNET sites which are
 4    considered rural.  Several differences are noted here. The patterns for the center of the
 5    distribution is similar to the patterns for the urban sites. The largest values of the 1-hr data
 6    exhibit no pattern but the largest values for the 8-hr data have a discemable pattern that differs
 7    from the patterns for the values in the center of the distribution. The weekday pattern for the
 8    highest values has a smooth sinusoidal pattern but reaches 2 peaks in the day (12:00 midnight
 9    and 12:00 noon). The week end pattern also shows a pronounced peak in the afternoon at about
10    1:00 PM which occurs about 2 hours after the peak for the values in the center of the distribution
11    (Fitz-Simons, et al., 2005).

12    2.6   CHARACTERIZATION OF OZONE EPISODES
13          Major episodes of high Oa concentrations in the eastern United States are associated with
14    slow moving, high pressure systems. High pressure systems during the warmer seasons are
15    associated with the sinking of air, resulting in warm, generally cloudless skies, with light winds.
16    These conditions result in the development of stable air masses near the surface which inhibit the
17    vertical mixing of 63 precursors. The combination of inhibited vertical mixing and light winds
18    minimizes the dispersal of pollutants emitted in urban areas, allowing their concentrations to
19    build up. Photochemical activity involving these precursors is also enhanced because of higher
20    temperatures and the availability of sunlight. In the eastern United States, high Os concentrations
21    during an episode can extend over hundreds of thousands of square kilometers for several days.
22          Episodes have two main characteristics, the concentration level reached and the length of
23    time that this level is reached in consecutive days.  The following discussion addresses how these
24    characteristics of episodes have varied through both space and time.
25          Numbers of episodes defined by daily maximum 1-hr 63 concentrations reaching a level
26    of 0.12ppm for 1 day generally follow the long term trend of central values (means or medians)
27    of the 1-hr O3 data (See Figures 2-10 and 2-20). As the length of these episodes increase, the
28    frequency of these episodes decreases.  In the most recent years (1997-2004) episodes lasting 5
29    days or more often have not occurred at all (Fitz-Simons, et al., 2005).
30          Numbers of episodes defined by daily maximum 8-hr 63 concentrations reaching a level
31    of O.OSppm for 1 day generally follow the long term trend of central values of the 8-hr Os data
32    (See Figures 2-8 and 2-21). As the length of these episodes increase, the frequency of these
33    episodes decreases. However, some of the longer episodes (6 days of more) continue to occur at
34    this level even in the most recent years. In fact the episode must be defined by a level of 0.10
35    ppm before these longer episodes disappear in the most recent years (Fitz-Simons, et al., 2005).
                                               2-29

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 1          As episode length and level increase for both 1-hr and 8-hr Os data the frequency
 2   decreases (Figure 2-22 and 2-23). The longer periods and higher levels disappear altogether in
 3   the period from 2000-2004 (Fitz-Simons, et al., 2005).
 4          One final aspect of episodes to examine is the return time or the number of days between
 '5   episodes.  Looking at the intervals between episodes of O.OSppm for 8-hr data, the most
 6   prevalent gap length in days is 1 day. There is a slight peak again at 4 days followed by a
 7   gradual decrease in frequency as the gap-length increases (see Figure 2-24).  Looking at the same
 8   data for episodes of 0.12ppm, it appears that some periodicities appear at 1 day, 5-6 days, 21
 9   days, and 33-34 days (see Figure 2-25). The frequencies for these episodes are so small
10   compared to the frequencies of the lower level episodes that these indications should not be
11   considered real or significant indications of periodicities. The 1-hr Oa data exhibit much the
12   same lack of periodicity as the 8-hr data (Fitz-Simons, et al., 2005).

13   2.7   BACKGROUND LEVELS
14          Policy relevant background (PRB) concentrations are those concentrations that would
15   result in the United States in the absence of anthropogenic emissions in North America
16   (including Canada and Mexico) (U.S. EPA, 2005a, AX3-130). Background concentrations
17   include contributions from global natural sources and from anthropogenic sources outside North
18   America. As discussed in Chapter 5 of this Staff Paper, PRB concentrations enter into the
19   assessment of risk to human health.
20          Contributions to background levels of O3 include: photochemical interactions involving
21   natural emissions of VOCs, NOX, and CO; the long-range transport of O3 and its precursors
22   from outside North America; and stratospheric-tropospheric exchange (STE). Processes involved
23   in STE are described in detail in Annex AX2.3 of the CD. Natural sources of O3 precursors
24   include biogenic emissions, wildfires, and lightning. Biogenic emissions from agricultural
25   activities are not considered in the formation of PRB (draft CD, p. AX2-145).
26          As a result of long-range transport from anthropogenic source regions within North
27   America, estimates of PRB O3 concentrations cannot be derived solely from measurements of
28   O3, and must be based on modeling. The global photochemical transport model GEOS-CHEM
29   (Fiore et al., 2003) has been applied to estimate PRB O3 concentrations across the U.S. (U.S.
30   EPA, 2005a, AX3-131). This model shows that PRB O3 concentrations are a function of season,
31   altitude and total surface O3 concentration. PRB 03 concentrations at the surface are generally
32   predicted to be in the range of 0.015 to 0.035 ppm in the afternoon, and they decline under
33   conditions conducive to O3 episodes. They are highest during spring and decline into summer.
34
                                              2-36

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 1   Higher values tend to occur at higher elevations during spring due to contributions from
 2   hemispheric pollution and stratospheric intrusions. The stratospheric contribution to surface O3 is
 3   typically well below 0.020 ppm and only rarely elevate O3 concentrations at low-altitude sites
 4   and only slightly more often elevate them at high-altitude sites (U.S. EPA, 2005a, AX3-148).
 5          Ozone concentrations measured at remote monitoring sites in'the Northern Hemisphere
 6   show a broad rarige in mean and median concentrations, as do annual maximum 1-hr
 7   concentrations. Generally, concentrations increase with elevation and the highest concentrations
 8   are found during spring. The overall average of the annual median O3 concentrations at all remote
 9   sites in the continental United States is about 30 ppb and excluding higher elevation sites it is
10   about 24 ppb. Maximum concentrations may be related to stratospheric intrusions, wildfires, and
11   intercontinental or regional transport 'of pollution. However, it should be noted that all of these
12   sites are affected by North American anthropogenic emissions to some extent making an
13   interpretation based on these data alone problematic (draft CD, p.AX2-147).
14          Background estimates of hour Oj concentrations from observations tend to be at the
15   higher end of the range of PRB estimates (25 to 45 ppbv), while the observational results, as well
16   as those from prior modeling studies, indicate that background O3 concentrations in surface air
17   are usually below 40 ppbv. The background O3 concentrations derived from observations may be
18   overestimated if observations at remote and rural sites contain some influence from regional
19   pollution. Natural O3 concentrations are generally in the 10 to 25 ppbv range and never exceed
20   40 ppbv. The range of the hemispheric pollution enhancement (the difference between the
21   background and natural 03 concentrations) is typically 4 to 12 ppbv and only rarely exceeds 20
22   ppbv (< 1% total incidences). The stratospheric contribution is usually below 10 ppbv (draft CD,
23   p.AX2-149).
24          In addition to policy relevant background concentrations, a second component of more
25   rare episodic high-concentration events over shorter periods of time (e.g.,  days or weeks) both
26   within and outside the U.S., Canada, and Mexico (e.g., volcanic eruptions, large forest fires).
27   Specific natural events such as stratospheric intrusions (STE), wildfires, and volcanic eruptions,
28   both of U.S. and international origin, can lead to very high levels of OB comparable to, or greater
29   man, those driven by man-made emissions in polluted urban atmospheres. Because such
30   excursions can be essentially uncontrollable, EPA has in place policies that can remove
31   consideration of them, where appropriate, from decisions when implementing the NAAQS (U.S.
32   EPA, 1986).
33          Currently, estimates of PRB Os concentrations used in this document are based on
34   predictions obtained by the global scale, three dimensional, chemical transport model GEOS-
35   CHEM (Fiore et al., 2003). Estimates of PRB O3 concentrations cannot be derived solely from
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 1   measurements of Oa at relatively unpolluted sites because of long-range transport from
 2   anthropogenic source regions within North America. PRB Oa concentrations are a function of
 3   season, altitude and total surface 63 concentration. PRB 03 concentrations at the surface are
 4   generally estimated to be in the range of 0.015 to 0.035 ppm from 1300 to 1700 local time, and
 5   they decline under conditions conducive to Os episodes. They are highest during spring and
 6   decline into summer. Higher values tend to occur at higher elevations during spring due to
 7   contributions from hemispheric pollution and stratospheric intrusions. The stratospheric
 8   contribution to surface Oj is typically well below 0.020 ppm.  The maximum probability of
 9   stratospheric intrusions reaching about 1800 m altitude was less than 1 %. Stratospheric
10   intrusions occur with higher probabilities of 1 to 2 % at about 4100 m, and 10 % at about 5400
11   m.  Thus, stratospheric intrusions only rarely elevate 03 concentrations at low-altitude sites and
12   only slightly more often elevate them at high-altitude sites.
13          The analysis used in Chapter 4 and 5 uses the estimates of PRB from the GEOS-CHEM
14   model. The data consist of gridded values with latitude running from 12° to 80 ° in 2 ° steps and
15   longitude running from -177.5 ° to -47.5° in 2.5 ° steps. These data are in hourly values for the
16   2001 warm season. The model estimated the PRB and total ozone concentrations at each grid
17   point.
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 1    REFERENCES
 2
 3    Byun, D. W., and Ching, J.K.S., Eds, 1999. Science algorithms of EPA Models-3 Community Multiscale Air Quality
 4          (CMAQ modeling system, EPA/600/R-99/030, Office of Research and Development, U.S. Environmental
 5          Protection Agency.
 6
 7    Civerolo, K. L.; Mao, H. T.; Rao, S. T. (2003) The airshed for ozone and fine particulate pollution in the eastern
 8          United States; Pure Appl. Geophys. 160: 81-105.
 9
10    Dennis, R.L., Byun, D.W., Novak, J.H., Galluppi, K.J., Coats, C.J., and Vouk, M.A., 1996. The next generation of
11          integrated air quality modeling: EPA's Models-3, Atmospheric Environment, 30,1925-1938.
12
13    Fiore, A.; Jacob, D.J.;Liu, H.; Yantosca, R.M.; Fairlie, T.D.; Li, Q. (2003). Variability in Surface Ozone
14          Background over the United States: Implications for Air Quality Policy. J. of Geophysical Research,
15          108(024)19-1-19-12.
16
17    Fits-Simons, T.; McCluney, L.; Rizzo, M.(2005) U.S. EPA Memorandum to File.  Subject:  Analysis of 2004 Ozone
18          Data for the Ozone NAAQS Review, November 7.
19
20    Kasibhatla, P.; Chameides, W. L. (2000) Seasonal modeling of regional ozone pollution in the eastern United States.
21          Geophys. Res. Lett. 27:1415-1418.
22
23    Lefohn A.S. and Runeckles'V.C.-, Establishing Standards to Protect Vegetation - Ozone Exposure/Dose
24          Considerations. Atmospheric Environment 21:561-568,1987.
25
26    Rao, S. T.; Ku, J.-Y.; Berman, S.; Zhang, K.; Mao, H. (2003) Summertime characteristics of the atmospheric
27          boundary layer and relationships to ozone levels over the eastern United States. Pure Appl. Geophys.  160:21-
28          55.
29    U.S. Environmental Protection Agency (1986). Guideline on the Identification and Use of Air Quality Data Affected
30          by Exceptional Events. EPA-450/4-86-007.
31
32    U.S. Environmental Protection Agency (2003).Clean Air Status and Trends Network (CASTNet) 2001 Quality
33          Assurance Report; Research Triangle Park, NC: Office of Air Quality Planning and Standards. Report from
34          EPA Contract No. 68-D-98-112.
35
36    U.S. Environmental Protection Agency (2004a). 2003 Criteria Pollutant Quality Indicator Summary Report for July
37          14,2004, AQS Data; Research Triangle Park, NC: Office of Air Quality Planning and Standards. Report from
3 8          EPA Contract No. 68-D-02-061.
39
40    U.S. Environmental Protection Agency (2004b).The Ozone Report: Measuring Progress through Research Triangle
41          Park, NC: Office of Air Quality Planning and Standards; Report no.EPA-454-K-04-001.
42
43    U.S. Environmental Protection Agency (2005a).Air Quality Criteria for Ozone and Related Photochemical Oxidants.
44          Research Triangle Park, NC: Office of Research and Development; Report no.  EPA/600/R-05/0054aB.
45
46    U.S. Environmental Protection Agency (2005b).Evaluating Ozone Control Programs in the Eastern United States:
47          NOX Budget Trading Program Progress and Compliance. Research Triangle Park, NC:  Office of Air Quality
48          Planning and Standards; Report no. EPA-454- K-05-001.
49
50
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 1                 3.      POLICY-RELEVANT ASSESSMENT OF HEALTH
 2                                      EFFECTS EVIDENCE

 3   3.1    INTRODUCTION
 4          This chapter assesses key policy-relevant information on the known and potential health
 5   effects associated with exposure to ambient Os, alone and in combination with other pollutants
 6   lhat are routinely present in ambient air. This assessment focuses specifically on the health
 7   effects evidence contained in Chapters 4 through 7 of the draft CD, with particular emphasis on
 8   the integrative synthesis presented in Chapter 8.  That integrative synthesis focuses on
 9   integrating newly available scientific information with that available from the last review, as well
10   as integrating information from various disciplines, to address a set of issues central to the
11   assessment of scientific information upon which this review of Os NAAQS is to be based. It is
12   intended to provide a coherent framework for assessment of human health effects posed by
13   ambient Os in the U.S. and to facilitate consideration of the key policy-related issues to be
14   addressed in this draft Staff Paper.
15          Thisrchapter summarizes that evidence as a basis for future development of staff
16   conclusions and recommendations related to primary standards for O3. These staff conclusions
17   and recommendations will be discussed in Chapter 6 of the second draft Staff Paper.
18   Furthermore, this assessment addresses key issues relevant to quantitative assessment of
19   controlled human exposure and epidemiological evidence so as to provide a foundation for  '
20   quantitative health risk assessment, as discussed in Chapter 5 of this draft Staff Paper.
21          The decision in the last Os primary NAAQS review was focused substantially on short-
22   term and prolonged controlled-exposure studies reporting lung function decrements, respiratory
23   symptoms, and respiratory inflammation in humans. The current review of the draft CD has
24   emphasized a large number of epidemiological studies with these and additional health
25   endpoints, including acute and long-term effects of Os on premature mortality, enhanced
26   respiratory symptoms and lung function decrements in asthmatic individuals, school absences,
27   emergency room visits and hospital admissions for respiratory causes, published since the last
28   review, with some important new information also coming from toxicology, dosimetry, and
29   controlled human exposure studies.  As discussed in more detail in section 3.3 of this draft Staff
30   Paper, highlights of the new evidence include:
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 1         •  Newly available, large multicity studies, designed specifically to examine the acute
 2            effects of PM and O3 on mortality, provide much more robust and credible information
 3            than was previously available in the last NAAQS review. The results from two key
 4            .studies carried out in 95 U.S. communities (U.S. National Morbidity, Mortality Air
 5            Pollution Study [NMMAPS]) and in 23 European cities (Air Pollution and Health:
 6            European Approach [APHEA]) showed positive and significant O3 effect estimates for
 7            all cause (nonaccidental) mortality.

 8         •  Numerous acute exposure epidemiological studies published during the past decade
 9            offer added evidence of ambient Correlated lung function decrements and respiratory
10            symptoms in exercising healthy subjects and asthmatic subjects, as well as evidence on
11            new health endpoints, such as the relationships between ambient O3 concentrations and
12            school absenteeism and between  ambient O3 and cardiac physiologic endpoints.

13         •  Several new studies have been published over the last decade examining the temporal
14            associations between O3 exposures and emergency department visits  for respiratory
15            diseases and a significant O3 effect on respiratory hospital admissions.

16         •  New controlled human-exposure studies offer evidence of increased  airway
17            responsiveness to allergens in subjects with  allergic asthma exposed  to O3 and of
18            increased airway allergen responsiveness in subjects with allergic rhinitis following
19            exposure to 03.

20         •  Numerous controlled human-exposure studies have reported indicators of O3-induced
21            inflammatory response in both the upper respiratory tract (URT) and lower respiratory
22            tract (LRT), while other studies have shown significant changes in host defense
23            capability following O3 exposure of healthy  young adults.

24         •  Animal toxicology studies provide new information regarding mechanisms of action,
25            dosimetry, increased susceptibility to respiratory infection, and the biological
26            plausibility of acute effects and chronic, irreversible respiratory damage.
27          The scientific evidence and conclusions presented in this chapter are based upon
28    information contained in the draft CD's evaluation of health evidence from various disciplines.
29    Section 3.2 is an overview of potential mechanisms by which exposure to O3 may result in health
30    effects, discussed in Chapters 5, 6, and 7 of the draft CD.  Section 3,3 summarizes the nature of
31    effects induced by O3 exposure, and draws on information contained in Chapters 5, 6 and 7 of the
32    draft CD. Section 3.4 presents several issues important to staffs interpretation and quantitative
33    assessment of epidemiological studies. Section 3.5 discusses biological plausibility and
34    coherence of evidence for 03-induced adverse health effects, including short-term respiratory
35    effects, short-term cardiovascular effects, long-term health effects, and mortality-related health
36    endpoints. Also drawing from the draft CD's integrative synthesis, section 3.6 discusses factors
37    that modify responsiveness to O3; potentially susceptible and vulnerable populations groups;
38    public health impacts of exposure to ambient O3; and what constitutes  an adverse health impact
39    from ambient O3 exposure. Finally, in section 3.7, staff builds upon the draft CD's detailed
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 1    evaluation and integration of the scientific evidence available on these issues to draw
 2    conclusions regarding the use of health study results in quantitative evaluation and risk
 3    assessments that will be relied upon in developing future staff recommendations on potential
 4    revisions to the primary O3 NAAQS to be presented in Chapter 6 of the second draft of the Staff
 5    Paper.

 6    3.2    MECHANISMS
 7          This section provides an overview of evidence covered in the draft CD (chapters 5 and 6)
 8    on possible mechanisms by which exposure to 03 may result in acute and chronic health effects.
 9    Evidence from dosimetry, toxicology, and human exposure studies has contributed to an
10    understanding of the mechanisms which help to explain the biological plausibility and coherence
11    of evidence for O3-induced respiratory health effects reported in epidemiological studies. In the
12    past, however, little information was available to help explain potential biological mechanisms
13    which linked O3 exposure to premature mortality or cardiovascular effects.
14          Scientific evidence discussed in the draft CD indicates that reactions with lipids and
15    antioxidants are the initial step in mediating deleterious health effects of O3.  Subsequent
16    activation of a cascade of events starting with inflammation, altered permeability of the epithelial
17    barrier, impaired clearance mechanisms (including host defense), and pulmonary structural
18    alterations that potentially exacerbate a preexisting disease status (CD, sec. 8.4.1). According to
19    the draft CD, the scientific evidence is still lacking for clearly establishing a role for one or a
20    group of mechanistic pathways underlying O3 health effects  observed in epidemiological studies.
21    Most of these mechanisms of action were based on animal toxicology studies with some support
22    from human exposure studies.

23          3.2.1    Direct Pulmonary Effects
24          Potential direct pulmonary effects of O3 include changes in breathing pattern, symptoms
25    of breathing discomfort, lung function changes, and airway hyperreactivity. Subjects who
26    engage in physical activity for multiple hrs while exposed to O3 may experience subjective
27    respiratory tract symptoms and acute physiological changes. Airway irritation is consistently  the
28    most typical symptomatic response reported in studies and is accompanied by several
29    physiological changes, depending on individual responsiveness to O3.  These physiological
30    changes include bronchoconstriction, airway hyperresponsiveness, airway inflammation,
31    immune system activation, and epithelial injury.  Severity of symptoms and magnitude of
32    response depend on dose of inhaled 03, individual sensitivity to O3, and extent of tolerance
33    resulting from previous 03 exposures. Development of effects is time-dependent with a
34    substantial degree of overlap of increasing and receding effects. Time sequences, magnitudes,
35    and types of responses of this series of events, in terms of development and recovery, indicate

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 1    that several mechanisms, activated at different times, contribute to the overall lung function
 2    response. (CD, pp. 6-8 to 6-9) For the full discussion of the mechanisms of pulmonary function
 3    responses, see section 6.2.5 of the draft CD.

 4            32.1.1    Breathing Pattern Changes
 5          Human controlled-exposure studies have consistently found that inhalation of Oj alters
 6    the breathing pattern without significantly affecting minute ventilation (CD, pp. 6-10 to 6-11).  A
 7    progressive decrease in tidal volume and an increase in frequency of breathing to maintain steady
 8    ventilation during exposure of human subjects suggest a direct impact on ventilation. These
 9    changes are similar to responses in many animal species exposed to O3 and other respiratory
10    irritants.  Bronchial C-fibers and rapidly adapting receptors appear to be the primary modulators
11    of Oj-induced changes in ventilation rate and O3 penetration in both humans and animals (CD,
12    section 6.2.5.1).

13            3.2.1.2    Symptoms and Lung Function Changes
14          In addition to changes in ventilatory control, 03 inhalation by humans induces a variety
15    of symptoms, reduces vital capacity (VC) and related functional measures, and increases airway
16    resistance (CD, pp. 6-11 to 6-12). The reduction in VC caused by exposure to O3 is a reflex
17    action and not a voluntary cessation of breathing resulting from discomfort. While O3-induced
18    symptom responses (mediated in part by bronchial C-fibers) are substantially reduced by inhaled
19    topical anesthetic, the anesthetic had a minor and irregular effect on pulmonary function
20    decrements and rapid, shallow breathing.  Since respiratory symptom responses were largely
21    abolished, these findings support reflex inhibition of VC due to stimulation of both bronchial and
                                                 t
22    pulmonary C-fibers. Intersubject variability in FEVi responses is not explained by differences in
23    O3doses  between similarly exposed individuals (CD, section 6.2.5.1).
24            3.2.1.3    Airway Hyperresponsiveness
25          Bronchial or airway hyperresponsiveness (AHR) refers to a condition in which the
26    propensity for the airways to constrict due to specific (e.g., allergens and antigens) or nonspecific
27    (e.g., histamine and cold air) stimuli becomes increased (CD, section 6.8).  Despite a common
28    mechanism (CD, p. 5-49, pp.6-12 to 6-13), post-O3 exposure pulmonary function changes and
29    AHR (either early or late phase) are poorly correlated. Neither does post-O3  exposure AHR
30    seem to be related to baseline airway reactivity.  These findings imply that the mechanisms are
31    either not related or are activated independent in time. Indeed, O3-induced increases in AHR
32    appear to persist longer than pulmonary function and symptom responses to O3. Animal studies
33    (with limited support from human studies) have suggested that that stimulation of C-fibers can
34    lead to increased responsiveness of bronchial smooth muscle independently of systemic and
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 1    inflammatory changes which may be absent. Characteristic O3-induced inflammatory, airway
 2    neutrophilia, which at one time was considered a leading AHR mechanism, appears to be only
 3    temporally correlated with AHR. This observation does not rule out involvement of other cells in
 4    AHR modulation.  However, there is some evidence that release of inflammatory mediators
 5    might sustain AHR and bronchoconstriction.  Late AHR observed in some studies is plausibly
 6    due to sustained damage of the airway epithelium and continual release of inflammatory
 7    mediators. Thus, O3-induced AHR appears to be a product of many mechanisms acting at
 8    different time periods.

 9          3.2.2   Extrapulmonary Effects
10          Ozone reacts rapidly on contact with lipids and antioxidants in the epithelial lining fluid
11    (ELF) and is not absorbed or transported to extrapulmonary sites (CD, p. 6-40, p. AX6-126).
12    Laboratory animal  studies suggest that reaction products formed by the interaction of O3 with
13    respiratory system  fluids or tissues may produce effects measured outside the respiratory tract—
14    either in the blood, as changes in circulating blood or as changes in the structure or function of
15    other organs, such as the parathyroid gland, the heart, the liver and the central nervous system.
16    However, very little is known about the mechanisms by which O3 could cause extrapulmonary
17    effects (CD, sections AX6.10 and 5.4). Human exposure studies discussed in previous criteria
18    documents (U.S. EPA, 1986,1996) failed to demonstrate any consistent extrapulmonary effects.
19    More recent human exposure studies have identified specific markers of exposure to O3 in the
20    blood, such as a reduction in the serum levels of a free radical scavenger after O3 exposure (CD,
21    sections 6.10 and AX6.10).
22          Alterations  in heart rate and/or rhythm are thought to reflect pathophysiologic changes
23    which may represent mechanisms by which pollutants like O3 may induce acute adverse
24    cardiovascular health effects. Decreased heart rate variability (HRV) has been suggested as a
25    predictor of increased  cardiovascular morbidity and mortality (CD, p. 7-55). Heart rate
26    variability, resting heart rate, and blood pressure are modulated by a balance between the
27    sympathetic arid parasympathetic nervous systems, and decreased HRV predicts an increased
28    risk of cardiovascular morbidity and mortality in the elderly and those with significant heart
29    disease.  Decreased parasympathetic input to the heart may provide an important mechanistic
30    link between air pollution and cardiovascular mortality by promoting fatal arrhythmias (CD,
31    section 7.2.7.1). The impact of O3  exposure on the cardiovascular system is discussed in section
32    3.3.1.4 of this draft Staff Paper.
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 1    3.3    NATURE OF EFFECTS
 2          When the primary O3 NAAQS was last reviewed, the decision was based largely upon
 3    evidence of pulmonary function decrements, respiratory symptoms, and indicators of
 4    inflammation collected in experimental controlled exposure studies of human subjects. Less
 5    consistent, but supportive evidence was provided by epidemiological studies that reported
 6    associations between ambient O3 levels and hospital admissions or emergency room (ER) visits
 7    for respiratory causes, as well as school absences, work loss days, and restricted activity days.  In
 8    addition, lexicological studies demonstrated morphological changes and altered host defense
 9    mechanisms with O3 exposure (U.S. EPA, 1996)
10          The current draft CD provides some new evidence of lung function, symptom, and
11    inflammatory effects in controlled exposure studies that supports the findings of the previous
12    CD. However, the most significant body of new studies in this review is the recent
                      i.
13    epidemiological evidence of associations between short-term exposure to O3 and effects such as
14    premature mortality, hospital admissions and ER visits for respiratory (e.g., asthma) and
15    cardiovascular causes.
16          The following discussions of O3-induced health effects are based on scientific evidence
17    critically reviewed in chapters 5, 6, and 7 of the draft CD, as well as the draft CD's integration of
18    scientific evidence contained in Chapter 8.  hi addition, these health effects discussions rely on
19    the more detailed information and tables presented in the draft CD's annexes AX5, AX6, and
20    AX7.  Conclusions drawn about O3-induced health effects depend on the full body of evidence
21    from controlled-exposure human, epidemiological and toxicological data contained in the draft
22    CD. Staff first focuses on the broad array of morbidity effects that have been associated with O3
23    exposure, including both acute and chronic exposures, in section 3.3.1.  Section 3.3.2 then
24    discusses the expanded body of evidence on associations between acute O3 exposure and
25    mortality, as well as the more limited evidence on chronic O3 exposures and mortality.

26          3.3.1     Morbidity
27          This section briefly summarizes evidence from toxicological, controlled human exposure
28    and epidemiological studies on respiratory and cardiovascular  effects associated with exposure to
29    O3, based on the draft CD's assessment in Chapters 4, 6 and 7. Evidence  of O3-related hospital
30    admissions and emergency room visits is discussed in section 3.3.2.1, followed by discussion of
31    the effects of short-term and long-term exposure to O3 on the respiratory system in sections
32    3.3.2.2 and 3.3.2.3, and Cvrelated cardiovascular effects in section 3.3.2.4.
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 1           33.1.1    Emergency Department Visits/Hospital Admissions for Respiratory
 2                     Causes
 3          In the last review of the O3 NAAQS, the 1996 CD evaluated emergency room visits and
 4   hospital admissions as possible outcomes following exposure to O3 (CD, section 7.3.1). The
 5   evidence was limited for emergency department visits, but results of several studies generally
 6   indicated that short-term exposures to O3were associated with respiratory emergency department
 7   visits (Bates et al.,  1990; Cody et al., 1992; Weisel et al., 1995; White et al., 1994). The
 8   strongest and most consistent evidence, both below and above 0.12 ppm 1-hr max O3, was found
 9   in the group of studies which investigated summertime daily hospital admissions for respiratory
10   causes in different  eastern North American cities (Bates and Sizto, 1983,1987,1989; Burnett et
11   al., 1994; Lipfert and Hammerstrom, 1992; Thurston et al., 1992,1994). These studies were
12   consistent in demonstrating that ambient O3 levels were associated with increased hospital
13   admissions and accounted for about one to three excess respiratory hospital admissions per
14   million persons with each 100 ppb increase in 1 -hr max O3, with adjustment for possible
15   confounding effects of temperature and copollutants. Overall, the 1996 CD concluded that there
16   was strong evidence that ambient O3 exposures were associated with exacerbation of respiratory
17   disease (CD, p. 7-57,7-58).
18          In the past decade, a number of studies have examined the temporal associations between
19   O3 exposures and emergency  department visits for respiratory causes (CD, section 7.3.2). These
20   studies are summarized in the draft CD (Table AX7-3, Chapter 7 Annex). Respiratory causes for
21   emergency room visits include asthma, bronchitis, emphysema, pneumonia, and other upper and
22   lower respiratory infections,  such as influenza, but asthma visits typically dominate the daily
23   incidence counts. Among studies with adequate controls for seasonal patterns, many reported at
24   least one significant positive  association involving O3.  These studies examined emergency
25   department visits for total respiratory  complaints (Delfmo et al., 1997b, 1998b; Hemandez-
26   Garduno et al., 1997; Ilabaca et al., 1999; Jones et al., 1995; Lin et al., 1999), asthma (Friedman
27   et al., 2001; Jaffe et al., 2003; Stieb et al., 1996; Tenias et al., 1998; Tobias et al., 1999; Tolbert
28   et al., 2000; Weisel et al., 2002), and COPD (Tenias et al., 2002).
29          Figure 7-8 (CD, p. 7-59) provides effect estimates for associations between emergency
30   department visits for asthma  and short-term O3 exposures". In general, O3 effect estimates from
31   summer only analyses tended to be positive and larger compared to results from cool season or
32   all year analyses (CD, p. 7-60). Several of the studies reported significant associations between
33   O3 concentrations and emergency department visits for respiratory causes. However,
34   inconsistencies were observed which were at least partially attributable to differences in model
35   specifications and analysis approach among various  studies. For example, ambient O3
36   concentrations, length of the  study period, and statistical methods used to control confounding by


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  1    seasonal patterns and copollutants appear to affect the observed 03 effect on emergency
  2    department visits. This has led the draft CD (p. 7-62) to conclude that Hie body of evidence
  3    remains inconclusive regarding effects of O3 on the risk of emergency department visits.
  4           Unscheduled hospital admissions occur in response to unanticipated disease
  5    exacerbations and are more likely to be affected by environmental factors, such as high 03 levels.
  6    Thus, hospital admissions studies focus specifically on unscheduled admissions.  Results of a
  7    fairly large number of these studies published during the past decade are summarized in Table -
  8    AX7-4 (CD, Chapter 7 Annex). As a-group, these hospital admissions studies tend to be larger
  9    geographically and temporally than the emergency department visit studies and provide results
10    that are generally more consistent.  The largest and most significant associations of respiratory
11    hospital admissions with O3  concentrations were observed using short lag periods, in particular
12    for a 0-day lag (same day exposure) and a 1-day lag (previous day exposure). In a 16-city
13    Canadian study, Burnett et al. (1997) found the strongest association at a 1 -day lag and a decline
14    in magnitude and significance of effect estimates with longer lag periods for O3 exposure. In
15    five European cities, Anderson et al., (1997) investigated the association between O3 and
16    unscheduled daily hospital admissions for COPD and found that the largest risk estimates were
17    for 0- and 1-day lags: Also,  among all pollutants examined, the most consistent and significant
18    findings were for O3. According to the draft CD (p. 7-67), other studies conducted in one or two
19    cities over a five year period or longer provided substantial additional evidence regarding O3
20    effects on respiratory hospital admissions (Anderson  et al., 1998; Burnett et al., 1999, 2001;
21    Moolgavkar et al., 1997;.Petroeschevsky et al., 2001; Ponce de Leon et al.,  1996; Sheppard et al.,
22    1999 [reanalysis Sheppard, 2003]; Yang et al., 2003). The draft CD observes that in some areas
23    with low ambient O3 concentrations, authors reported that significant associations between O3
24    exposure and respiratory  hospitalization were not found but did not provide quantitative results
25    (e.g., Lin et al., 2004).
26           Overall, the  draft  CD concludes that positive and robust associations were found between
27    ambient 63 concentrations and hospital admissions, when focusing particularly on results of
28    warm-season analyses. Recent studies have also reported associations with ER visits for
29    respiratory diseases, though the draft CD finds this evidence to be less consistent (CD, p. 7-177).

30           33.1.2    Effects on the Respiratory System from Short-term Exposures
31           Short-term exposures to O3 have been reported to induce a wide variety of respiratory
32    health effects. These effects include a range of more subtle effects such as including
33    morphological changes in the respiratory tract, pulmonary function decrements, respiratory
34    inflammation, increased airway responsiveness, morphological effects, changes in host defense
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 1    capability, and effects on exercise performance.  Short-term O3 exposure has also been
 2    associated with increases in respiratory symptoms, restricted activity days, and school absences.
 3             3.3.1.2.1   Pulmonary Function Decrements, Respiratory Symptoms, and Asthma
 4                       Medication Use
 5          A very large literature base of studies published prior to 1996, which investigated the
 6    health effects on the respiratory system from short-term 03 exposures, was reviewed in the 1986
 7    and 1996 CDs (U.S. Environmental Protection Agency, 1986,1996). In the last review, the
 8    lowest 03 concentration at which statistically significant reductions in forced vital capacity
 9    (FVC) and forced expiratory volume in 1 second (FEV() had been reported in sedentary subjects
10    was 0.5 ppm (CD, p 6-3). During exercise, spirometric and symptomatic responses were
11    observed at much lower O3 exposures. When minute ventilation was considerably increased by
12    continuous exercise (CE) during O3 exposures lasting 2 hr or less at > 0.12 ppm, healthy subjects
13    generally experienced decreases in FEVl3 FVC,  total lung capacity (TLC), inspiratory capacity
14    (1C), mean forced expiratory flow from 25%  to 75% of FVC (FEF25_75), and tidal volume (VT);
15    increases in specific airway resistance (sRaw), breathing frequency (fB), and airway
16    responsiveness; and symptoms such as cough, pain on deep  inspiration, shortness of breath,
17    throat irritation, and wheezing.  When exposures were increased to 4- to 8-hr in duration,
18    statistically significant spirometric and symptom responses were reported at lower O3,
19    concentrations, as low as 0.08 ppm, and at lower minute ventilation (i.e., moderate exercise) than
20    the shorter duration studies (CD. p. 6-5).
21          The most important observations drawn from studies reviewed in the 1996 CD were that:
22    (1) young healthy adults exposed to O3 concentrations > 0.08 ppm develop significant,
23    reversible, transient decrements in pulmonary function if VE or duration of exposure is increased
24    sufficiently, (2) children experience similar spirometric responses but lesser symptoms from O3
25    exposure relative to young adults, (3) 03-induced spirometric responses are decreased in the
26    elderly relative to young adults, (4) there is a large degree of intersubjecf variability in
27    physiologic and symptomatic responses to O3 but responses tend to be reproducible within a
28    given individual over a period of several months, and (5) subjects exposed repeatedly to O3 for
29    several days develop a tolerance to successive exposures, as demonstrated by an attenuation of
30    responses, which is lost after about a week without exposure (CD, p. 6-1).
31          Since 1996, there have been a number of studies published investigating spirometric and
32    symptomatic responses, and they generally support the observations previously drawn. Recent
33    studies for acute exposures of 1 to  2 hrs in duration are summarized in Table AX6-1 of the draft
34    CD (p. AX6-5 to AX 6-7). Among the more important of the recent studies was McDonnell et
35    al. (1997), which examined reported changes in FEVt in 485 white males (ages 18-36) exposed
36    for 2 hrs to O3 concentrations from as low as 0.08 ppm up to 0.40 ppm, at rest or with IE.

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 1   Decrements in FEVi were modeled by sigmoid-shaped curve as a function of subject age, O3
 2   concentration, minute ventilation, and duration of exposure.  In another study, Ultman et al.
 3   (2004) found that exposing 60 young, healthy subjects to 0.25 ppm O3 for 1 hr with CE produced
 4   considerable intersubject variability in FEVi decrements ranging from 4% improvement to a
 5   56% decrement, which was consistent with findings in the 1996 CD.'  One third of subjects had
 6   FEV, decrements of > 15% and 7% had decrements of > 40%.  Foster et al. (1993,1997)
 7   examined the effects of O3 on ventilation distribution and reported results suggesting a prolonged
 8   O3 effect on the small airways and ventilation distribution (CD, p. 6-5).
 9          For prolonged exposures (4 to 8 hr) in the range of 0.08 to 0.16 ppm O3 using moderate
10   quasi continuous exercise (QCE; 50 min exercise [minute ventilation of 35  to 40 L/min] and 10
11   min rest per hr), several pre- and post-1996 studies (Folinsbee et al.; 1988; Folinsbee et al., 1994;
12   Horstman et al., 1990; Adams 2002; Adams 2003) have reported statistically significant
13   responses and increased symptoms and spirometric responses with increasing duration of
14   exposure, O3 concentration, and total minute ventilation. Based on review of several prolonged
15   exposure studies, the draft CD (p. 6-6) concluded that FEVt decrements are a function of minute
16   ventilation  in 6.6 hr exposure studies  and that data from recent studies do not support the
17   contention that minute ventilation should be normalized to BSA. Triangular exposure studies
18   (Hazucha et al., 1992; Adams,- 2003)  suggest that depending upon the profile of the exposure, the
19   triangular exposure, which is more representative of actual ambient exposures, can potentially
20   lead to greater FEV, decrements than square wave exposures at overall equivalent O3 doses (CD,
21   p. 6-8). McDonnell (1996) used data from a series of studies to investigate the frequency
22   distributions of FEVi decrements following 6.6 hr exposures and found that average FEVi
23   responses were relatively small (between 5 and 10 %) at 0,08 ppm O3. However, about 18% of
24   the exposed subjects had moderate functional decrements (10 to 20%), and about 8%
25   experienced large decrements (>20%). This demonstrates that while average responses may
26   appear small and insignificant, some individuals can experience much more significant and
27   severe effects.
28          A relatively large number of field studies investigating  the effects of ambient O3
29   concentrations on lung function decrements and respiratory symptoms have been published since
30   1996 and are reviewed and summarized in the draft CD (sections 7.2.3, 7.2.4, and 8.4.2.1.1).
31   These newer studies support the major findings of the 1996 CD that lung function changes, as
32   measured by decrements in FEVi or peak expiratory flow (PEF), and respiratory symptoms are
33   closely correlated to ambient O3 concentrations. Pre-1996 field studies focused primarily on
34   children attending summer camps (Spektor et al., 1988a, 1991; Avol et al.,  1990; Raizenne et al.,
35   1987,1989; Higgins et al., 1990). The newer studies have expanded into looking at O3-induced
36   effects on outdoor workers (Brauer et al., 1996; Romieu et al.,  1998), athletes (Hoppe et al.,

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 1    1998, 2003), the elderly (Schindler et al, 2001; H6ppe et al., 2003), hikers (Korrick et al, 1998),
 2    school children (Uhner et al., 1997; Linn et al., 1996; Scarlett et al., 1996), and asthmatics
 3    (Hoppe et al., 2003; Romieu et al, 2002). Collectively, these studies confirm and extend clinical
 4    observations that prolonged exposure periods, combined with elevated levels of exertion or
 5    exercise, may magnify the effect of O3 on lung function. The most representative data come
 6    from the Korrick et al. (1998) hiker study, which provided-outcome measures stratified by.
 7    several factors (e.g., gender, age, smoking status, presence of asthma) within a population
 8    capable of more than normal exertion. In this study, lung function was measured before and.
 9    after hiking, and both ambient and personal 03 exposure measurements were made. Decreased
10    lung function was associated with O3 exposure, with the greatest effect estimates reported for
11    subgroup who reported having asthma or wheezing, and those who hiked for longer periods of
12    time, thus increasing the exposure period (CD, p. 7-27, 7-31).
13          Asthma panel studies, conducted both in the U.S. and in other countries, have reported
14    that decrements in PEF are associated with O3 exposures among asthmatic and healthy persons
15    (CD, sections 7.2.3.2 and 8.4.2.1.1).  One large U.S. multicity study (Mortimer et al., 2002)
16    examined 03-related changes in PEF in 846 asthmatic children from 8 urban areas and reported
17    that the incidence of > 10% decrements in morning PEF are associated with 30 ppb increase in 8-
18    hr average O3 for a 5-day cumulative lag, suggesting that 03 exposure may be associated with
19    clinically significant .changes in PEF in asthmatic children; however, no associations were
20    reported with evening PEF (CD, p. 7-40). The authors also reported that the associations
21    reported with morning PEF remained statistically significant when days with 8-hr O3
22    concentrations above 80 ppb were excluded (CD, p. 7-40). Two studies (Romieu et al, 1996,
23    1997) carried out simultaneously in northern and southwestern Mexico City with mildly
24    asthmatic school children reported statistically significant Q3-related reductions in PEF, with
25    variations in effect depending on lag time and time of day. While several other studies report
26    statistically significant associations between O3 exposure and reduced PEF in asthmatics (Gielen
27    et al., 1997; Jalaludin et al., 2000; Just et al.,  2002; Ross et al., 2002; Thurston et al., 1997), other
28    studies did not (Hilterman et al., 1988; Delfino et al., 1997a), possibly due to very low levels of
29    O3. Collectively, however,  these studies indicate that O3 may, be associated with declines in lung
30    function in asthmatic individuals (CD, p. 7-40).
31          Mortimer et al. (2002) discussed biological mechanisms for delayed effects on pulmonary
32    function, which included increased bronchial reactivity secondary to airway inflammation
33    associated with irritant exposure.  Animal toxicological and human chamber studies (CD,
34    Chapters 5 and 6) provide supporting evidence that exposure to 03 may  augment cellular
35    infiltration and cellular activation, enhance release of cytotoxic inflammatory mediators, and
36    alter membrane permeability (CD, p.7-38). In most laboratory animals studied, biochemical

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 1    markers of lung injury and associated morphological changes were not found to be attenuated.
 2    Although there are no data available on pulmonary function changes in animals chronically
 3    exposed to O3, earlier work of repeated exposures of rats to an episodic profile of O3
 4    demonstrated small but significant decrements in lung function consistent with  early indicators
 5    of focal fibrogenesis  in the proximal alveolar region (CD, p. 8-26).
 6          Most of the panel studies which have investigated associations between O3 exposure and
 7    respiratory symptoms or increased use of asthma medication are focused on asthmatic children
 8    (CD, sections 7.2.4 and 8.4.2.1.1). Two large U.S. studies (Mortimer et al., 2002; Gent et al.,
 9    2003), as well as several small er U. S. (Delfino et al., 2003; Just et al., 2002; Newhouse et al.,
10    2004; Romieu et al.,  1996,1997; Ross et al., 2002; Thurston et al., 1997) and international
11    studies (Hilterman et al., 1998; Desqueyroux et al., 2002a,b), have reported fairly robust
12    associations between ambient O3 concentrations and daily symptoms/asthma medication use,
13    even after adjustment for copollutants. The CD observes mat there are a number of well-
14    conducted, albeit smaller, studies (Avol et al., 1998; Chen et al., 1998; Delfino  et al., 1996,
15    1997a, 1998a; Gielen et al., 1997; Jalaludin et al., 2004; Ostro et al., 2001; Taggart  et al., 1996)
16    which showed only limited or a lack of evidence for symptom increases associated with O3
17    exposure.
18          The draft CD (p. 7-48) concludes that the asthma panel studies as a group indicate a
19    positive association between ambient concentrations and respiratory symptoms and increased
20    medication use in asthmatics. The evidence has continued to expand since 1996 and now is
21    considered to be much stronger than in the previous review of the 03 primary standard.
22             3.3,1.2,2  Airway Responsiveness
23          Airway hyperresponsiveness (AHR), also know as bronchial hyperreactivity, refers to a
24    condition in which the propensity for the airways to bronchoconstrict due to a variety of stimuli
25    (e.g., exposure to cold air, allergens, or exercise) becomes augmented. This condition is
26    typically quantified by measuring the decrement in pulmonary function (e.g., spirometry or
27    plethysmography) after inhalation exposure to specific (e.g., antigen, allergen)  or nonspecific
28    (e.g., methacholine, histamine) bronchoconstrictor stimuli. Exposure to Os causes an increase in
29    nonspecific airway responsiveness as indicated by a reduction in the concentration of
30    methacholine or histamine required to produce a given reduction in' FEVj or increase in SRaw.
31    Increased airway responsiveness is an important consequence of exposure to O3 because its
32    presence means that the airways are predisposed to narrowing on inhalation of various  stimuli,
33    such as specific allergens, cold air or SO2 (CD, p. 8-29).  Significant, clinically relevant
34    decreases in pulmonary function have been observed in early phase allergen response in subjects
35    with rhinitis after consecutive (4-day) exposure to 0.125  ppm O3 (Holz et al., 2002). Similar
36    increased airway responsiveness in asthmatics to house dust mite antigen 16 to  18 hrs after

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 1   exposure to a single dose of O3 (0.16 ppm for 7.6 hrs) was observed. These observations suggest
 2   that O3 exposure may be a clinically important factor that can exacerbate the response to ambient
 3   bronchoconstrictor substances in individual with preexisting allergic asthma and that its
 4   influence may be both immediate and persist for long periods (CD, p. 8-29).
 5          An important aspect of increased airway responsiveness after O3 exposure is that it
 6   represents a plausible link between 03 exposure and increased hospital admissions. Kreit et al.
 7   (1989) found that O3 can induce increased airway responsiveness in asthmatic subjects to  O3,
 8   who typically have increased airway responsiveness at baseline. A subsequent study (Jdrres et
 9   al., 1996) suggested an increase in specific (i.e., allergen-induced) airway reactivity in subjects
10   with allergic asthma, and to a lesser extent in subjects with allergic rhinitis after exposure to 0.25
11   ppm O3 for 3  hrs; other studies (Molfino et al., 1991; Kehrl et al., 1999) reported similar results.
12   According to one study (Folinsbee and Hazucha, 2000), changes in airway responsiveness after
13   O3 exposure resolve more slowly than changes in FEVt or respiratory symptoms. Other studies
14   of repeated exposure to O3 suggest that changes in airway responsiveness tend to be somewhat
15   less affected by attenuation with consecutive exposures than changes in FEVi (Dimeo et al.,
16   1981; Folinsbee et al., 1994; Gong et al.,  1997a; Kulle et al., 1982).
17          An extensive laboratory animal data base exploring the effects of acute, long-term, and
18   repeated exposure to O3 indicates that induction of AHR occurs at relatively high O3
19   concentrations. These studies provide clues to the roles of physiological and biochemical
20   components involved in this process, but  caution should be exercised in interpreting these
21   results, as different mechanisms may be involved in mediating high- and low-dose responses.  As
22   observed in humans, the acute changes in AHR do not persist after long-term exposure of
23   animals exposed to near-ambient concentrations of O3, and attenuation has been reported.
24          The draft CD concludes that exposure is linked with increased AHR (CD, p. 6-43,6-44).
25   Both human and animal  studies indicate that airway responses  are not associated with
26   inflammation, but they do suggest a likely role for neuronal involvement (CD, 8.4.2.4.2).
27   Increases in AHR do not appear to be strongly associated with decrements in lung function or
28   increases in symptoms (CD, p. 6-30). These findings suggest that different mechanisms underlie
29   reported changes in AHR and changes in lung function or respiratory symptoms.
30             3,3.1.2.3  Respiratory Inflammation and Permeability
31          Short-term exposures to O3 can cause acute respiratory  inflammation and increased
32   permeability in the lungs of humans  and experimental animals  (CD,  sections 5.2.3, 6.9, 7.2.5 and
33   8.4.1.4.3).  Lung inflammation and increased permeability, which are distinct events controlled
34   by different mechanisms, are two well characterized effects of O3 exposure observed in all
35   species studied.  Disruption of the lung barrier leads to leakage of serum proteins, influx of
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 1   polymorphonuclear leukocytes (PMNs), release of bioactive mediators, and movement of
 2   compounds from the airspaces into the blood.
 3          In the animal lexicological studies discussed in the draft CD (Chapter 5), the lowest O3
 4   concentration that induced inflammation in the mouse lung was 0.11 ppm for 24 hr exposures.
 5   Shorter exposures of 8 hrs required concentrations of 0,26 ppm to induce epithelial permeability
 6   thought there was no effect on inflammation. The lowest O3 concentration that affected-
 7   epithelial permeability of inflammation in the rat was 0.5 ppm for a 3 hr exposure (CD, p. 8-32).
 8   After acute exposures, the influence of the time of exposure increases as the concentration of 03
 9   increases. Hie exact role of inflammation in causation of lung disease is not known, nor is the
10   relationship between inflammation and lung function (CD, section 5.2.3).
11          A number of human Cvexposure studies have analyzed bronchoalveolar lavage (BAL)
12   and nasal lavage (ML) fluids and cells for markers of inflammation and lung damage.  These
13   studies are summarized in the draft CD (Annex AX6, Tables AX6-12 and AX6-13). Increased
14   lung inflammation is demonstrated by the presence of neutrophils (PMNs) found in BAL fluid in
15   the lungs, which has long been accepted as a hallmark of inflammation.  It is apparent, however,
16   that inflammation within airway tissues may persist beyond the point that inflammatory cells are
17   found in the BAL fluid.  Soluble mediators of inflammation, such as cytokines and arachidonic
18   acid metabolites have been measured in the BAL fluid of humans exposed to O3.  In addition to
19   their role in inflammation, many of these compounds have bronchoconstrictive properties and
20   may be involved in increased airway responsiveness (CD, p. 6-31).
21          In the 1996 CD, assessment of human exposure studies indicated that a single, acute (1 to
22   4 hrs) O3 exposure (0.2 to 0.6 ppm) of subjects engaged in moderate to heavy exercise could
23   induce a number of cellular and biochemical changes suggestive of pulmonary inflammation and
24   lung permeability (CD, p. 8-33). These changes persisted for at least 18 hrs. Graham and Koren
25   (1990) compared inflammatory mediators present in NL and BAL fluids of humans exposed to
26   0.4 ppm O3 for 2 hrs and found similar increases in PMNs in both fluids, suggesting a qualitative
27   correlation between inflammatory changes in the lower airways (BAL) and upper respiratory
28   tract (NL).  Acute airway inflammation was shown to occur among adults exposed to 0.08 ppm
29   O3 for 6.6 hrs with exercise (Devlin et al., 1990).  Another study (McBride et al., 1994) reported
30   that asthmatic subjects were more sensitive than non-asthmatics to upper airway inflammation
31   for O3 exposures (0.24 ppm, 1.5 hrs, with light IE) that did not affect pulmonary function.
32          Since 1996, a substantial number of human exposure studies have been published which
33   have provided important new information on lung inflammation and epithelial permeability.
34   One publication (Mudway and Kelly, 2004) examined 03-induced inflammatory responses and
35   epithelial permeability with a meta-analysis of 21 controlled human exposure studies.  Results of
36   the analysis suggest that for a 1 hr exposure to 0.12 ppm.O3, the threshold dose for early phase
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 1   PMN response would not be exceeded unless an individual was engaged in very heavy exercise
 2   (minute ventilation of 90 L/min),  For 8 hr exposures to 0.08 ppm O3, early phase PMN dose
 3   threshold could be reached during relatively light sustained activity (minute ventilation of 17
 4   L/min). For these 1- and 8-hr exposure scenarios, BAL fluid protein levels would be predicted to
 5   increase by about 1.1 fold.. For late phase PMN responses, threshold dose was 26% greater than
 6   for early phase responses. Mudway and Kelly (2004) indicated.that their threshold doses were
 7   for average PMN responses in healthy adults and that some individuals would respond at lower
 8   doses.
 9          A number of more recent studies (Peden et al., 1997; Scannell et al., 1996; Hilterman et
10   al., 1999; Bosson et al., 2003) have provided evidence suggesting that asthmatics show greater
11   inflammatory response than healthy subjects when exposed to similar O3 levels. Markers from
12   BAL fluid following both 2-hr (Devlin et al., 1997) and 4-hr (Christian et al., 1998; Jorres et al.,
13   2000) O3 exposures repeated up to 5 days indicate that there is ongoing cellular damage
14   irrespective of attenuation of some cellular inflammatory responses of the airways, pulmonary
15   function, and symptom responses.
16          The draft CD (p. 8-35) concludes that interaction of O3 with constituents of ELF-and
17   induction of oxidative stress is implicated in injury and inflammation. Alterations in the
18   expression of cytokines, chemokines, and adhesion molecules, indicative of an ongoing active
19   stress response, as well as injury repair and regeneration processes, have been reported in animal
20   toxicology and human in vitro studies evaluating biochemical mediators implicated in injury and
21   inflammation.    .
22             3.3.1.2.4  Changes in Host Defense Capability
23          As discussed in section 8.4.1.4.2 of the draft CD, acute exposures to O3 have been shown
24   to impair host defense capabilities in both humans and experimental animals by depressing
25   alveolar macrophage functions and by altering the mucociliary clearance of inhaled particles and
26   microbes. Acute O3 exposures also interfere with the clearance process by accelerating clearance
27   for low doses and slowing clearance for high doses.  Animal toxicological studies have reported
28   that acute O3 exposures suppress alveolar phagocytes and immune functions.  Dysfunction of
29   host defenses and subsequent increased susceptibility to bacterial lung infection in laboratory
30   animals has been induced by acute exposures to O3 levels as low as 0.08 ppm (CD, p. 8-36).
31   Changes in antibacterial defenses are dependent on exposure regimens, species and strain of lab
32   animals, species of bacteria, and age of the animals used. Acute O3-induced suppression of
33   alveolar phagocytosis and immune function in experimental animals appeared to be transient and
34   attenuated with continuous or repeated exposures (CD, p. 8-36).
35          Ozone exposure has also been show to interfere with AM-mediated clearance in the
36   respiratory region of the lung and with mucociliary clearance of the tracheobronchial airways.
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 1   These interferences with clearance are dose dependent, with low doses accelerating clearance
 2   and high doses slowing the process.  An in vitro study of epithelial cells from nonatopic and
 3   atopic asthmatics exposed to 0.01 to 0.10 ppm O3 showed significantly increased permeability
 4   compared to cells from normal persons. This indicates a potentially inherent susceptibility of •
 5   cells from asthmatic individuals for O3-induced permeability. Although the available
 6   information suggests that acute O3 exposures can impair host defense capability by interfering
 7   with AM functions, there is no compelling evidence from animal or human studies that O3
 8   increases the incidence of respiratory viral infection in humans (CD, p, 8-36).
 9          A single human exposure study (Devlin et al., 1991) reviewed in the 1996 CD reported
10   that exposure to 0.08 to 0.10 ppm 03 for 6.6 hrs induced decrements in the ability of alveolar
11   macrophages (AMs) to phagocytose microorganisms; several other studies reported similar
12   effects but with higher exposure concentrations (CD, p. 6-39). Few new controlled human
13   exposure studies are available in this draft CD (section 6.9.6).  Integrating the recent study  -
14   results with evidence available in the 1996 CD, the draft CD concludes that evidence supports
15   the conclusion that short-term 03 exposures have an adverse impact on host defense capability,
16   even for exposures as low as 0.08 ppm to 0.10 ppm (CD, p. 6-39).
17             3.3.1.2.5  Morphological Effects
18       .In the 1996 CD, it was found that short-term 03 exposures cause similar alterations in
19   lung morphology in all laboratory animal species"studied, including primates. Cells in the
20   centriacinar region (CAR) of the lung (the segment between the last conducting airway and the
21   gas exchange region) have been recognized as a primary target of Cvinduced damage (epithelial
22   cell necrosis and remodeling of respiratory bronchioles), possibly because this region receives
23   the greatest dose of O3 delivered to the lower respiratory tract (CD, p. 8-30).  Ciliated cells in the
24   nasal cavity and airways, as wellvas Type I cells in the gas-exchange region, are also identified as
25   targets. Differences in distribution of antioxidants in the CAR of the lungs are responsible for
26   differences in injury and morphological effects observed in nonhuman primates and rodents.
27   While short-term O3 exposures can cause structural changes such as fibrosis in the CAR, these
28   changes appear to be transient with recovery time after exposure dependent on species and O3
29   dose.
30        •  Recent studies continue to show that short-term exposures to O3 cause similar alterations
31   in lung structure in a variety of experimental animal species, at concentrations of 0.15 ppm in
32   rats and even lower concentrations in primates (CD, section 5.2.4.1 and 5.2.4.2). New work
33   (Hotchkiss et al.,  1998) has shown that a topical anti-inflammatory corticosteroid can prevent
34   these effects in nasal epithelia, while exposure to bacterial endotoxin can potentiate effects
35   (Fanucchi et al.,  1998). Ozone-induced fibrotic changes in the CAR are maximal at 3 days of
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 1    exposure and recover 3 days post-exposure with exposures of 0,2 ppm 03 in rodents (Dormans et
 2    al., 1999).  •  •                                                            .
 3          New studies of susceptibility factors demonstrated that ferrets and monkeys have similar
 4    inflammatory and necrotic responses to 1 ppm O3, which differs from lesser injury seen in rats
 5    (Stemer-Kock et al., 2000). Rats with induced allergic rhinitis are more susceptible to 0.5 ppm>
 6    O3 than are controls (Cho et al., 1999b). Important new work has demonstrated variability of
 7    local O3 dose and subsequent injury in the respiratory tract due to depletion of glutathione (GSH)
 8    (Plopper et al., 1998). The proximal respiratory bronchiole receives the most acute epithelial
 9    injury from exposures < 1 ppm, while metabolic effects were greatest in the distal bronchioles
10    and minor daughter airways (CD, p. 5-32).
11          Based on evidence from animal toxicological studies, the draft CD concludes that short-
12    term exposures to O3 can cause morphological changes in the respiratory systems of a number of
13    laboratory animal species (CD, p. 5-38).  Little evidence is available from human studies.
14             3.3.1.2.6  Effects on Exercise Performance
15          The effects of O3 exposure on exercise performance of healthy individuals have been •
16    investigated in a number of controlled exposure studies (CD, section 6.7). Several studies
17    reported that endurance exercise performance and VOama* may be limited by acute exposure to O3
18    (Adams and Schelegle, 1983; Schelegle and Adams, 1986; Gong et al., 1986; Foxcroft and
19    Adams, 1986; Folinsbee et al., 1977; Linder et al., 1988).  Gong et al. (1986) and Schelegle and
20    Adams (1986) found that significant reductions in maximal endurance exercise performance may
21    occur in well-conditioned athletes while they perform CE (VB >-80 L/min) for 1 hr at O3
22    concentrations > 0.18 ppm. There are no new studies available in the draft CD.
23          Thus, as in the 1996 CD, the draft CD concludes that reports from studies of O3 exposure
24    during high-intensity exercise indicate that breathing discomfort associated with maximal
25    ventilation may be an important factor in limiting exercise performance in some, but not all,
26    subjects (CD; p. 6-29).
27             3.3.1.2.7  Increased School Absences
28          The association between school absenteeism and ambient O3 concentrations was assessed
29    in three relatively large field studies (CD, section 7.2.6). One study (Chen et al., 2000) examined
30    daily school absenteeism in 27,793 elementary school students in Nevada over a 2-year period
31    (after adjusting for PMio and CO concentrations) found that  ambient O3 concentrations were
32    associated with 10.41 % excess rate of school absences per 40 ppb increase in 1 -hr max O3.
33    Another study (Gilliland et al., 2001) studied O3-related absences among 1,933 4th grade students
34    in 12 southern California communities and found significant associations between 30-day
35    distributed lag of 8-hr average O3 concentrations and all absence categories, particularly for
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 1   respiratory causes. Neither PMio nor N02 were associated with any respiratory or nonrespiratory
 2   illness-related absences in single pollutant models. A third study (Park et al., 2002) investigated
 3   associations between air pollution and school absences in 1,264 students (1st to 6th grades) in
 4   Seoul, Korea and reported that same day O3 concentrations were positively associated with
 5   illness-related absences. Models of PMio alone and of both PMio and 03 showed positive
 6   associations with illness-related absences, with a slightly greater effect seen for O3.
 7         • The draft CD concludes that these studies of school absences suggest that ambient O3
 8   concentrations on the same day, as well as accumulated over two to four weeks, may be
 9   associated with school absenteeism, but further replication is needed before firm conclusions can
10   be reached regarding this effect (CD, p. 7-52).

11            3.3.1.3    Effects on the  Respiratory System from Long-term Exposures
12          The 1996 CD concluded that there was insufficient evidence from the limited number of
13   studies to determine whether long-term O3 exposures resulted in chronic health effects. •
14   However, the aggregate evidence suggested that 03 exposure, along with other environmental
15   factors, could be responsible for health effects in exposed populations (CD, section 7.5).  Animal
16   toxicological studies carried out in the 1980' s and 1990' s demonstrated that long-term exposures
17   can result in a variety of morphological effects, including permanent changes in the small
18   airways of the lungs, including remodeling of the distal airways and CAR and deposition of
19   collagen. These changes result from the damage and repair processes that occur with repeated
20   exposure. Fibrotic changes were also found to persist after months of exposure providing a
21   potential pathophysiologic basis for changes in airway function observed in children in some
22   recent epidemiological studies.  It appears that variable seasonal ambient patterns of exposure
23   may be of greater concern than continuous daily exposures. One important toxicological study
24   (Tyler et al., 1988) reported that young monkeys exposed to seasonal ambient O3 patterns, but not
25   daily exposures, experienced increases in total lung collagen content, chest wall compliance, and
26   inspiratory capacity, suggesting a delay in lung maturation in seasonally-exposed animals. This
27   section reviews studies published since 1996 in which health effects were assessed for O3
28   exposures lasting from weeks to several years. Summaries of new morphological effects studies
29   of long-term exposures are listed in Table AX5-6 (CD, Annex AX5) and of new morbidity
30   effects epidemiological studies long-term exposure are listed in Table AX7-7 (CD, Annex AX7).
31             3.3.1.3.1  Seasonal Ozone Effects on Lung Function
32          It is well documented in controlled human exposure and field studies that daily multi-
33   hour exposures to O3 produce transient declines in lung function; however, lung function effects
34   of repeated exposures to O3 over extended periods are far less studied. Several studies published
35   since 1996 have investigated lung function changes over seasonal time periods (CD, section


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 1   7.5.3). One large, three-year study (Frischer et al., 1999) collected repeated lung function
 2   measurements in 1,150 young, Austrian school children and found that growth-related increases
 3   in lung function over the summer season were reduced in relation to seasonal mean O3 levels. A
 4   one-year extension of this study by Horak et al. (2002a,b) confirmed the results that seasonal
 5   mean O3 levels are associated with a negative effect on increases in lung function in children.
 6   Another study (Kopp et al., 2000)  of 797 children in Austria and southwestern Germany reported
 7   smaller increases in lung function  in children exposed to higher levels of ambient O3 compared
 8   to children living in areas with lower ambient 03 levels. Another Austrian study (Ihorst et al.,
 9   2004) of 2,153 young children found significantly lower FVC and FEVi increases associated
10   with higher O3 exposures in the summer but not in the winter. A pilot study (Kinney and
11   Lippmann, 2000) of 72 young adult, military  academy students provided results that are
12   consistent with a seasonal decline  in lung function that may be due, in part, to O3 exposures.
13   According to the draft CD (p. 7-102), these studies collectively indicate that seasonal O3
14   exposure is associated with smaller increases in lung function in children and that there is limited
15   evidence that seasonal O3 also may affect young adults.
16          .   3,3.1.3.2  Reduced Baseline Lung Function and Respiratory Symptoms
17          Lung capacity grows during childhood and adolescence as body size increases, reaches a
18   maximum during the twenties, and then begins to decline steadily and progressively with age.
19   Long-term exposure to air pollution has long been thought to contribute to slower growth in lung
20   capacity, diminished maximally attained capacity, and/or more rapid decline in lung capacity
21   with age (CD, section 7.5.4).  Toxicological findings evaluated in the 1996 CD demonstrated that
22   repeated daily exposure of rats to an episodic profile of Os caused small, but significant,
23   decrements in lung function that were consistent with early indicators  of focal fibrogenesis in the
24   proximal alveolar region, without  overt fibrosis (CD, section 5.2.5.2).  Because.O3 is a strong
25   respiratory irritant and has been shown to cause inflammation and restructuring of the respiratory
26   airways, it is plausible that long-term O3 exposures might have a negative impact on baseline
27   lung function, particularly during childhood when these exposures might have long-term risks.
28   In the current draft CD, however, no recent toxicological studies have been published on effects
29   of chronic  Os exposure.
30          Several epidemiological studies published since 1996 have examined the relationship
31   between lung function and long-term 03 exposure. The most extensive and robust study of
32   respiratory effects in relation to long-term air pollution exposures among children in the U.S. is
33   the Children's Health Study carried out in 12 communities of southern California starting in
34   1993 (Avol et al., 2001; Gauderman et al., 2000, 2002, 2004a,b; Peters et al., 1999a,b). One
35   study (Peters et al.,1999a) examined the relationship between long-term O3 exposures and self
36   reports of respiratory symptoms and asthma in a cross sectional analysis and found a limited
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 1    relationship between outcomes of current asthma, bronchitis, cough and wheeze and a 40 ppb
 2    increase in 1-hr max O3. Another analysis (Peters et al., 1999b) examined the relationship
 3    between lung function at baseline and levels of air pollution in the community and reported
 4    evidence that annual mean 03 levels were associated with decreases in FVC, FEVi, PEF and
 5    FEF25-?5 (the latter two being statistically significant) among females but not males. In a separate
 6    study (Gauderman et al., 2000) of 4th, 7th, and 10th grade students, a longitudinal analysis of lung
 7    function over four years found no association with 03 exposure.  Subsequent studies by the same
 8    group (Gauderman et al., 2002,2004a,b) led the authors to conclude that results provide little
 9    evidence that ambient O3 at current levels is associated with chronic deficits in the rate of
10    increase in lung function in children.  Avol et al.  (2001) examined children who had moved from
11    participating communities in southern California to other states with improved air quality and
12    found, with the exception of FEVi, the 03 effect estimates for all other spirometric parameters
13    were negative, but the associations were not as strong as those observed for PMi0.  Collectively,
14    the results of these reports from the children's health cohorts provide little evidence for impact of
15    long-term O3 exposures on smaller increases in lung function, but further study is needed to
16    address mis question (CD, p. 7-104). Three other studies (Frisher et al., 1999; Ihorst et al, 2004;
17    Horak et al., 2002a) conducted in Austria and Germany also found no associations between
18    increases  in lung function parameters and mean summer O3levels over a three- to five-year
19    period of study.
20          Evidence for a significant relationship between long-term O3 exposures and decrements
21    in maximally attained lung function was reported in a nationwide study (Galizia and Kinney,
22    1999; Kinney et al., 1998) of first year Yale students. Males had much larger effect estimates
23    than females, which might reflect higher outdoor activity levels and correspondingly higher Oj
24    exposures during childhood. A similar study (Kunzli et al., 1997; Tager et al., 1998) of college
25    freshmen at University of California at Berkeley  also reported significant effects of long-term O3
26    exposures on lung-function.  In a comparison of students whose city of origin was either Los
27    Angeles or San Francisco, long-term O3 exposures were associated with significant changes in .
28    mid- and  end-expiratory flow measures, which could be considered early indicators for
29    pathologic changes that might progress to COPD. An autopsy pathologic study (Sherwin et al.,
30    2000) examined subjects for CAR alterations in LA and in Miami, FL.  A trend toward greater -
31    extent and severity of CAR alterations, in LA residents was observed,' and it was suggested that
32    this effect might be related to higher O3 exposures in LA.
33          Recent publications from the southern California children's cohort study provide no
34    evidence  for an association between long-term Os exposure and lung function in children (CD, p.
35    7-106). Limited evidence is available from studies of adults and college studies to suggest that
36    long-term Os exposure may affect lung function or respiratory symptoms (CD, p. 7-105).

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 1    Overall, the draft CD concluded that this body of evidence was generally inconclusive for effects
 2    of long-term Os exposure on respiratory symptoms or lung function (CD, p. 7-178).
 3             3.3. L 3.3   Long-term O3 Exposure and Respiratory Inflammation
 4          As noted earlier in section 3.3.1.2 of this Staff Paper and in the draft CD (Chapter 6),
 5    chamber studies of exercising humans exposed to 03 for 2 to 6.6 hrs have demonstrated
 6    inflammation in the lungs, including the alveolar region where gas exchange takes place. The
 7    potential long-term significance of short-term exposures to O3 is that they can result in the  -
 8    release of reactive substances from inflammatory cells that can damage the sensitive cells lining
 9    the lungs.  Over time repeated inflammation can lead to permanent lung damage and
10  •  restructuring of the small airways and alveoli. Also since inflammation is a hallmark
11    characteristic of asthma, there is the possibility that O3-induced inflammation may exacerbate
12    existing asthma or contribute to the development of asthma in genetically predisposed
13    individuals (CD, section 7.5.5).
14          For subchronic exposures of animals, permeability changes are transient (and species-
15    dependent) and return to control levels even with continuing exposure.  For long-term O3
16    exposures, persistent O3-induced inflammation plays an important role in alterations of lung
17    structure and function.  Significant remodeling of the epithelium and underlying connective
18    tissues in distal airways have been reported in rats exposed to 0.25 ppm O3 (12 hr/day for 6
19    weeks) and in monkeys exposed to 0.2 ppm 03 (8hr/day for 90 days) (CD, p. 8-32).
20          In one'epidemiological field study (Kinney et al, 1996), BAL fluids were  taken in the
21    summer and winter from a group of joggers in New York and were compared for  evidence of
22    acute inflammation and of enhanced cell damage. There was little evidence of acute
23    inflammation in the summer BAL fluids  compared to winter, but there was evidence of enhanced
24    cell damage.  This suggests that even though inflammation may diminish over the summer, cell
25    damage may be continuing.  A series of studies (Calderon-Garciduenas et al., 1995,1997,1999)
26    conducted in Mexico City provides evidence of inflammation and genetic damage to cells in the
27    nasal passages of children chronically exposed to O3 and other air pollutants. Significantly
28    higher DNA damage was reported in children living in Mexico City compared to nonurban
29    children and in older compared to younger children.  A more recent study (Calderon-
30    Garciduenas et al., 2003) of Mexico City children reported that they exhibited nasal
31    abnormalities (22%), hyperinflation (67%), interstitial markings (49%), and a mild restrictive
32    pattern by spirometry (10%), while a control  group of nonurban children showed no significant
33    abnormalities. Another marker of inflammation, urinary eosinophil, was analyzed in an Austrian
34    school children study (Frischer et al., 2001), and it was reported that O3 exposure  was
35    significantly associated with eosinophil inflammation.
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 1          In assessing these studies, the draft CD (p. 7-110) concluded that specific attribution of
 2   these adverse respiratory and genotoxic effects to 03 is difficult given the complex mixture in
 3   ambient air, although inflammatory changes like eosinophil levels observed in the Austrian study
 4   would be consistent with known effects of O3.
 5            3.3.1.3.4   Risk of Asthma Development
 6          There have been a few studies investigating associations between long-term O3 exposures
 7   and the onset of new cases of asthma (CD, section 7.5.6).  The Adventist Health and Smog
 8   (AHSMOG) study cohort of 3,914 was drawn from nonsmoking, non-Hispanic white adult
 9   Seventh Day Adventists living in California (Greer et al., 1993; McDonnell et al., '1999).
10   Subjects  were surveyed in 1977,1987, and 1992, and new cases of asthma were defined as self-
11   reported  doctor-diagnosed asthma at either the 1987 or 1992 follow-up questionnaire among
12   those who had not reported having asthma when the enrolled in 1977.  During the ten-year
13   follow-up in 1987, it was reported that the incidence of new asthma was 2.1 % for males and
14   2.2% for females (Greer etal., 1993). A statistically significant relative risk of 3.12 per 10 ppb
15   increase in annual mean O3 (no exposure metric given) as observed in males, compared to a
16   nonsignificant relative risk of 0.94 in females. In the 15-year follow-up in 1992, it was reported
17   that 3.2% of eligible males and 4.3% of eligible females had developed adult asthma (McDonnell
18   etal., 1999).  For males, the relative risk of developing asthma was 2.27 per 30 ppb increase in
19   8-hr average O3, but there was no evidence of an association in females. The lack of an
20   association in females does not necessarily mean there is no effect but may be due to differences.
21   in time-activity patterns in males and females, which could lead to greater misclassification of
22   exposure in females.  Consistency of results in the two follow-up studies provides evidence of an
23   association between long-term O3 exposure and asthma incidence in adult males; however,
24   representativeness of this cohort to the general U.S. population may be limited (CD, p. 7-111).
25         • In a similarstudy (McConnell et al., 2002) of incident asthma among children (ages 9 to
26   16 at enrollment), annual surveys of 3,535 children initially without asthma were used to identify
27   new-onset asthma cases as part of the Children's Health Study. Six high-O3(mean 1-hr max O3
28   of 75.4 ppb over four years) and six low-03(50.1 ppb) communities were identified where the
29   children resided. There were 265 children who reported new-onset asthma during the follow-up
30   period. Although asthma risk was no higher for all residents of the six high-O3 versus six low-O3
31   communities, asthma risk was 3.3 times greater for children who played three or more sports as
32   compared with children who played no sports within the high-O3 communities. This association
33   was absent in the communities with lower O3 concentrations. No other pollutants were found to
34   be associated with new-onset asthma.
35          The draft CD  (p. 7-111) suggests that playing sports may indicate outdoor activity when
36   O3 levels would be higher, as well as an increased ventilation rate, both of which could increase

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  1   O3 exposure and dose.  These results, however, were based on a small number (29) of new-onset
  2   asthma cases among children who played three or more sports.  Future replication of these
  3   findings in other cohorts would help support a causal interpretation.
  4             3.3.1.3. S  Morphological Effects
  5          The progression of morphological effects during and after a chronic exposure in the range
  6   of 0.5 to 1.0 ppm O3is complex, with inflammation peaking over the first few days of exposure,
  7   then dropping, then plateauing, and finally, largely disappearing (CD, section 5.2.4.3).  Epithelial
  8   hyperplasia follows a somewhat similar pattern.  In contrast, fibrotic changes in the tissue -
  9   increase very slowly over months of exposure, and, after exposure ceases, the changes
 10   sometimes persist or increase.  Patterns of exposure in this same concentration range determine -.
 11   effects, with 18 months of daily exposure causing less morphologic damage than exposures on
 12   alternating months. This is important as environmental O3 exposure is typically seasonal. The
 13   long-term study of Plopper et al.  (1998) investigated infant rhesus monkeys exposed to
 14   simulated, seasonal O3 (0.5 ppm, 8 hrs/day for 5 days, every 14 days for 11 episodes) and
 15   demonstrated: 1) remodeling in the distal airways, 2) abnormalities in trachea! basement
 16   membrane; 3) eosinophil accumulation in conducting airways; and 4). decrements in airway
 17   innervation. The only epidemiological study (Sherwin et al., 2000) that investigated severity of
 18   CAR alterations in human lungs compared autopsy results of lungs for Miami and LA residents.
 19   The results indicate a significantly greater extent and severity of CAR alterations in LA
 20   residents,  suggesting that the CAR alterations may be related to higher O3 levels in LA. These
 21   findings advance earlier information regarding possible injury-repair processes occurring with
 22   seasonal O3 exposures (CD, p. 5-36).
 23             3.3.L3.6  Summary
 24          In  the past decade, important new longitudinal studies have examined the effect of
. 25   chronic O3 exposure on respiratory health outcomes.  Evidence from recent long-term morbidity
 26   studies have suggested in  some cases that chronic exposure to 03 may be associated with
 27   seasonal declines in lung function, increases in inflammation, and development of asthma in
 28   children and adults.  Seasonal decrements or smaller increases in lung function measures have
 29   been reported in several studies; however, it remains  uncertain to what extent these changes are
 30   transient.  In contrast to the supportive evidence from animal studies with chronic exposures,   •
 31   epidemiological studies of new asthma development and longer-term lung function declines
 32   remain inconclusive at present (CD, p. 7-118).
 33           3.3.1.4    Effects on the Cardiovascular System
 34          Epidemiological studies of cardiovascular effects have investigated associations with
 35   several air pollutants, including O3, PM,  CO, NO2 and SO2, most often with a focus on PM health
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 1    endpoints (CD, p. 7-54). Several studies also have examined associations of O3 and other
 2    gaseous pollutants with heart rate variability (HRV) in the elderly and the increased risk of
 3    myocardial infarction associated with exposure to air pollution.  One study (Liao et al. 2004)
 4    reported larger effect estimates for PM,0 than those for the gaseous pollutants such as 03;
 5    however, the findings are suggestive of short-term effects of 03 and other pollutants on HRV.
 6    Another study (Park et al., 2005) reported that in analyses by ischemic heart disease,
 7    hypertension, and diabetes status, stronger associations of HRV and both O3 and PM^s were
 8    observed for individuals with ischemic heart disease and hypertension than those without these
 9    preexisting conditions. These results were consistent with another study (Holguin et al., 2003)
10    conducted in Mexico City, which reported an association between decreased HRV with O3 in
11    subjects with hypertension. Other studies did not provide evidence for an O3 effect on cardiac
12    arrhythmias; however, the draft CD notes that the 03 concentrations in these studies were low
13    (CD, p. 7-57).
14           Some hew epidemiological studies have reported associations with more severe effects,
15    such as myocardial infarction.  Peters et al. (2001) reported positive, but not statistically
16    significant associations between ozone and the incidence of myocardial  infarction in Boston
17    (CD, p. 7-55). The effect estimate for the association with Oa averaged  over 2 hrs prior to the
18    myocardial infarction was substantially  larger than that reported for an association with 24-hr
19    average Oj (Peters et al., 2001). In France, Ruidavets et al. (2005) reported a statistically
20    significant association between  ambient Oj concentrations and incidence of myocardial
21    infarction (CD, p. 7-55).
22           A number of epidemiological studies have also reported associations between short-term
23    exposures and hospitalization for cardiovascular diseases. As shown in  Figure 7-13 of the draft
24    CD, the results of these studies are inconsistent (CD, p. 7-72). In addition, in Denver, (Koken et
25    al., 2003) reported associations between hospitalization for specific cardiovascular diseases and
26    ambient O3 concentrations; the associations were inconsistent, however,  and generally not
27    statistically significant.
28           There is limited controlled-exposure human experimental information available which
29    suggests that O3 exposure induces cardiovascular effects.(CD, sections 6.10 and AX6.10).  In one
30    study, Gong et al. (1998) monitored numerous cardiac variables in both healthy and hypertensive
31    subjects. Results suggested that by impairing the alveolar-to-arterial oxygen transfer, the O3
32    exposure could potentially lead to adverse cardiac events by decreasing oxygen supply to the
33    myocardium. The subjects in the Gong  et al. (1998) study had sufficient functional reserve so  as
34    not to experience significant ECG changes or myocardial ischemia and/or injury; however, it was
35    concluded that O3 exposure could pose a cardiopulmonary risk to persons with preexisting
36    cardiovascular disease, with or without concomitant respiratory disease.  In other research,

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 1   Foster et al. (1993) demonstrated that even in relatively healthy young adults, O3 exposure can
 2   cause ventilation to shift away from the well perfused basal lung, an effect on small airways
 3   which Foster et al. (1997) showed may persist for over 24 hr after exposure.  Hypoxic pulmonary
 4   artery vasoconstriction acts to shift perfusion away from areas of low ventilation and moderate
 5   ventilation-perfusion mismatches (Santak et al., 1998).  This arterial vasoconstriction is thought
 6   to be mediated by protein kinase C (Barman, 2001; Tsai et al., 2004).  A more generalized (i.e.,
 7   not localized to poor ventilated ^areas) increase in pulmonary vascular resistance in response to
 8   03 exposure would presumably act against the ability of the hypoxic vasoconstriction in
 9   mediating ventilation-perfusion mismatches (CD, sections 6-10 and AX6-10).
10          Based on epidemiological study results, the draft CD concludes that the current evidence
11   from field studies is rather limited, but supportive of a potential effect of short-term O3 exposure
12   and heart rate variability, cardiac arrhythmia and incidence of myocardial infarction (CD, p. 7-
13   57). In the draft CD's evaluation of studies of hospital admissions for cardiovascular disease
14   (CD, section 7.3.4), it is concluded that evidence from this growing group of studies is generally
15   inconsistent, but is suggestive of an association with 03 in studies conducted during the warm
16   season (CD, p. 7-73,7-74).

17          3.3.2   Premature Mortality
18          There were only a limited number of studies which examined the relationship between 03
19   and mortality available for review in the 1996 CD. Some studies suggested that mortality was
20   associated with short-term exposure to ozone, but conclusions could not be drawn regarding such
21   associations (U.S EPA, 1996, p. 42). Numerous recent studies have provided new and more
22   substantial evidence supporting such an association, as discussed below in section 3.3.2.1.
23          At the time of the last review, little epidemiological evidence was available on potential
24   associations between long-term exposure to O3 and mortality. Among the recent studies are
25   some that have evaluated this relationship, and still provided limited, if any,  evidence for an
26   association between chronic ozone exposure and mortality,  as described in section 3.3.2.2.

27            3.3.2.1     Mortality and Short-term 63 Exposure
28          In the 1996 CD, some, but not all, epidemiological studies had reported associations
29   between short-term ozone exposure and mortality. Given the information available from the
30   studies modeling for O3 and weather, it was difficult to evaluate whether associations were
31   possibly not achieving statistical significance due to overspecification of the weather model.  ••  .
32   Based on Ihe limited evidence available from the epidemiological studies and the uncertainties
33   regarding weather model specifications, the 1996 CD was unable to quantitatively assess the O3-
34   mortality relationship, or even provide qualitative assessment of the likelihood of Os-mortality
35   associations (CD, p. 7-74).
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 1          The draft CD includes results from numerous epidemiological analyses of the
 2    relationship between O3 and mortality. Key findings are available from multicity time-series
 3    studies that report associations between O3 and mortality. These studies include analyses using
 4    data from 90 U.S. cities in the National Mortality, Morbidity and Air Pollution (NMMAPS)
 5    study (Samet et al., 2000, reanalyzed in Dominici, 2003) and from 95 U.S. cities in an extension
 6    to the NMMAPS analyses (Bell et al., 2004), and further analyses using a subset of 19 U.S. cities
 7    and focusing on cause-specific mortality associations (Huang et al.5 2005). An additional study
 8    used case-crossover design and data from 14 U.S. cities (Schwartz, 2005), to further investigate
 9    the influence of adjustment for weather variables in the O3-mortality relationship.  Finally,
10    results are available from a European study, Air Pollution and Health: a European Approach
11    (APHEA), an analysis using data from 23 cities (Gryparis et al., 2004) and 4 cities (Touloumi et
12    al., 1997).
13          In the original 90-city NMMAPS analysis, which was primarily focused on investigating
14    effects of PMio on mortality, a significant association was reported between mortality and 24-hr
15    average O3 concentrations during the warm season, but the association was not significant in
16    analyses for the full year (Samet et al., 2000; CD, Figure 7-19; p. 7-86). The extended
17    NMMAPS analysis included data from 95 U.S. cities and included data from 1987-2000 (Bell, et
18    al., 2004), and significant associations were reported between ozone and mortality. The effect
19    estimate for increased mortality was 0.5% per 24-hr average O3 measured on the same day (20
20    ppb change; 95% PI: 0.24, 0.78), and 1.04% per 24-hr  average O3  in a 7-day distributed lag
21    model (20 ppb change, 95% PI: 0.54,135) (CD, p. 7-78).  In analyses using only data from the
22    warm season, the results were not significantly different from the full-year results; the effect
23    estimate for increased mortality was 0.44% per 24-hr average O3 measured on the same day (20
24    ppb change; 95% PI: 0.14,0.74), and 0.78% per 24-hr  average O3  in a 7-day distributed lag
25    model (20 ppb change, 95% PI: 0.26,1.30) (CD, p. 7-85).  The authors also report that O3-
26    mortality associations were robust to adjustment for PM (CD, p. 7-87).
27          Using a subset of the NMMAPS data set, Huang et al. (2005) focused.on associations
28    between cardiopulmonary mortality and ozone exposure (24-hr average) during the summer
29    season only. The authors report a 1.47% increase per 20 ppb change in O3 concentration
30    measured on the same day (95% PI: 0.54, 2.39), and a 2.52% increase per 20 ppb change in O3
31    concentration using a 7-day distributed lag model (95% PI: 0.94,4.10) (CD, p. 7-78, 7-80).
32          As discussed in section 3.4, assessment of confounding by weather, especially
33    temperature, is complicated by the fact that higher temperatures are important for O3 formation.
34    Using case-crossover study design, Schwartz (2005) assessed associations between daily
35    maximum concentrations and  mortality, matching case and control periods by temperature, and
36    using data only from the warm season. The reported effect estimate of 0.92% change in

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 1    mortality per 40 ppb O3 (1-hr maximum, 95% PI: 0.06,1.80) was similar to time-series analysis
 2    results with adjustment for temperature (0.76% per 40 ppb O3; 95% Probability Interval: 0.13,
 3    1.40), suggesting that associations between O3 and mortality are not sensitive to these adjustment
 4    methods for temperature (CD, p. 7-80, 7-81).
 5          An initial publication from APHEA, a European multi-city study, reported statistically
 6    significant associations between daily maximum O3 concentrations and mortality, with an effect
 7    estimate of 4.5% change in mortality per 40 ppb O3 (95% CI:  1.6, 7.7) in four cities (Touloumi et
 8    al., 1997).  An extended analysis was done using data from 23 cities throughout Europe
 9    (Gryparis et al., 2004).  In this report, a positive but not statistically significant association was
10    found between mortality and 1-hr daily maximum O3 in a full year analysis (CD, p. 7-81).
11    Focusing on analyses using summer measurements, the authors report statistically significant
12    associations with total mortality [1.8% increase per 30 ppb 8-hr ozone (95% CI: 0.8,2.9)],
13    cardiovascular mortality [2.7% increase per 30 ppb 8-hr ozone (95% CI: 1.2,  4.3)] and with
14    respiratory mortality [6.8% increase per 30 ppb 8-hr ozone (95% CI: 4.5, 9.2)] (Gryparis et al.,
15    2004; CD,  p. 7-85).
16          Two of the recent multi-city mortality studies have also reported associations for multiple
17    averaging times (Bell et al., 2004; Gryparis et al., 2004). Bell and colleagues (2004) reported
18    associations between mortality and 1-hr daily maximum, 8-hr daily maximum and 24-hr average
19    O3 concentrations.  Effect estimates for associations with 1-hr O3 was slightly larger than that
20    reported for 8-hr O3 concentrations, and both were distinctly larger than the association with 24-
21    hr average  O3, but the effect estimates did not differ statistically. Gryparis et al. (2004) also
22    reported effect estimates that were slightly larger with 1 -hr than with 8-hr O3  concentrations, but
23    not significantly so.
24          Numerous single-city analyses have also reported associations between mortality and
25    short-term  O3 exposure, especially for those analyses using warm season data. As shown in
26    Figure 7-19 of the draft CD, the results of recent publications  show a pattern of positive, often
27    statistically significant associations between short-term O3 exposure and mortality during the
28    warm season (CD, p. 7-86). For example, statistically significant associations were reported in
29    southern California (Ostro et al., 1995), Philadelphia (Moolgavkar et al., 1995), Dallas (Gamble
30    et al., 1998), and Vancouver (Vedal et al., 2003) as well as numerous studies conducted in other
31    countries.  However, no evidence of an association was seen in a study conducted in Pittsburgh
32    (Chock et al., 2000). In considering results from year-round analyses, there remains a pattern of
33    positive results but the findings are less consistent. For example, statistically significant
34    associations were reported in Philadelphia (Moolgavkar et al., 1995) and Dallas (Gamble et al.,
35    1998) while positive but not statistically significant associations were reported in Detroit
36    (Lippmann et al., 2000; reanalyzed in Ito, 2003), San Jose (Fairley, 1999; reanalyzed Fairley,

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 1    2003), and Atlanta (Klemm et al., 2004). No evidence for associations was reported in Los
 2    Angeles (Kinney et al., 1995), Coachella Valley (Ostro et al., 2003) and St. Louis and Eastern
 3    Tennessee (Dockery et al., 1992). In most single-city analyses, effect estimates were not
 4    substantially changed with adjustment for PM (CD Figure 7-20, p. 7-88).
 5          In addition, several meta-analyses have been conducted on the relationship between 03
 6    and mortality. As described in section 7.4.4 of the draft CD, these analyses reported.fairly
 7    consistent and positive combined effect estimates ranging from 1.5 to 2.5% increase in mortality
 8    for a standardized change in O3 (CD Figure 7-18,  page 7-84).  Three recent meta-analyses
 9    evaluated potential sources of heterogeneity in Cvmortality associations (Bell et al., 2005; Ito et
10    al., 2005; Levy et al., 2005). The draft CD observes common findings across all three analyses,
11    in that all reported that effect estimates were larger in warm season analyses, reanalysis of results
12    using default GAM criteria did not change the effect estimates, and there was no strong evidence
13    of confounding by PM (CD, p. 7-84). Bell et al. (2005) and Ito et al. (2005) both provided
14    suggestive evidence of publication bias, but Cvmortality associations remained after accounting
15    for that potential bias. The draft CD concludes that Ihese studies "provide strong evidence that
16    O3 is associated with mortality." (CD, p. 7-84)
17          Taken together, the draft CD concludes that the epidemiological evidence shows robust
18    associations between daily O3 concentrations and  mortality (CD, p. 7-96).  For standardized
19    ozone increments, effect estimates range from 0.5 to 2.5% increases in mortality in the multi-city
20    studies, and from 0.5 to 5% in single-city studies.  For most studies that conducted season-
21    specific analyses, effects  were larger and more precise in warm-season analyses (CD, p. 7-96).
22    The results of multi-city studies, single-city studies and the recent meta-analyses all indicate that
23    associations reported between O3 and mortality are also robust to adjustment for PM in the
24    models (CD, p. 7-89). Finally, from those studies that included assessment of associations with
25    specific causes of death, it appears that effect estimates for associations  with cardiovascular
26    mortality are larger than those for total mortality;  effect estimates for respiratory mortality are
27    less consistent in size, possibly due to reduced statistical power (CD, p.  7-94).

28            33.2.2    Mortality and Long-term Os Exposure
29          Little evidence was available in the previous O3 NAAQS review on the potential for
30    associations between mortality and long-term exposure to O3.  In the Harvard Six City
31    prospective cohort analysis, the authors report that mortality was not associated with long-term
32    exposure to O3; the mortality and 03  concentration data are presented in a figure but quantitative
33    concentration-response functions.are not available in this report (Dockery et al., 1993).  The
34    authors note that the range of O3 concentrations across the six cities was small (19;7 to 28.0 ppb
35    in average 24-hr concentrations over the 7-year study period) which may have limited the power
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 1    of the study to detect associations between mortality and O3 levels (Dockery et al., 1993, p.
 2    1755).
 3          As discussed in section 7.5.8 of the draft CD, in this review there are results available
 4    from three prospective cohort studies: the American Cancer Society (ACS) study, the Adventist
 5    Health and Smog (AHSMOG) study, and the U.S. Veterans Cohort study.  In addition, a major
 6    reanalysis report includes evaluation of data from the Harvard Six City cohort study (Krewski et
 7    al., 2000). This reanalysis also includes additional evaluation of data from the initial ACS cohort
 8    study report that had only reported results of associations between mortality and long-term
 9    exposure to fine particles and sulfates (Pope et al., 1995).'
10          In this reanalysis of data from previous prospective cohort study reports, the investigators
11    replicated and validated the findings of the original studies, and the report included additional
12    quantitative results beyond those available in the original report (Krewski et al., 2000).  In the
13    reanalysis of data from the Harvard Six Cities study, the  effect estimate for the association
14    between long-term O3 concentrations (8.3 ppb between the highest and lowest concentrations in
15    the cities) and mortality was negative and nearly statistically significant (relative risk ~ 0.87,
16    95% CI 0.76,1.00) (Krewski et al., 2000, p. 150).
17          The ACS study is based on health data from a large prospective cohort of approximately
18    500,000 adults and air quality data from about 150 U.S. cities. The initial report (Pope et al.,
19    1995) focused on associations with fine particles and sulfates, for which significant associations
20    had been reported in the earlier Harvard Six Cities report (Dockery et al,, 1993).  As part of the
21    major reanalysis of these data, results for associations with other air pollutants were also
22    reported, and the authors report that no significant associations were found with O3. However,
23    results of seasonal analyses show a small positive association between long-term O3
24    concentrations in the warm months (April-September) with a relative risk of 1.02 for all-cause
25    mortality (95% CI 0.96-1.07) and a stronger association was reported for cardiopulmonary
26    mortality (relative risk 1.08, 95% CI 1.01 -1.16) (Krewski et al., 2000, p. 174).
27          A recent report from this study reported results of associations with an extended data
28    base; the mortality records for the cohort had been updated to include 16 years of follow-up
29    (compared with 8 years in the first report) and more recent air quality data were included in the
30    analyses (Pope et al., 2002).  Results are presented for full-year analyses, and show no evidence
31    for a significant association between long-term exposure to O3 and mortality.  As shown in
32    Figure 7-24 of the draft CD, the effect estimates are near zero and sometimes negative (though
      1 This reanalysis report and the original prospective cohort study findings are discussed in more detail in section
      8.2.3 mAir Quality Criteria for Particulate Matter (EPA, 2004).
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 1    not statistically significant) for associations between long-term O3 exposure and all-cause,
 2    cardiopulmonary, and lung cancer mortality (CD, p. 7-112).
 3          The Adventist Health and Smog (AHSMOG) cohort includes about 6,000 adults living in
 4    California. In two studies from this cohort, a significant association has been reported between
 5    long-term 03 exposure and increased lung cancer risk among males only (Beeson et al, 1998;
 6    Abbey et al., 1999). No significant associations were reported between long-term 03 exposure
 7    and mortality from all causes or cardiopulmonary causes, however (Abbey et al., 1999). Due to
 8    the small numbers of lung cancer deaths (12 for males, 18 for females) and the precision of the
 9    effect estimate (i.e., the wide confidence intervals), the draft CD raised concerns about the
10    plausibility of the reported association with lung cancer (CD, p. 7-114.)
11          The U.S. Veterans Cohort study (Lipfert et al., 2000b) of approximately 50,000 middle-
12    aged males diagnosed with hypertension, reported some positive'associations between mortality
13    and peak O3 exposures (95th percentile level for several years of data).  The analysis included
14    numerous analyses using subsets of exposure and mortality follow-up periods which spanned the
15    years 1960 to 1996. In the results of analyses using deaths and O3 exposure estimates
16    concurrently across the study period, there were positive, statistically significant associations
17    between peak O3 and mortality, with a 9.4% excess risk (95% CI: 0.4,18.4) per mean 95%
18    percentile O3 (CD, p. 7-112).
19          Thus, the results  from all-year analyses in the Harvard Six Cities and ACS cohorts
20    provide no evidence for  associations between long-term O3 exposure and mortality, though the
21    warm-season results in the reanalysis of the ACS cohort study suggest a potential association.
22    Imprecise and inconclusive associations were reported in analyses for the AHSMOG cohort
23    study. Significant associations between long-term O3 exposure and mortality were only reported
24    for the Veterans cohort study; while this study used an indicator of peak ozone concentrations.,
25    the cohort is also a rather specific subgroup of the U. S. population. Overall, the draft CD
26    concludes that consistent associations have not been reported between long-term O3 exposure
27    and all-cause, cardiopulmonary or lung cancer mortality (CD, p. 7-114).

28          3.3.3    Summary
29          The draft CD (Chapters 4-8) summarizes and assesses substantial new evidence which
30    builds upon what was previously known about the health effects of O3. The new information
31    supports previous findings that short-term O3 is associated with lung function decrements and
32    respiratory symptoms, as well as numerous more subtle effects on the respiratory system such  as
33    morphological changes and altered host defense mechanisms (CD, p. 7-177).  Short-term O3
34    exposure has also been associated with hospital admissions for respiratory causes in numerous
35    new studies that support findings in the 1996 CD.  The draft CD reports that warm-season


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 1    studies show evidence for positive and robust associations between ambient O3 concentrations
 2    and respiratory admissions, and positive but less conclusive evidence for associations with
 3    respiratory ER visits (CD, p. 7-177).
 4          Some new studies have suggested associations between increased incidence of asthma or
 5    reduced lung function and long-term exposure to elevated ambient O3 levels. The findings of
 6    this small group of studies are inconsistent, however, and the draft CD concludes lhat the
 7    evidence for this group of associations is inconclusive (CD, p. 7-178).
 8          A new body of studies has suggested associations between short-term 03 exposure and
 9    effects on the cardiovascular system, including changes in heart rate variability, cardiac
10    arrhythmia, incidence of myocardial infarction and hospitalization for cardiovascular diseases.
11    The draft CD finds this body of evidence to be limited but supportive of potential effects of O3
12    on the cardiovascular system (CD, p. 7-177).
13          The major new information presented in the draft CD is evidence of an elevated risk of
14    mortality associated with acute exposure to O3, especially in the summer or warm season when
15    O3 levels are typically high. Recent meta-analyses also showed risk estimates that are consistent
16    across studies  and robust to control for potential confounders, providing strong evidence for an
17    association between short-term O3 exposure and mortality (CD, p. 7-78). The limited evidence
18    from long-term O3 exposure studies, however, does not provide conclusive evidence of an
19    association with mortality.

20    3.4    INTEGRATIVE ASSESSMENT OF EVIDENCE FROM EPIDEMIOLOGICAL
21          STUDIES
22          In Chapter 8, the draft  CD assesses the new health evidence, integrating findings from
23    experimental (e.g., toxicological, dosimetric and controlled human exposure) and
24    epidemiological studies, to make judgments about the extent to which causal inferences can be
25    made about observed associations between health endpoints and exposure to Oj.  In evaluating
26    the evidence from epidemiological studies in section 8.4, the draft CD focuses on well-
27    recognized criteria, including: (1) the quality of the  exposure metrics; (2) the quality and size  of
28    the study population; (3) the robustness of reported associations to the use of alternative model
29    specifications  and potential confounding by co-pollutants; (4) the strength of reported
30    associations; (5) evidence for temporality between exposure and observed effects (CD, p. 8-10).
31    Integrating more broadly across  epidemiological and experimental evidence, the draft CD also
32    focuses on the coherence and.plausibility of observed Os-related health effects to reach
33    judgments about causality (Section 8.4.8); this will be the focus of section 3.5.
34          The following discussion summarizes the conclusions and judgments from the draft CD's
35    integrative assessment, focusing in particular on discussions of strength, consistency, robustness,
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 1    temporality and in the epidemiolbgical evidence. This section also addresses several issues
 2    relevant to the interpretation of epidemiological evidence. In particular, staff has focused on
 3    issues related to exposure error in 03 epidemiological studies, potential confounding by co-
 4    pollutants, the affect of alternative model specifications on O3-health associations, the lag periods
 5    between O3 ambient exposure levels and health outcomes, and the nature of Orhealth
 6    concentration-response relationships.

 7          3.4.1    Strength of Associations
 8          The strength of associations most directly refers to the magnitude of the reported relative
 9    risk estimates.  Taking a broader view, the CD draws upon the criteria summarized in a recent
10    report from the U.S. Surgeon General, which define strength of an association as "the magnitude
11    of the association and its statistical strength" which includes assessment of both effect estimate
12    size and precision, which is related to the statistical power of the study (CD, p. 8-10; CDC,
13    2004). In general, when associations are strong in terms of yielding large relative risk estimates,
14    it is less likely that the association could be completely accounted for by a potential confounder
15    or some other source of bias (CDC, 2004). With associations that yield small relative risk
16    estimates it is especially important to consider potential confounding and other factors in
17    assessing causality.
18          Effect estimates between O3 and various health outcomes  are generally small in  size. For
19    example, the draft CD reports effect estimates in the range of 0.5  to 5% increase in mortality per
20    40 ppb increase in Ch or equivalent (CD, p. 7-80).  The magnitude of these associations, while
21    small, is found to be relatively consistent between studies (CD, p. 8-12).  As shown in Figure 8-5
22    in the draft CD, effect estimates for associations with emergency  department visits  and hospital
23    admissions range up to 40% increases per incremental change in Os (CD, p. 8-47).
24          In considering both the magnitude and statistical strength of the associations, a pattern of
25    positive and often statistically significant associations can be seen between mortality and
26    respiratory morbidity and short-term exposures to Os (CD, pp. 7-45, 7-46,7-74). Such
27    associations are strong in terms of the precision of the studies; that is, the associations were
28    strong enough to have been reliably measured by the studies such that many of the associations
29    can be distinguished from the null hypothesis with statistical confidence.  Thus, while the
30    associations reported in the more recent body of epidemiological studies are approximately
31    characterized as being modest in terms of the magnitude of the relative risk estimates, such
32    modest associations are generally coherent with outcomes that may reasonably be expected.
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 1          3.4.2    Robustness of Associations
 2          In section 8.4.7, the draft CD evaluates the robustness of epidemiological associations,
 3    reporting that the health associations reported with short-term exposure to Os are generally
 4    robust (CD, p. 8-58). In this evaluation, the draft CD focuses on the impact of exposure error,
 5    statistical model specification, and potential confounding by co-pollutants on Os-health
 6    associations; these issues are discussed below.

 7            3.4.2.1    Exposure Error
 8          In time-series epidemiological studies, concentrations measured at ambient monitoring
 9    stations are generally used to represent a community's exposure to ambient Os.  For time-series
10    studies, the emphasis is on the temporal (e.g., daily or hourly) changes in ambient Os. In cohort
11    or cross-sectional studies, air quality data averaged over a period of months to years are used as
12    indicators of a community's long-term exposure to ambient 03 and other pollutants. In both
13    types of analyses, exposure error is an important consideration as actual exposures to individuals
14    in the population will vary across the community. As described in the draft CD, there are very
15    few sources of Os exposure for most people other than ambient air; one potential source is 03
16    emitted from office equipment (CD, p. 7-6). Exposure to ambient Os  for individuals is
17    influenced by factors related to the infiltration of Os into buildings, as well as the time spent out
18    of doors by the individuals.
19          The draft CD discusses the potential influence of exposure error on epidemiological study
20    results in section 7.1.3.1.  Three components to exposure measurement error are outlined: (1) the
21    use of average population rather than individual exposure data; (2) the difference between
22    average personal ambient exposure and ambient concentrations at central monitoring sites; and
23    (3) the difference between true and measured ambient concentrations (CD, p. 7-7). These
24    components are expected to have different effects, with the first and third likely not causing bias
25    in a particular direction ("nondifferential error") but increasing the standard error, while the
26    second component may result in downward bias, or attenuation of the risk estimate (CD, p. 7-7).
27          Some recent studies have evaluated the impact of exposure measurements error on Os
28    effect estimates. Navidi et al. (1999) used data from a children's cohort study to compare effect
29    estimates from a simulated "true" exposure level to results of analyses from Os exposures
30    determined by several methods. The results indicated that  the use of Os exposures from personal
31    sampling or microenvironmental approaches is  associated with nondifferential error in Os effect
32    estimates, compared with effect estimates from "true" exposures.  However,  Os exposures based
33    on the use of ambient monitoring data overestimates the individual's O3 exposure and thus
34    generally results in Os effect estimates that are biased downward (CD, p. 7-7).  Similarly, Zidek
35    (1997) used data from a previous epidemiological study and observed that accounting for
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 1    exposure measurement error produced results that were similar to the conclusions of the original
 2    report, but the effect estimates were considerably larger in magnitude (CD, p. 7-7).
 3          The draft CD concludes that ambient Os concentrations "may serve as valid surrogate
 4    measures for aggregate personal Oa exposures in time-series studies. However, using ambient
 5    concentrations to determine exposure generally overestimates true personal Os exposures,
 6    resulting in biased descriptions of underlying concentration-response relationships." (CD, p. 7-
 7    8)  The draft CD recommends caution in the quantitative use of these effect estimates as they
 8    may lead to underestimation of the overall health impact of air pollution. In using
 9    epidemiological study results for quantification of health risks for certain health outcomes, staff
10    recognizes that the risk estimates may be underestimating true public health risk. However, staff
11    observes that the use of risk estimates for comparing relative risk reductions between alternative
12    Cb standards considered in the risk assessment is less likely to suffer-from this concern. In
13    addition, as discussed in Chapter 5, staff has conducted an exposure assessment in conjunction
14    with a portion of the health risk assessment that incorporates estimated population exposures in
15    developing risk estimates for health outcomes based on controlled human exposure studies,
16    where concern about use of ambient concentrations as a surrogate for exposure is not an issue.
17            3.4.2.2    Confounding by Copollutants
18          Confounding occurs when a health effect that is caused by one risk factor is attributed to
19    another variable that is correlated with the causal risk factor; epidemiological analyses attempt to
20    adjust or control for potential confounders. Copollutants (e.g., PM, CO, SC*2 and NCh) can meet
21    the criteria for potential confounding in O3-health associations if they are potential risk factors
22    for the health effect under study and are correlated with O3. Effect modifiers include variables
23    that may influence the health response to the pollutant exposure (e.g., co-pollutants, individual
24    susceptibility, smoking or age).  Both are important considerations for evaluating effects in a
25    mixture  of pollutants, but for confounding, the emphasis is on controlling or adjusting  for
26    potential confounders in estimating the effects of one pollutant, while the emphasis for effect
27    modification is on identifying and assessing the level of effect modification.
28          The draft CD observes that 03 is generally not highly correlated with other criteria
29    pollutants (e.g., PMio, CO, SO2 and NO2), but may be more highly correlated with fine particles,
30    especially during the summer months (CD, p. 7-130). In addition, the correlation between O3
31    and other pollutants may vary  across seasons, since O3  concentrations are generally,higher in the
32    summer  months. This may lead to negative correlations between 03 and other pollutants during
33    the cooler months, but positive associations between O3 and pollutants such as fine particles
34    during the wanner months (CD, p. 7-14). Thus, the draft CD pays particular attention to the
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 1   results of season-specific analyses and studies that assess effects of PM in potential confounding
 2   of Da-health relationships in its discussions in section 7.6.4.
 3          Multipollutant models are commonly used to assess potential confounding in
 4   epidemiological studies. As discussed in the draft CD, the limitations to the use of
 5   multipollutant models include the difficulty in interpreting results where the copollutants are
 6   highly colinear, or where correlations between pollutants change by season (CD, p. 7-131).  This
 7   is particularly the situations where 03 and a copollutant, such as sulfates, are formed under the
 8   same atmospheric condition; in such cases multipollutant models would produce unstable and
 9   possibly misleading results (CD, p. 7-132).
10          For mortality, the results from numerous multi-city and single-city studies are shown in
11   Figure 7-20 of the draft CD. These results indicate that 03-mortality associations do not appear
12   to be substantially changed in multipollutant models including PMio.or PMi5 (CD, p. 7-88).
13   Focusing on results of warm season analyses, Figure 7-21 of the draft CD shows risk estimates
14   for Cvmortality associations that are fairly robust to adjustment for PM in multipollutant models
15   (CD, p. 7-90).
16          Similarly, multipollutant models are presented for associations between short-term O3
17   exposures and respiratory hospitalization in Figure 7-12 of the draft CD; the draft CD concludes
18   that copollutants generally do not confound the relationship between O3 and respiratory
19   hospitalization (CD, p. 7-70,7-71). Multipollutant models were not used as commonly in studies
20   of relationships between respiratory symptoms or lung function with O3, but the CD reports that
21   results of available analyses indicate that such associations were robust to adjustment for PMzs
22   (CD, p. 7-134).  In reports from U.S. multi-city studies of respiratory symptoms, associations
23   with O3 were found to be remain statistically significant and little changed in magnitude in two-
24   pollutant models including PMio or PM2.3 (Mortimer et al., 2002; Gent et al., 2003; CD pp. 7-45,
25   7-46)."
26          Considering this body of studies, the draft CD  concludes: "These findings indicate that
27   the effects of O3 on various health outcomes are robust and independent of the effects of other
28   copollutants." (CD, p. 7-151) Staff will use the results of single-pollutant model results in
29   presentation of results in this chapter and in quantitative assessments conducted as part of mis
30   review for purposes of comparing results from different studies. However,  staff will also  include
31   the use of multi-pollutant model results in presenting risk estimates, Where available to more
32   completely assess the quantitative health risks associated with alternative Os standards.

33            3.4.2.3    Model Specification
34          The draft CD observes that one challenge of time-series epidemiological analysis is
35   assessing the relationship between 03 and health outcomes while avoiding bias due to
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 1    confounding by other time-varying factors, particularly seasonal trends and weather variables.
 2    (CD;'p. 7-12) These variables are of particular interest because O3 concentrations have a well-
 3    characterized seasonal pattern (see Chapter 2) and are also highly correlated with changes in
 4    temperature. Thus it can be difficult distinguish effects associated with O3 or the seasonal or
 5    weather variables in statistical analyses.
 6          Section 7.1.3.4 of the draft CD discusses statistical modeling approaches that have been
 7    used to adjust for time-varying factors, highlighting a series of analyses that were done in a
 8    Health Effects Institute-funded reanalysis of numerous time-series studies. While the focus of
 9    these reanalyses was on associations with PM, a number of investigators also'examined the
10    sensitivity of 03 coefficients to the extent of adjustment for temporal trends and weather factors.
11    In addition, several recent studies, including U.S. multi-city studies (Bell et al., 2005; Huang et
12    al., 2005; Schwartz et al., 2005) and a meta-analysis study (Ito et al., 2005) evaluated the effect
13    of model specification on Cvmortality associations (CD, p. 7-14).  These studies generally report
14    that associations reported with O3 are not substantially changed  with alternative modeling
15    strategies (CD, p. 7-122). Overall, the draft CD concludes that O3 effects are generally robust to
16    various model specifications for temporal trend adjustment though additional research would
17    help better understand the influence of different modeling approaches. (CD, p. 7-150)
18          A number of epidemiological studies have conducted season-specific analyses, as
19    discussed in section 7.6.3.2 of the draft CD. As observed above in section 3.3, such'studies have
20    generally reported stronger and more precise effect estimates for O3 associations in the warm
21    season than in analyses conducted in the cool seasons or over the full year. For assessing
22    relationships between O3 and health outcomes, the draft CD highlights several reasons to focus
23    on warm season analyses: (1) the seasonal nature of O3 concentrations; (2) the relationship
24    between O3 formation and temperature; (3) correlations between other pollutants, particularly
25    fine particles, and O3 varies across seasons in some areas; and (4) factors affecting exposure to
26    ambient O3, such as air conditioning use, varies seasonally in most areas of the U.S. The draft
27    CD  concludes:  "Given the potentially significant effect of season, O3 effect estimates computed
28    for year-round data need to be interpreted with caution." (CD, p. 7-130)  Staff has therefore
29    focused on epidemiological findings from warm season analyses, where available, for
30    quantitative and qualitative assessments.

31          3.4.3    Consistency
32          Consistency refers to the persistent finding of an association between exposure and
33    outcome in multiple studies of adequate power in different persons, places, circumstances and
34    times (CDC, 2004). The draft CD observes that the magnitude of effect estimates is relatively
35    consistent across the results of recently published studies of associations between short-term


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 1    ozone exposure and mortality (CD, p. 8-41).  Including results from studies conducted on several
 2    continents, the draft CD finds that effect estimates range from 0.5 to 5% increases in mortality
 3    per incremental change in Os (CD, p. 8-56). For associations with morbidity, the draft CD
 4    reports that there is greater variability in effect estimates between studies, but that fairly
 5    consistent positive associations between short-term ozone exposure and various respiratory
 6    health outcomes have been observed (CD, p.  ^51).       ;
 1          While concluding that Os-health associations are found to be generally consistent, the
 8    recent Da-mortality meta^analyses indicate that some heterogeneity exists across studies (CD, p.
 9    7-84). The draft CD discusses a number of factors that could result in heterogeneity in
10    associations between different geographic areas, focusing particularly on variables that can affect
11    exposure to ambient Os. For example, the use of air conditioning can reduce ambient exposures
12    during the warm season, while increased outdoor activity can increase exposure. In addition, as
13    discussed previously, stronger and more consistent associations have been reported in analyses
14    for the warm season.  The meta-analysis results indicated that these two factors were important
15    sources of variability in Os-mortality relationships (Levy et al., 2005; CD, p. 8-57), but also
16    reported that the associations were fairly consistent between studies; addressing these sources of
17    heterogeneity  resulted in stronger and more consistent findings.. Overall, the epidemiological
18    findings are fairly consistent for associations  between short-term exposure to Os and both
19    respiratory morbidity and mortality.

20          3.4.4    Temporality
21          Temporality refers to the occurrence of a cause before its purported effect, and is most
22    relevant to studies of diseases that develop over time.  This factor is difficult to investigate in
23    situations where the pollutant concentrations  are correlated over time as is the case to some
24    degree in time series studies and to a greater degree in cohort studies. The short-term exposure
25    studies evaluate associations between acute health outcomes and ozone measured on an hourly
26    basis. In many studies, associations have been reported between health events and ozone
27    measured contemporaneously. For example,  in studies of total and cardiovascular mortality, the
28    draft CD observes that effects have been most clearly linked with ozone measured on the same
29    day or the preceding day (CD, p. 8-59): This would be expected for acute health outcomes;
30    however, it is  difficult to characterize these associations in terms of temporality.  Issues related
31    to the evaluation and selection of lag periods  among studies are discussed in the next section.

32          3.4.5    Lag Structure in Short-term Exposure Studies
33          In the short-term exposure epidemiological studies, many investigators have tested
34    associations for a range of lag periods between the health outcome and ozone concentration (see
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 1    CD, sections 7,1,3.3 and 8.4.2.3). The draft CD observes that the selection of an appropriate lag
 2    period can depend on the health outcome under study. For example, if cough is resulting from
 3    irritant action of ozone, that would be expected to occur with a short lag time; however,
 4    exacerbation of asthma through an inflammatory response might occur up to several days after
 5    initial exposure CD, p. 7-9). For both mortality and respiratory hospital admissions, the draft CD
 6    reports that most significant associations between ozone and mortality were observed with ozone
 7    measured on the same day or a 1-day lag period in studies using individual lag periods (CD, p, 8-
 8    59). In U.S. multi-city studies, larger effect estimate sizes were reported for the ozone-mortality
 9  '  relationship with the distributed lag structure (CD, p. 7-80). Field studies of lung function or   *
10    respiratory symptoms reported associations with ozone across a range of lag periods from the
11    exposure on the same day to exposures averaged over several  days (CD, Sections 7.2.3 and
12    7.2.4). Cardiovascular effects appeared to be associated with ozone at shorter lag periods;
13    cardiovascular health  outcomes such as changes in cardiac autonomic control were associated
14    with ozone measured  on the same day (CD, section 7.2.7.1).  In addition, Peters et al. (2001)
15    reported a positive but not statistically significant association between myocardial infarction
16    onset and ozone witii  very short lag times of 1- to 4 hrs (CD, p. 7-55).
17          In focusing on an effect estimate reported for any individual lag period, the draft CD
18    observes that it is important to consider the pattern of results across the series of lag periods.  If
19    there is an apparent pattern of results across the different lags, then selecting the single-day lag
20    with the largest effect from a series of positive associations is  likely to underestimate the overall
21    effect size, since single-day lag effect estimates do not fully capture the risk that may be
22    distributed over adjacent or other days (CD, p. 7-10). However, if the reported effect estimates
23    vary substantially across lag periods, any result for a single day may  well be biased (CD, p. 7-  •
24    11). If the effect of ozone on health outcomes persists over several days, distributed lag model
25    results can provide more accurate effect estimates for quantitative assessment than  an effect
26    estimate for a single lag period (CD, p. 7-10).  Conversely, if the underlying ozone-health
27    relationship is truly an acute effect, then a distributed lag model would likely result in reduced
28    effect estimate size that may underestimate the effect (CD, p. 7-10).
29          On this basis, the draft CD focuses on effect estimates  from models using 0- or 1-day lag
30    periods,  with some consideration of multi-day lag effects  (CD, p. 7-11). For quantitative
31    assessments, staff concludes that it is appropriate to  use results from lag period analyses
32    consistent with those reported in the draft CD, focusing on single day lag periods of 0-1 days for
33    associations with mortality or respiratory hospitalization,  depending on availability of results
34    (CD, p. 8-59). When  available, distributed lag model results also have been used in the
35    quantitative risk assessment. However, for those few studies that show inconsistent patterns, the
36    use of single-day lag results is not appropriate for inclusion in the quantitative assessment.

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 1          3.4.6    Concentration-Response Relationships and Potential Thresholds
 2          It has been recognized that it is reasonable to expect that there likely are biological
 3    thresholds for different health effects in individuals or groups of individuals with similar innate
 4    characteristics and health status. For ozone exposure, individual thresholds would presumably
 5    vary substantially from person to person due to individual differences in genetic-level   •
 6    susceptibility, pre-existing disease conditions and possibly individual risk factors such as diet or
 7    exercise levels (and could even vary from one time to another for a given person). Thus, it
 8    would be difficult to detect a distinct threshold at the population level, below which no
 9    individual would experience a given effect, especially if some members of a population are
10    unusually sensitive even down to very low concentrations. (U.S. EPA, 2004, p. 9-43, 9-44)
11          Some time-series epidemiological studies have used statistical modeling approaches to
12    evaluate whether thresholds exist in associations between short-term ozone exposure and
13    mortality. As discussed in section 7.6.5 of the draft CD, one European multi-city study included
14    evaluation of the shape of the concentration-response curve, and observed no deviation from a
15    linear function across the range of ozone measurements from the study (Gryparis et al., 2004;
16    CD p. 7-135). Several single-city studies also observed amonotonic increase in associations
17    between ozone and morbidity that  suggest that no threshold exists (CD, p. 7-137).
18          On the other hand, a study in Korea used several different modeling approaches and
19    reported that a threshold model provided the best fit for the data. The results suggested a
20    potential threshold level of about 45 ppb (1-hr maximum concentration) for an association
21    between mortality and short-term ozone exposure during the summer months (Kim et al., 2004;
22    CD, p. 7-136). The authors reported larger effect estimates for the association for data above the
23    potential threshold level, suggesting that an ozone-mortality association might be underestimated
24    in the non-threshold model. In addition, Burnett and colleagues (1997) plotted the relationships
25    between air pollutant concentrations and both respiratory and cardiovascular hospitalization, and
26    it appears in these results that the associations with ozone are found in the concentration range
27    above about 30 ppb (1-hr maximum).
28          Other studies have tested associations between ozone and health outcomes after removal
29    of days with higher ozone levels from the data set; such analyses do not necessarily indicate the
30    presence or absence of a threshold, but provide some information on whether the relationship is
31    found using only lower-concentration data,. For example, using data from 95 U.S. cities, Bell et
32    al. (2004) found that the effect estimate for an association between short-term ozone exposure
33    and mortality was little changed when days exceeding 60 ppb (24-hr average) were excluded in
34    the analysis (CD, p. 7-135). Using data from 8 U.S. cities, Mortimer and colleagues (2002) also
35    reported that associations between ozone and both lung function and respiratory symptoms
36    remained statistically significant and of the same or greater magnitude in effect size when
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  1    concentrations greater than 80 ppb (8-hr average) were excluded (CD, p. 7-137). Several single-
  2    city studies are also summarized in section 7.6.5 that report similar findings of associations that
  3    remain or are increased in magnitude and statistical significance when data at the upper end of
  4    the concentration range are removed.
  5           Finally, Vedal and colleagues (2003) reported a significant association between ozone
  6    and mortality in British Columbia where ozone concentrations were quite low (mean
  7    concentration of 27.3 ppb). The authors did not specifically test for threshold levels, but the fact
  8    that the association was found in an area with such low ozone concentrations suggests that any
  9    potential threshold level would be quite low in this data set.
10           In summary, some epidemiological analyses have suggested that no threshold levels can
11    be found in associations between ozone and mortality or morbidity. In those studies that provide
12    suggestive evidence of thresholds, the potential thresholds are at low concentrations (CD, p. 7-
13    138). The draft CD finds that no definitive conclusion can be reached with regard to the
14    existence of thresholds in epidemiological studies (CD, p. 8-24).  Staff recognizes, however, the
15    possibility that thresholds for individuals may exist in reported associations at fairly low levels
16    within the range of air quality observed in the studies, but not be detectable as population
17    thresholds  in epidemiological analyses. Based on the draft CD's conclusions, staff judges that
18    there is insufficient evidence to support use of potential threshold levels in quantitative
19    assessments, but that data should be used within the range of air quality concentrations down to a
20    policy-relevant background level.

21    3.5     BIOLOGICAL PLAUSIBILITY AND COHERENCE  OF EVIDENCE
22           This section summarizes material contained in section 8.5  of the CD, which integrates
23    epidemiological studies with mechanistic information from controlled human exposure studies
24    and animal toxicological studies to draw conclusions regarding the coherence of evidence and
25    biological plausibility of Oa-related health effects.  For its assessment, the draft CD's discussion
26    draws from epidemiological evidence on a range of relevant health endpoints (from
27    cardiopulmonary and physiological changes to morbidity and mortality) and assessment of
28    available toxicological and biochemical evidence on potential plausible causal relationships for
29    the observed epidemiological associations (CD, p. 8-59).
30           Table 3-1 (Table 8-1, CD, p. 8-60) summarizes physiological and biochemical
31    observations which represent the knowledge base available from toxicological studies in humans
32    and animals that underlie biological alterations that cause acute Os-induced health effects.  Table
33    3-1 was based upon experimental data (contained in CD  Chapters 5 and 6, as well as the chapter
34    annexes),-which used environmentally relevant exposure regimens.  Although most of the acute
35    O3-induced health effects are transient and attenuate over time, the time-line for resolution of

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 1    many of the physiological and biological parameters presented in Figure 3-1 (Figure 8-9, CD, p.
 2    8-61) differ for healthy human subjects and those with underlying cardiopulmonary diseases.
 3    The CD further notes that alterations in acute Oa-induced cellular and molecular changes
 4    observed in human airway epithelium evolve over time, as depicted in Figure 3-2 (Figure 8-10,
 5    CD, p. 8-62), and that the knowledge of this profile is important in assessing biological
 6    plausibility to integrate across evidence of various health endpoints.
 7          The similarities in physiological, biochemical and pathological processes between
 8    humans and many animal species are due to the high level of genome sequence homology that
 9    exists across species (CD, p. 8-62). It is this homology that supports the use of knowledge
10    gained on initiation, progression, and treatment regimes for disease processes across species,
11    especially on the acute Os-induced effects in the respiratory tracts of humans and various animal
12    species, as depicted in CD Table 3-1 and Figures 3-1 and 3-2. The similarities observed in
13    human and rat respiratory system effects  (e.g., in spirometry, ventilatory response, host defense),
14    attenuation, and at higher levels of cellular of organization (e.g., neutrophilic inflammation,
15    macrophage phagocytosis processes) lend support to animal-to-hurnan extrapolation. This is
16    particularly important in collecting information that would not be possible to gather in human
17    exposure or epidemiological studies but may corroborate data from both types of studies. Since
18    quantitative extrapolation requires a combination of dosimetry, end point homology, and species
19    sensitivity and because uncertainties continue to exist, extrapolation models have not been
20    completely validated. However, one study (Hatch etal., 1994) of inflammatory markers
21    suggests mat a 2 ppm Oa  exposure in sedentary rats approximates a 0.4 ppm exposure in
22    exercising humans, which supports the use of some animal data collected at higher Os exposures
23    to help understand molecular changes in acutely exposed humans.  Also of great importance are
24    the chronic exposure studies (12 to 24 months) reporting lesions caused by long-term Oa
25    exposures, which may facilitate a more direct assessment of chronic health effects in humans
26    (CD, p. 8-63).

27          3.5.1     Coherence and Plausibility of Short-term Effects on the Respiratory
28                   System
29          Acute respiratory  morbidity effects that have been associated with short-term exposure to
30    Os include such health endpoints as decrements in lung function, bronchoconstriction, increased
31    airway responsiveness, airway inflammation, epithelial injury, and immune system effects,
32    emergency department visits for respiratory  diseases, and hospitalization due to respiratory
33    illness.
34          Recent epidemiological studies have supported evidence available in the previous Oa
35    NAAQS review on associations between ambient Oa exposure and decline in lung function for
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                  Table 3-1. Acute Oj-induced Physiological and Biochemical
                                 Changes in Human and Animals
 Physiological/biochemical
 Alterations
Human Exposure Studies u
Animal Toxicology Studies3-4
 Pulmonary Function:
 Airway Responsiveness:


 Inflammation:


 ROS

 Host Defense:
 Lung injury:
 Morphology

 Susceptibility:
 Cardiovascular Changes:
1FEV,
I Frequency of breathing
(rapid, shallow)
1 inspiratory capacity
(cough, breathing discomfort,
throat irritation, wheezing)
Mild bronchoconstriction

I (neuronal involvement)
change in lung resistance

Yes
T inflammatory mediators

I

t Particle clearance
I permeability
1 AM phagocytosis
Yes
Age,
Inter individual variability
Disease status
Polymorphism in certain genes
being recognized

Impairment in arterial O2 transfer
Ventilation-perfusion mismatch
(suggesting potential arterial
vasoconstriction)
I
1 Frequency of breathing
 (Rapid, shallow )
J inspiratory capacity
t (vagal mediation)
Change in lung resistance

Yes
I inflammatory mediators

I

t Particle clearance
t permeability
1 clearance of bacteria
t severity of infection
I Mortality & morbidity

Yes
Species specific differences
Genetic basis for susceptibility
indicated
Heart rate variability (HRV)
i core body temperature
T ANF
Role for PAF indicated
increased pulmonary vascular
resistance
  1 Controlled chamber exposure studies in human volunteers were carried out for a duration of 1-6.6 h with O}
   concentration in the range of 0.08-0.4 ppm with intermittent exercise.
  2 Data on some of the biochemical parameters were obtained from in vitro studies using cells recovered
   from BALF.
  3 Responses were observed in animal toxicology studies with exposure for a duration of 2-72h with O3
   concentration in the range of 0.1- 2.0 ppm.
 * Various species (mice, rat, guinea pigs and rabbit) and strains.

(Reproduced from Table 8-1, CD, p. 8-60).
November 2005
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Figure 3-2.   O3-induced cellular and molecular changes and their evolution depicted here
             is derived from the data reported in Leikauf et al. (1995) and Mudway and
             Kelly (2000). (Reproduced from Figure 8-10, CD, p. 8-62)
November 2005
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 1    children.  Earlier observations that children and asthmatic individuals are particularly susceptible
 2    to ambient Os are supported by a meta-analysis (Kinney et al, 1996) of summer camp studies
 3    and a multicity study (Mortimer et al., 2002).  The draft CD concludes that exposure to ambient
 4    Os has a significant effect on lung function, is associated with increased respiratory symptoms
 5    and medication use, particularly in asthmatics.
 6          Short-term exposure to Oa has also been associated with more severe morbidity
 7    endpoints, such as emergency department visits and hospital admissions for respiratory cases,
 8    including specific respiratory illness (e.g., asthma) (CD, sections 7.3.2 and 7.3.3). In addition, a
 9    few epidemiological studies have reported positive associations between short-term Oj exposure
10    and respiratory mortality, though the associations are not generally statistically significant,
11    possibly due to a lack of statistical power for this mortality subcategory. (CD, p. 7-94).
12          Considering Hie evidence from epidemiological studies, the results described above
13    provide evidence for coherence in Os-related effects on the respiratory system. Effect estimates
14    from U.S. and Canadian studies are shown in Figure 3-3, where it can be seen that mostly
15    positive associations have been reported with respiratory effects ranging from respiratory
16    symptoms, such as cough or wheeze, to hospitalization for various respiratory diseases, and there
17    is suggestive evidence for associations with respiratory mortality. Many of the reported
18    associations are statistically significant.
19          Considering also evidence from toxicological studies, the CD (section 8.5.1) discusses
20    biological plausibility and coherence of evidence for acute Os-induced respiratory health effects.
21    Inhalation of O3 for several hrs while subjects are physically active can elicit both acute
22    pathophysiological changes and subjective respiratory tract symptoms (CD, section 8.4.2.4.1).
23    Acute pulmonary responses observed in healthy humans exposed to O3 at ambient concentrations
24    include: decreased inspiratory capacity; mild bronchoconstriction; rapid, shallow breathing
25    during exercise; subjective symptoms of tracheobronchial airway irritation, including cough and
26    pain on deep inspiration; decreases in FVC and FEVi; and increased SRaw  The severity of
27    symptoms and magnitude of response depends on inhaled dose, individual O3 sensitivity, and the
28    degree of attenuation resulting from previous 03 exposures.  Pulmonary function studies of
29    several animal species acutely exposed to relatively low O3 levels (0.25 to 0.4 ppm) show
30    responses similar to those observed in humans, including increased breathing frequency,
31    decreased tidal volume, increased resistance, and decreased FVC. Alterations in breathing
32    pattern return to normal within hrs of exposure, and attenuation in functional responses following
33    repeated O3 exposures is similar to those observed in humans.
      November 2005
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U.S EPA Headquarters Library
      Mail code 3404T
1200 Pennsylvania Avenue NW
   Washington, DC  20460  .
       202-566-0556
                              fc
                              i
                              en
                             1

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 1          Physiological and biochemical alterations investigated in controlled human exposure and
 2    animal toxicology studies tend to support certain hypotheses of underlying pathological
 3    mechanisms which lead to the development of respiratory-related effects reported in
 4    epidemiology studies (e.g., increased hospitalization and medication use).  Some of these are:
 5    (a) decrements in lung function, (b) bronchoconstriction, (c) increased airway responsiveness, (d)
 6    airway inflammation,  (e) epithelial injury, (f) immune system activation, (g) host defense
 7    impairment, and sensitivity of individuals, such as age, genetic susceptibility, and the degree of
 8    attenuation present due to prior exposures.  The time sequence, magnitude, and overlap of these
 9    complex events, both in terms of development and recovery (as depicted in Figures 3-1 and 3-2),
10    illustrate the inherent difficulty of interpreting the biological plausibility of Oa-induced
11    cardiopulmonary health effects (CD, p. 8-64).
12          The interaction of Os with airway epithelial cell membranes and ELF to form lipid
13    ozonation products and ROS is supported by numerous human, animal and in vitro studies.
14    Ozonation products and ROS initiate a cascade of events that lead to oxidative stress, injury,
15    inflammation, airway  epithelial damage and increased epithelial damage and increased alveolar
16    permeability to vascular fluids. Repeated respiratory inflammation can lead to a chronic
17    inflammatory state with altered lung structure and lung function and may lead to chronic
18    respiratory diseases such as fibrosis and emphysema (CD, p. 8-65). Continued respiratory
19    inflammation also can alter the ability to respond to infectious agents, allergens and toxins.
20    Acute inflammatory responses to Os are well documented, and lung injury can become apparent
21    within 3 hr after exposure in humans. Initial inflammatory response phase is characterized by
22    increased PMNs in the BAL fluid and increased levels of inflammatory mediators (e.g.,
23    interleukins, prostaglandins, complement component C3a).  Late inflammatory phase in the
24    lungs is characterized by increased levels of monocytes and eosinophils and mediators, such as
25    cytokines,  leukotrienes, proteinases, and ROS. Ozone-induced lung injury and subsequent
26    disruption  of the airway epithelial barrier has been implicated in increased mucociliary clearance
27    of particles in human subjects. Similarly, animal toxicology studies have shown that Os
28    exposure increased clearance of particles and increased mortality resulting from bacterial and
29    viral infections (CD, p. 8-65).
30          The draft CD concludes that the findings of Os-mduced lung function changes,
31    respiratory symptoms, inflammation, and permeability changes in animal toxicological studies
32    are consistent with the associations with respiratory health outcomes reported in epidemiological
33    studies. Taken together, there appears to be substantial evidence for coherence and biological
34    plausibility for effects of Os on the respiratory system.
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 1          3.5.2    Coherence and Plausibility of Effects on the Cardiovascular System
 2          As described in sections 7.2.7 and 7.3.4, some new epidetniological studies have reported
 3    associations between short-term Os exposure and effects on the cardiovascular system. In the
 4    recent studies on incidence of myocardial infarction and some more subtle cardiovascular health
 5    endpoints, such as changes in heart rate variability or cardiac arrhythmia, some but not all studies
 6    reported associations with short-term exposure to Os (CD, section 7.2.7.1).  From these studies,
 7    the draft CD concludes that the "current evidence is rather limited but supportive of a potential
 8    effect on [heart rate variability], ventricular arrhythmias, and the incidence of MI." (CD, p. 7-57)
 9          Some studies have reported associations with hospitalization or emergency department
10    visits for cardiovascular diseases.  As shown in Figure 7-13 of the draft CD, the results are
11    somewhat inconsistent, but a number of the associations are positive and statistically significant,
12    especially those conducted during the warm season. The draft CD finds that the  evidence from
13    these studies is inconclusive, but the results from studies using warm season analyses suggest
14    potential effects of Os on the cardiovascular system (CD, p. 7-73).
15          Finally, several recent studies report associations between short-term 63 exposure and
16    mortality from cardiovascular or cardiopulmonary causes, and numerous studies have reported
17    statistically significant associations with total nonaccidental mortality, and cardiopulmonary
18    causes constitute the largest category. Based on results of multi-city analyses, meta-analyses and
19    numerous single-city analyses, the draft CD concludes that there is strong evidence for
20    associations between short-term 63 exposure and mortality (CD, p. 7-74).  As shown in Figure 7-
21    22 of the draft CD, all associations reported in these studies are positive, and many are
22    statistically significant, particularly the associations reported from warm season analyses (CD, p.
23    7-92).
24          There are very few human or animal experimental studies that have investigated potential
25    cardiovascular effects of acute Oj exposure, in contrast to the large data base of studies
26    indicating that 03 exposure induces lung injury, inflammation, impaired mucociliary clearance,
27    and increased epithelial permeability. The draft CD observes that generation of lipid ozonation
28    products and ROS in lung tissue can influence pulmonary hemodynamics and the cardiovascular
29    system (CD, section 5.4.2). Recent reports of interaction between Os and cholesterol in the lung
30    surfactant and the generation of highly reactive products, such as  oxysterols and B-epoxide,
31    indicate a role for cardiovascular effects and atherosclerosis (CD, p. 8-66).  Changes in heart rate
32    variability, heart tissue edema, and increased tissue and serum levels of ANF have been reported
33    in experimental animals and support the potential for cardiovascular effects induced by acute Os
34    exposures. Such effects are the result of stimulation of airway irritant receptors  and C-fiber
35    activation and may result from either local or CNS involvement.  Ozone-induced changes in
36    alveolar-arterial oxygen transfer observed in controlled exposure human studies  of subjects with

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 1   hypertension suggest potential complex ANF effects that require further investigation (CD, p. 8-
 2   66).
 3          While still limited, the evidence from recent epidemiological studies suggests some
 4   coherence in effects of short-term Os exposure on the cardiovascular system, from subtle
                                           v                        t
 5   changes in physiological cardiac responses to hospitalization for cardiovascular disease to
 6   cardiopulmonary mortality. The draft CD also describes toxicological evidence that provides
 7   some potential plausible mechanisms or pathways for effects on the cardiovascular system.

 8          3.5.3    Coherence and Plausibility of Effects Related to Long-Term O3 Exposure
 9          As discussed in section 8.5.2 of the draft CD, previous epidemiological studies have
10   provided only inconclusive evidence for either mortality or morbidity effects of long-term Oa
11   exposure. The draft CD observes mat the inconsistency in findings may be due to a lack of
12   precise exposure information, the possibility of selection bias, and the difficulty of controlling
13   for confounders  (CD, p. 8-69). Several new longitudinal epidemiology studies hav.e evaluated
14   associations between long-term OB exposures and morbidity and mortality and suggest that these
15   long-term exposures may be related to changes in lung function, increased incidence in asthma,.
16   mortality, and possibly lung cancer (CD, section 7.5).  Considering these new findings, the draft
17   CD concludes: "The strongest evidence is for negative seasonal effects of Os on lung function in
18   adults and children. Less conclusive are longer-term studies investigating the association of
19   chronic Os exposure on yearly lung function, asthma incidence, and respiratory symptoms.
20   Chronic Os-mortality studies observed inconsistencies across exposure perio'ds, cause-specific
21   mortality  outcomes, and gender." (CD, p. 7-150) Thus, the epidemiological evidence suggests
22   some potential effects on the respiratory system, but provides no evidence for associations
23   between long-term Os exposure and mortality.
24          Human chamber studies have not evaluated effects with long-term exposures to Os, but
25   some evidence is available from toxicological studies.  While early animal toxicology studies of
26   long-term Os exposures were conducted using continuous exposures, more recent studies have
27   focused on exposures which mimic diurnal and seasonal patterns and more realistic Os exposure
28   levels (CD, p. 8-69). Studies of monkeys that compared these two exposure scenarios found
29   increased airway pathology only'with the latter. A long-term study of rhesus monkeys exposed
30   to simulated seasonal Os (0.5 ppm, 8 hr/day for 5 days every 14 days for 11 episodes) reported
31   remodeling of the distal airways, abnormalities in trachea! basement membrane, accumulation of
32   eosinophils in conducting airways, and decrements in airway innervation.  Another seasonal
33   exposure  study of monkeys exposed (0.61 ppm Os) for a year reported increased deposition of
34   collagen and thickening of the CAR of the deep lung.  Long-term seasonal Os exposure studies of
35   rats also have provided evidence of biochemical and morphological changes suggestive of
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  1    irreversible chronic damage to the lungs. One of these studies exposed rats for 20 months (0.5-
  2    1.0 ppm Os for 6 hr/day) and found increased deposition of collagen and thickening of the CAR
  3    of the deep lung. Although some earlier seasonal exposure studies of rats reported small, but
  4    significant, decrements in lung function consistent with focal fibrogenesis in the proximal
  5    alveolar region, other chronic exposure studies with exposures of 0.5 to 1.0 ppm (^report
  6    epithelial hyperplasia that disappears in a few days.
  7          The draft CD concludes that the totality of evidence from animal toxicology studies
  8    strongly suggests that Ps exposure can damage the distal airways and proximal alveoli, resulting
  9    in lung tissue remodeling thus leading to apparent irreversible damage. Such structural changes
10    and compromised pulmonary function caused by persistent inflammation may exacerbate the
11    progression and development of chronic lung disease (CD, p. 8-70).  Together with the limited
12    evidence available from epidemiological studies, these studies suggest coherence and plausibility
13    for associations between long-term exposure to Oa and adverse effects on the respiratory system;
14    however, as noted previously, there is not clear evidence linking long-term exposure to Os and
15    mortality.

16          3.5.4     Coherence and Plausibility of Mortality-Related Health Endpoints
17          An extensive epidemiological  literature on air pollution related mortality risk estimates
18    from the U.S., Canada, and Europe is  discussed in the draft CD (section 7-4). These mortality
19    studies suggest a pattern of effects for causality that has a biologically plausible explanation, but
20    our knowledge regarding potential underlying mechanisms is very limited at this time and
21    requires  further research. Most of the physiological and biochemical parameters investigated in
22    human and animal studies suggest that (^-induced biochemical effects are relatively transient
23    and attenuate over time. A generic pathway of Os-induced lung damage, potentially involving
24    oxidative lung damage with subsequent inflammation and/or decline in lung function leading to
25    respiratory distress is hypothesized in the CD (p. 8-70).
26          The third National Health and  Nutrition Examination Followup data analysis indicates
27    mat about 20% of the adult population has reduced FEVi values, suggesting impaired lung
28    function. Most of these individuals have COPD, asthma or fibrotic lung disease (Manino et al.,
29    2003), which are associated with persistent low-grade inflammation. Furthermore, patients with
30    COPD are  at increased risk for cardiovascular disease,  and lung disease with underlying
31    inflammation may be linked to low-grade systemic inflammation associated with atherosclerosis,
32    independent of cigarette smoking (CD, p. 8-71). Lung  function decrements in persons with
33    cardiopuhnonary disease have been associated with inflammatory markers, such as C-reactive
34    protein (CRP) in the blood. At a population level it has been found that individuals with the
35    lowest FEVi values have the highest levels of CRP, and those with the highest FEVi values have


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 1   the lowest CRP levels (Manino et al., 2003; Sin and Man, 2003). Although this complex series
 2   of physiological and biochemical reactions following Os exposure could lead to adverse health
 3   effects in those with cardiopulmonary disease, there is no experimental data available to support
 4   such a hypothesis at this time to explain the cardiovascular mortality, evaluated in the
 5   epidemiological studies. Future reevaluation may help in understanding the biological
 6   plausibility of changes in CRP in the context of Os and other air pollution related mortality (CD,
 7   section 8.5.3).

 8   3.6    OZONE-RELATED IMPACTS ON PUBLIC HEALTH
 9          The following discussion draws from section 8.6 of the draft CD to characterize factors
10   which modify responsiveness to O^t subpopulations potentially at risk for Os-related health
11   effects, and potential public health impacts associated with exposure to ambient Og.  Providing
12   appropriate protection of public health requires that a distinction be made between those health
13   effects that are considered adverse and those that are not adverse. What constitutes an adverse
14   health effect depends not only on the type and magnitude of effect but also on the population
15   group being affected.  While some changes in healthy individuals would not be considered
16   adverse,  similar changes in susceptible individuals would be seen as adverse. In order to
17   estimate  the potential public health impact, it is important to consider both the susceptible
18   subpopulations for 03 exposure and the definition of adversity for Os health effects.

19          3.6.1    Factors which Modify Responsiveness to Ozone
20          There are numerous factors which can modify individual responsiveness to 63. These
21   include:  influence of physical activity; age; gender and hormonal influences; racial, ethnic and
22   socioeconomic status (SES) factors; environmental factors;  and oxidant-antioxidant balance.
23   These factors are discussed in more detail in section 6.5 of the CD.
24          It is well established that physical activity increases  an individual's minute ventilation
25   and will  thus increase the dose of Os inhaled (CD, section 6.5.4). Increased physical activity
26   results in deeper penetration of Os into more peripheral regions of the lungs, which are more
27   sensitive to acute Os response and injury. This will result in greater lung function decrements for
28   acute exposures of individuals during increased physical activity. Research has shown that
29   respiratory effects are observed at lower O$ concentrations if the level of exertion is increased
30   and/or duration of exposure and exertion are extended.  Predicted O3-induced decrements in lung
31   function  have been shown to be a function of exposure duration and exercise level for healthy,
32   young adults (McDonnell etal.51997)
33          Most of the studies investigating the influence of age have used lung function decrements
34   and symptoms as measures of response. After 18 to 20 years of age, lung function and symptom
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  1    responses to Os decline as age increases. The rate of decline in Os responsiveness appears
  2    greater in those 18 to 35 years old compared to those 35 to 55 years old, while there is very little
  3    change after age 55.  In one study (Seal et al., 1996) analyzing a large data set, a 5.4% decrement
  4    in FEVi was predicted for 20 year old individuals exposed to 0.12 ppm Os, whereas similar
  5    exposure of 35 year old individuals were predicted to have a 2.6% decrement. While healthy
  6    children tend not to report respiratory symptoms when exposed to low levels of Os, for subjects
  7    18 to 36 years old symptom responses induced by Os tend to decrease with increasing age
  8    (McDonnell etal., 1999).
  9          Limited evidence of gender differences in response to Os exposure has suggested that
10    females may be predisposed to a greater susceptibility to Os. Lower plasma and NL fluid levels
11    of the most prevalent antioxidant, uric acid, in females relative to males may be a contributing
12    factor (Housley et al., 1996). Consequently, reduced removal of Os in the upper airways may
13    promote deeper penetration.  However, most of the evidence on gender differences appears to be
14    equivocal, with one study (Hazucha et al., 2003) suggesting that physiological responses of
15    young healthy males and females may be comparable (CD, section 6.5.2).
16          A few studies have suggested that ethnic minorities might be more responsive to Os than
17    Caucasian population groups (CD, section 6.5.3). This  may be more the result of a lack of
18    adequate health care  and socioeconomic status than any differences in sensitivity to Os.  The
19  '  limited data available, which have investigated the influence of race, ethnic or other related
20    factors on responsiveness to  Os, prevent drawing any clear conclusions at this time.
21          Few human studies have examined the potential influence of environmental factors such
22    as the sensitivity of individuals who voluntarily smoke tobacco (i.e., smokers) and the effect of
23    high temperatures. New controlled human exposure studies have confirmed that smokers are
24    less responsive to Os than nonsmokers; however, time course of development and recovery of
25    these effects, as well as reproducibility, was not different from nonsmokers (CD, section 6.5.5).
26    Influence of ambient temperature on pulmonary effects induced by Os has been studied very
27    little, but additive effects of heat and Os exposure have been reported.
28          Antioxidants, which scavenge free radicals and limit lipid peroxidation present in the
29    ELF, are the first line of defense against oxidative stress. Ozone exposure depletes the
30    antioxidant level in the nasal ELF by scrubbing of Os, but concentration and antioxidant enzyme
31    activity in ELF or plasma don't appear related to Os responsiveness (CD, section 6.5.6).
32    Controlled studies of the protective effects of dietary antioxidant supplements have shown some
33    protective effects of lung function but not of subjective  symptoms or inflammatory response.
34    Dietary antioxidant supplements have provided some protection to asthmatics by attenuating
35    post-exposure airway hyperresponsiveness. Animal studies have also  supported the protective
36    effects of ELF antioxidants.

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 1          3.6.2 ,   Susceptible Population Groups
 2          Several characteristics that may increase the extent to which a population group shows
 3    sensitivity to Os have been discussed in the draft CD, in the sections on clinical studies in
 4    Chapter 6, epidemiological studies in Chapter 7,  and in the integrated assessment in Chapter 8;
 5    this section will draw on all of these. The characteristics that likely increase susceptibility to 63
 6    are based on:  (1) activity patterns; (2) lung disease; (3) age; and (4) biological responsiveness to
 7    Cb. Other groups that might have enhanced sensitivity to Oj, but for which there is currently
 8    very little evidence, include: people with heart disease;  groups based on race, gender and
 9    socioeconomic status; and those with nutritional  deficiencies.

10        ,    3.6.2.1    Active People
11          A large group of individuals at risk from Os exposure consists of children, adolescents,
12    and adults who engage in outdoor activities involving exertion or exercise during summer
13    daylight hours when ambient Os concentrations tend to  be higher. This conclusion is based on a
14    large number of controlled-exposure human studies which have been conducted with healthy
15    children and adults and those with preexisting respiratory diseases (CD, section 6.2 and 6.3).
16    These studies show a clear 63 exposure-response relationship with increasing spirometric and
17    symptomatic response as exercise level increases. Furthermore, Os-induced response increases
18    as time of exposure increases. Although these studies show a wide variability of response and
19    sensitivity among subjects and the factors  contributing to this variability continue to be
20    incompletely understood, as discussed below, the effect of increased exertion is consistent.

21            3.6.2.2    People with Lung Disease
22          People with preexisting pulmonary disease may be at increased risk from Os exposure.
23    Altered physiological, morphological and  biochemical states typical of respiratory diseases like
24    aslhma, COPD and chronic bronchitis may render people sensitive to additional  oxidative burden
25    induced by Os exposure. Evidence contained in the 1996 CD indicated that people with asthma
26    appear to be at least as sensitive, or more,  to the acute effects of Os as healthy nonasthmatic
27    individuals. The new results reviewed in Chapters 6 and 7 of the draft CD from controlled  .
28    human exposure, field, and epidemiological studies continue to suggest that people with aslhma
29    are a potentially sensitive subpopulation for Os health effects. This information expands  the
30    understanding of the physiological basis for increased sensitivity in people with  asthma.  It
31    indicates that there are slightly increased spirometric responses in mild asthmatics compared to
32    healthy subjects. Small airways tend to be more  affected in people with asthma than in healthy
33    subjects (Alexis et al., 2000), Oa-induced  FEVi decrements tended to be greater in people with
34    asthma and allergic rhinitis compared to healthy  controls (J6rres et al., 1996), and Oa-induced
35    increases in sRaW were reported to be greater in people with asthma compared to healthy subjects
36    (Aris et al., 1995; Balmes et al., 1996). In a study (Horstman et al., 1995) of people with mild-
37    to-moderate asthma exposed for longer durations (6.6 hr), FEVi and FEF25-75 decrements were
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  1    found to be significantly greater than for healthy subjects. Moreover, a significant positive
  2    correlation reported in people with asthma between Os-induced spirometric responses and
  3    baseline lung function suggested that responses increased with severity of disease. Ozone-
  4    induced inflammatory responses also have been reported to be greater in people with asthma as
  5    compared to healthy individuals (Peden et al., 1995; Scannell et al., 1996; Holz et al. 1999).
  6    New evidence also indicates that people with asthma may have increased occurrence and
  7    duration of nonspecific airway responsiveness, and that people with pre-existing allergic asthma
  8    may have increased airway responsiveness to allergens following Os exposure (CD, p. 8-29).
  9          A number of epidemiological studies have been conducted using asthmatic study
10    populations. The majority of epidemiological panel studies that evaluated respiratory symptoms
11    and medication use related to Os exposures focused on children (CD, p. 8-44). These studies
12    suggest that Os exposure may be associated with increased respiratory symptoms and medication
13    use in children with asthma.  Other reported effects include respiratory symptoms, lung function
14    decrements, and emergency department visits, as discussed in the draft CD (section 7.6.7.1).
15    Strong evidence from a large multi-city study (Mortimer et al., 2002), along with support from
16    several single-city studies suggest that Os exposure may be associated with increased respiratory
17    symptoms and medication use in children with asthma (CD, p. 8-44). With regard to ambient Os
18    levels and increased hospital admissions and emergency department visits for asthma and other
19    respiratory causes, strong evidence establishes a correlation between Os exposure and increased
20    exacerbations of preexisting respiratory disease for 1-hr maximum Os concentrations <0.12 ppm
21    (CD, p. 8-46). Several hospital admission and emergency department visit studies in the U.S.
22    (Peel et al.,  2005), Canada (Burnett et al., 1997a; Anderson et al., 1997), and Europe (Anderson
23    et al., 1997) have reported positive associations between increase in Os and increased risk of
24    emergency department visits and hospital admissions.

25            3.6.2.3    Children and Older Adults
26          Supporting evidence exists for heterogeneity in the effects of 03 by age.  As discussed in
27    section 6.5.1 of the draft CD, children, adolescents, and young adults (<18 yrs of age) appear, on
28    average, to have nearly equivalent spirometric responses to Os, but have greater responses than
29    middle-aged and older adults when exposed to comparable Os doses.  Symptomatic responses to
30    Os exposure, however, appear to increase with age until early adulthood and then gradually
31    decrease with increasing age. In contrast to young adults, the diminished symptomatic responses
32    in children and symptomatic and spirometric responses in the elderly may put them at an
33    increased risk for continued exposure.
34          As described in the section 7.6.7.2  of the draft CD, many  epidemiological field studies
35    focused on the effect of Os on the respiratory health of school children. In general, children
36    experienced decrements in pulmonary function parameters, including PEF, FEVj, and FVC.
37    Increases in respiratory symptoms and asthma medication use were also observed in asthmatic
38    children. In one German study, children with and  without asthma were found to be particularly
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 1    susceptible to 63 effects on lung function. Approximately 20% of the children, both with and
 2    without asthma, experienced a greater than 10% change in FEVi, compared to only 5% of the
 3    elderly population and athletes (Hoppe et al., 2003).
 4          The American Academy of Pediatrics (2004) notes that children and infants are among
 .5    the population groups most susceptible to many air pollutants, including Os.  This is in part
 6    because their lungs are still developing. For example, eighty percent of alveoli are formed after
 7    birth, and changes in lung development continue through adolescence (Dietert et al., 2000).
 8    Children are also likely to spend more time outdoors than adults do, which results in increased
 9    exposure to air pollutants (Wiley et al., 1991a,b).  Moreover, children have high minute
10    ventilation rates and high levels of physical activity which also increases their dose (Plunkett et
11    al., 1992).
12          Several mortality studies have investigated age-related differences in Os effects. Among
13    the studies that observed positive associations between Os and mortality, a comparison of all age
14    or younger age (^65 years of age) Os-mortality risk estimates to that of the elderly .population
15    (>65 years) indicates that, in general, the elderly population is more susceptible to p3 effects
16    (Borja-Aburto et al. 1997; Bremner et al., 1999; Gouveia and Fletcher 2000b; O'Neill et al.,
17    2004; Simpson et al., 1997; Sartor et al., 1995; Sunyer et al., 2002). For example, a study by
18    Gouveia and Fletcher (2000b) examined the Os-mortality effect by age in Sao Paulo, Brazil.
19    Among all ages, Os was associated with a 0.6% excess risk in all cause mortality per 40 ppb
20    increase in 1-hr max 03. In comparison, in the elderly population, the Os-mortality risk estimate
21    was nearly threefold greater, at 1.7%. Similarly, a Mexico City study found mat Oa-mortalily
22    risk estimates were 1.3% and 2.8% per 20 ppb increase in 24-hr  average Os concentration in all
23    ages and the elderly, respectively (O'Neill et al., 2004).
24          The meta-analysis by Bell et al. (2005) found a larger effect estimate for the elderly
25    (2.92% per 20 ppb increase in 24-hr average O3) man for all ages (1.75%). In the large U.S. 95
26    communities study (Bell et al., 2004), effect estimates were slightly higher for those aged 65 to
27    74 years, 1.40% excess risk per 20 ppb increase in 24-hr average Oa, compared to individuals
28    less than 65 years and 75 years or greater, 1.00% and 1.04%, respectively, using a constrained
29    distributed 7-day lag model. Bell et al. (2004) note that despite similar effects estimates, the
30    absolute effect of Oa is substantially greater in the elderly population due to the higher
31    underlying mortality rates, which lead to a larger number of extra deaths for the elderly
32    compared to the general population.  The draft CD concludes that the elderly population (>65
33    years of age) appear to be at greater risk of Os-related mortality and hospitalizations compared to
34    all age or younger populations (CD,  p. 7-151).
35          The draft CD notes that, collectively, there is supporting  evidence of age-related
36    differences in susceptibility to Os health effects. The elderly population (>65 years of age)
37    appear to be at increased risk of Oj-related mortality and hospitalizations, and children (<18
38    years of age) experience other potentially adverse respiratory health outcomes with increased Os
39    exposure (CD,  section 7.6.7.2).    •
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  1            3.6.2.4    People with Increased Responsiveness to Ozone
  2          New animal toxicology studies using various strains of mice and rats have identified Os-
  3    sensitive and resistant strains and illustrated the importance of genetic background in
  4    determining O3 susceptibility. Using subacute low exposure regimen (0.3 ppm Os, 48h) studies
  5    on inbred strains that have been designated as inflammation prone or resistant, Kleeberger et al.,
  6    (1997) identified the pro-inflammatory cytokine gene, Tnf-most of these
28    studies were carried out using relatively high doses of Os, making the relevance of these studies
29    questionable in human  health effects assessment. No doubt, the molecular parameters identified
30    in these studies may serve as useful biomarkers  with the availability of suitable technologies and,
31    ultimately, can likely be integrated with epidemiological studies. Interindividual differences in
32    Os responsiveness have been observed across a spectrum of symptoms and lung function
33    responses do not yet allow identification of important underlying factors, except a significant
34    role for age.
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 1            3.6.2.5    Other Population Groups
 2          There is limited, new evidence supporting associations between short-term Os exposures
 3    and a range of effects on the cardiovascular system. Some but not all, epidemiological studies
 4    have reported associations between short-term 63 exposures and the incidence of myocardial
 5    infarction and more subtle cardiovascular health endpoints, such as changes in heart rate
 6    variability and cardiac arrhythmia.  Others have reported associations with hospitalization or
 7    emergency department visits for cardiovascular diseases, although the results across the studies
 8    are not consistent. Studies also report associations between short-term 63 exposure and
 9    mortality from cardiovascular or cardiopulmonary causes.  Based on epidemiological study
10    results, the draft CD concludes that the current evidence from field studies is rather limited but
11    supportive of a potential effect of short-term 03 exposure and heart rate variability, cardiac
12    arrhythmia and incidence of myocardial infarction (CD, p.  7-57).  In the draft CD's evaluation of
13    studies of hospital admissions for cardiovascular disease (CD, section 7.3.4), it is concluded that
14    evidence from this growing group of studies is generally inconsistent but is suggestive of an
15    association with O3 in studies conducted during the warm season (CD, p. 7-73,7-74). This body
16    of evidence suggests that people with heart disease may be at increased risk from short-term
17    exposures to 63; however, more evidence is needed to conclude that people with heart disease
18    are a susceptible population.
19          Other groups that might have enhanced sensitivity to Os, but for which there is currently
20    very little evidence, include, groups based on race, gender and socioeconomic status, and those
21    with nutritional deficiencies, as discussed in section about factors which modify responsiveness
22    to Os, above.

23          3.6.3     What Constitutes an Adverse Health Impact from Ozone Exposure?
24        .  In making judgments as to when various Os-related effects become significant enough
25    that they should be regarded as adverse to the health of individuals, in previous NAAQS reviews
26    staff has relied upon the guidelines published by the American Thoracic Society (ATS) and the
27    advice of CAS AC.  While recognizing that perceptions of "medical significance" and "normal
28    activity" may  differ among physicians, lung physiologists and experimental subjects, the ATS
29    (1985) defined adverse respiratory health effects "medically significant physiologic changes
30    generally evidenced by one or more of the following: (1) interference with the normal activity of
31    the affected person or persons, (2) episodic respiratory illness, (3) incapacitating illness, (4)  ,
32    permanent respiratory injury, and/or (5) progressive respiratory dysfunction."
33          During the 1997 review, it was concluded that there was evidence of causal associations
34    from controlled human exposure studies for effects in the first category, evidence of statistically
35    significant associations from epidemiological studies for effects in the second and third
36    categories, and evidence from animal toxicology studies, which could be extrapolated to humans
37    only with a significant degree of uncertainty, for the last two categories. For the current review
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 1    the evidence is much stronger across the categories. For ethical reasons, clear causal evidence
 2    from controlled human exposure studies still covers only effects in the first category. However,
 3    for this review there are results from epidemiolpgical studies, upon which to base judgments
 4    about adversity, for effects in all of the categories.  Statistically significant and robust
 5    associations have been reported in epidemiology studies fall into the second and third categories.
 6    These more serious effects include respiratory illness that may require medication (e.g., asthma),
 7    but not necessarily hospitalization,-as well as respiratory hospital admissions. Less conclusive,
 8    but still positive associations have been reported for school absences, emergency room visits for
 9    respiratory causes, and cardiovascular hospital admissions.  Human health effects for which
10    associations have been suggested through evidence from epidemiological and animal toxicology
11    studies, but have not been conclusively  demonstrated still fall primarily into the last two
12    categories, but the evidence is much stronger in this review than in the 1997 review. In the last
13    review of the 63 standard, evidence for these more serious effects came from studies of effects in
14    laboratory animals, and could be extrapolated to humans only with a significant degree of
15    uncertainty.  Evidence from animal studies evaluated in this draft CD strongly suggests that Os  is
16    capable of damaging the distal airways and proximal alveoli, resulting in lung tissue remodeling
17    leading to apparently irreversible changes. Recent advancements of dosimetry modeling also
18    provide a better basis for extrapolation from animals to humans. Information from
19    epidemiological studies provides supporting, but limited evidence of irreversible respiratory
20    effects  in humans (as described in section 6.3.3.2 below). Moreover, the draft CD concludes that
21    the findings from multi-city times series, single city, and meta-analyses epidemiology studies
22    support a causal association between short-term Oa exposure and mortality  particularly in the
23    warm season.
24           While Os has been associated with effects that are clearly adverse, application of these
25    guidelines, in particular to the least serious category of effects related to ambient Os exposures,
26    involves judgments about which medical experts on the CASAC panel and  public commenters
27    have in the past expressed diverse views. -To help frame such judgments, staff defined
28    gradations of individual functional responses (e.g., decrements FEVi and airway  responsiveness)
29    and symptomatic responses (e.g., cough, chest pain, wheeze), together with judgments as to the
30    potential impact on individuals experiencing varying degrees of severity of these responses, that
31    have been used in previous NAAQS reviews.  These gradations and impacts are summarized
32    below in Tables 3-2 and 3-3 below.
3 3           For active healthy people, it has been j udged that moderate levels of functional responses
34    (e.g., FEVi decrements of >10% but < 20%, lasting up to 24 hrs) and/or moderate symptomatic
35    responses (e.g., frequent spontaneous cough, marked discomfort on exercise or deep breath, .
36    lasting  up to 24 hrs) would likely interfere with normal activity for relatively few sensitive

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 1    individuals; whereas large functional responses (e.g., FEVi decrements > 20%, lasting longer
 2    than 24 hrs) and/or severe symptomatic responses (e.g., persistent uncontrollable cough, severe
 3    discomfort on exercise or deep breath, lasting longer than 24 hrs) would likely interfere with
 4    normal activities for many sensitive individuals and therefore would be considered adverse under
 5    ATS guidelines. However, for people with lung disease, even moderate functional (e.g., FEVi
 6    decrements >  10% but < 20%, lasting up to 24 hrs) or symptomatic responses (e.g., frequent
 7    spontaneous cough, marked discomfort on exercise or with.deep breath, wheeze accompanied by
 8    shortness of breath,  lasting up to 24 hrs) would likely interfere with normal activity for many
 9    individuals, and would likely result in additional and more frequent use of medication. For
10    people wilh lung disease, large functional responses (e.g., FEVi decrements > 20%, lasting
11    longer than 24 hrs) and/or severe symptomatic responses (e.g., persistent uncontrollable cough,
12    severe discomfort on exercise or deep breath, persistent wheeze accompanied by shortness of
13    breath, lasting longer than 24 hrs) would likely interfere with normal activity for most
14    individuals and would increase the likelihood that these individuals would seek medical
15   .treatment or go to an emergency room for relief.
16          In judging the extent to which these impacts represent effects that should be regarded as
17    adverse to the health status of individuals, an additional factor that has been considered in
18    previous NAAQS reviews is whether such effects are experienced repeatedly during the course
19    of ayear or only on a single occasion.  While some experts would judge single occurrences of
20    moderate responses to be a "nuisance," especially for healthy individuals, a more general
21    consensus view of the adversity of such moderate responses emerges as the frequency of
22    occurrence increases.  Thus it has been judged that repeated occurrences of moderate responses,
23    even in otherwise healthy individuals, may  be considered to be adverse since they could well set
24    the stage for more serious illness (61 FR 65723).  The CAS AC panel.in the last review expressed
25    a consensus view that these "criteria for the determination of an adverse physiological response
26    was reasonable" (Wolff, 1995b).
27          In 2000, the American Thoracic Society (ATS) published an official statement on "What
28    Constitutes an Adverse Health Effect of Air Pollution?" (ATS, 2000), which updated the
29    guidance for defining adverse respiratory health effects (ATS, 1985) that was published fifteen
30    years earlier and has been used in past NAAQS reviews.  The revised guidance was intended to
31    address new investigative approaches used  to identify the effects of air pollution, and to reflect
32    the concern for the impacts of air pollution  on specific groups that had been expressed through
33    the environmental justice movement.
34          The new guidance builds upon and expands the 1985 definition of adversity in several
35    ways.  There is an increased focus on quality of life measures as indicators of adversity. There is
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Table 3-2. Gradation of Individual Responses to Short-Term Ozone Exposure in Healthy
           Persons2
Functional
Response
FEVi


Nonspecific
bronchial
responsivenessS
Duration of response

Symptom Response
Cough


Chest pain



Duration of response
Impact of Responses
Interference with normal
activity


None

Within
normal
range (±3%)
Within
normal range

None

Normal
Infrequent
cough

None



None
Normal
None



Small

Decrements of
3 to slO%

Increases of
<100%

<4hrs

Mild
Cough with deep
breath

Discomfort just
noticeable on
exercise or
deep breath
<4hrs
Normal
None



Moderate

Decrements of
>10but<20%

Increases of
*300%

>4 hrs but
*24hrs
Moderate
Frequent
spontaneous cough

Marked discomfort
on exercise or deep
breath

>4 hrs but £24 hrs
Mild
A few sensitive
individuals choose
to limit activity

Large

Decrements of
a20%

Increases of
>300%

>24 hrs

Severe
Persistent
uncontrollable
cough
Severe discomfort
on exercise or
deep breath

>24 hrs
Moderate
Many sensitive
individuals
choose to limit
activity
 2 This table is reproduced from the 1996 O3 AQCD (Table 9-1, page 9-24) (U.S. Environmental Protection
 Agency, 1996). ,
 3 An increase in nonspecific bronchial responsiveness of 100% is equivalent to a 50% decrease in PDjo or PDjoo-
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 Table 3-3. Gradation of Individual Responses to Short-Term Ozone Exposure in Persons
            with Impaired Respiratory Systems
Functional
Response
FEVt change
Nonspecific
bronchial
responsiveness 4
Airway resistance
(SRaw)
Duration of
response
Symptom
Response
Wheeze
Cough
Chest pain
Duration of
response
Impact of
Responses
Interference with
normal activity
Medical treatment
None
Decrements of
<3%
Within normal
range
Within normal
range (±20%)
None

Normal
None
Infrequent
cough '
None
None

Normal
None
No change
Small
Decrements of
3 to slO%
Increases of <1 00%
•* ^
SRaw increased
<100%
<4hr

Mild
With otherwise
normal breathing
Cough with deep
breath
Discomfort just
noticeable on exercise
or deep breath
<4hr

Mild
Few individuals
choose to limit
activity
Normal medication as
needed
Moderate
Decrements of >10
but <20%
Increases of s300%
SRaw increased up to
200% or up to 15cm
H2O/S
>4hrbut<:24hr

Moderate
With shortness of
breath
Frequent spontaneous
cough
Marked discomfort on
exercise or deep
breath
>4hrbut<24hr

Moderate
Many individuals
choose to limit
activity
Increased frequency
of medication use or
additional medication
Large
Decrements of
i20%
Increases of >300%
SRaw increased
>200% or more than
15cmH2O/s
>24hr

Severe
Persistent with
shortness of breath
Persistent
uncontrollable
cough
Severe discomfort
on exercise or deep
breath
>24 hr

Severe
Most individuals
choose to limit
activity
Physician or
emergency room
visit

 An increase in nonspecific bronchial responsiveness of 100% is equivalent to a 50% decrease in PD2o or PDn».
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 1    also a more specific consideration of population risk. Exposure to air pollution that increases the
 2    risk of an adverse effect to the entire population is adverse, even though it may not increase the
 3    risk of any individual to an unacceptable level.  For example, a population of asthmatics could
 4    have a distribution of lung function such that no individual has a level associated with significant
 5    impairment.  Exposure to air pollution could shift the distribution to lower levels that still do not
 6    bring any individual to a level that is associated with clinically relevant effects.  However, this
 7    would be considered to be adverse because individuals within the population would have
 8    diminished reserve function, and therefore would be at increased risk if affected by another
 9    agent
10          Of the various effects of 63 exposure that have been studied, many would meet the ATS
11    definition of adversity. Such effects include, for example, any detectible level of permanent lung
12    function loss attributable to air pollution, including both reductions in lung growth or
13    acceleration of the age-related decline of lung function; exacerbations of disease in individuals
14    with chronic cardiopulmonary diseases; reversible loss of lung function in combination with the
15    presence of symptoms; as well as more serious effects such as those requiring medical  care
16    including hospitalization and, obviously, mortality.
17          As discussed above, relatively small, reversible declines in lung function parameters may
18    be of questionable significance in healthy people. However, a 5 to 15 % change in FEVi is
19    considered to have clinical importance to asthma morbidity (ATS 1991; Lebowitz et al. 1987;
20    Lippmann, 1988).  The National Institutes of Health (1997) has stated that a PEF below 80% of a
21    person's personal best indicates a need for continued medication use in asthmatics.  In  Mortimer
22    et al. (2002), Os was associated  with increased incidence of > 10%,declines in morning PEF as
23    well as morning symptoms, suggesting that Oa exposure may have clinically significant effects
24    on asthmatic children.
25          Reflecting new investigative approaches, the ATS statement describes the potential
26    usefulness of research into the genetic basis for disease, including responses to environmental
27    agents that will provide insights into the mechanistic basis for susceptibility, and provide
28    markers  of risk status.  Likewise biomarkers, that are indicators of exposure, effect or
29    susceptibility, may someday be useful in defining the point at which a response should be
30    equated with an adverse effect.  Based on concern for segments of the population that may be
31    disproportionately exposed to environmental contaminants, or have other factors that may
32    increase susceptibility (e.g., genetic or nutritional factors), there was a call for increased research
33    in these areas.
34          Overall, the new guidance  does not fundamentally change the approach previously taken
35    to define adversity, nor does it suggest a need at this time to change the structure or content of
36    the tables describing gradation of severity and adversity of effects in Tables 3-2 or 3-2  above.

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 1   3.7    SUMMARY AND CONCLUSIONS FOR OZONE HEALTH EFFECTS
 2          Based on dosimetric, experimental, and epidemiological evidence assessed in the 1996
 3   CD, a set of findings and conclusions were drawn regarding potential health effects of Os
 4   exposure as of 1996, and is reproduced in the draft CD (section 8.4.1). Similarly, section 8.7 of
 5   the draft CD has summarized the main conclusions derived from the integrated analysis of
 6   animal toxicology (CD, Chapter 5), human experimental (CD, Chapter 6) and epidemiological
 7   (CD, Chapter 7) studies that evaluated evidence of health effects associated with short-term,
 8   repeated, and long-term exposures to 63 alone or in combination with other pollutants commonly
 9   found in the ambient air. This section of the draft Staff Paper integrates conclusions drawn from
10   both sections of the draft CD to provide an overview of health effects of Os alone and in
11   mixtures and to identify susceptibility factors associated with exposure to O3.

12          3.7.1    Morbidity Health Effects of Acute (Short-term) Exposures to Ozone
13          In the 1996 CD, it was concluded mat short-term 63 exposures cause: changes in
14   pulmonary function, including tachypnea (rapid, shallow breathing), decreased lung volumes and
15   flows, and increased airway responsiveness to nonspecific stimuli; increased airway resistance;
16   and airway irritation such as cough or chest pain (CD, p. 8-12). Changes in pulmonary function
17   and respiratory symptoms occur as a function of exposure concentration, duration and level of
18   exercise. According to the draft CD, results from the maj ority of acute exposure studies continue
19   to support the conclusions reported in the 1996 CD.
20          The 1996 CD concluded that group mean data from numerous controlled human exposure
21   and field studies of healthy subjects (8 to 45 years of age) exposed for 1 to 3 hr indicate that, in
22   general, statistically significant pulmonary function decrements beyond the range of normal
23   measurement variability (e.g., 3 to 5% for FEV]) occur
24         •  at >0.12 ppm Os with very heavy  exercise (competitive running).
25         •  atXXISppmOs with heavy exercise (easy jogging),
26         *  at >0.30 ppm 63 with moderate exercise (brisk walking),
27         •  at >0.37 ppm Os with light exercise (slow walking), arid
28         •  at XX50 ppm Os when at rest.
29          Small group mean changes (e.g., <5%) in FEVi have been observed in healthy young .
30   adults at levels as low as 0.12 ppm Oa. Also, pulmonary function decrements have been
31   observed in children and adolescents at concentrations of 0.12 and 0.14 ppm Os with heavy
32   exercise. Some individuals within a study may experience FEVi  decrements in excess of 15%
33   under these conditions, even when group mean decrements are less than 5%.


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 1          For exposures of healthy subjects performing moderate exercise during longer duration
 2    exposures (6 to 8 hr), 5% group mean decrements in FEVi were observed at
 3         •  0.08 ppm after O3 5.6 hr,
 4         •  0.10 ppm after Os 4.6 hr, and
 5         *  0.12 ppm after O3 3 hr.
 6    For these same subjects, 10% group mean FEVi decrements were observed at 0.12 ppm O3 after
 7    5.6 and 6.6 hr. As in the shorter duration studies, some individuals experience changes larger
 8    than those represented by group mean changes.
 9          The draft CD (section 8.7) concludes that newer meta-analyses confirmed interindividual  '
10    differences in lung function decrements reported in the 1996 CD. Age-specific differences in
11    lung function responses were also observed. Spirometric responses (due to decrements in lung
12    function) in healthy adults exposed to near ambient Os levels typically resolve to near baseline
13    within 4-6 hr.  Meta-analyses of four controlled human exposure studies (two new and two
14    assessed in the 1996 CD) reporting the effects of prolonged (6.6 hr) exposures to 0.08 ppm Os
15    during moderate exercise on pulmonary function in young healthy adults (M=90, F=30; mean
16    age 23 years) indicate an absolute FEVi decrease of 6%, whereas FEVt increased by 1%
17    following free air exposures.
18          The 1996 CD concluded that an increase in the incidence of cough has been reported at
19    Os concentrations as low as 0.12 ppm in healthy adults during 1 to 3 hr of exposure with very
20    heavy exercise.  Other respiratory symptoms, such as pain on deep inspiration, shortness of
21    breath, and lower respiratory scores (i.e., a combination of several symptoms), have been
22    observed at 0.16 ppm to 0.18 ppm Os with heavy and very heavy exercise.  Respiratory
23    symptoms also have been observed following exposure to 0.08,0.10 and 0.12 ppm Os for 6.6 hr
24    with moderate exercise levels.  Also, increases in nonspecific airway responsiveness in healthy
25    adults at rest have been observed after 1 to 3 hr of exposures to 0.40 ppm but not to 0.20 ppm Os;
26    during very heavy exercise, these increases were observed at concentrations as low as 0.18 ppm
27    but not at 0.12 ppm Os. Increases in nonspecific airway responsiveness during the 6.6 hr
28    exposures with moderate levels of exercise have been observed at 0.08,0.10 and 0.12 ppm Os.
29    See Table 3.4 for a summary of short-term health effects of Os based on clinical studies.
30          The 1996 CD concluded that increased Os levels are associated with increased hospital
31    admissions and emergency department visits for respiratory causes. Analyses from data in the
32    northeastern U.S. suggest that Os air pollution is associated with a substantial portion (on the
33    order of 10 to 20%) of all summertime respiratory hospital visits and admissions. The draft CD
34    concludes that a large multi-city and several single-city studies have indicated a positive
35


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2
3
Table 3-4. Summary of Ozone-Induced Respiratory Health Effects from Clinical Studies3
Health Effect
Pulmonary
Function
Decrements
Increased
Respiratory
Symptoms
Airway
Responsiveness
Respiratory
Inflammation
Changes in Host
Defenses
Decreased
Exercise
Performance
Exercise Level
Moderate
Moderate
Moderate
Competitive
Very Heavy
Heavy
Moderate
Light
At rest
Moderate
Very Heavy
Moderate
Very Heavy
At rest
Moderate
Very Heavy
Moderate
Competitive
Prolonged
Exposure
6.6 hr
4.6 hr
3.0 hr
6.6 hr
6.6 hr
6.6 hr
6.6 hr

Short-term
Exposure
Ihr
1-3 hr
1-3 hr
1-3 hr
1-3 hr
1-3 hr
1-3 hr
1-3 hr
1-3 hr
1-3 hr

Ihr
Lowest Ozone Effect
Level
0.08 ppm
0.10 ppm
0.1 2 ppm
0.1 2-0. 14 ppm
0.1 6 ppm
0.18 ppm
0.30 ppm
0.37 ppm
0.50 ppm
0.08 ppm
0.1 2 ppm
0.08 ppm
0.1 8 ppm
0.40 ppm
0.08 ppm
0.20 ppm
0.08 ppm
0.1 8 ppm
      Information contained in this table is based on scientific data assessed in Chapters 6 and 8 of the CD.
    November 2005
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 1    association between increased 63 levels (especially during the warm season) and increased risk
 2    for hospital admissions.
 3          Pulmonary function in children at summer camps in southern Ontario, Canada, in the
 4    northeastern U.S., and in southern California is associated with ambient 03 levels (CD, p. 8-13).
 5    Meta-analyses indicate that a 0.50-mL decrease in FEVi is associated with a 1 ppb increase in Os
 6    concentration. For preadolescent children exposed to 120 ppb (0.12 ppm) ambient 0% this
 7    amounts to an average decrement of 2.4 to 3.0% in FEVi. Similar responses are reported for
 8    exercising children and adolescents exposed to Os in ambient air or 63 in purified air for 1 -2 hr.
 9          Short-term Os exposure of lab animals and humans disrupts the barrier function of the  •
10    lung epithelium, permitting materials in the airspaces to enter lung tissue, allowing cells and
11    serum proteins to enter the airspaces, and setting off a cascade of responses (CD, p. 8-14).
12    Increased levels of PMNs and protein in lung lavage fluid have been observed following
13    exposure of healthy adults to 0.20,0.30, and 0.40 ppm Os with very heavy exercise and have not
14    been studied at lower concentrations for 1-to 3-hr exposures.  Increases in lung lavage protein
15    and PMNs also have been observed at 0.08 and 0.10 ppm 0$ during 6.6 hr exposures with
16    moderate exercise; lower levels have not been tested. Short-term Os exposure of lab animals and
17    humans impairs alveolar macrophage (AM) clearance of viable and nonviable particles from the
18    lungs and decreases the effectiveness of host defenses against bacterial lung infections in animals
19    and perhaps humans. The ability of AMs to engulf microorganisms is decreased in humans
20    exposed to 0.08 and 0.10 ppm Os for 6.6 hr with moderate exercise.
21          The draft CD (p. 8-83) concludes that inflammatory responses (PMNs, inflammatory
22    mediators such as cytokines and chemokines) and permeability change (proteins, albumin),
23    typically measured in BAL fluid, also exhibit intersubject variability. Recent meta-analyses on
24    numerous clinical studies indicate interindividual differences in response to short-term 63
25    exposures. Also, inflammatory and permeability responses resolve (in some instances complete
26    recovery) and exhibit differential attenuation profiles between normal healthy subjects and
27    people with preexisting respiratory diseases. Some inflammation markers may not resolve
28    readily, and mild persistent inflammation has been reported. It was also  concluded that short-
29    term O3-induced lung function decrements, respiratory symptoms, inflammation, and
30    permeability changes observed in animal toxicology studies are consistent with human studies.
31          Two health endpoints that were not addressed in the 1996 CD conclusions, but are
32    addressed in the draft CD, are school absenteeism and cardiovascular effects. The draft CD (p.
33    8-83) concludes that an association between short-term Os exposures  and school absenteeism
34    (due to respiratory illness) has been suggested. Also, with regard to cardiac outcomes, a limited
35    number of field studies that examined the relationship between short-term Os exposures and
36    cardiovascular effects (heart rate variability, myocardial infarction) suggest an association.

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 1          3.7.2    Mortality-Related Health Effects of Short-tenn Exposures to Ozone
 2          The 1996 CD concluded that an association between daily mortality and O3 concentration
 3   for areas with high 03 levels (e.g., Los Angeles) was suggested. However, due to a very limited
 4   number of studies available at that time, the magnitude of the effect was unclear. Since 1996,
 5   new data are available from large multicity studies conducted in the U.S. and several single-city
 6   studies conducted all over the world, as well as from several meta-analyses that have combined
 7   information from multiple studies. The majority of these studies suggest an elevated risk of total
 8   nonaccidental mortality associated with acute exposure to Os, especially in the summer or warm
 9   season when Os levels are typically high, with somewhat larger effect estimate sizes for
10   associations with cardiovascular mortality (CD, p. 7-177,7-178). The draft CD finds that the
11   results from U.S. multicity time-series studies provide the strongest evidence to-date for
12   associations between short-term Os exposure and mortality. These studies, along with recent
13   meta-analyses, showed consistent risk estimates that are unlikely to be confounded by PM,
14   though the CD observes that future work is needed to better understand the influence of model
15   specifications on the risk coefficient (CD, p. 7-177 to 7-178).  For cardiovascular mortality, the
16   draft CD reports that effect estimates are consistently positive,  falling in the range of 1 to 8%
17   increases per 40 ppb in 1 -hr O3 (CD, p. 7-108). Overall, the draft CD concludes that these
18   findings appear to be consistent with a causal association between short-term Os exposure and
19   mortality particularly in the warm season (CD,  p. 8-52).

20          3.7.3    Health Effects of Repeated Short-term Exposures to Ozone
21          The 1996 CD drew several conclusions regarding repeated short-term Os exposures (CD,
22   p. 8-15). Partial or complete attenuation is observed for some of the Os-induced responses.
23   After 5 days of exposure, pulmonary function changes return to control levels with the greatest
24   changes usually occurring on the second day, but the attenuation was reversed after 7 to  10 days
25   without Os exposure. Most inflammatory markers (e.g., PMN  influx) attenuate after 5 days of
26   exposure, but markers of cell damage (e.g., LDH enzyme activity) do not attenuate and continue
27   to increase. Recovery of some inflammatory markers occurred a week to 10 days after exposure
28   ceased, but some responses were not normal after 20 days.  Animal studies suggest underlying
29   cell damage continues throughout the attenuation process. Also, attenuation may alter normal
30   distribution of Os within the lungs, allowing more Os to reach sensitive regions, possibly
31   affecting lung defenses.  Newer studies assessed in the draft CD (p. 8-84) supported all of these
32   conclusions in addition to which it was concluded that repeated daily, multi-hour exposure to
33   lower concentrations of Os (0.125 ppm for 4 days) causes an increased response to bronchial
34   allergen challenge in subjects with preexisting  allergic airway disease, with or without asthma.
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 1    In these subjects, changes in airway responsiveness after Os exposure appear to be resolved more
 2    slowly than changes in FEVi or respiratory symptoms.

 3          3.7.4     Health Effects of Long-term Exposures to Ozone
 4          In the 1996 CD, available data, primarily from animal toxicology studies, indicated that
 5    exposure to Os for months to years causes structural changes in several regions of the respiratory
 6    tract (CD, p. 8-15).  Effects may be of greatest importance in the CAR, where the alveoli and
 7    conducting airways meet. This region of the lungs is typically affected in most human airway
 8    diseases.  However, data from epidemiological and clinical studies is lacking, and most
 9    information on chronic Os effects in the distal lungs continue to be extrapolated from animal
10    toxicology studies.
11          What had been previously been viewed as an apparent lack of reversibility of effects
12    during clean air exposures has been investigated since 1996 with animal toxicology studies using
13    exposure regimens simulating a seasonal exposure pattern. One long-term study exposed rhesus
14    monkeys to a simulated seasonal Os pattern (0.5 ppm Os 8hr/day for 5 days, every 14 days for 11
15    episodes) and reported:  (1) remodeling in the distal airways; (2) abnormalities in trachea!
16    basement membrane; (3) eosinopHil accumulation in conducting airways; and (4) decrements in
17    airway innervatiori.  These findings support and advance the earlier information suggestive of
18    injury and repair processes which are caused by seasonal Os exposures (CD, p.8-85). Although
19    pathophysiological changes associated with long-term Os exposures reported in animal studies
20    suggest similar changes in humans, interspecies differences in sensitivity to chronic effects of 03
21    continue to be a limiting factor in extrapolation of effect responses in animals to human health
22    effects.                                                           •  •
23    •      Epidemiological  studies investigating chronic effects in humans following long-term
24    exposures to Oa previously provided only limited suggestive evidence. However, recent studies
25    of pulmonary function changes observed in children living in cities with high Os levels as well as
26    alterations in lung structure alterations reported in an autopsy study in LA support the conclusion
27    that long-term Os exposure may play a role in causing irreversible lung damage.  Further
28    investigation will be necessary to draw firmer conclusions about chronic health effects of Os.

29          3.7.5     Health Effects of Binary Pollutant Mixtures Containing Ozone
30          In the 1996 CD, it was recognized that coexposure of humans and animals to Os and
31    other pollutants, such as  NO2, SO2, H2SO4, HNO3, or CO, showed additive response for lung
32    spirometry or respiratory symptoms (CD, p..8-16).  Since 1996, most animal toxicology studies
33    investigating Oj  in a mixture with NO2 and H2SO4 have shown that effects can be additive,
34    synergistic, or even antagonistic, depending on the exposure regimen and the endpoint studied.
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 1    Although the issue of exposure to copollutants was previously described as poorly understood,
 2    especially with regard to chronic effects, newer information from human and animal studies of
 3    binary mixtures containing O3 suggest potential interactions depending on the exposure regimen
 4    and pollutant mix (CD, p. 8-87). Examples of this newer information include:' (1) continuous
 5    exposure to SO2 and NO2 increased inhaled Oj bolus absorption,'while continuous exposure to
 6    O3 decreased Oa bolus absorption; (2) asthmatics exhibited enhanced airway reactivity to house
 7    dust mite allergen following exposures to 03, N02 and the combination of the two gases;
 8    however, spirometric response was impaired only by O3 and O3+ NO2 at higher concentrations;
 9    and (3) animal toxicology studies with Os in mixture with NO2, formaldehyde, and PM
10    demonstrated additive, synergistic, or antagonistic effects depending on the exposure regimen
11    and the endpoints evaluated. One controlled-exposure study of children, designed to
12    approximate conditions of an epidemiological study by matching population and exposure
13    atmosphere (0.1 ppm 63,0.1 ppm SCh, and 101 ug/m2 H2SO4), failed to support the findings of
14    the epidemiological study. This points out the difficulty of trying to link outcomes of
15    epidemiological studies and controlled-exposure studies with binary pollutant mixtures.

16          3.7.6   Populations at Risk/Susceptibility Factors Associated with Ozone Exposure
17          The 1996 CD (p. 8-16) identified several factors that may increase sensitivity to 03 of
18    population groups, including:  (1) biological variation in responsiveness to O3; (2) preexisting
19    lung disease (e.g., asthma); (3) activity patterns (e.g., exercise level); (4) personal exposure
20    history (e.g., indoor v. outdoor); and (5) personal factors (e.g., age, nutritional status, gender,
21    smoking history, ethnicity). Based on the information assessed in the 1996 CD (p. 8-18),
22    population groups that demonstrated increased responsiveness to ambient concentrations of 03
23    consist of exercising, healthy and asthmatic individuals, including children, adolescents, and
24    adults (CD, p. 8-18). Since 1996, evidence from conttolled-exposure human and animal studies,
25    as well as from epidemiological studies, has provided further support for these and other
26    susceptibility factors and populations at risk. For example, controlled-exposure human studies
27    continue to show differential biological response to O3 based on physical activity (exertion) and
28    age. These studies demonstrate a large variation in sensitivity and responsiveness to Os,
29    although specific factors that contribute to mis intersubject variability are yet to be identified.
30    Associations of increased summertime hospital admissions for asthma and COPD with ambient
31    O3 levels suggest that individuals with these respiratory diseases are populations at risk to O3
32    exposure effects. Also, based on O3-induced differential response in lung inflammation and
33    airway responsiveness, asthmatic adults and children appear to have potentially increased
34    susceptibility to O3. There is no evidence from controlled-exposure human studies which
35    suggests that individuals with COPD are more sensitive to health effects of O3. There is some
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 1   animal toxicology evidence which has demonstrated the importance of genetic background in Os
 2   susceptibility. Genetic and molecular characterization studies of experimental animals have
 3   identified genetic loci responsible for both sensitivity and resistance.  Taking all of this.
 4   information into account, the draft CD (p. 8-86) concludes that even though the role of ethnic,
 5   racial, and nutrition status factors for O3 susceptibility remains inconclusive, all exercising
 6   (moderate to high physical exertion) healthy and asthmatic adults, adolescents, and children
 7   appear to exhibit increased responsiveness to ambient O3 levels and continue to be considered at
 8   increased risk of O3-induced health effects. Also, any individual with respiratory or
 9   cardiovascular disease or any healthy individual who is engaged in vigorous physical activity
10   outdoors during periods when Os levels are high (e.g., active outdoor children) is potentially at
11   increased risk to (Vinduced health effects, hi addition, healthy individuals and those with
                        «  •                "                     .*
12   cardiorespiratory impairment (e.g., those with COPD or cardiovascular disease) who are
13   "hyperresponsive" to  Oj exposure (i.e., exhibit much higher than normal lung function
14   decrements) would be considered at greater risk to Os exposure.      .  .
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 1
 2       4.     CHARACTERIZATION OF HUMAN EXPOSURE TO OZONE
 3   4.1    INTRODUCTION
 4          As part of the last 63 NAAQS review, EPA conducted exposure analyses for the general
 5   population, children who spent more time outdoors, and outdoor workers. Exposure estimates
 6   were generated for nine urban areas for "as is" (i.e., a recent year) air quality and for just meeting
 7   the existing 1-hr standard and several alternative 8-hr standards. EPA also conducted a health
 8   risk assessment that produced risk estimates for the number of children and percent of children
 9   experiencing lung function and respiratory symptoms associated with the exposures estimated
10   for these same nine urban areas.
11          The exposure analysis conducted for the current review builds upon the methodology and
12   lessons learned from the exposure analyses conducted for the last review (US EPA, 1996a). The
13   methodology used to conduct the exposure analysis as well as summary results from the
14   exposure analysis are described in this chapter.  The exposure analysis technical support
15   document, Ozone Population Exposure Analysis for Selected Urban Areas (US EPA, 2005a)
16   (hereafter cited as "draft Exposure Analysis TSD") presents a more detailed description of the
17   exposure analysis methodology,
18          Population exposures to ambient Os levels are modeled for 12 urban areas located across
19   the U. S. using the Air Pollutants Exposure (APEX) model, also referred to as the Total Risk
20   Integrated Methodology Inhalation Exposure (TRIM. Expo) model. Exposure estimates are
21   developed for current Ojlevels, based on 2004 ambient air quality measurements, and for Oj
22   levels associated with just meeting the current 8-hr Oa NAAQS, based on adjusting the 2004 air
23   quality data. Exposures to background levels of O3 are also estimated, based on Oa
24   concentrations predicted by the GEOS-CHEM atmospheric photochemical model. The model
25   estimated the PRB and total ozone concentrations at each grid point and the grid points selected
26   to represent the 12 urban areas used in the exposure analysis are included in Table 4D-1 in
27   Appendix 4D.      ,
28          Exposures are modeled for 1) the general population, 2) all school-age children, and 3)
29   active school-age children (defined below). The strong emphasis on children reflects the rinding
30   of the last O3 NAAQS-review that children, especially those who are active outdoors, are an
31   important at-risk group. An assessment of exposures of asthmatic school-age children will be
32   presented in the next draft Os Staff Paper.
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 1          This chapter provides a brief overview of the types of studies that provide data which this
 2   analysis is based on, followed by a description of the exposure model used for this analysis, the
 3   model input data, and the results of the analysis.

 4   4.2    OZONE EXPOSURE STUDIES

 5          Many studies have produced information and data supporting the development of
 6   methods for estimating human exposure to ambient Os over the past several decades.  These
 7   studies have been reviewed in the current and previous EPA Ozone Air Quality Criteria
 8   Documents (US EPA, 1986,1996b, 2005b).            :
 9          The types of measurements that have proven to be useful for understanding and
10   estimating exposure obtained from personal exposure assessment studies include fixed-site
11   ambient concentrations, concentrations in specific indoor and outdoor microenvironments,
12   personal exposure measurements, personal activity patterns, air exchange rates, infiltration rates,
13   deposition and decay rates, and meteorology.
14          4.2.1    Exposure Concepts and Definitions
15          Human exposure to a contaminant is defined as "contact at a boundary between a human
16   and the environment at a specific contaminant concentration for a specific interval of time"
17   (National Research Council, 1991). For airborne pollutants the contact boundary is nasal and
18   oral openings in the body, and personal exposure of an individual to a chemical in the air for a
19   discrete time period is quantified as (Lioy, 1990; National Research Council,  1991):
20          £[*,,'3]=  .   ^,(t)ftt                                                    (4-1)
                      "i
21   where Eft,^] is the personal exposure during the time period from 11 to ?2, and C(0 is the
22   concentration at time t in the breathing zone. The breathing rate (ventilation rate) at the time of
23   exposure is also an important determinant of the dose received by the individual.
24          Personal exposure to Oa can be estimated directly, by monitoring the concentration of Os
25   in the person's breathing zone (close to the nose/mouth), using a personal exposure monitor
26   (PEM).  Exposure can also be estimated indirectly, by estimating or monitoring the
27   concentrations over time in locations in which the individual spends time and estimating the time
28   and duration the individual spends in each location.  In both of these methods, Equation 4-1 is
29   used to calculate an estimate of personal exposure.
30          A key concept in modeling exposure is the microenviroranent, a term that refers to the
31   immediate surroundings of an individual.  A microenvironment is a location in which pollutant
32   concentrations are relatively homogeneous for short periods of time. Microenvironments can be
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 1    outdoors or indoors; some examples are outdoors near the home, outdoors near the place of
 2    work, bedrooms, kitchens, vehicles, stores, restaurants, street-comer bus stops, schools, and
 3    places of work. A bedroom may be treated as a different microenvironment than a kitchen if the
 4    concentrations are significantly different in the two rooms. The concentrations in a
 5    microenvironment typically change over time; for example, Os concentrations in a kitchen while
 6    cooking with a gas stove may be lower than when these activities are not being performed, due to
 7    scavenging of Os by NOX emissions from the gas burned.
 8          An important factor affecting the concentrations of Oa indoors is the degree to which the
 9    ambient outdoor air is transported indoors. This can be estimated using physical factors such as
10    air exchange rates, deposition and decay rates, and penetration factors. The volumetric exchange
11    rate (m3/hour) is the rate of air exchange between the indoor and outdoor air.  The air exchange
12    rate (AER) between indoors and outdoors is the number of complete air exchanges per hour and
13    is equal to the volumetric exchange rate divided by the volume of the well-mixed indoor air.
14    Indoor concentrations of Os can be decreased by uptake of 63 by surfaces and by chemical
15    reactions. The deposition and decay rates are the rates (per hour) at which Os is removed from'
16    the air by surface uptake and chemical reactions.  Some exposure models employ an infiltration
17    factor, which is conceptually useful if distinguishing between the air exchange processes of air
18    blowing through open doors and windows and the infiltration of air through smaller openings.
19    Since measurements of air exchange rates account for all of these processes (including
20    "infiltration"), this distinction is not useful in applied modeling of Os exposures and will not be
21    discussed further here.  Simplistic exposure models use a "factor model" approach to estimate
22    indoor Os concentrations by multiplying the ambient outdoor concentrations by an
23    indoor/outdoor concentration ratio, referred to as a penetration factor.

24          4.2.2    Monitoring Equipment Considerations
25          Exposure assessment studies involve monitoring airborne Os and/or other pollutants, and
26    monitor design and placement play a critical role in interpreting the results of these studies. For
27    exposure assessment purposes there are two general classes of monitors, personal exposure
28    monitors (PEMs) and fixed site monitors.
29          PEMs are designed to be worn or carried easily by individuals and to measure the
30    concentrations experienced by individuals over a period of hours, days, or weeks. The
31    placement of PEMs is important; the desired placement is usually in the breathing zone near the
32    mouth and nose, but where the monitor will not be excessively impacted by exhaled air. This
33    placement is intended to represent the concentrations the individual breathes in. PEMs typically
34    report continuously measured Os concentrations with averaging times ranging from 1 to 24
35    hours.
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 1          The draft CD reviews 03 PEMS (draft CD Appendix AX3, p. 163-4) and notes that
 2   humidity, wind velocity, badge placement, and interference with other copollutants may result in
 3   measurement error.  The draft CD reports PEM detection limits ranging from 5 to 23 ppb for
 4   averaging times from 24 hours to 1 hour.
 5          Fixed-site monitors measure concentrations over time at a given location. There are
 6   numerous fixed-site O3 monitors which are part of national, state, and local air monitoring
 7   networks.  In addition to their role of being used to determine which areas are in compliance with
 8   existing Os NAAQS, these are also useful for alerting the public to high O^ days, providing air
 9   quality data in support of exposure assessments for a study area, for tracking Os levels and
10   trends, and for studying the representativeness of measurements at these monitors for the study.
11   area. Existing fixed-site monitors usually report hourly averaged concentrations, and are in
12   operation over a period of years.  A discussion of monitoring equipment and networks can be
13   found in Chapter 2 of this Staff Paper and in section 2.6 in the draft CD.
14          There are also stationary monitors expressly set up for particular exposure field studies.
15   These are used to measure concentrations over time in microenvironments, such as rooms in a
16   home, just outside a home, roadsides, and so forth. The stationary monitors which are outdoors
17   can provide information about community-scale representativeness  of fixed-site monitors in or
18   near the community.

19          4.2.3    Personal Ozone Exposure Assessment Studies
20          The most useful PEM studies have data collected repeatedly from each individual in the
21   study over a period of time, yielding a longitudinal time series of concentrations each individual
22   is exposed to.  These studies permit analysis of both the temporal and spatial variability of each
23   person's personal exposure to Os.
24          Some studies are designed so that the data are sampled randomly from the population,
25   which reduces bias and allows one to make inferences about exposure in the broader population.
26   Most studies addressing Os exposure have not been random. They might have specific goals for
27   which randomness is not required, or be subject to constraints which do not allow for random
28   sampling.  Some studies draw upon data from existing measurement systems or historical data
29   collection efforts. These non-random studies can be very helpful in the development of models
30   of exposure; however, their use must recognize that they may not be.representative of the
31   broader population.
32          The draft CD summarizes results from several personal exposure studies that measured
33   Os conducted in the U.S., Canada, and France (draft CD, p.  3-60 to  3-61, Appendix AX3, p. 185-
34   189).
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 1          4.2.4    Microenvironmental Studies
 2          The focus of microenvironmental studies is on measuring concentrations in different
 3    locations that people spend time in, as well as on measuring the movement of pollutants from
 4    one microenvironment to another and on measuring other parameters that contribute to
 5    variability in exposure.  Typically, microenvironmental measurements include indoor and
 6    outdoor concentrations of Os and other pollutants, air exchange rates, infiltration factors,
 7    deposition rates, decay rates, emissions of Oa, NOX, VOCs, and other pollutants, operating
 8    characteristics of air conditioning systems, and meteorological data such as wind velocity,
 9    temperature, and humidity. The draft CD discusses several studies of microenvironments that
10    contribute to our understanding of the factors and processes that affect exposure to Os (draft CD
11    Appendix AX3, p. 190-216).
12          There is a great deal of variability among individuals in the amount of time spent indoors,
13    but the majority of people spend most of their time indoors (Graham & McCurdy, 2004), and
14    therefore the concentrations of Os indoors can be an important determinant of people's exposure
15    to Os. There are several factors affecting Os concentrations indoors.  The ambient outdoor
16    concentration of Os and the air exchange rate are the primary determinants of the indoor
17    concentrations. Removal processes are also significant, the most important of which is
18    deposition onto indoor surfaces such  as carpets, furnishings, and ventilation ductwork.  Chemical
19    reactions of 63 with other compounds, such as solvents from consumer products or NOX
20    emissions from gas stoves, also deplete Os indoors.
21          There are very few sources of O3 indoors. The draft CD  reports on 63 emissions from
22 '   photocopiers and from home/office Os generators.  Some older photocopiers, if run continuously
23    in an enclosed area, can increase O3 concentrations by as much as 20 ppb.  Ozone generators can
24    increase indoor concentrations by more than 200 ppb.

25    4.3   EXPOSURE MODELING

26          Models of human exposure to airborne pollutants are typically driven by estimates of
27    ambient outdoor concentrations of the pollutants, which vary by time of day as  well as by
28    location. These concentration estimates may be provided by measurements, by air quality
                                                                       j
29    models, or by a combination of these. It is only possible to address hypothetical future scenarios
30    using modeling. The main purpose of this exposure analysis is to allow comparisons of
31    population exposures to Os within each urban area, associated with current air quality levels and
32    with alternative air quality standards  or scenarios. Human exposure, regardless of the pollutant,.
33    depends on where an individual is located and what they are doing. Exposure models are useful
34    in realistically estimating personal air concentrations and intake  dose based on activity-specific
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 1    ventilation rates, particularly when recognizing that these measurements cannot be performed for
 2    a given population. This section provides a brief overview of the model used by EPA staff to
 3    estimate Os population exposure.  Details about the application of the model to estimate Os
 4    population exposure are provided in sections 4.4 and 4.5 and in the draft Exposure Analysis
 5    TSD.

 6          4.3.1    The APEX Model
 7          The EPA has developed the APEX model for estimating human population exposure to
 8    criteria and air toxic pollutants.  APEX also serves as the human inhalation exposure model'
 9    within the Total Risk Integrated Methodology (TRIM) framework (Richmond et al., 2002; EPA
10    2005c). APEX is conceptually based on the probabilistic NAAQS Exposure Model (pNEM) that
11    was used in the last O3 NAAQS review (Johnson et al., 1996a, 1996b, 1996c).  Since that time
12    the model has been restructured, improved, and expanded to reflect conceptual advances in the
13    science of exposure modeling and newer input data needed for the model.  Key improvements to
14    algorithms include replacement of the cohort approach with a probabilistic sampling approach
15    focused on individuals, accounting for fatigue and oxygen debt after exercise in the calculation
16    of ventilation rates, and anew approach for construction of longitudinal activity patterns for
17    simulated persons. Major improvements to data input to the model include air exchange rates
18    and the people's daily activities database. These improvements are described later in this
19    chapter.
20          APEX simulates the movement of individuals through time and space and their exposure
21    to a given pollutant in indoor, outdoor, and in-vehicle microenvironments. Figure 4-1 provides a
22    schematic overview of the APEX model. The model stochastically generates simulated
23    individuals using census-derived probability distributions for demographic characteristics
24    (Figure 4-1, steps 1-3). The population demographics are drawn from the year 2000 Census at
25    the tract level, and a national commuting database based on 2000 census data provides home-to-
26    work commuting flows between tracts.J Any number of simulated individuals can be modeled,
27    and collectively they approximate a random sampling of people residing in a particular study
28    area
29          Daily activity patterns for individuals in a study area, an input to APEX, are obtained
30    from detailed diaries that are compiled in the Consolidated Human Activity Database (CHAD)
31    (McCurdy et al., 2000; EPA, 2002).  The diaries are used to construct a sequence of activity
32    events for simulated individuals consistent with their demographic characteristics, day type, and
33    season of the year, as defined by ambient temperature regimes (Graham & McCurdy, 2004)
     1 There are approximately 65,400 census tracts in the ~3,200 counties in the U.S. „

     November 2005                           4-6               Draft - Do Not Quote or Cite

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 1    (Figure 4-1, step 4). APEX calculates the concentration in the microenvironment associated with
 2    each event in an individual's activity pattern and sums the event-specific exposures within each
 3    hour to obtain a continuous series of hourly exposures spanning the time period of interest
 4    (Figure 4-1, steps 5,6).
 5          APEX has a flexible approach for modeling microenvironmental concentrations, where
 6    the user can define the microenvironments to be modeled and their characteristics.  Typical
 7    indoor microenvironments include residences, schools and offices. Outdoor microenvironments
 8    might include near roadways, at bus stops, and playgrounds. Inside cars, trucks, and mass transit
 9    vehicles are microenvironments which are classified separately from indoors and outdoors.
10          Activity-specific simulated breathing rates of individuals are used in APEX to
11    characterize intake dose received from an exposure.  These breathing, or ventilation, rates are
12    derived from energy expenditure estimates for each activity included in CHAD and are adjusted
13    for age- and gender-specific physiological parameters associated with each simulated individual.
14    Energy expenditure estimates themselves are derived from METS (metabolic equivalents  of
15    work) distributions associated with every activity in CHAD (McCurdy et al., 2000), largely
16    based upon the Ainsworth et al. (1993) "Compendium of Physical Activities." METS are a
17    dimensionless ratio of the activity-specific energy expenditure rate to the basal or resting energy
18    expenditure rate, and the metric is used by exercise physiologists and clinical nutritionists to
19    estimate work undertaken by individuals as they go through their daily life (Montoye et al.,
20    1996). This approach is discussed more thoroughly in McCurdy (2000).

21          4.3.2    Key Algorithms
22          Ozone concentrations in each microenvironment are estimated using either a mass-
23    balance or transfer factors approach, and the user specifies probability distributions for the
24    parameters that are used in the microenvironment model  (e.g., indoor-outdoor air exchange
25    rates). These distributions can depend on the values of other variables calculated in the model or
26    input to APEX. For example, the distribution of air exchange rates in a home, office, or car can
27    depend on the type of heating and air conditioning present, which are stochastic inputs to the
28    model, as well as the ambient temperature.  The user can choose to keep the value of a stochastic
29    parameter constant for the entire simulation (which would be appropriate for the volume of a
30    house), or can specify that a new value shall be drawn hourly, daily, or seasonally from specified
31    distributions. APEX also allows the user to specify, diurnal, weekly, or seasonal patterns for
32    various microenvironmental parameters.
      November 2005
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 1          The mass balance method assumes that the air in an enclosed microenvironment is well-
 2    mixed and that the air concentration is fairly spatially uniform at a given time within the
 3    microenvironment. The following four processes are modeled to predict the concentration of an
 4    air pollutant in such a microenvironment:
 5         •  Inflow of air into the microenvironment;

 6         •  Outflow of air from the microenvironment;

 7         •  Removal of a pollutant from the microenvironment due to deposition, filtration, and
 8            chemical degradation; and

 9         •  Emissions from sources of a pollutant inside the microenvironment.
10          The transfer factors model is simpler than the mass balance model, however, still most
11    parameters are derived from distributions rather than single values, to account for observed
12    variability. It does not calculate concentration in a microenvironment from the concentration in
13    the previous hour and it has only two parameters, a proximity factor, used to account for
14    proximity of the microenvironment to sources or sinks of pollution, or other systematic
15    differences between concentrations just outside the microenvironment and the ambient
16    concentrations (at the measurements site), and a penetration factor, which quantifies the degree
17    to which Ihe outdoor  air penetrates into the microenvironment and is essentially the ratio of the
18    concentration in the microenvironment to the outdoor concentration.
19          Regardless of the method used to estimate the microenvironmental concentrations, APEX
20    calculates a time series of exposure concentrations that a simulated individual experiences during
21    the modeled time period. APEX estimates the exposure using the concentrations calculated for
22    each microenvironment and the time spent in each of a sequence of microenvironments visited
23    according to the "activity diary" of each individual. The hourly average exposures of each
24    simulated individual are time-weighted averages of the within-hour exposures. From hourly
25    exposures, APEX calculates the time series of 8-hr and daily average exposure concentrations
26    that simulated individuals experience during the simulation period.  APEX then statistically
27    summarizes and tabulates the hourly, 8-hr, and daily exposures.

28          4.3.3    Model Output
29          There are several useful indicators of exposure and intake dose rate of people to O3 air
30    pollution. Factors that are important include the magnitude and duration of exposure, frequency
31    of repeated high exposures, and the breathing rate of individuals at the time of exposure.  In this
32    analysis, exposure indicators include daily maximum 1-hr and 8-hr average Oa exposures,
33    stratified by a measure of the level of exertion at the times of exposure. The level  of exertion of
34    individuals engaged in particular activities is measured by an equivalent ventilation rate (EVR),

      November 2005                           4-11              Draft - Do Not Quote or Cite

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 1   ventilation normalized by body surface area, which is calculated as Ve/BSA, where Ve is the
 2   ventilation rate "and BSA is the body surface area of the individual. Table 4-1 lists the ranges of
 3   EVR corresponding to "moderate" and "heavy" levels of exertion.                   .
 4

 5   Table 4-1. Exertion Levels in Terms of Equivalent Ventilation Rates (liters/min-mZ)

                   Averaging time      Moderate exertion   Heavy exertion
                         Ihour             16-30 EVR           > 30 EVR
                          8-hr              13-27 EVR           > 27 EVR
 6                 from Whitfield et al, 1996, page 15.
 7
 8          APEX calculates two general types of exposure estimates:  counts of the estimated
 9   number of people exposed to a specified Oa concentration level and the number of times per Os
10   season2 mat they are so exposed; the latter metric is in terms of "person-occurrences." The
11.  former highlights the number of individuals exposed one or more times per 63 season to the
12   exposure indicator of interest. In the case where the exposure indicator is a benchmark
13   concentration level, the model estimates the number of people who are expected to experience
14   that level of air pollution, or higher, at least once during the modeled period. The person-
15   occurrences measure estimates the number of times per season that individuals are exposed to the
16   exposure indicator of interest and then accumulates these estimates for the entire population
17   residing in an area.  The latter metric conflates people and occurrences: one occurrence for each
18   of 10 people is counted the same as 10 occurrences for one person.
19          APEX tabulates and displays the two measures for exposures above levels ranging from 0
20   to 0.16 ppm by 0,01 ppm increments,  where the exposures are:
21       •  Daily maximum 1-hr average exposures
22       •  Daily maximum 8-hr average exposures
23       •  Daily average exposures.
24   These results are tabulated for the following population groups:
25       •  All ages and activity levels
26       •  Children at all activity levels
27       •  Active people of all ages
28       •  Active children.
29   Separate output tables are produced for different levels of exertion concomitant with the
30   exposures:
     2 For purposes of the current exposure analysis, the Oj season was defined as a fixed period from April 1 through
     September 30 for all urban areas included in the analysis.

     November 2005                           4-12              Draft - Do Not Quote or Cite

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 1         «A11 exertion levels

 2         •  Moderate exertion levels
 3         •  Heavy exertion levels.
 4
 5   APEX also produces tables of the time spent in different microenvironments, stratified by
 6   exposure levels.

 7          4.3.4   Limitations of the Model
 8          APEX has a strong scientific foundation and incorporates several significant algorithmic
 9   improvements and updates to input data since its predecessor pNEM was used in the last review.
10   However, significant uncertainties in the predictions of APEX remain.  In this section we discuss
11   qualitatively some of the limitations of this application of APEX to model population exposures
12   to Os pollution. A quantitative uncertainty analysis will be presented in the next draft of this
13   Staff Paper, which will address the impacts of these limitations.
14          We divide our discussion of the limitations of APEX into four areas: estimation of
15   ambient air quality,  estimati on of concentrations in microenvironments, characterization of
16   population demographics and activity  patterns,  and modeling physiological processes. In
17   general, limitations and uncertainties result from variability not modeled or modeled incorrectly,
18   erroneous or uncertain inputs, errors in coding,  simplifications of physical, chemical, and
19   biological processes to form the conceptual model, and flaws in the conceptual model. We
20   restrict the discussion here to limitations of the  modeling of variability and the quality of input
21   data

22             4.3.4.1  Estimation of Ambient Air Quality
23          For estimating ambient Os concentrations to use in the exposure model, the urban areas
24   modeled have several monitors measuring hourly Os  concentrations. The primary uncertainties
25   in the air quality data input to the model result from errors in estimating concentrations at   ,
26   locations which are not close to monitoring sites (spatial interpolation) and from the estimation
27   of missing data. Concentrations of Oj near roadways are particularly difficult to estimate due to
28   tfie rapid reaction of 03 with N02 emitted from motor vehicles.
29          If a single Os season is modeled, another source of uncertainty results from the year-to-
30   year variability of CH concentrations.  We have modeled the year 2004, the most recent year with
31   air quality and meteorological data. For most of the 12 areas modeled,  Oa concentrations were
32   lower than previous years, due to  a combination of reduced emissions of precursors and weather
33   patterns less conducive to the formation of 03.  We plan to also model the year 2002 as part of an
     November 2005                           4-13               Draft - Do Not Quote or Cite

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 1   analysis of the sensitivity of the exposure modeling results to year-to-year variability of air
 2   quality and meteorology, and present these results in the next draft Staff Paper.
 3          Modeling exposures for an unspecified future year simulated to just meet alternative air
 4   quality standards has, in addition to the uncertainties involved with modeling historical
 5   scenarios, Ihe uncertainties of the complex process of projecting to future years air quality,
 6   population demographics, activity patterns, and other changing parameters. For the purpose of
 7   estimating population exposure as an input to decisions about the appropriate level of a NAAQS,
 8   EPA has historically not incorporated any projections in population demographics, activity
 9   patterns, or other factors (e.g., air conditioning use, changes in housing types, etc). This allows
10   policy makers to focus on the impact of changing the allowed air quality distribution on
11   population exposure and public health while avoiding the additional uncertainties that inclusion
12   of these other factors would introduce.
13             4.3.4.2 Estimation of Concentrations in Indoor Microenvironments
14          The importance of estimation of concentrations in indoor microenvironments (homes,
15   offices, schools, restaurants, vehicles, etc.) is underscored by the finding that personal exposure
16   measurements of O$ are often not well-correlated with ambient measurements (draft CD, pages
17   3-59 to 3-61).  However, in some cases, particularly where air exchange rates are high, indoor Oa.
18   concentrations generally closely track outdoor Os concentrations (draft CD, Appendix AX3,
19   page 175).
20          The niicroenvironmental characteristics used to model the concentrations in
21   microenvironments tend to be highly variable, both between microenvironments (e.g., different
22   houses have varying characteristics) and within microenvironments (e.g., the characteristics of a
23   given house can vary over time).  Since APEX is a probabilistic model, if data accurately
24   characterizing this  variability could be provided to the model, such variability would not result in
25   uncertainties. However, input data are always a limiting factor. Even if we can accurately
26   characterize the distributions of each individual microenvironmental parameter, we still need to
27   account for the relationships between the different parameters, as well as the relationships
28   between the microenvironmental parameters, human activities, physiology, and other
29   components of the  exposure model.
                                                                              /-
30             43.4.2.1  Air Exchange Processes
31          The AER is the single most important factor in determining the ratio  of outdoor to indoor
32   concentrations of 63. AERs are highly variable, both within a microenvironment over time and
33   between microenvironments of the same type. AERs depend on the physical characteristics of a
34   microenvironment  and also on the behavior of the occupants of the microenvironment. There is
35   also some dependence on the atmospheric conditions. APEX uses probabilistic distributions of

     November 2005                          4-14              Draft - Do Not Quote or Cite

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 1   AERs which were derived from seven measurement studies in a number of locations, thought to
 2   be sufficient to adequately characterize AERs for this analysis (see Appendix A of the draft
 3   Exposure Analysis TSD),
 4             4.3.4.2.2   Deposition Processes
 5          The rate of deposition of Os to a surface depends on the material the surface is made of,
 6   the humidity, and the concentration of 63. The rate of removal of Os from a microenvironment
 7   depends on the dimensions, the ratio of surface area to volume, surface coverings, and
 8   furnishings in the microenvironment. This is modeled in APEX by a distribution of decay rates
 9   based on a study which measured decay rates in 26 homes in Southern California (Lee et al.5
10   1999). Although we do not expect inter-city differences in decay rates to be more important than
11   differences between homes within cities, there is some uncertainty associated with the small
12   sample size of this study. We do not expect this to be a major contributor to the uncertainty of
13   the modeling results.
14             4.3.4.2.3   Chemical Reaction Processes
15          Ozone reacts with a number of indoor pollutants, such as NOX from gas stoves and VOCs
16   from consumer products. However, Os reacts slowly with most indoor pollutants, and this is a
17   minor removal process compared to air exchange and surface removal (Weschler, 2000). Thus
18   the lack of a better treatment of indoor air chemistry is not considered to be a significant
19   limitation of APEX for modeling Os.

20             4.3.4.3 Characterization of Population Demographics and Activity Patterns
21          In addition to the uncertainty inherent in the human activity data input to APEX, there are
22   a number of population characteristics or attributes that contribute to the variability of exposures
23   which are modeled in APEX, but for which the assignment to simulated individuals is not
24   entirely reflective of real people:

25       •  Occupational category
26       •  Longitudinal stability in occupation, exercise levels, and leisure activities
27       •  Geographical locations of activities away from the home
28       •  The specific microenvironments visited away from home
29       •  Representativeness of CHAD diaries (numbers of diaries used (20,000 used to represent
30          several million people over long periods of time), age of diaries (some are more than 20
31          years old), diary structure differences, etc.)
32
     November 2005                           4-15              Draft - Do Not Quote or Cite

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 1          In addition, the extent to which the human activity database provides a balanced
 2   representation of the population being modeled is likely to vary across areas.  Although the
 3   algorithm (hat constructs activity sequences accounts to some extent for the effects of population
 4   demographics and local climate on activity, this adjustment procedure is unlikely to fully account
 5   for all intercity differences in people's activities. Activity patterns are likely to be affected by
 6   many local factors, including topography, land use, traffic patterns, mass transit systems, and
 7   recreational opportunities.

 8            43.4.4 Modeling Physiological Processes
 9          The modeling of physiological processes that are relevant to the exposure and dose of 63
10   is a complicated endeavor. APEX currently has a physiological model for ventilation rates,
11   which is the primary driver of dose of Os. The limitations of this model have not yet been
12   characterized.                                     •
13
14   4.4    SCOPE OF EXPOSURE ASSESSMENT

15          4.4.1    Selection of Urban Areas to be Modeled
16          The selection of urban areas to include in the exposure analysis takes into consideration
17   the location of Os epidemiologic studies, the availability of ambient 03 data, and the desire to
18   represent a range of geographic areas, population demographics, and Os climatology. These
19   selection criteria are discussed further in Chapter 5.  Based on these criteria, staff chose the 12
20   urban areas listed in Table 4-2 to develop population exposure estimates.  The geographic extent
21   of each modeled area consists of the census tracts in the combined statistical area (CS A) as
22   defined by OMB (OMB, 2005).
23          4.4.2    Time Periods Modeled
24          The exposure period modeled is from April 1 through September 30 for the most recent
25   year. This period encompasses all or most of the O3 season in 9 of the 12 urban study areas
26   when high ambient Os levels are most likely to occur, and for which routine hourly Os
27   monitoring data are available. For three of the study areas (Houston, Los Angeles, and
28   Sacramento) the Os season is the entire year, but the current exposure analysis only includes the
29   six month period from April through September. The geographic scope and time period modeled
30   are summarized in  Table 4-2.
31
32
33
     November 2005                          4-16               Draft - Do Not Quote or Cite

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 1   Table 4-2. Urban Areas and Time Periods Modeled
     Urban Area (CSA)                                  Period modeled
     Atlanta-Sandy Springs-Gainesville, GA-AL             April 1 to Sept. 30
     Boston-Worcester-Manchester, MA-NH                April 1 to Sept 30
     Chicago-Naperville-Michigan City, IL-IN-WI           April 1 to Sept 30
     Cleveland-Akron-Elyria, OH                          April 1 to Sept. 30
     Detroit-Warren-Flint, MI                             April 1 to Sept. 30
     Houston-Baytown-Huntsville, TX                     April 1 to Sept 30
     Los Angeles-Long Beach-Riverside, CA                April 1 to Sept 30
     New York-Newark-Bridgeport, NY-NJ-CT-PA          April 1 to Sept. 30
     Philadelphia-Camden-Vineland, PA-NJ-DE-MD         April 1 to Sept. 30
     Sacramento-Arden-Arcade-Truckee, CA-NV           April 1 to Sept. 30
     St. Louis-St Charles-Farmington, MO-IL               April 1 to Sept 30
     Washington-Baltimore-N. Virginia, DC-MD-VA-WV    April 1 to Sept. 30
 3          4.4.3    Populations Modeled
 4          Exposure modeling is conducted for the general population residing in each area
 5   modeled, as well as for school-age children (ages 5 to 18) and active school-age children. Due to
 6   the increased amount of time spent outdoors engaged in relatively high-levels of physical activity
 7   (which increases dose rates), school-age children as a group are particularly at risk for   •
 8   experiencing Os-related health effects. The next draft of this Staff Paper will include exposure
 9   modeling for asthmatic school-age children.
10          Levels of physical activity are categorized by a daily physical activity index (PAI), a time
11   integrated measure of METS (discussed in section 4.3.1 above).  Children are characterized as
12   active if their median daily PAI over the period modeled is greater than 1.75, a level
13   characterized by exercise physiologists as being "moderately active" or "active" (McCurdy,
14   2000).
15          Table 4-3 lists the year 2000 populations of the modeled areas. The 12 modeled areas
16   combined represent 40 percent of the total U.S. urban population (approximately 222 million) in
17   2000.
     November 2005                          4-17              Draft - Do Not Quote or Cite

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 1   Table 4-3. Population Coverage of Modeled Areas
Urban Area (CSA) Modeled Modeled Active
population children children
(thousands) (thousands) (thousands)
Atlanta
Boston
Chicago
Cleveland
Detroit
Houston
Los Angeles
New York
Philadelphia
Sacramento
St. Louis
Washington, DC
Population in all 12 areas
4,548
5,714
9,311
2,945
5,357
4,815
16,349
21,357
5,832
1,930
2,754
7,572
88,484
942
1,098
1,946
582
1,110
1,076
3,594
4,084
1,179
418
572
1,473
18,074
519
529
933
295
553
598
1,951
2,009
609
226
309
759
9,290
 3   4.5    INPUTS TO THE EXPOSURE MODEL
 4          The data inputs to the APEX model are briefly described in this section. A more detailed
 5   description of the development of these data and the derivation of input distributions can be
 6   found in the draft Exposure Analysis TSD.

 7          4.5.1    Population Demographics
 8          APEX takes population characteristics into account to develop accurate representations of
 9   study area demographics. Population counts and employment probabilities by age and gender
10   are used to develop representative profiles of hypothetical individuals for the simulation. Tract-
11   level population counts by age in one-year increments, from birth to 99 years, come from the
12   2000 Census of Population and Housing Summary File 1. Summary File 1 contains the 100-
13   percent data, which is the information compiled from the questions asked of all people and about
14   every housing unit.
15          Employment data from the 2000 Census provide employment probabilities for each
16   gender and specific age groups for every Census tract. The employment age groupings are: 16-
     November 2005
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 1    19, 20-21, 22-24, 25-29, 30-34, 35-44, 45-54, 55-59, 60-613 62-64, 65-69, 70-74, and >75 years
 2    of age. Children under the age of 16 are assigned employment probabilities of zero.

 3          4.5.2    Population Commuting Patterns
 4          To ensure that the people's daily activities are accurately represented within APEX, it is
 5    important to integrate working patterns into the assessment. The APEX commuting data were
 6    originally derived from the 2000 Census and were collected as part of the Census Transportation
 7    Planning Package (CTPP). CTPP contains tabulations by place of residence, place of work, and
 8    the flows between the residence and work. These data are available from the U.S.  Department of
 9    Transportation, Bureau of Transportation Statistics (U.S. Department of Transportation and U.S.
10    Census Bureau, 2000).
11          It was assumed that all persons with home-to-work distances up to 120 km are daily
12    commuters, and that persons who travel further than 120 km do not commute daily. Therefore
13    the list of commuting destinations for each home tract is restricted to only those work tracts that
14    are within 120 km of the home tract.
15          APEX allows the user to specify how to handle individuals who commute to destinations
16    outside the study area. One option is to drop them from the simulation. If they are included, the
17    user specifies values for two additional parameters, called LU and LA (Multiplicative and
18    Additive factors for commuters who Leave the area). While a commuter is at work, if the
19    workplace is outside the study area, then the ambient concentration cannot be determined from
                              "  ;
20    any air district (since districts are inside the study area). Instead, it is assumed to be related to
21    the average concentration  CAVB(() over all air districts at the time in question.  The ambient
22    concentration outside the study area at time t, Cour(f), is estimated as:

23          COUT(0 = LM * CAVE (0 + LA                                              (4-2)
24          The microenvironmental concentration (for example, in an office outside the study, area)
25    is determined from this ambient concentration by the same model (mass balance or factor) as
26    applies inside the study area.  The parameters LM and LA were both' set to zero for this modeling
27    analysis; thus, exposures to individuals are set to zero when they are outside of the study area,
28    This was done since we have not estimated ambient concentrations of Oa in counties outside of
29    the modeled areas.

30          4.5.3    Human Activity Data
31          The human activity data are drawn from the Consolidated Human Activity  Database
32    (CHAD) (McCurdy et al.,  2000; EPA, 2002), developed and maintained by the Office of
33    Research and Development's (ORD) National Exposure Research Laboratory (NERL). The
34    CHAD includes data from several surveys covering specific time periods at city, state, and

      November 2005                           4-19              Draft - Do Not Quote or Cite

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 1    national levels, with varying degrees of representativeness. Table 4-4 summarizes the studies in
 2    the version of CHAD used in this modeling analysis.
 3          A key issue in this assessment is Hie development of an approach for creating (Vseason
 4    or year-long activity sequences for individuals based on a cross-sectional activity data base that
 5    includes 24-hr records. The average subject in the time/activity studies in CHAD provided less
 6    than two days of diary data.  For this reason, the construction of a season-long activity sequence
 7    for each individual requires some combination of repeating data from one subject and using data
 8    from multiple subjects. An appropriate approach should adequately account for the day-to-day
 9    and week-to-week repetition of activities common to individuals while maintaining realistic
10    variability between individuals. The method in APEX for creating longitudinal diaries which
11    reflect the tendency of individuals to repeat activities is based on reproducing realistic variation
12    in a key diary variable, which is a user-selected function of diary variables. For this analysis the
13    key variable is set to the amount of time an individual spends outdoors each day.
14          The  actual diary construction method targets two statistics, a diversity statistic (£>) and an
15    autocorrelation statistic (A).  The D statistic reflects the relative importance of within-person
16    variance and between-person variance in the key variable. The A statistic quantifies the lag-one
17    (day-to-day) key variable autocorrelation. Desired D and A values for the key variable are
18    selected by the user and set in the APEX  parameters file, and the method algorithm construct
19    longitudinal diaries that preserve these parameters.  Longitudinal diary data from a field study of
20    school-age children (Geyh et al., 2000) and subsequent analyses (Xue et al., 2004) suggest thatD
21    and ./Tare stable over time (and perhaps over cohorts as well). Based on these studies,
22    appropriate  target values for the two statistics for outdoor time for children are determined to be
23    0.22 for D and 0.19 for A. In the absence of data for estimating these statistics for younger
24    children and for adults, these values are also used for adults. This method for constructing
25    longitudinal diaries from the CHAD data is described in detail in Appendix C of the Exposure
26    Analysis TSD.

27          4.5.4    Physiological Data
28          APEX requires values for various physiological parameters for subjects in order to
29    accurately model their pollutant intake via metabolic processes.  This is because physiological
30    differences may cause people with the same exposure and activity scenarios to have different
31    pollutant intake levels.  The physiological parameters file distributed with APEX contains
32    physiological data or distributions by age and gender for maximum ventilatory capacity (in terms
33    of age- and gender-specific maximum oxygen consumption potential), body mass, resting
34    metabolic rate, and oxygen consumption-to-ventilation rate relationships.
     November 2005
4-20
Draft -Do Not Quote or Cite

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 1          4,5.5    Microenvironments Modeled
 2          In APEX, microenvironments provide the exposure locations for modeled individuals.
 3    For exposures to be measured accurately, it is important to have realistic microenvironments that
 4    are matched closely to what actual people experience on a daily basis. As discussed in section
 5    4.3.2 above, the two methods available in APEX for calculating pollutant concentrations within
 6    microenvironments are a mass balance model and a transfer factor approach. Table 4-5 lists the
 7    12 microenvironments selected for this analysis and the exposure calculation method for each. .
 8    The parameters used in mis analysis for modeling these microenvironments are described in
 9    Appendix 4A.

10    Table 4-5.  Microenvironments Modeled
11

12
13
14
15
16
17
18
19
20
Microenvironment
Indoors - Residence
Indoors - Bars and restaurants
Indoors - Schools
Indoors - Day -care centers
Indoors - Office
Indoors - Shopping
Indoors - Other
Outdoors - Near road
Outdoors - Public garage/parking lot
Outdoors - Other
In-vehicle - Cars and Trucks
Calculation Method
Mass balance
Mass balance
Mass balance
Mass balance
Mass balance
Mass balance
Mass balance
Factors
Factors
Factors
Factors
Parameters1
AER and DE
AER and DE
AER and DE
AER and DE
AER and DE
AER and DE
AER and DE
PR
PR
None
PE and PR
    1 A£R=air exchange rate, DE=decay-deposition rate, PR=proximity factor, PE=penetration factor

       4.5.6    Ambient Ozone Concentrations
       APEX requires hourly ambient Os concentrations at a set of locations in the study area.
Data from the EPA AIRS Air Quality Subsystem were used to prepare the ambient air quality
input files, using the most recent year (2004) of Os measurements.  The hourly Os concentrations
at the AIRS sites in each CS A were interpolated to a 20 by 20 km rectangular grid covering the •
CS A using a simple inverse squared-distance weighted average for each hour.  Grid locations
further than 75 km from the closest Os monitor were dropped. The hourly gridded and site
concentrations were used as input to APEX to represent the ambient concentrations within each
urban area.  For near road and parking garage microenvironments the ambient concentrations are
     November 2005
                                           4-23
Draft - Do Not Quote or Cite

-------
 1   adjusted by a proximity factor. An analysis of the interpolation errors and uncertainty of the 63
 2   concentrations input to APEX will be presented in the next draft Staff Paper.
 3          In addition to modeling exposures based on 2004 air quality, an analysis was conducted
 4   using air quality representative of just meeting the current 8-hr Os NAAQS of 0.08 ppm. This
 5   was done using a quadratic rollback approach to adjust the hourly 63 concentrations observed in •
 6   2002-2004 to yield a design value of 0.084 ppm (based on rounding conventions, concentrations
 7   at or below 0.084 ppm are considered to meet the standard).  Design values for the 8-hr Os
 8   NAAQS  are calculated as the 3-year averages of the annual 4th daily maximum 8-hr average
 9   concentration based on the maximum monitor within an urban area and are given in Table 4-6
10   for the 2002-2004 period. The quadratic rollback technique combines both linear and quadratic
11   elements to reduce higher concentrations more than lower concentrations near ambient
12   background levels.  The quadratic rollback adjustment procedure was considered in a sensitivity
13   analysis during the last review of the Oj NAAQS and has been shown to be more realistic than
14   the linear proportional rollback method, where all  of the ambient measurements are reduced by a
15   constant multiplicative factor regardless of their individual magnitudes. The rollback approach
16   and evaluation of this approach are described by Johnson (1997), Duff, Horst, and Johnson
17   (1998), and Rizzo (2005).

18   Table 4-6. 2002-2004 8-Hour Ozone Design Values for die Modeled Areas
     Urban Area (CSA)
2002-2004 design   Ratio of 0.084 to
     value (ppm)   the design value
19
Atlanta
Boston
Chicago
Cleveland
Detroit
Houston
Los Angeles
New York
Philadelphia
Sacramento
St. Louis ,
Washington, DC
0.093
0.091
0.094
0.095 1 .
0.092
0.101
0.127
0.094
0.094
0.102
0.089
0.089
0.90
0.92
0.89
0.88
0.91
0.83
0.66
0.89
0.89
0.82
0.94
0.94
     November 2005
                4-24
Draft - Do Not Quote or Cite

-------
 1          The observed concentrations and the concentrations representative of just meeting the
 2   current standard are summarized (for 2004 only) in figures in Appendix 4B in terms of the
 3   frequencies of daily maximum 8-hr average Os concentrations above different concentration
 4   levels. These figures also illustrate the percent reduction in exceedances of levels from the 2004
 5   base year to when the current standard is just met.

 6          4.5.7    Meteorological Data
 7          Daily average and maximum 1 -hr temperatures are computed from hourly surface
 8   temperature measurements obtained from the National Weather Service. These data are not
 9   spatially interpolated; APEX uses the data from the closest weather station to each Census tract.
10   Temperatures are used in APEX both in selecting human activity data and in estimating air
11   exchange rates for indoor microenvironments, as discussed above.

12   4.6    EXPOSURE ASSESSMENT RESULTS
13
14          The results of the exposure analysis are presented in a series of tables in this section and
15   in graphs in Appendix 4C. The tables summarize exposures to Os concentrations above two
16   specific levels, 0.08 and 0.07 ppm, while the graphs in Appendix 4C depict these results over the
17   entire range of observed concentrations. The 0.08  ppm level corresponds to the lowest exposure
18   level used in the controlled human studies (see section 3.6.1).  The exposure-response
19   relationships based on these studies are extrapolated down to background levels (section 5.3.1),
20   and the 0.07 ppm level was chosen to illustrate the sensitivity of the exposure modeling results to
21   the selected level. The tables summarize two measures of the extent of population exposures
22   over the modeled period (April 1 through September 30):
23         »  numbers of person-days with daily maximum 8-hr average exposures under moderate
24            exertion above 0.08 and 0.07 ppm (Table 4-77 and Table 4-10),
25         •  numbers of persons who experience one or more daily maximum 8-hr average
26            exposures under moderate exertion above 0.08 and 0.07 ppm (Table 4-8 and Table
27            4-111), also expressed as percentages of the population (Table 4-9 and Table 4-22) and
28          Exertion is characterized by equivalent ventilation rates (section 4.3.3). Results are
29   presented for the 2004 base case, "just meeting" the current standard, and the difference between
30   these scenarios (as a percent reduction), for the general population, children (ages 5-18), and for
31   active children. For the tables reporting counts of persons, there are companion tables with the
32   same results expressed as percentages of the population group totals given in Table 4-3.
33          For example,  for Atlanta, Table 4-8 reports an estimated 13.8 thousand active children
34   who experience an 8-hr average exposure above 0.08 ppm under moderate exertion at least once
     November 2005                             4-25             Draft - Do Not Quote or Cite

-------
 1   during the 2004 Oa season. Under the scenario of just meeting the current 8-hr standard, this
 2   number is reduced by 87 percent to 1.8 thousand active children.  These correspond to 2.7 and
 3   0.4 percent respectively (Table 4-9) of the population of active children in Atlanta (519
 4   thousand).
 5          The tables in this section have counts of exposures above a level of 0.08 ppm. Appendix
 6   4C shows graphs of counts of person-days of 8-hr exposures above different levels ranging from
 7   0 to 0.16 ppm, concomitant with moderate exertion, for children ages 5 to 18.
 8          These results indicate a significant reduction in 8-hr average exposures above 0.08 ppm
 9   under attainment of the current 8-hr Os NAAQS.  In addition, under the current standard it is rare
10   for an individual to experience more than one 8-hr exposure above 0.08 ppm, as evidenced by
11   the average number of 8-hr exposures above 0.08 for individuals, which is less than 1.01 for each
12   of the three population groups in these tables (compared to 1.2 for historical 2004 air quality).
     November 2005
4-26
Draft - Do Not Quote or Cite

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Johnson, T., Capel, M. McCoy, and J. Wamasch. (1 996c). Estimation of Ozone Exposures Experienced by
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1 5    McCurdy, T., Glen, G., Smith, L., Lakkadi, Y. (2000). "The National Exposure Research Laboratory's Consolidated
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24         of APEX (3.0): EPA's population exposure model for criteria and air toxic inhalation exposures." Poster
25         presentation.  Joint meeting of the International Society of Exposure Analysis and International Society of
26         Environmental Epidemiology, August 11-15, 2002, Vancouver, Canada,

27    Rizzo, M. (2005). Evaluation of a quadratic approach for adjusting distributions of hourly ozone concentrations to
28         meet air quality standards. November 7, 2005.

29    Robinson, J. P., Wiley, J. A., Piazza, T., Garrett, K., and Cirksena, K. (1 989). Activity patterns of California
30         residents and their implications for potential exposure to pollution. California Air Resources Board (CARB-
31        . A6-177-33), Sacramento, CA.

32    Spier, C. E.; Little, D. E.; Trim, S.  C.; Johnson, T. R.; Linn, W. S.; Hackney, J. D. (1992). Activity patterns in
33         elementary and high school students exposed to oxidant pollution. J. Exposure Anal. Environ. Epidemiol. 2:
34         277-293.         .

35    Tsang A. M. and N. E. Klepeis (1 996). Descriptive Statistics Tables from a Detailed Analysis of the National
36         Human Activity Pattern Survey rNHAPS~) Data. U.S. Environmental Protection Agency (EPA/600/R-
37         96/148).

38    U.S. Department of Transportation and U.S. Census Bureau (2000). Census of Population and Housing, 2000 long-
39         form (sample) data, Census Transportation Planning Package (CTPP) 2000. Available at:
40         http://transtats.bts.gov/.

41    U.S..Environmental Protection Agency (1986). Air Quality Criteria for Ozone and Other Photochemical Oxidants.
42         EPA-600/8-84-020aF-eF. Office of Health and Environmental Assessment, Environmental Criteria and
43         Assessment Office, U.S. Environmental Protection Agency, Research Triangle Park, NC. Available from:
44         NTIS, Springfield, VA; PB87-142949.
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 1    U.S. Environmental Protection Agency (1996a).  Review of National Ambient Air Quality Standards for Ozone:
 2          Assessment of Scientific and Technical Information - OAQPS Staff Paper.  EPA/452/R-96-007. Office of
 3          Air Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC.
 4          Available at:  http://www.epa.gov/itrt/naaqs/siandards/ozone/s o3 pr sp.html

 5    U.S. Environmental Protection Agency (1996b).  Air Quality Criteria for Ozone and Related Photochemical
 6          Oxidanis! EPA/600/P-93/004aF-cF. Office of Research and Development, National Center for
 7          Environmental Assessment, U.S. Environmental Protection Agency, Research Triangle Park, NC. Available
 8          at: http://cfpub.epa.gov/ncea/ciin/recordispluv.crm7deid~2831.

 9    U.S. Environmental Protection Agency (2002). Consolidated Human Activities Database (CHAD) Users Guide.
10          The database and documentation are available electronically on the internet at: h^//ww.epa.gov/chadnetl/.

II    U.S. Environmental Protection Agency (2005a).  Ozone Population Exposure'Analysis for Selected Urban Areas
12          (draft).  Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, Research
13          Triangle Park, NC. November.  Available electronically on the internet at:
14          http://\vww.epa.gov/(tn/naiiqs/'s(3ndards/ozone/s_o3 cr_td.html.

15    U.S. Environmental Protection Agency (2005b).  Air Quality Criteria for Ozone and Other Related Photochemical
16          Oxidants. Second External Review Draft. National Center for Environmental Assessment, U.S.
17          Environmental Protection Agency, Research Triangle Park, NC.  Available electronically on the internet at:
18          http://cfpxib.epa.gov/ncea/cfm/recordisplav.crni7deid~137307

19    U. S. Environmental Protection Agency (2005c).  Total Risk Integrated Methodology (TRIM) - Air Pollutants
20          Exposure Model Documentation (TRIM-Expo / APEX, Version 4) Volume I: User's Guide. Office of Air
21          Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC.
22      .    November 2005. Available at: htta://www.e»a.aov.''tJn/fCTa/human apex .him!.

23    Weschler, C. J. (2000) Ozone in indoor environments: concentration and chemistry. Indoor Air 10: 269-288.

24    Whitfield, R., Biller, W,, Jusko, M., and Keisler, J. (1996). A Probabilistic Assessment of Health Risks Associated
25          with Short- and Long-Term Exposure to Tropospheric Ozone. Argonne National Laboratory, Argonne, IL.

26    Wiley, J. A.; Robinson, J. P.; Piazza, T., Garrett, K.; Cirksena, K.; Cheng, Y.-T.; Martin, G. (1991a). Activity
27          patterns of California residents. Final report. Sacramento, CA: California Air Resources Board; report no.
28          ARB/R93/487. Available from: NTIS, Springfield, VA.; PB94-108719.

29    Wiley, J. A.; Robinson, J. P.; Cheng, Y.-T.; Piazza, T.; Stork, L.; Pladsen, K.  (1991b).  Study of children's activity
30          patterns: final report. Sacramento, CA: California Air Resources Board; report no. ARB-R-93/489.

31    Williams, R., Suggs, J., Creason, J., Rodes, C., Lawless, P., Kwok, R., Zweidinger, R., and Sheldon, L. (2000).  The
32          1998 Baltimore particulate matter epidemiology-exposure study: Part 2. Personal exposure associated with an
33          elderly population. J. Expos. Anal. Environ. Epidemiol.

34    Xue, J., McCurdy, T., Spengler, J., Ozkaynak, H. (2004). Understanding variability in time spent in selected
35          locations for 7-12-year old children. J Expo Anal Environ Epidemiol 14(3):222-33.
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                          5.    CHARACTERIZATION OF HEALTH RISKS
 2    5.1    INTRODUCTION
 3          This chapter presents information regarding the results from an updated ozone (Os) health
 4    risk assessment that builds supon the methodology used in the assessment conducted as part of the
 5    last Os NAAQS review.  This updated assessment includes estimates of (1) risks of lung function
 6    decrements, hospital admissions, and mortality associated with recent ambient Oa levels; and (2)
 7    risk reductions associated with just meeting the current 8-hr Oa NAAQS. The next draft of the
 8    Staff Paper will also include risk reductions associated with just meeting various alternative Os
 9    standards. The current risk assessment is more fully described and presented in a draft technical
10    support document, Ozone Health Risk Assessment for Selected Urban Areas (Abt Associates,
11    2005a; henceforth referred to as the Risk Assessment Technical Support Document and cited as
12    draft Risk Assessment TSD).
13          The goals of this  Os risk assessment are: (1) to provide estimates of the potential
14    magnitude of mortality and morbidity effects associated with current 63 levels, and with meeting
15    the current Os NAAQS and alternative Os standards, in specific urban areas; (2) to develop a
16    better understanding of the influence  of various inputs and assumptions on the risk estimates; and
17    (3) to gain insights into the distribution of risks and patterns of risk reductions associated with
18    meeting alternative Oj standards.  Staff recognizes that while there are many sources of
19    uncertainty and variability inherent in the inputs to this assessment which make the specific
20    estimates uncertain, there is sufficient confidence in the direction and general indications
21    provided by the assessment for the assessment to serve as a useful input to decisions on the
22    adequacy of the 63 standard. While some of these uncertainties have been addressed
23    quantitatively in the form of estimated confidence ranges around central risk estimates, other
24    uncertainties and the variability in key inputs are not reflected in these confidence ranges, but
25    rather are addressed through separate sensitivity analyses or characterized qualitatively.
26          Following this introductory section, this chapter discusses the scope of the risk
27    assessment,  including selection of urban areas and health endpoints; components of the risk
28    model; characterization of uncertainty and variability associated with the risk estimates; and key
29    results from the assessment.  The draft Risk Assessment TSD provides a more detailed
30    discussion of the risk assessment methodology and includes additional risk estimates beyond
31    those summarized herein.

32          5.1.1  Overview of Risk Assessment From Last Review
33          EPA conducted a health risk assessment that produced risk estimates for the number and
34    percent of children and outdoor workers experiencing lung function and respiratory symptoms
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 1   associated with the exposures estimated for 9 urban areas. This portion of the risk assessment
 2   was based on exposure-response relationships developed from analysis of data from several
 3   controlled human exposure studies which was combined with exposure  estimates developed for
 4   children who spent more time outdoors and for outdoor workers. The risk assessment for the last
 5   review also included risk estimates for excess respiratory-related hospital admissions related to
 6   Os concentrations for New York City based on a concentration-response relationship reported in
 7   an epidemiological study (Thurston et al., 1992). Risk estimates for lung function decrements,
 8   respiratory symptoms, and hospital admissions were developed associated with recent air quality
 9   levels (referred to as "as is" air quality) and for just meeting the existing 1-hr standard and
10   several alternative 8-hr standards. The methodological  approach followed in Conducting the last
11   risk assessment and risk estimates resulting from that assessment are described in Chapter 6 of
12   the 1996 Staff Paper (EPA, 1996b) and in several technical reports and publications (Whitfield et
13   al, 1996; Whitfield, 1997; Whitfield et al., 1998).
14          In me 1997 review of the Os NAAQS,' the risk estimates played a significant role in both
15   the staff recommendations and in the proposed and final decisions to revise the 63 standards.
16   CAS AC stated (Wolff, 1995) in its advice and recommendations to the Administrator on the Os
17   Staff Paper that "EPA's risk assessments must play a central role in identifying an appropriate
18   level," while also noting that "because of the myriad of assumptions that are made to estimate
19   population exposure and risk, large uncertainties exist in these estimates." In the 1997
20   promulgation notice (62 FR 38856) announcing the decision to revise the Os standards EPA
21   indicated that the Administrator considered the results of the exposure and risk analyses and key
22   observations and conclusions from these analyses in putting effects considered to be adverse to
23   individuals into a broader public health perspective and in making judgments about the level of a
24   standard that would be requisite to protect public health with an adequate margin of safety.

25          5.1.2  Development of Approach for Current Risk Assessment
26          The health risk assessment described in this Chapter and in the draft Risk Assessment
27   TSD builds upon the methodology and lessons learned from the risk assessment work conducted
28   for the last review.  The current risk assessment also is based on the information evaluated in the
29   second external review draft of the Os CD (EPA, 2005 c).  Some aspects of the current risk
30   assessment may change based on changes that may be incorporated in the final Oj CD. The
31   general approach used in the current risk assessment was described in the draft Health
32   Assessment Plan (EPA, 2005a), that was released to the CASAC and  general public in April
33   2005 for review and comment and which was the subject of a consultation with the CASAC Os
34   Panel on May 5,2005.  The approach used in the current risk assessment reflects consideration
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 1    of the comments offered by CAS AC members and the public on the draft Health Assessment
 2    Plan.
 3          The basic structure of the current risk assessment reflects the two different types of
 4    human studies on which the Os health risk assessment is based: controlled human exposure
 5    studies and epidemiological studies.  Controlled human exposure studies involve volunteer
 6    subjects who are exposed while engaged in different exercise regimens to specified levels of
 7    under controlled conditions for specified amounts of time. For the current health risk
 8    assessment, staff is using probabilistic exposure-response relationships developed during the last
 9    review which were based on analysis of individual data that describe the relationship between a
10    measure of personal exposure to 03 and measures of lung function recorded in the studies. The
11    measure of personal exposure to ambient Os is typically some function of hourly exposures -
12    e.g., 1-hr maximum or 8-hr maximum. Therefore, a risk assessment based on exposure-response
13    relationships derived from controlled human exposure study data requires estimates of personal
14    exposure to Os, typically on a 1 -hr or multi-hour basis.  Because data on personal hourly Os
15    exposures are not available, estimates of personal exposures to varying ambient concentrations
16    are derived through exposure modeling, as described in Chapter 4.
17          In contrast to the exposure-response relationships derived from controlled human
18    exposure studies, epidemiological studies provide estimated concentration-response
19    relationships based on data collected in real world settings. Ambient O3 concentration is
20    typically measured as the average of monitor-specific measurements, using population-oriented
21    monitors. Population health responses for Os have included population counts of.hospital
22    admissions for respiratory and cardiac illness and premature mortality. As described more fully
23    below, a risk assessment based on epidemiological studies typically requires baseline incidence
24    rates and population data for the risk assessment locations.
25          The characteristics that are relevant to carrying out a risk assessment based on controlled
26    human exposure studies versus one based on epidemiology studies can be summarized as
27    follows:
28          •   A risk assessment based on controlled human exposure studies uses exposure-
29              response functions, and therefore requires as input (modeled) personal exposures to
30              ambient Os. A risk assessment based on epidemiological studies uses concentration-
31              response functions, and therefore requires as input (monitored) ambient Os
32              concentrations.
33         •   Epidemiological studies are carried out in specific real world locations (e.g., specific
34            urban areas). To minimize uncertainty, a risk assessment based on epidemiological
35            studies has been performed for the locations in which the studies  were carried out
36            Controlled human exposure studies, carried out in laboratory settings, are generally not
37            specific to any particular real world location.  A controlled human exposure studies-
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 1            based risk assessment can therefore appropriately be carried out for any location for
 2            which there are adequate air quality and other data on which to base the modeling of
 3            personal exposures. There are, therefore, some locations for which a controlled human
 4            exposure studies-based risk assessment could appropriately be carried out but an
 5            epidemiological studies-based risk assessment could not.

 6         •  The adequate modeling of hourly personal exposures associated with ambient
 7            concentrations for use with exposure-response relationships requires more complete
 8            ambient monitoring data than are necessary to estimate average ambient concentrations
 9            used to  calculate risks based on concentration-response relationships.  Therefore, there
10            may be some locations in which an epidemiological studies-based risk assessment
11            could appropriately be carried out but a controlled human exposure studies-based risk
12            assessment could not.
13         •  To derive estimates of risk from concentration-response relationships estimated in
14            epidemiological studies, it is usually necessary to, have estimates of the baseline
15            incidences of the health effects involved. Such baseline incidence estimates are not
16            needed  in a controlled human exposure studies-based risk assessment
17          The scope of the current Os risk assessment is described in the next section along with air
18    quality considerations that are relevant to both parts of the risk assessment. Then, the methods
19    for the two parts of the risk assessment - the part based on controlled human exposure studies
20    and the part based on epidemiological and field studies - are discussed in sections 5.3.1 and 5.3.2
21    below, followed by presentation and discussion of the 03 risk estimates in section 5.4.

22    S.2     SCOPE OF OZONE HEALTH RISK ASSESSMENT
23          The current Oj health risk assessment estimates risks of various health effects associated
24    with exposure to  ambient 63 in a number of urban areas selected to illustrate the public health
25    impacts of this pollutant. The short-term exposure related health endpoints selected for the Os
26    risk assessment, discussed in section 5.2.1, include those for which the draft CD concludes that
27    the weight of the  evidence supports the general conclusion that Os, acting alone and/or in
28    combination with other co-pollutants is likely causal.  The current risk assessment includes risk
29    estimates for 12 urban areas.  The basis for selection of these areas is discussed below (section
30    5.2.2).
31          Another important aspect of the current risk assessment is that the risks estimated are
32    only those associated with ambient 63 concentrations exceeding estimated policy-relevant
33    background levels (hereafter, referred to as "background" in this Chapter).'  Risks associated
34"   with concentrations above this background are judged to be more relevant to policy decisions
      1 Policy relevant background is defined in section 2.7 of this Staff Paper and development of estimates for policy
      relevant background for use in the risk assessment are discussed in section 5.2.3.

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 1    about the NAAQS than estimates that include risks potentially attributable to uncontrollable
 2    background concentrations.

 3          5.2.1   Selection of Health Endpoint Categories
 4          As noted above, in the last review a significant portion of the health risk assessment
 5    involved developing risk estimates for both lung function decrements (> 10, > 15, and > 20%
 6    changes in FEV0 and respiratory symptoms in children (age 6 to 18 years old) who spend more
 7    time-outdoors and outdoor workers with 1 -hr exposures at moderate and heavy exertion and 8-hr
 8    exposures at moderate exertion. As discussed in section 3.3.2.2 and Chapter 6 of the draft CD,
 9    there is a significant body of controlled human exposure studies reporting lung function
10    decrements and respiratory symptoms in adults associated with 1- and 6-8-hr exposures to ozone.
11           Consistent with the approach used in the last review, staff judges that it is reasonable to
12    estimate exposure-response relationships for lung function decrements associated with ozone
13    exposures in children 5-18 years old based on data from adult subjects (18-35 years old). As
14    discussed in the 1996 Staff Paper and 1996 CD, findings from other chamber studies
15    (McDonnell et al., 1985) for children 8-11 years old and summer camp field studies in at least
16    six different locations in the U.S. and Canada found lung function decrements in healthy children
17    similar to those observed in heallhy adults exposed to Os under controlled chamber conditions.
18    The same approach is being used in the current assessment.
19          In the prior risk assessment, staff focused on the risk estimates for lung function
20    decrements associated with 1-hr heavy exertion, 1-hr moderate exertion, and 8-hr moderate
21    exertion exposures in children age 5-18 years of age. Since the 8-hr moderate exertion exposure
22    scenario in children who spend more time outdoors clearly resulted in the greatest health risks in
23    terms of lung function decrements, and since no new information published since the last review
24    suggests any changes that would impact this conclusion, staff has included only the lung function
25    decrements (>10,15, and 20% FEVO associated with 8-hr moderate exertion exposures in
26    children (age 5 to 18 years old) in the current risk assessment.
27          Although respiratory symptoms in healthy children were  estimated in the last review,
28    staff has not included this endpoint in the current quantitative risk assessment This is because
29    several field studies conducted since the last review failed to find respiratory symptoms in field
30    studies examining responses in healthy children.  The draft CD concludes (p. 7-48) that "these
31    studies indicate mat there is no consistent evidence of an association between Os and respiratory
32    symptoms among children."
33          As discussed in section 3.3.2.2, the draft CD also concludes that collectively, the results
34    of field studies suggest that respiratory symptoms and increased medication use in asthmatic
35    children are associated with acute exposure to Os. While these recent studies provide strong
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 1    evidence that some asthmatic children are likely to experience O3-related effects, the selective
 2    recruitment of inner city asthmatic subjects makes it very difficult to develop quantitative risk
 3    estimates for asthmatic children based on these studies.
 4          While a number of controlled human exposure studies have reported additional health
 5    endpoints associated with short-term exposures to Os, including airway hyperresponsiveness,
 6    inflammation, and immune system effects, there is insufficient exposure-response data at
 7    different concentrations to develop quantitative risk estimates for these effects. These additional
 8    effects are discussed in Chapter 3 and it is important-to recognize that the current quantitative
 9    risk assessment only presents a partial picture of the risks to public health associated with short-
10    term Os  exposures.
11          As discussed in the draft CD and Chapter 3, a significant number of epidemiological
12    studies examining a variety of health effects associated with ambient Os concentrations in
13    various locations-throughout the U.S., Canada, Europe, and other regions of the world have been
14    published since the last Oj NAAQS review. Chapter 3 reviews the epidemiological evidence
15    evaluated in Chapter 7 of the draft CD. In selecting health endpoints to be included in the
16    current quantitative risk assessment, staff has focused on health endpoints that are better
17    understood in terms of health consequences (i.e., adversity) and endpoint categories for which
18    the weight of the evidence supports the inference of a likely causal relationship between Os and
19    the effect category. Based on these considerations, the following endpoints associated with
20    short-term exposures to Os have been included:
21         •  Hospital admissions for respiratory and cardiovascular illness;
22         •  Premature total, respiratory, and cardiovascular mortality.
23       As noted in the draft CD (p.7-149), "large multi-city studies, as well as many studies  from
24    individual cities have reported an association of Os concentrations with respiratory and
25    cardiovascular hospital admissions. Studies with data restricted to the summer or warm season,
26    in general indicated positive and robust associations between ambient Os concentrations and
27    cardiopulmonary hospital admissions." With respect to acute Os effects on mortality, the draft
28    CD concludes (p.7-149) that "The majority of the studies suggest an elevated risk of all cause
29    mortality associated with acute exposure to Os, especially in the summer or warm season when
30    Os levels are typically high."
31          As discussed in Chapter 7 of the draft CD and section 3.3.2, several additional health
32    endpoints including emergency department visits for respiratory  illness, increased respiratory
33    symptoms in asthmatic children, and increased school absences have been reported to be
34    associated with short-term Os exposures. The current quantitative risk assessment does not
35    include these additional health endpoints. Emergency department visits were excluded from the

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 3
 4
 5
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 7
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11

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13
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15

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1 9
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21

22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
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quantitative risk assessment because of the limited and less consistent database as well as the
lack of baseline incidence data for emergency department visits, With respect to increased
respiratory symptoms in asthmatic children, the evidence is strong that ambient 63 exposures can
lead to these effects, but the design of these epidemiological studies, which focus on subjects
recruited in inner-city neighborhoods, pose significant problems since there is a lack of baseline
incidence data for this endpoint for asthmatic children residing in urban areas.  Further, the staff
judges that the data reporting an association between short-term 03 exposures and school
absences is too limited to include in the current risk assessment.
       5.2.2   Selection of Study Areas
       The criteria and considerations that went into selection of urban areas for the
assessment included the following:
                                                                               risk
      •  The overall set of urban locations should represent a range of geographic areas, urban
         populations demographics, and climatology and be focused on areas that do not meet
         the current 8-hr O3 NAAQS.

      •  The largest areas with major 63 nonattainment problems should be included.

      •  There must be sufficient air quality data for a recent three year period.

      •  An area should be the same or close to the location where at least one concentration-
         response function for the health endpoints included in the assessment has been
         estimated by a study that satisfies the study selection criteria (see below). If the study
         was a hospital admissions study, then relatively recent location-specific baseline
         incidence data had to be available.

      •  Locations in which more health endpoints have been assessed were preferred to those
         with fewer.

Since the exposure-response functions for lung function decrements based on the controlled
human exposure studies were based on controlled laboratory conditions, the location of these
studies played no role in selecting urban locations for the risk assessment.
       Based on the selection criteria and considerations listed above, the following urban areas
were included in the risk assessment:
       •     Atlanta
       •     Boston
       •     Chicago
       •     Cleveland
       •     Detroit
       •     Houston
       •     Los Angeles
       •     New York City
       *     Philadelphia
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 1           •      Sacramento
 2           •      St. Louis
 3           •      Washington, D.C.
 4
 5           As discussed in Chapter 4, for the purposes of estimating population exposure and the
 6    risk of lung function decrements associated with these population exposure estimates, the 12
 7    urban areas have been defined based on consolidated statistical areas (CSAs). In contrast, for the
 8    risk estimates for premature mortality and excess hospital admissions, the urban areas have been
 9    defined to be generally consistent with the geographic boundaries used in the epidemiological
10    studies which were the source of the concentration-response functions used in this risk
11    assessment. In most cases the epidemiological studies only included the core urban county or a
12    limited number of counties in each of the 12 urban areas.

13           5.2.3   Air Quality Considerations
14          Both the controlled human exposure and epidemiolgic-based portions of the risk
                                              i
15    assessment include risk estimates for a recent year of air quality (labeled "as is" air quality in the
16    draft Risk Assessment TSD) and for air quality adjusted so that it simulates just meeting the
17    current 8-hr 63 NAAQS. The year selected to represent recent air quality data is 2004, since this
18    is the most recent year for which complete data are currently available.
19          In order to estimate health risks associated with just meeting the current 8-hr 03 NAAQS,
20    it is necessary to estimate the distribution of hourly Oa concentrations that would occur under
21    any given standard.  Since compliance with the current 63 standard is based on a 3-year average,
22    air quality data from 2002 to 2004 have been used to determine the amount of reduction in Os
23    concentrations required to meet the current standard. Estimated design values2 are used to
24    determine the adjustment necessary to just meet the current 8-hr daily maximum standard. The
25    amount of control has then been applied to a single year of data (2004) to estimate risks for a
26    single season (April through September) in a single year. As described in section 4.5.6 and in
27    more detail in Rizzo (2005), after considering several approaches, including proportional
28    rollback and Weibull adjustment procedures, staff concluded that the Quadratic air quality
29    adjustment procedure generally best represented the  pattern of reductions across the Os air
30    quality distribution observed  over the last decade. The Quadratic air quality  adjustment
31    procedure was applied to the filled in 2004 Os monitoring data, based on the 3-year period
32    (2002-2004) Os design value, to generate a new time series of hourly Os concentrations that
      2 A design value is a statistic that describes the air quality status of a given area relative to the level of the NAAQS..
      Design values are often based on multiple years of data, consistent with the specification of the NAAQS in Part 50
      of the CFR. For example, for the current OjNAAQS, the 3-year averages of the annual 4th daily maximum 8-hr
      average concentration based on the maximum monitor within an urban area are the design values.
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  1    reflects air quality levels just meeting the current 8-hr Os standard for this single year.  It should
  2   " be noted that since compliance with the current standard is based on the 3-year average of the 4th
  3    daily maximum 8-hr values, the air quality distribution in each of the 3 years can and generally
  4    does vary. As a consequence, the risk estimates associated with air quality just meeting the
  5    current standard also will vary depending on the year chosen for the analysis.  Staff plans to
  6    explore the magnitude of this year-to-year variability in the next draft of the assessment by
  7    conducting assessments involving adjusting 2002 air quality (a year with generally higher 03
  8    levels in many of the 12 urban study areas) to just meet the current 8-hr standard.
  9          As noted earlier, the risk estimates developed for both the recent air quality scenario and
 10    just meeting the current 8-hr standard represent risks in excess of estimated background
 11    concentrations. The results of the global tropospheric Os model GEOS-CHEM have been used
 12    to estimate monthly average background Oa levels for different geographic regions across the
 13    U.S. These GEOS-CHEM simulations include a background  simulation in which North
 14    American anthropogenic emissions of nitrogen oxides, non-methane volatile organic compounds,
 15    and carbon monoxide are set to zero, as described in' Fiore et al. (2003). Staff estimated monthly
 16    background concentrations for each of the 12 urban areas based on the GEOS-CHEM
 17    simulations (Langstaff, 2005a).
 18

 19    5.3     COMPONENTS OF THE RISK MODEL
 20         As noted above in section 5.1.2, there are two parts to the health risk assessment: one
 21    based on combining information from controlled human exposure studies with modeled
 22    population exposure and the other based on combining information from community
 23    epidemiological studies with either monitored or adjusted ambient concentrations levels. Section
 24    5.3.1 below discusses the portion of the current risk assessment related to effects reported in
 25    controlled human exposure studies and section 5.3.2 below discusses the portion of the current
 26    risk assessment related to health effects reported in community epidemiological studies.

 27          5.3.1   Assessment of Risk Based on Controlled Human Exposure Studies
 28            5.3.1.1 General Approach
 29          The maj or components of the portion of the health risk assessment based on data from
 30    controlled human exposure studies are illustrated in Figure 5-1. As shown in Figure 5-1, under
 31    this portion of the risk assessment, exposure estimates for a number of different air quality
 32    scenarios (i.e, recent year of air quality, just meeting the current 8-hr standard, just meeting
33    alternative standards, and background)  are combined with probabilistic exposure-response
 34    relationships  derived from the controlled human exposure studies to develop risk estimates
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 1
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 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
for recent air quality and just meeting the current and alternative standards in excess of
background. As discussed above, the health effect included in this portion of the risk assessment
is lung function decrement, as measured by FEVi. The air quality and exposure analysis
components that are integral to this portion of the risk assessment are discussed in greater detail
in Chapter 4 and in the draft Exposure Assessment TSD.
       Several risk measures were generated for this portion of the risk assessment. In addition
to the estimates of the number of school age children and active children experiencing 1
or more occurrences of a lung function decrement >10, >15, and >20% in an Os season, risk
estimates have been developed for the total number of occurrences of these lung function
decrements in school age children and active school age children.
       A population risk estimate for a given lung function decrement (e.g., ^20% change in
FEVi) is an estimate of the expected number of people who will experience that lung function
decrement Since staff is interested in risk estimates associated with Oa concentrations in excess
of background concentrations, the following steps were taken: (1) expected risk given the
personal exposures associated with recent ambient Oa concentrations was estimated, (2) expected
risk given the personal exposures associated with estimated background ambient Os
concentrations was estimated, and (3) the latter was subtracted from the former. As shown in
Equation 5-1 below, the population risk is then calculated by multiplying the resulting expected
risk by the number of people in the relevant population. Because response rates are calculated
for 21 fractiles, estimated population risks are similarly tractile-specific.
     November 2005
                                        5-10
Draft - Do Not Quote or Cite

-------
W
15 -3 § °>
2 < ,_ -s 1 -s
.E -p >. n eo to  -o c TZ
UJ g « § S J £
3 KOO w< w
ic . . .
t
£ .* *«
ro .2 ^
4*S
j L

W «^
£ £ T3
Cu ^^ ™
E£ » 3-g
S ? T. g 0 §
»Ic!l*«J3
§s l« 1 1 1 S
88iS|Sg51
Sl*3*y?*
t
a
1 S, '
2 5? "S
B, o o
^ 8-5
Ed UJ
ik j i j k i


^ •« «»
?ffll
8^t^
*6|0«
"
Jf St^s Sll III Si
i ii|| |l! oil |i
§ <§S Isl 5fe S|
Z, =5 m3 <
^
fe
1
t
%
•-i     (N

-------
 1          The risk (i.e., expected fractional response rate) for the k* fractile, Rt is:
 2
                         N                   «t
 3                 Rk = £PJ x W I e>•)  -  ZP-* x W Ie-*)  (Equati<>n 5-1)
                        >i                   w
 4   where:
 5
 6          ey = (the midpoint of) the jth category of personal exposure to ozone, given recent
 7          ambient Os concentrations;
 8
 9          ef = (the midpoint of) the ith category of personal exposure to ozone, given background
10          ambient 03 concentrations;
11
12          Pj = the fraction of the population having personal exposures to Os concentration of BJ
                      *•
13          ppm, given recent ambient Os concentrations;
14
15          Pf = the fraction of the population having personal exposures to Oj concentration of
16          ef ppm, given background ambient Os concentrations;
17
18          RRk | Cj = k-fractile response rate at Os concentration q;
19
20          RRk | ef = k-fractile response rate at Os concentration e\; and
21
22          N=number of intervals (categories) of Os personal exposure concentration, given recent
23          ambient Os concentrations; and
24
25          Nb - number of intervals of Os personal exposure concentration, given background
26          ambient Os concentrations.
27
28          For example, if the median expected response rate for recent ambient concentrations is
                                                                                    *
29   0.065 (i.e., the median expected fraction of the population responding is 6.5%) and the. median
30   expected response rate for background ambient concentrations is 0.001 (i.e., the median expected
31   fraction of the population responding is  0.1 %), then the median expected response rate
32   associated with recent ambient concentrations above background concentrations is 0.065 - 0.001
                                                                               t

     November 2005                         5-12                Draft - Do Not Quote or Cite

-------
 1   = 0.064. If there are 300,000 people in the relevant population, then the population risk is 0.064
 2   x 300,000 = 19,200.

 3            5.3.1.2 Exposure Estimates
 4          Exposure estimates used in this portion of the risk assessment were obtained from
 5   running TRIM.Expo for each of the 12 urban areas for the various air quality scenarios (i.e., for
 6   2004 air quality representing a recent year, for 2004 air quality adjusted to just meet the current
 7   8-hr standard, and for air quality levels representing background based on estimates from the
 8   GEOS-CHEM model). Chapter 4 and the draft Exposure Assessment TSD (EPA, 2005d)
 9   provide additional details about the inputs and methodology used to estimate population
10   exposure in the 12 urban areas.  Exposure estimates for all and "active" school age'children (ages
11   5 to 18) were separately combined with probabilistic exposure-response relationships for lung
12   function decrements associated with 8-hr exposure while engaged in moderate exertion.
13   Children were characterized as active if their median daily physical activity index (see section
14   4.4.3) over the period modeled was 1.75 or higher, a level characterized by exercise
15   physiologists as being "moderately active" or "active." Individuals engaged in activities that
16   resulted in an  average equivalent ventilation rate (EVR) for the 8-hr period in the range of 13 to
17   271/min-m2 were included in the exposure estimates for 8-hr moderate exertion.  This range was
18   selected to match the range of EVR for the group of subj ects in the controlled human exposure
19   studies that were the basis for the exposure-response relationships used in this portion of the risk
20   assessment.

21            53.1.3 Exposure Response Functions
22          A similar methodology to that developed in the prior risk assessment has been used to
23   estimate probabilistic exposure-response relationships for lung function decrements in school age
24   children and active school age children associated with 8-hr moderate exertion exposures. As in
25   the prior assessment, the combined data set from the Folinsbee et al. (1988), Horstman et al.
26   (1990), and McDonnell et al. (1991) studies have been used to estimate exposure-response
27   relationships for 8-hr exposures.  Data from these controlled human exposure studies  were
28   corrected for the effect of exercise in clean air to remove any systematic bias that might be
29   present in the  data attributable to an exercise effect. Generally, this correction for exercise in
30   clean air was small relative to the total effects measures in the Os-exposed cases. Regression
31   techniques were then used .to fit a function to the data for each of the three measures1 of lung
32   function decrement. In each case, a linear function provided a'good fit.3
      3 As noted in Whitfield et al., 1996, the response data point associated with 0.12 ppm for the response measure
      FEV1 > 15% appeared to be inconsistent with the other data points (see Whitfield et al., 1996, Table 10, footnote c).
      November 2005          •                5-13                Draft - Do Not Quote or Cite

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 1            53.1.4 Characterizing Uncertainty and Variability
 2          An important issue associated with any population health risk assessment is the
 3    characterization of uncertainty and variability. Uncertainty refers to the lack of knowledge
 4    regarding both the actual values of model input variables (parameter uncertainty) and the
 5    physical systems or relationships (model uncertainty - e.g., the shapes of concentration-response
 6    functions). In any risk assessment uncertainly is, ideally, reduced to the maximum extent
 7    possible, .but significant uncertainty often remains. It can be reduced by improved measurement
 8    and improved model formulation. In addition, the degree of uncertainty can be characterized,
 9    sometimes quantitatively. For example, the statistical uncertainty surrounding the estimated Oa
10    coefficients in the exposure-response functions is reflected in the credible intervals provided for
11    the risk estimates in this chapter and in the draft Risk Assessment TSD.
12          A Bayesian approach was used to characterize uncertainty attributable to sampling error
13    based on sample size considerations at each of the three Oa  concentrations for which there were
14    data from the underlying studies (0.08, 0.10, and 0.12 ppm). Using diffuse Beta distributions as
15    priors distributions, the resulting posterior distributions are also Beta distributions (see Appendix
16    A in Whitfield et al., 1996).  Response rates were calculated for 21 fractiles (for cumulative
17    probabilities  from 0.05 to 0.95 in steps of 0.05) plus probabilities of 0.01 and 0.990 using these
18    posterior Beta distributions.  For other concentrations, regression techniques were used to fit a
19    linear function through the three points at Os concentrations of 0.08, 0.10, and 0.12 ppm and then
20    this function was used to generate response rates for all 21 fractiles at specified Og
21    concentrations. If the estimated response rate was less than 0.0, it was set equal to 0.0 and if the
22    response rate was greater than 1.0, it was set to 1.0.
23          In addition to uncertainties arising from sample size considerations, other uncertainties
24    associated with the use of the exposure-response relationships for lung function responses are
25    briefly summarized below. Additional uncertainties with respect to the exposure inputs to the
26    risk assessment are described in Chapter 4 and the draft Exposure Assessment TSD. These
27    additional uncertainties include:
28         •  Length of exposure.  The 8-hr moderate exertion risk estimates are based on a
29            combined data set from three controlled human exposure studies conducted using 6.6-
30            hr exposures.  The use of these data to estimate responses associated with an 8-hr
31            exposure are reasonable, in our judgment, because lung function response appears to
32            level off after exposure for 4 to 6 hours. It is unlikely that the exposure-response
33            relationships would have been appreciably different had the studies been conducted
34            over an 8-hr period.
      Because of this, we estimated the probability of a response of FEV1 Z 15% at an O3 concentration of 0.12 ppm by
      interpolating between the FEV1 £ 10% and FEV1 £ 20% response rates at that O3 concentration.
      November 2005                          5-14                 Draft - Do Not Quote or Cite

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 1         *  Extrapolation of exposure-response relationships. It was necessary to estimate
 2            responses at Oa levels below the lowest exposure levels used in the controlled human
 3            studies (i.e., 0.08 ppm). In the prior review the CASAC Os Panel supported the staffs
 4            decision to use a linear extrapolation approach down to background levels.  The same •'
 5            extrapolation has been applied in the current risk assessment.

 6         •  Reproducibilitv of Ounduced responses.  The risk assessment assumed that the (V
 7            induced responses for individuals are reproducible.  This assumption is supported by
 8            the evaluation in the draft CD (see section AX6.4) which cites studies by McDonnell et
 9            al. (1985b) and Hazucha et al. (2003) as showing significant reproducibility of
10            response.
11         •  Age and lung function response. As in the prior review, exposure-response
12            relationships based on controlled human exposure studies involving 18-35 year old
13            subjects were used in the risk assessment to estimate responses for school age children
14            (ages 5-18).  This approach is supported by evaluation in the draft CD (see section
15            AX6.4) which cites the findings of McDonnell et al. (1985a) who reported that children
16            8-11 years old experienced FEVi responses similar to those observed in adults 18-35
17            years old when both groups were exposed to concentrations of 0.12 ppm at an EVR of
18            35 L/min/m2. The draft CD also notes that Hazucha et al. (2003) similarly observed
19            generally reproducible Ch-induced lung function responses in a controlled human
20            exposure study. In addition, a number of summer camp studies of school age children
21            exposed in outdoor environments in the Northeast also showed Os-induced lung
22            function changes similar to those observed in controlled human exposure studies.

23         •  Exposure history. The risk assessment assumed that the Os-induced response on any
24            given day is independent of previous Os exposures.  As discussed in Chapter 3 and in
25            the draft CD, Cvinduced responses can be enhanced or attenuated as a result of recent
26            prior exposures.  The possible impact of exposure history on the risk estimates is an
27            additional source of uncertainty that is not quantified in Ihis assessment.

28         •  Interaction between 0^ and other pollutants. Because the controlled human exposure
29            studies used in the risk assessment involved only 03 exposures, it was assumed that
30            estimates of Os-induced health responses would not be affected by the presence of
31            olher pollutants (e.g., SOi, PM2.5, etc). Some evidence exists that other pollutants may
32            enhance the respiratory effects associated with exposure to C% but the evidence is not
33            consistent across studies.
34          Variability refers to the heterogeneity in a population or variable of interest that is
35   inherent and cannot be reduced through further research. The current controlled human exposure
36   studies portion of the risk assessment incorporates some of the variability in key inputs to the
37   analysis by using location-specific inputs for the exposure analysis (e.g., location-specific
38   population data, air exchange rates, air quality and temperature data). Although spatial
39   variability in these key inputs across all U.S. locations has not been fully characterized,
40   variability across the selected locations is embedded in the analysis by using, to the extent
41   possible, inputs specific to each urban area. Temporal variability is more difficult to address,
42   because the risk assessment focuses on some unspecified time in the future.  To minimize the
     November 2005                           5-15                Draft - Do Not Quote or Cite

-------
 1    degree to which values of inputs to the analysis may be different from the values of those inputs
 2    at that unspecified time, we have used the most current inputs available - for example, year 2004
 3    air quality data for all of the urban locations, and the most recent available population data (from
 4    the 2000 Census). However, future changes in inputs have not been predicted (e.g., future
 5    population levels).

 6          5.3.2   Assessment of Risk Based on Epidemiological Studies
 7          As discussed above, the current quantitative risk assessment based on epidemiological
 8    studies includes risk estimates for cardiopulmonary-related hospital admissions and total and
 9    cardiopulmonary mortality associated with short-term 63  exposures in selected urban locations
10    in the U.S. The methods used in this  portion of the risk assessment are described below.

11            5.3.2.1 General Approach
12          In order to estimate the incidence of a particular health effect associated with recent
13    conditions in a specific county or set of counties attributable to ambient Os exposures in excess
14    of background, as well as the change  in incidence of the health effect in that county or set of
15    counties corresponding to a given change in Os levels resulting from just meeting the current or
16    alternative 8-hr Oa standards, the following three elements are required:
17    •     Air quality information including: (1) recent air  quality data for Oa from population-
18          oriented monitors in the assessment location, (2) estimates of background Os
19          concentrations appropriate to this location, and (3) recent concentrations adjusted to
20          reflect patterns of air quality estimated to occur when the area just meets the specified
21          standards.  (These air quality inputs are discussed  in more detail in section 4.5.6)
22    *     Concentration-response function(s) which provide an estimate of the relationship
23          between the health endpoint of interest and ambient  Os concentrations, preferably derived
24          in the assessment location, although functions estimated in other locations can be used at
25          the cost of increased uncertainty.
26    •     Seasonal baseline health effects incidence rate and population. The baseline
27          incidence rate provides an estimate of the incidence  rate in the assessment location
28          corresponding to recent Oa levels in that location
29
30    Figure 5-2 provides a broad schematic depicting the role of these components in this part of the
31    risk assessment. Each of the key components (i.e., air quality information, estimated
32    concentration-response functions, and baseline incidence  and population data) is discussed
33    below, highlighting those points at  which judgments have been made.
34          These inputs are combined to  estimate health effect incidence changes associated with
35    specified changes in Os levels. Although some epidemiological studies have estimated linear or
36    logistic concentration-response functions, by far the most common form is the exponential (or
37    log-linear) form:

      November 2005                          5-16                Draft - Do Not Quote or Cite

-------
                                                             O
                                    (0
I  *
I  <    _ "S J "S
*s  -g £. "c 
J
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i
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-------
 1                                     y = Beftf,                         (Equation 5-2)
 2
 3   where x is the ambient O$ level, y is the incidence of the health endpoint of interest at 03 level x,
 4   pis the coefficient of ambient 63 concentration, and B is the incidence at x=0, i.e., when there is
 5   no ambient 63. The relationship between a specified ambient Os level, XQ, for example, and the
 6   incidence of a given health endpoint associated with that level (denoted as yo) is then
 7
 8                                     y0=Beftc°.                       (Equation 5-3)
 9
10   Because the log-linear form of concentration-response function (equation (5-2)) is by far the
11   most common form, we use this form to illustrate the derivation of the "health impact function"
12   used in this portion of the risk assessment.
13
14          The difference in health effects incidence, Ay = y0 - y, from yfl to the baseline incidence
15   rate, y, corresponding to a given difference in ambient 03 levels, Ax = XQ - x, can be derived by
16   dividing equation (5-3) by equation (5-2), which yields:
17
18                                     Ay = y[ep** -1]  .                 (Equation 5-4)
19
20   Alternatively, the difference in health effects incidence can be calculated indirectly using relative
21   risk.  Relative risk (RR) is a measure commonly used by epidemiologists to characterize the
22   comparative health effects associated with a particular air quality comparison. The risk of
23   mortality  at ambient Os level xo relative to the risk of mortality at ambient Os level x, for
24   example,  may be characterized by the ratio of the two mortality rates: the mortality rate among
25   individuals when the ambient Os level  is XQ and the mortality rate among (otherwise identical)
26   individuals when the ambient Os level  is x. This is the RR for mortality associated with the
27   difference between the two ambient Os levels, x0 and x. Given a concentration-response function
28   of the form shown in equation (5-1) and a particular difference in ambient 63 levels, Ax, the RR
29   associated with that difference in ambient O3, denoted as RR^, is equal to epAx . The difference
30   in health effects incidence, Ay, corresponding to a given difference in ambient Os levels, Ax, can
31   men be calculated based on this RRax:
32
33                                     &y = y[RRfr -1].                 (Equation 5-5)
34

     November 2005                          5-18                 Draft - Do Not Quote or Cite

-------
 1    Equations (5-4) and (5-5) are simply alternative ways of expressing the relationship between a
 2    given difference in ambient Os levels, Ax, and the corresponding difference in health effects
 3    incidence, Ay. These health impact equations are the key equations that combine air quality
 4    information, concentration-response function information, and baseline health effects incidence
 5    information to estimate ambient Os health risk.

 6           5.3.2.2 Air Quality Considerations
 7          As illustrated in Figure 5-2, and noted earlier, air quality information required to conduct
 8    the Oa risk assessment includes: (1) recent air quality data for Os from suitable monitors for each
 9    selected location, (2) estimates of background concentrations for each selected location, and (3)
10    air quality adjustment procedures to modify the recent data to reflect changes in the distribution
11    of hourly 63 air quality estimated to occur when an area just meets a given Os standard. Staff
12    retrieved Os ambient air quality  data for the years 2002 through 2004 from EPA's Air Quality
13    System(AQS).
14          To estimate the change in incidence of a health effect associated with a change in Os
15    concentrations from recent levels to background levels in an assessment location, two time series
16    of Os concentrations are needed for that location: (1) hourly Os concentrations from a recent
17    year, and (2) hourly background Os concentrations. In order to be consistent with the approach
18    generally used in the epidemiological studies that estimated Os concentration-response functions,
19    the (spatial) average ambient Os concentration on each hour for which measured data are
20    available is deemed most appropriate for the risk assessment. A composite monitor data set was
21    created for each assessment location based on averaging each hourly value from all monitors
22    eligible for comparison with the current standard for each hour of the day.  Table 4-6 provides a
23    summary of the design values for the 12 urban study areas. Table 5B-1 (Appendix 5B) provides
24    more detailed information on ambient Os concentrations for these locations, including 1 -hr and
25    24-hr average statistics across monitors in each location and the composite monitor values used
26    in this part of the risk assessment.
27          Different exposure metrics have been used in epidemiological Os studies, including the
28    24-hr average and the daily 1-hr maximum.  Therefore,  daily changes at the composite monitor
29    in the Os exposure metric appropriate to a given concentration-response function were calculated
30    (see Table A-13, Appendix A for summary statistics for the composite monitor Os concentrations
31    in the 12 urban locations). For example, if a concentration-response function related daily
32    mortality to daily 1-hr maximum Os concentrations, the daily changes in 1-hr maximum Os
33    concentrations at the composite monitor were calculated. In the first part of the epidemiology -
34    based risk assessment, in which risks associated with the recent levels of Os above background
35    levels were estimated, this required the following steps:

      November 2005          '                5-19                Draft - Do Not Quote or Cite

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 1         •  Using the monitor-specific input streams of hourly Os concentrations from a recent
 2            year, calculate a stream of hourly Os concentrations at the composite monitor. The
 3            recent Os concentration at the composite monitor for a given hour on a given day is the
 4            average of the monitor-specific Os concentrations for that hour on that day.
 5         •  Using the stream of hourly Os concentrations from a recent year at the composite
 6            monitor, just created, calculate the 1-hr maximum Os concentration for each day at the
 7            composite monitor.
 8         •  Using the monitor-specific input streams of hourly background 03 concentrations,
 9            calculate a stream of hourly background Os concentrations at the composite monitor.
10         •  Using the stream of background hourly Os concentrations at the composite monitor,
11            just created, calculate the 1 -hr maximum background Os concentration for each day at
12            the composite monitor.
13         •  For each day, calculate Ax = (the 1 -hr maximum Os concentration for that day at the
14            composite monitor) (the 1 -hr maximum background Os concentration for that day at the
15            composite monitor).
16
17      The calculations for the second part of the epidemiology-based risk assessment, in which
18    risks associated with estimated Os levels that just meet the current standard above background
19    levels were estimated, were done analogously. For this case the monitor-specific series of
20    adjusted hourly concentrations were used rather than the monitor-specific series of recent
21    monitored hourly concentrations.  Similarly, calculations for concentration-response functions
22    that used a different exposure metric (e.g., the 24-hr average) were done analogously, using the
23    exposure metric appropriate to the concentration-response function.

24            5.3.2.3 Concentration-Response Functions
25           As indicated in Figure 5-2, another key component in the epidemiological-based risk
26    model is the set of concentration-response functions which provide estimates of the relationships
27    between each health endpoint of interest and ambient concentrations. As  discussed above, the
28    health endpoints that have been included in the Os risk assessment include mortality and hospital
29    admissions associated with short-term exposures.  Once it has been determined that a health
30    endpoint is to be included in the assessment, the assessment includes all estimates of response
31    magnitude from studies judged suitable for inclusion in this assessment, including those which
32    are not statistically significant. Effect estimates that are not statistically significant are used from
33    studies judged suitable for inclusion in this assessment to avoid introducing bias into the estimate
34    of the magnitude of the effect. Table 5-1 summarizes the studies included in this part of the risk
35    assessment for each of the urban locations.
36           Studies often report more than one estimated concentration-response function for the
37    same location and health endpoint. Sometimes models including different sets of co-pollutants
      November 2005                          5-20                 Draft - Do Not Quote or Cite

-------
 1    are estimated in a study; sometimes different lags are estimated. In some cases, two or more
 2    studies estimated a concentration-response function for Os and the same health endpoint in the
 3    same location (this is the case, for example, with Os and mortality associated with short-term
 4    exposures). For some health endpoints, there are studies that estimated multi-city Os
 5    concentration-response functions, while other studies estimated single-city functions.
 6          All else being equal, a concentration-response function estimated in the assessment
 7    location is preferable to a function estimated elsewhere, since it avoids uncertainties related to
 8    potential differences due to geographic location. That is why the urban areas selected for the
 9    epidemiological studies-based part of the Os risk assessment are those locations in which
10    concentration-response functions have been estimated.  There are several advantages, however,
11    to using estimates  from multi-city studies versus studies carried out in single cities. These
12    advantages include, but are not limited to: (1) more precise effect estimates due to larger data
13    sets, (2) greater consistency in data handling and model specification that can eliminate city-to-
14    city variation due to study design, and (3) less likelihood of publication bias or exclusion of
15    reporting of negative or nonsignificant findings. Multi-city studies are applicable to a variety of
16    settings, since they estimate a central tendency across multiple locations. When they are
17    estimating a single concentration-response function based on several cities, multi-city studies
18    also tend to have more statistical power and provide effect estimates with relatively greater
19    precision than single city studies due to larger sample sizes, reducing the uncertainty around the
20    estimated coefficient. Because single-city  and multi-city studies have different advantages,
21    where both are available for a given location, risk estimates are presented for both functions.
22          In summary:
23         •  if a single-city concentration-response function was estimated in a risk assessment
24            location  and a multi-city function which includes that location was also available for
25            the same health endpoint, both functions were included for that location in the risk
26            assessment;
27         •  risk estimates based on both single- and multi-pollutant models were used when both
28            were available;
      November 2005
5-21
Draft - Do Not Quote or Cite

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1   Table 5-1. Locations and Health Endpoints Included in the 03 Risk Assessment Based on
2   Epidemiological Studies*
Urban Area
Atlanta
Boston
Chicago
Cleveland
Detroit
Houston
Los Angeles
New York
Philadelphia
Sacramento
St. Louis
Washington, D.C.
Premature Total Mortality or
Cardiorespiratory Mortality
Bell etal, (2004)
Bell et al. (2004) - 95 cities
Huang et al. (2004)
Huang et al. (2004) - 19 cities
Bell et al. (2004) - 95 cities
Bell et al. (2004) - 95 cities
Huang et al. (2004)
Huang et al. (2004) - 1 9 cities
Schwartz (2004)
Schwartz (2004) - 14 cities
Bell et al. (2004)
Bell et al. (2004) - 95 cities
Huang et al. (2004)
Huang et al. (2004) - 19 cities
Bell etal. (2004)
Bell et al. (2004) - 95 cities
Huang et al. (2004)
Huang et al. (2004) - 1 9 cities
Schwartz (2004)
Schwartz (2004) - 14 cities
Ito (2003)
Bell et al. (2004)
Bell et al. (2004) - 95 cities
Huang etal. (2004)
Huang et al. (2004) - 1 9 cities
Schwartz (2004)
Schwartz (2004) - 14 cities
Bell et al. (2004)
Bell etal. (2004) -95 cities
Huang etal. (2004)
Huang et al. (2004) - 1 9 cities
Bell et al. (2004) - 95 cities
Huang etal. (2004)
Huang et al. (2004) - 19 cities
Bell et al. (2004) - 95 cities
Huang et al. (2004)
Huang et al. (2004) - 19 cities
Moolgavkar et al. (1995)
Bell et al. (2004)
Bell et al. (2004) - 95 cities
Bell et al. (2004)
Bell et al. (2004) - 95 cities
Bell et al. (2004) - 95 cities
Hospital Admissions for Respiratory and
Cardiovascular Dines ses



Schwartz etal. (1996)
ItO (2003)

Linn et al. (2000)
Thurston etal. (1992)




    November 2005
5-22
Draft - Do Not Quote or Cite

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 1         •   distributed lag models were used, when available; when a study reported several single
 2             lag models for a health effect, the initial selection of the appropriate lag structure for
 3             the health effect was based on the overall assessment in the draft CD, considering all
 4             studies reporting concentration-response functions for that health effect.
 5           The locations, health endpoints, studies, and concentration-response functions included in
 6    that portion of the risk assessment based on epidemiological studies are summarized in Table
 7    5A-1 (Appendix 5A).

 8            5.3.2.4 Baseline Health Effects Incidence and Population Estimates
 9           As illustrated in Equation 5-4, the most common epidemiological-based health risk
10    model expresses the reduction in health risk (Ay) associated with a given reduction in Os
11    concentrations (Ax) as a percentage of the baseline incidence (y). To accurately assess the
12    impact of changes in Os air quality on health risk in the selected urban areas, information on the
13    baseline incidence of health effects (i.e., the incidence under recent air quality conditions) in
14    each location is therefore needed. Population sizes, for both total population and various age
15    ranges used in the risk assessment were obtained for the year 2002 (need citation) and are
16    summarized in Table 5-2. Where possible, county-specific incidence or incidence rates have
17    been used in the assessment.  County specific mortality incidences were available for the year
18    2002 from CDC Wonder (CDC, 2005), an interface for public health data dissemination
19    provided by the Centers for Disease Control (CDC).  The baseline mortality rates for each risk
20    assessment location are provided in Table 5-3 and are expressed as a rate per 100,000
21    population.4
22           County-specific rates for cardiovascular and respiratory hospital discharges, and various
23    subcategories (e.g., asthma, pneumonia, ischemic heart disease), have been obtained, where
24    possible, from state, local, and regional health departments and hospital planning commissions
25    for each of the risk assessment locations.5 Baseline hospitalization rates used in each risk
26    assessment location are summarized in Table 5-4 and are expressed as a rate per 100,000
27    relevant population.
      4 Since the baseline incidence rates are expressed in terms of cases per 100,000 general population, the general
      population estimates have been used in combination with these rates to generate the baseline incidence in each
      location for non-accidental and various types of mortality in calculating the risk estimates.
      5 The data were annual hospital discharge data, which were used as a proxy for hospital admissions. Hospital
      discharges are issued to all people who are admitted to the hospital, including those who die in the hospital. Use of
      the annual or seasonal discharge rate is based on the assumption that the admissions at the end of the year (or
      season) that carry over to the beginning of the next year (or season), and are therefore not included in the discharge
      data, are offset by the admissions in the previous year (or season) that cany over to the beginning of the current year
      (or season).
      November 2005                           5-23                  Draft - Do Not Quote or Cite

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1    Table 5-4. Baseline Rates for Hospital Admissions
Relevant Population
Rate per 100,000 Relevant Population*
Los
Angeles'
Ages 30+
New
York2
All Ages
Detroit3
Ages
65+
Cleveland4
Ages 65+
Admissions for:
Cardiovascular illness (DRG Codes 103 - 144) - spring
Cardiovascular illness (DRG Codes 103'- 144) - summer
Pulmonary illness (DRG Codes 75 - 1 01) - spring
Pulmonary illness (DRG Codes 75 - 101) - summer
Respiratory illness (ICD codes 466, 480-486, 490, 491,
492, 493)
Asthma (ICD code 493)
Pneumonia (ICD codes 480-486)
COPD (ICD codes 490-496)
Ischemic heart disease (ICD codes 410-414)
Heart failure (ICD code, 428)
Dysrhythmias (ICD code 427)
Respiratory illness ((ICD codes 460-519)

-
431
421
208
174
—
—
—
...
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800
327
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—
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...
2,068
1,593
4,030
2,822
1,330
...


—
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—
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3,632


2
3
4
5
6
7
8
 Rates of unscheduled hospital admissions were calculated from patient discharge data for 1999, obtained from
California's Office of Statewide Health Planning and Development, which also provided records of hospital
admissions for the study by Linn et al. (2000).
2 Rates of unscheduled hospital admissions were calculated from patient discharge data for 2001, obtained from the
New York Statewide Planning and Research Cooperative.
3 Rates were calculated from hospitalization data for Wayne Comity for the year 2000, obtained from the Michigan
Health and Hospital Association in April 2002.
     November 2005
                                              5-26
Draft - Do Not Quote or Cite

-------
 1            5.3.2.5 Characterizing Uncertainty and Variability
 2          Section 5.3.1.4 previously defined what is meant by uncertainty and variability in the
 3    context of this risk assessment.  For the epidemiological-based portion of the risk assessment, the
 4    statistical uncertainty surrounding the estimated 0.3 coefficients in the reported concentration-
 5    response functions is reflected in the confidence or credible intervals provided for the risk
 6    estimates in this chapter and in the draft Risk Assessment TSD.  Additional uncertainties have
 7    been addressed quantitatively through sensitivity analyses and/or have been discussed throughout
 8    section 5.3.
 9          With respect to variability within the epidemioiogical-based portion of the risk
10    assessment, there may be variability among concentration-response functions describing the
11    relation between Q3 and mortality across urban areas.  This variability may be due to differences
12    in population (e.g., age distribution), population activities that affect exposure to Oa (e.g., use of
13    air conditioning), levels  and composition of co-pollutants, and/or other factors that vary across
14    urban areas.
15         ' The current risk assessment incorporates some of the variability in key inputs to the
16    analysis by using location-specific inputs (e.g., location-specific concentration-response
17    functions, baseline incidence rates, and air quality data). Although spatial variability in these
18    key inputs across all U.S. locations has not been fully characterized, variability across the
19    selected locations is imbedded in the analysis by using, to the extent possible, inputs specific to
20    each urban area  Temporal variability is more difficult to address, because the risk assessment
21    focuses on some unspecified time in the future. To minimize the degree to which values of
22    inputs to the analysis may be different from the values of those inputs at that unspecified time,
23    we have used the most current inputs available - for example, year 2004  air  quality data for all of
24    the urban locations, and the most recent available mortality baseline incidence rates (from 2002).
25    However, future changes in inputs have not been predicted (e.g., future population levels or
26    possible changes in baseline incidence rates).
27           A number of important sources of uncertainty were addressed where possible. Section
28    4.19 in the draft Risk Assessment TSD discusses in greater detail the uncertainties and variability
29    present in the health risk assessment.  The following is a brief discussion of the major sources of
30    uncertainty and variability in the epidemiological portion of the risk assessment and how they are
31    dealt with or considered in the risk assessment:
32         •   Causality.  There is uncertainty about whether each of the estimated associations
33             between Oj indicators and the various health endpoints included in this risk assessment
34             actually reflect a causal relationship.  The staffs judgment, as discussed in more  detail
35             in Chapter 3, is that for the health effects included in the risk assessment (i.e, total non-
36             accidental mortality, cardiorespiratory mortality, cardiovascular and respiratory
      November 2005
5-27
Draft - Do Not Quote or Cite

-------
 1            hospital admissions) there is a likely causal relationship with short-term 0$ exposures,
 2            especially during the warm Os season.

 3         •  Empirically estimated concentration-response relationships. In estimating the
 4            concentration-response relationships, there are uncertainties: (1) surrounding estimates
 5            of 63 coefficients in concentration-response functions used in the assessment, (2)
 6            concerning the specification of the concentration-response model (including the shape
 7            of the relationship) and whether or not a population threshold or non-linear relationship
 8            exists within the range of concentrations examined in the studies, (3) related to the
 9            extent to which concentration-response relationships derived from studies in a given
10            location and time when Os levels were higher or behavior and/or housing conditions
11            were different provide accurate representations of the relationships for the same
12            locations with lower air quality distributions and different behavior and/or housing
13            conditions, and (4) concerning the possible role of co-pollutants which also may have
14            varied between the time of the studies and the current assessment period. The
15            approach taken to characterize uncertainties in the concentration-response functions
16            arising from sample size considerations is discussed below. With respect to the shape
17            of the function and whether or not a population threshold may exist, as discussed in
18            Chapter 3, the draft CD concludes (section 8.4.3.4, p.8-56) that "the limited evidence
19            suggests that if there is a threshold level in Oj health effects, it is likely near the lower
20            limit of ambient Oj concentrations in the United States." The draft CD also concludes
21            (section 8.4.3.2.3, p.8-54) that the U.S. time series studies conducted in multiple cities
22            "provide substantial epidemiological evidence indicating that associations for Os with
23            mortality and morbidity are robust to confounding by copollutants."

24         •  Adequacy of ambient (^monitors as surrogate for population exposure. The extent to
25            which there are differences  in the relationship between spatial variation in ambient Os
26            concentrations and ambient exposures in the original epidemiology studies compared
27            to more recent ambient Os data introduces additional uncertainty in the risk estimates.
28            The draft CD  (section 8.4.3.2.1, p.8-53) states that "ambient concentrations generally
29            overestimate true personal Oa exposures" and that the "use of ambient concentrations
30            in risk calculations will likely result in effect estimates that are biased towards the null,
31            resulting in biased descriptions of underlying concentration-response relationships."
32            Thus, the risk  estimates presented here may underestimate the overall impact of Os
33            exposures on mortality and  hospital admissions.

34         •  Adjustment of air quality distributions to simulate just meeting the current standard.
35            The shape of the distribution of hourly Os concentrations that would result upon just
36            meeting the current or alternative 8-hr standards is unknown. Based on an analysis of
37            historical data, staff believes mat the Quadratic air quality adjustment procedure
38       .     provides reasonable estimates of the shape of the distribution; however, there is greater
39            uncertainty for those urban  areas that have air quality well above the current standard
40            (e.g., Los Angeles, Houston).  Staff plans to include additional sensitivity analyses
41            exploring the potential impact of using alternative air quality adjustment procedures on
42            the risk estimates associated with just meeting the current.and alternative Oa standards
43            in the next draft of the Risk Assessment TSD. Staff also plans to develop risk
44            estimates associated with just meeting the current standard based on a different year


      November 2005                          5-28                  Draft - Do Not Quote or Cite

-------
 1            within the three-year period on which the design value is based (e.g., 2002, in which Os
 2            levels were generally higher in most of the locations).
 3         •  Estimated background concentrations for each location. The calculation of risk
 4            associated with recent air quality in excess of background requires as an input
 5            estimates of background concentrations for each location throughout the period of the
 6            assessment.  The estimated background concentrations have been obtained from runs
 7            of the GEOS-CHEM global model (see section 2.7) and introduce some uncertainty
 8            into the risk estimates for both the recent air quality scenario and the just meeting the
 9            current 8-hr standard, both of which are calculated as risk in excess of background.
10         •  Baseline incidence rates and population data.  There are uncertainties related to: (1) the
11            extent to which baseline incidence rates, age distributions, and other relevant
12            demographic variables that impact the risk estimates vary for the year(s) when the
13            actual  epidemiological studies were conducted, the recent year of air quality used in
14            mis assessment, and some unspecified future year when air quality is adjusted to
15            simulate just meeting the current or alternative standards and (2) the use of annual or
16            seasonal incidence rate data to develop daily health effects incidence data.  Spatial
17            variability in baseline incidence and population data is taken into account by use of
18            city-specific data in most cases.
19          One of the most critical elements in the risk assessment is the concentration-response
20    relationships used in the assessment. The uncertainty resulting from the statistical uncertainty
21    associated with the estimate of the 63 coefficient in the concentration-response function was
22    characterized either by confidence intervals or by Bayesian credible intervals around the
23    corresponding point estimates of risk.  Confidence and credible intervals express the range
24    within which the true risk is likely to fall if the only uncertainty surrounding the Os coefficient
25    involved sample size considerations.  Other uncertainties, such as differences in study location,
26    time period, and model uncertainties are not represented by the confidence or  credible intervals
27    presented.
28          The two  multi-city mortality studies, Bell et al. (2004) and Huang et al. (2004), reported
29    both multi-location and single-location concentration-response functions, using a Bayesian two-
30    stage hierarchical model. In these cases, the single-location estimates can be adjusted to make
31    more efficient use of the data from all locations. The resulting "shrinkage" estimates are so
32    called because they "shrink" the location-specific estimates towards the overall mean estimate
33    (the mean of the posteri or distribution of the multi-location concentration-response function
34    coefficient).  The greater the uncertainty about the estimate of the location-specific coefficient
35    relative to the estimate of between-study heterogeneity, the more the location-specific estimate is
36    "pulled in" towards the overall mean estimate. Bell et al.  (2004) calculated these shrinkage
37    estimates, which were presented in Figure 2 of that paper.  These location-specific shrinkage
38    estimates, and their adjusted standard errors were provided by the study authors and were used in
39    the risk assessment.
     November 2005
5-29
Draft - Do Not Quote or Cite

-------
 1          The location-specific estimates reported in Table 1 of Huang et al. (2004) are not
 2    "shrinkage" estimates.  However, the study authors provided the posterior distribution for the
 3    heterogeneity parameter, T, for their distributed lag model, shown in Figure 4(b) of their paper.
 4    Given this posterior distribution, and the original location-specific estimates presented in Table 1
 5    of their paper, we calculated location-specific "shrinkage" estimates using a Bayesian method
 6    described in DuMoucheL (1994) (see Appendix B of the draft Risk Assessment TSD for details
 7    about the calculation).  As with the shrinkage estimates presented in Bell et al. (2004), the
 8    resulting Bayesian shrinkage estimates use the data from all of the locations considered in the
 9    study more efficiently than do the original location-specific estimates. The calculation of these
10    shrinkage estimates is thus one way to address the relatively large uncertainty surrounding
11    estimates of coefficients in location-specific concentration-response functions.
12          With respect to model form, most of the epidemiological studies estimated Oa coefficients
13    using log-linear models. However, there still is substantial uncertainty about the correct
14    functional form of the relationship between 63 and various health endpoints, especially at the low
15    end of the range of observed' concentrations. While there are likely biological thresholds in
16    individuals for specific health responses, the available epidemiological studies do not support or
17    refute the existence of thresholds as Os levels approach background concentrations.
18          Several meta-analy ses addressing the impact of various factors on estimates of mortality
19    associated with short-term exposures to  Os were recently published and are discussed in the draft
20    CD.  Staff plans to review these analyses and explore whether they provide additional
21    information that can be used to assist in  characterizing the uncertainties associated with risk
22    estimates for this health outcome.

23    5.4    OZONE RISK ESTIMATES
24          The risk estimates associated with two air quality scenarios, a recent year of air quality as
25    represented by 2004 monitoring data and air quality adjusted to simulate just meeting the current
26    8-hr standard are presented in this draft Staff Paper in the sections below.  The next draft Staff •
27    Paper will include risk estimates for alternative 8-hr standards.
28          5.4.1    Recent Air Quality
29          In the prior risk assessment, risks for lung function decrements associated with 1-hr
30    heavy exertion, 1-hr moderate exertion,  and 8-hr moderate exertion exposures were estimated.
31    Since the 8-hr moderate exertion exposure scenario for children clearly resulted in the greatest
32    health risks in terms of lung function decrements, staff has chosen to include only the 8-hr
33    moderate exertion exposures in the current risk assessment for this health endpoint.  Thus, the
34    risk estimates presented here are most useful for making relative comparisons across alternative

      November 2005                          5-30                 Draft - Do Not Quote or Cite

-------
 1    air quality scenarios and do not represent the total risks for lung function decrements in children
 2    or other groups within the general population associated with any of the air quality scenarios.
 3          Tables 5-5 and 5-6 display the risk estimates for all and "active" school age children
 4    (ages 5-18) associated with'2004 63 concentrations for two different levels of lung function
 5    decrement responses for the 12 urban areas.  These two tables also include risk estimates
 6    associated.with air quality adjusted to simulate just meeting the current 0.08 ppm, 8-hr standard,
 7    which will be discussed further in section 5.4.2.  All estimates in both tables reflect responses
 8    associated with exposure to 63 in excess of exposures associated with background Os
 9    concentrations. Table 5^5 shows the number and percent of children estimated to have at least 1
10    lung function response during the Os season. Table 5-6 displays the total number of occurrences
11    for the specified lung function responses during the Oj season. As illustrated by the estimates
12    shown in these two tables, a child may experience multiple occurrences of a lung function
13    response during the Os season. For example, in Atlanta the median estimate is that 96,000 school
14    age children experienced an FEVi decrement > 15% during the Os season with a median estimate
15    of 738,000 occurrences of this same response in this population. Thus, for this example on
16    average each child is estimated to have over 7 occurrences of this lung function response during
17    the Os season.
18          As shown in Table 5-5, across the 12 urban areas, the ranges in median estimates of the
19    percent of all and "active".school age children estimated to experience at least one FEVi,
20    decrement >  15% during the OB season are 6.8-12.7 and 7.2-13.5%, respectively. The ranges in
21    median estimates of the percent of all and "active" school age children estimated to experience at
22    least one FEVi decrement > 20% during the Oa season across these same 12 urban areas are 0.8-
23    4.6% and 0.9-5.1 %, respectively.
24          In terms of total occurrences of FEVi decrement > 15% during the Os season, Table 5-6
25    shows a range of median estimates from 339,000 to over 6.1 million responses during the 63
26    season for all school age children and from 202,000 to 3.9 million responses for "active" school
27    age children across the 12 urban areas associated with 2004 Os concentrations. For FEVi
28    decrement > 20% during the Os season, Table 5-6 shows a range of median estimates from
29    13,000 to 670,000 for all school age children and from 9,000 to 440,000 for "active" school age
30    children.
     November 2005
5-31
Draft - Do Not Quote or Cite

-------


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 1          The risk estimates associated with 2004 Os concentrations for the health endpoints based
 2    on epidemiological studies are shown in Figures 5-3 and 5-4 and Table 5-7 for non-accidental
 3    mortality and Figures 5-5 and 5-6 and Table 5-8 for cardiovascular and respiratory mortality in
 4    all of Ihe urban locations included in the assessment.  Table 5-9 presents risk estimates for excess
 5    hospital  admissions for total respiratory illness and asthma (which is a subset of total respiratory
 6    illness admissions) for the New York City urban area. Additional hospital admission estimates
 7    for three other locations are provided in the draft Risk Assessment TSD.  All results are for
 8    health risks associated with short-term exposures to Os concentrations in excess of background
 9    levels from April through September 2004. The percent of total incidence that is Os-related is
10    shown in the top portion of Figures 5-3 through 5-7; the incidence per 100,000 relevant
11    population is shown in the bottom portion of Figures 5-3 through 5-7.
12          The central tendency estimates in all of the figures and in Tables 5-7 through 5-9 are
13    based on the Os coefficients estimated in the studies,  or, in the case of the location-specific
14    estimates from Huang et al. (2004) and Bell et al. (2004), on "shrinkage" estimates based on the
15    Os coefficients estimated in the study (see section 4.1.9.1.2 of the draft Risk Assessment TSD).
16    The ranges are based either on the 95 percent confidence intervals (CIs) around  those estimates
17    (if the coefficients were estimated using classical statistical techniques) or on the 95 percent
18    credible intervals (if the coefficients were estimated using Bayesian statistical techniques).
19          As discussed previously, assessment locations were chosen in part on the basis of
20    whether an acceptable concentration-response function had been reported for that location. As a
21    result, risks were estimated in a given assessment location only for those health  endpoints for
22    which there is at least one acceptable concentration-response function reported for that location.
23    For non-accidental mortality associated with short-term exposure to Os, Figure 5-3 displays
24    estimates for only nine of the twelve risk assessment locations because acceptable (single-city)
25    concentration-response functions for this health outcome were not available for  the other three
26    locations. Figure 5-3  shows estimated percent of non-accidental mortality and cases per 100,000
27    relevant population related to recent O3 concentrations over background levels,  based on single-
28    pollutant, single-city models across all locations for which such models were available.
29          Table 5-7 shows estimates of incidence, incidence per 100,000 relevant population, and
30    percent of total incidence of non-accidental mortality related to recent Os concentrations over
31    background levels in all locations, based on both single-city and multi-city models.  Estimates of
32    Os-related (non-accidental) mortality ranged from 0.4 per 100,000 relevant population in Atlanta
33    (Bell et al., 2004) to 7.3 per 100,000 relevant population in Chicago (Schwartz,  2004).
34    Estimated Os-related (non-accidental) mortality reported by Schwartz (2004) for Chicago,
35    Detroit,  and Houston, based on both the single-city and the multi-city concentration-response
36    functions, tend to be higher than other estimates in those locations in large part because Schwartz
      November 2005                          5-36                 Draft - Do Not Quote or Cite

-------
1
2
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 7
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 9
10
11
12
13
14
15
16
17
18
19
20,

21

22
23
24

26
27
28
29
     Figure 5-3. Estimated (Non-Accidental) Mortality Associated with Short-Term Exposure to
     Ozone Above Background: Single-Pollutant, Single-City Models (April - September, 2004)

                   5-3a.  Estimated Percent of Total Incidence that is O3-Related
           3.0%
           2.5%
            1.5%
            1.0%
           0.0%
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                                          H	1-
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               5-3b. Estimated O3-Related Cases per 100,000 Relevant Population
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     November 2005
                                           5-37
- Do Not Quote or Cite

-------
1   Figure 5-4. Estimated (Non-Accidental) Mortality Associated with Short-Term Exposure to
2             Ozone Above Background (April - September, 2004): Single-City Model (left
3             bar) vs. Multi-City Model (right bar)
                  5-4a. Estimated Percent of Total Incidence that is O3-Related
 5

 6

. 7

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            Figure 5-4b. Estimated O3-Related Cases per 100,000 Relevant Population
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    November 2005
                                            5-38
Dra/f - £)o Not Quote or Cite

-------
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10
11
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13
14
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21

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25

26

27
28

29
30
Figure 5-5. Estimated Cardiovascular and Respiratory Mortality Associated with Short*
          Term Exposure to Ozone Above Background (April - September, 2004):
          Single-City Model (left bar) vs. Multi-City Model (right bar) - Based on Huang
          etal. (2004)
             5-Sa. Estimated Percent of Total Incidence that is Oa-Related
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       Figure 5-5b. Estimated O3-Related Cases per 100.000 Relevant Population
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     November 2005
                                     5-39
Draft - Do Not Quote or Cite

-------
1   Figure 5-6. Estimated Cardiovascular and Respiratory Mortality Associated with Short-
2             Term Exposure to Ozone Above Background (April - September, 2004):
3             Single-Pollutant vs. Multi-Pollutant Models [Huang et al. (2004), additional
4             pollutants, from left to right:  none, PM10, NO2, SO2, CO]
5
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1    Table 5-9. Estimated Hospital Admissions Associated with Recent Ozone Concentrations
2               in New York, NY* (April - September, 2004)
Health
Effects**
Respiratory
Illness
(unscheduled)
Asthma
(unscheduled)
Ages
All
All
Lag
3-day
1-day
Exposure
Metric
1-hr max
1-hrmax
Health Effects Associated with O3 Above Policy
Relevant Background Levels***
Incidence
(95% CI)
447
(108-786)
382
(81-683)
Incidence per
100,000 '
Relevant
Population
(95% CI)
5.6
(1.4-9.8)
4.8
(1.0-8.5)
Percent of Total
Incidence (95%
CI)
1.3
(0.3-2.2)
2.9
(0.6-5.2)
3
4
5
6
7
8
*New York in this study is defined as the five boroughs of New York City
"""Concentration-response relationships are from Thurston et el. (1992) and are associated with short-term
exposures.
"""""Incidence was quantified down to estimated policy relevant background levels. Incidences per 100,000 relevant
population and percent of total incidence are rounded to nearest tenth.
     November 2005
                                            5-46
Draft - Do Not Quote or Cite

-------
 1    used the 1 -hr maximum Os concentration, rather than the 24-hr average, as the exposure metric.
 2    The changes from recent (2004) 1-hr maximum to background 1-hr maximum Os concentrations
 3    were generally larger in the assessment locations than the corresponding changes from recent 24-
 4    hr average to background 24-hr average Oj concentrations. As a percent of total incidence,
 5    estimated (Vrelated (non-accidental) mortality ranged from 0.1 percent in Atlanta (Bell et al.,
 6    2004) to 1.9 percent in Chicago (Schwartz, 2004).
 7          Figure 5-4 shows estimated percent of non-accidental mortality that is Os-related and Oa-
 8    related cases per 100,000 relevant population, based on single-city versus  multi-city models
 9    across all locations for which both types of model were available.  Estimates of Os-related non-
10    accidental mortality based on single-city models tended to have wider confidence or credible
11    intervals than those based on multi-city models, with both multi-city models (from Bell et al.,
12    2004 and Schwartz, 2004) producing statistically significant results.   However, the choice of
13    single-city versus multi-city model did not have a uniform effect on the magnitude of the point
14    estimate.  In some cases (Atlanta, Los Angeles, and Sacramento), the multi-city models produced
15    larger estimates than the single-city models, while in other cases (Chicago, Cleveland, Detroit,
16    Houston, and St. Louis) the reverse was true.
17          As shown in Figure 5-5, Bayesian credible intervals around the "shrinkage" estimates
18    (see section 5.3.2.5) of Os-related cardiovascular and respiratory mortality based on single-city
19    models in Huang et al. (2004) were uniformly larger than the corresponding credible intervals
20    around estimates based on the multi-city model from that study. As noted above, all  of the
21    estimates were positive and, with the exception of the single-city estimate for Chicago, all were
22    statistically significant.
23          Figure 5-6 shows estimated percent of cardiovascular and respiratory mortality and cases
24    per 100,000 relevant population related to recent Os concentrations over background  levels,
25    based on multi-city models for a single-pollutant versus multi-pollutant models from Huang et al.
26    (2004) across all locations for which such models were available. Table 5-8 shows estimates of
27    incidence, incidence per 100,000 relevant population, and percent of total  incidence of
28    cardiovascular and respiratory mortality related to recent 63 concentrations over background
29    levels in all risk assessment locations covered in Huang et al. (2004),  based on both single-city
30    and multi-city single-pollutant models from that study.  Estimates of Oa-related cardiovascular
31    and respiratory mortality ranged from 0.4 per 100,000 relevant population in Chicago (using the
32    single-city concentration-response function) and Houston (using both the single-city and the
33    multi-city concentration-response functions) to 1.3 per  100,000 relevant population in
34    Philadelphia (using the single-city concentration-response function).  As a percent of total
35    incidence, estimated Os-related cardiovascular and respiratory mortality ranged from 0.4 percent

      November 2005                          5-47                 Draft - Do Not Quote or Cite

-------
 1    in Chicago (using the single-city concentration-response function) to 1.6 percent in Los Angeles
 2    (using the multi-city concentration-response function). All of the estimates of Oa-related
 3    cardiovascular and respiratory mortality based on Huang et:al. (2004), from both single-city and
 4    multi-city models, and from both single-pollutant and multi-pollutant models, were positive.
 5    The shrinkage-based single-city single-pollutant models for Atlanta, Chicago, Cleveland,
 6    Detroit, and Houston for Os-related cardiovascular and respiratory mortality based on Huang et
 7    al. (2004) were not statistically significant.  The single city," single pollutant model for the other
 8    three locations (Los Angeles, New York, and Philadelphia) and all of the single pollutant, multi-
 9    city models were statistically significant for this same health endpoint based on Huang et al.
10    (2004). With respect to the multi-pollutant models for this health endpoint and study, all of the
11    multi-pollutant models  were statistically significant, with the exception of the models which
12    included PMio.
13          Table 5-9 shows estimates of unscheduled hospital admissions for respiratory illness in
14    the New York City area associated with Os levels above background of about 450 cases or 5.6
15    cases per 100,000 relevant population, which represents 1.3% of total incidence for recent (2004)
16    Os levels. For asthma-related hospital admissions, the estimates are about 380 cases or 4.8 cases
17    per 100,000 relevant population, which represents about 2.9% of total incidence.

18          5.4.2  Just Meeting Current Ozone Standards
19          As described in Chapter 4 and briefly in section 5.3.2.2, the risk estimates  described in
20    this section represent the risks for a single example year based on adjusting the Os levels
21    observed in 2004 to Os levels predicted when just meeting the current 0.08 ppm standard, using
22    the 3-year design value from the 2002-2004 time period This section first discusses the risk
23    estimates for lung function responses, which are based on exposure-response relationships
24    derived from controlled human exposure studies, and then risk estimates are explored for
25    mortality and hospital admissions, which are based on concentration-response relationships
26    obtained from epidemiological studies.
27          The risk estimates for lung function responses are for the.Oa season, which is all year in 3
28    of the study areas (Houston, Los Angeles, and Sacramento) and which is generally 6-7 months
29    long in the other 9 urban study areas (e.g., April to September). The risk estimates for lung
30    function responses in all and "active" school age children (ages 5 to 18) for just meeting the
31    current 8-hr standard for 12 urban areas are summarized in Tables 5-5 and 5-6.  As shown in
32    Table 5-5, across the 12 urban areas, the ranges in median estimates of the percent of all and
33    "active" school age children estimated to experience at least one FEVi decrement > 15% during
34    the Os season are 5.0-8.3% and 5.3-9.0%, respectively.  The ranges in median estimates of the
35    percent of all and "active" school age children estimated to experience at least one FEVi

      November 2005                          5-48                 Draft - Do Not Quote or Cite

-------
 1   decrement > 20% during the 63 season across these same 12 urban areas are 0.2-1.4% and 0.3-
 2   1.7%, respectively.
 3          In terms of total-occurrences of FEVi decrement > 15% during the 63 season, Table 5-6
 4   shows a range of median estimates from 222,000 to over 1.9 million responses during the Os
 5   season for all school age children and from 129,000 to nearly 1.3 million responses for "active"
 6   school age children across .the 12 urban areas associated with 2004 Os concentrations.  For FEVi
 7   decrement > 20% during the Os season, Table 5-6 shows a range of median estimates from 5,000
 8   to 33,000 for all school age children and from 3,000 to 22-000 for "active" school age children.
 9          The results of the assessment of the reduced mortality risks associated with Os
10   concentrations above background that j ust meet the current 8-hr daily maximum standard are
11   summarized across urban areas in Figures 5-7 through 5-10, and in Tables 5-10 and 5-11.  In
12   addition, Table 5-12 summarizes unscheduled hospital admission risk estimates for respiratory
13   illness and asthma in New York  City associated with Os concentrations above background and
14   just meeting the current 8-hr standard. Additional hospital admission estimates for three other
15   locations are provided in the draft Risk Assessment TSD. All results for the epidemiological
16   based part of the risk assessment are for health risks associated with short-term exposures  to Os
17   concentrations in excess of background levels from April through September. The percent of
18   total incidence that is Os-related is shown in top portion of Figures 5-7 through 5-10; the
19   incidence per 100,000 relevant population is shown in the bottom portion of these same figures.
20          As described in the previous section, the central tendency estimates in all of the figures
21   and tables are based on the Os coefficients estimated in the studies, or, in the case of the location-
22   specific estimates from Huang et al. (2004), on "shrinkage" estimates based on the Oj
23   coefficients estimated in the study (see section 5.3.2.5). The ranges are based either on the 95
24   percent confidence intervals around those estimates (if the coefficients were estimated  using
25   classical statistical techniques) or on the 95 percent credible intervals (if the coefficients were
26   estimated using Bayesian statistical techniques).
27          The results in this portion of the risk assessment follow the same patterns as the results
28   discussed in section 5.4.2 for risks associated with recent Oj concentrations, because they are
29   largely driven by the same concentration-response function coefficient estimates and confidence
30   or credible intervals.
31          Figure 5-7 shows estimated percent of non-accidental mortality and cases per 100,000
32   relevant population related to Os concentrations that just meet the current 8-hr Os standard, based
33   on single-pollutant, single-city models across all locations for which such models were available.
34   Table 5-10 shows estimates of incidence, incidence per 100,000 relevant population, and percent
35   of total incidence of non-accidental mortality related to 63 concentrations that just meet the
36   current 8-hr Os standard, based on both single-city and multi-city models. Estimates of Os-
     November 2005                         5-49                 Draft - Do Not Quote or Cite

-------
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21

22
23
24
25
26
27
28
29
30
Figure 5-7. Estimated (Non-Accidental) Mortality Associated with Short-Term Exposure to
          O3 Above Background When the Current 8-Hour Standard is Just Met: Single-
          Pollutant, Single-City Models (April - September)
             5-7a. Estimated Percent of Total Incidence that is Oa-Related
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          5-50
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-------
1   Figure 5-8. Estimated (Non-Accidental) Mortality Associated with Short-Term Exposure to
2            Ozone Above Background When the Current 8-Hour Standard is Just Met
3            (April - September): Single-City Model (left bar) vs. Multi-City Model (right
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Figure 5-9. Estimated Cardiovascular and Respiratory Mortality Associated with Short-
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     November 2005
                                     5-52
Draft - Do Not Quote or Cite

-------
1 1
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figure 5-10. Estimated Cardiovascular and Respiratory Mortality Associated with Short-
Term Exposure to Ozone Above Background When the Current 8-Hour
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Models [Huang et al. (2004), additional pollutants, from left to right: none,
PM10,NO2,SO2,CO]
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 1    Table 5-12. Estimated Hospital Admissions Associated with Ozone Above Background In
 2               New York, NY* When the Current 8-Hour Standard is Just Met (April -
 3               September)
Health
Effects**
Respiratory
Illness
(unscheduled)
Asthma
(unscheduled)
Ages
All
All
Lag
3-day
1-day
Exposure
Metric
1-hr max
1-hrmax
Health Effects Associated with 63 Above Policy
Relevant Background Levels***
Incidence
(95% CI)
364
(88-639)
310
(66-555)
Incidence per
100,000
Relevant
Population
(95% CI)
4.5
(1.1-8.0)
3.9
(0.8-6.9)
Percent of Total
Incidence (95%
CI)
1.0
(0.2-1.8)
2.4
(0.5-4.2)
 4
 5
 6
 7
 8
 9
10
11
*New York in this study is defined as the five boroughs of New York City
*'Concentration-response relationships are from Thurston et al. (1992) and are associated with short-term
exposures.
***Incidence was quantified down to estimated policy relevant background levels. Incidences per 100,000 relevant
population and percent of total incidence are rounded to nearest tenth.
     November 2005
                                          5-59
Draft - Do Not Quote or Cite

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 1   related (non-accidental) mortality ranged from 0.3 per 100,000 relevant population in Atlanta
 2   (Bell et at, 2004), Houston (Bell et al., 2004 - 95 U.S. Cities), and Los Angeles (Bell et al.,
 3   2004) to 5.8 per 100,000 relevant population in Chicago (Schwartz, 2004).
 4          As was the case for the analysis of effects associated with recent Os concentrations,
 5   estimated Os-related (non-accidental) mortality reported by Schwartz (2004) for Chicago,
 6   Detroit, and Houston, based on both the single-city and the multi-city concentration-response
 7   functions, tend to be higher than other estimates in those locations in large part because Schwartz
 8   used the 1 -hr maximum Os concentration, rather than the 24-hr average, as the exposure metric.
 9   The changes from 1 -hr maximum Os concentrations that just meet the current 8-hr Os standard to
10   background 1-hr maximum Os concentrations were generally larger in the assessment locations
11   than tiie corresponding changes using the 24-hr average metric.
12          As a percent of total incidence, estimated non-accidental mortality related to Os
13   concentrations that just meet the current 8-hr Os standard ranged from 0.1 percent in several
14   locations (Atlanta, Chicago, Detroit, Houston, Los Angeles, New York, and St. Louis) to 1.5
15   percent in Chicago (Schwartz, 2004). Although 7 of the 12 estimates from single-city single-
16   pollutant models shown in Figure 5-7 were not statistically significant, all 12 were positive. In
17   addition, it should be noted that the multi-city model estimates for non-accidental mortality were
18   statistically significant based on Bell et al. (2004) and S chwartz  (2004).
19          Figure 5-8 shows estimated percent of non-accidental mortality and cases per 100,000
20   relevant population related to Os concentrations that just meet the current 8-hr Os standard, based
21   on single-city versus multi-city models across all locations for which both types of model were
22   available. The results followed the same patterns as were observed in the analysis of effects
23   associated with recent Os concentrations above background levels, discussed in section 4.2.1
24   above (see also Figures 4-4a and b).  Similarly, the results seen  in Figure 5-9, for cardiovascular
25   and respiratory mortality, followed the same patterns as are evident in the corresponding analysis
26   of recent Os concentrations (see Figures 5-4 and 5-5).
27          Figure 5-10 shows estimated percent of cardiovascular and respiratory mortality and
28   cases per 100,000 relevant population related to Os concentrations that just  meet the current 8-hr
29   Os standard, based on multi-city models which include a single-pollutant versus multi-city
30   models with multiple pollutants from Huang et al. (2004) across all locations for which such
31   models were available. Table 5-11 shows estimates of incidence, incidence per 100,000 relevant
32   population, and percent of total incidence of cardiovascular and  respiratory mortality related to
33   Os concentrations above background that just meet the current 8-hr standard in all risk
34   assessment locations covered in Huang et al. (2004), based on both single-city and multi-city
35   models from that study. Estimates of Os-related cardiovascular  and respiratory mortality ranged
36   from 0.2 per 100,000 relevant population in Houston (using both the single-city and the multi-
     November 2005                          5-60                  Draft - Do Not Quote or Cite

-------
 1    city concentration-response functions) to 1.0 per 100,000 relevant population in Philadelphia
 2    (using the single-city concentration-response function).  As a percent of total incidence,
 3    estimated Os-related cardiovascular and respiratory mortality ranged from 0.3 percent in Chicago
 4    (using the single-city function) to 0.8 percent in Los Angeles (using the multi-city function) and
 5    Philadelphia (using the single-city function).
 6          The staff notes that all  of the estimates of Os-related cardiovascular and respiratory
 7    mortality based on Huang et al. (2004), from both single-pollutant and multi-pollutant models
 8    (see Figure 5-10) and from both single-city and multi-city models (see Figure 5-9and Table 5-11)
 9    were positive.
10          Table 5-12 shows estimates of unscheduled hospital admissions for both respiratory
11    illness and asthma in New York City associated with Os levels above background for the period
12    from April to September with air quality adjusted to just meet the current 8-hr standard.  For
13    total respiratory illness, Table  5-12 shows about 450 cases or 5.6 cases per 100,000 relevant
14    population, which represents 1.3% of total incidence for recent (2004) Os levels.  For asthma-
15    related hospital admissions, which are a subset of total respiratory illness admissions, the
16    estimates are about 380 cases or 4.8 cases per 100,000 relevant population, which represents
17    about 2.9% of total incidence.  The reduction in incidence for both total respiratory illness and.
18    asthma admissions from the recent Os levels to air quality just meeting the current 8-hr standard
19    is about  19%. Staff also notes that the estimates for this health endpoint for New York City are
20    higher than the estimates in the risk assessment conducted during the prior Os NAAQS review
21    which used the same concentration-response function. The main reason for this is the use of, a
22    single value of 0.04 ppm for background which is higher than the current modeled values for
23    background in the current assessment and, thus Os levels below 0.04 ppm are contributing
24    additional estimated cases in the current assessment
25

26          5.4.3   Just Meeting Alternative Ozone Standards [to be included in next draft of
27                 Staff Paper]
28

29          5.4.4   Key Observations [to be included in next draft of Staff Paper]
30                                                          •                 .
31
     November 2005                          5-61                  Draft - Do Not Quote or Cite

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38  ,

39


40

41
      November 2005                              5-65                    Draft - Do Not Quote or Cite

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 1             6.   STAFF CONCLUSIONS AND RECOMMENDATIONS ON
 2                                  PRIMARY O3 NAAQS
 3   6.1    INTRODUCTION
 4          This chapter presents preliminary staff conclusions as to whether consideration should be
 5   given to revising the existing primary 63 standard and, if so, what alternative standards should be
 6   considered for additional exposure and risk assessments beyond those presented in Chapters 4
 7   and 5. The results of these additional assessments will then be used to inform the staff
 8   recommendations on the primary Oa NAAQS to be included in the next draft Staff Paper.
 9          The existing 63 standard is an 8-hour standard set to protect public health from short-
10   term and prolonged exposures to Os.  The standard is defined in terms of four basic elements:
11   indicator, averaging time, level and form. Preliminary staff conclusions on this standard and on
12   alternatives' for additional analyses are based on the assessment and integrative synthesis of
13   information presented in the draft CD and on initial staff analyses and evaluations presented in
14   Chapters 2 through 5 herein. As noted in Chapter 1, staff conclusions and recommendations
15   presented in the next draft Staff Paper will be further informed by consideration of the
16   information and analyses in the final CD, additional staff analyses and the results of the
17   completed population exposure and human health risk assessments, and CAS AC and public
18   comments received on this draft.
19          Staff notes that the final decision on retaining or revising the current standard is largely a
20   public health policy judgment. A final decision must draw upon scientific information and
21   analyses about health effects, population exposure, and risks, as well as judgments about how to
22   deal with the range of uncertainties that are inherent in the scientific evidence and analyses. The
23   staffs approach to these judgments, discussed more fully below, is based on a recognition that
24   the available health effects evidence generally reflects a continuum consisting of ambient levels
25   at which scientists generally agree that health effects are likely to occur through lower levels at
26   which the likelihood and magnitude of the response become increasingly uncertain.  This
27   approach is consistent with the requirements of the NAAQS provisions  of the Act and with how
28   EPA and.the courts have historically interpreted the Act. These provisions require the
29   Administrator to establish primary standards that, in the Administrator's judgment, are requisite
30   to protect public health with an adequate margin of safety. In so doing, the Administrator seeks
31   to establish standards that are neither more nor less stringent than necessary for this purpose.
32   The Act does not require that primary standards be set at a zero-risk level but rather at a level
33   that avoids unacceptable risks to public health.
     November 2005                            6-1                Draft - Do Not Quote or Cite

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 1    6.2    APPROACH
 2          In evaluating whether the current primary standard is adequate or whether consideration
 3    of revisions is appropriate, and in developing recommendations on the elements of possible
 4    alternative standards for further analyses, staffs approach in this review builds upon the general
 5    approach used in the last review by expanding the exposure and risk assessments to reflect the
 6    larger body of evidencenow available.  The 1997 final decision notice (62 FR 38861) outlined
 7    the key factors considered in selecting the elements of a standard for 63: the averaging time; 03
 8    concentration (i.e., level); and the form (i. e., the air quality statistic to be used as a basis for
 9    determining compliance with the standard).  These factors represent an integration of
10    information on acute and chronic health effects associated with exposure to ambient Oj, expert
11    judgment on the adversity of such effects on individuals; and policy judgments, informed by air
12    quality, exposure assessment, and quantitative risk assessment when possible, as to the point at
13    which the standards are requisite to protect public health with an adequate margin of safely. This
14    approach to selecting a primary standard was endorsed by CASAC in the last review (Wolff,
15    1995b), particularly through its advice that "EPA's risk assessments must play a central role in
16    identifying an appropriate level" and recognition that "the selection of a specific level and [form]
17    is a policy judgment."
18          In developing these preliminary conclusions on the Os standard, staff has taken into
19    account evidence-based considerations primarily by assessing the evidence from
20    epidemiological, controlled human exposure, animal toxicological and field studies for a variety
21    of health endpoints.  For those endpoints based on epidemiological studies, staff has placed
22    greater weight on associations with health endpoints that the draft CD has judged to be likely
23    causal based on an integrative synthesis of the entire body of evidence, including not only all
24    available epidemiological evidence but also evidence from animal toxicological and controlled
25    human exposure studies. Less weight is given to evidence of associations that are judged to be
26    only suggestive of possible causal relationships, although we have taken this information into
27    account as part of margin of safety considerations.  For the purpose of evaluating the level of the
28    Oa standard in this review, staff has placed greater weight on U.S. and Canadian studies
29    reporting statistically significant associations. This is because findings of U.S. and Canadian
30    studies are more directly applicable for quantitative considerations in this review, since studies
31    conducted in other countries may well reflect quite different populations and air pollution
32    characteristics.
33          Staff has also taken into account quantitative exposure- and risk-based considerations,
34    drawn from the results of the exposure and risk assessments conducted in as many as twelve
35    urban areas (discussed in Chapters 4 and 5).  More specifically, staff has considered estimates of
36    the magnitude of Os-related exposures and risks associated with current air quality levels, as well

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 1    as the exposure and risk reductions likely to be associated with meeting the current 8-hour
 2    primary Os NAAQS.  Staff recognizes the considerable uncertainties inherent in such estimates,
 3    and, as described in Chapters 4 and 5, will take such uncertainties into account by considering
 4    the sensitivity of the exposure and risk estimates to alternative assumptions likely to have
 5    substantial impact on the estimates.
 6           In mis review, as in the previous review,  a series of general questions frames staffs
 7    approach to reaching conclusions and recommendations, based on the available evidence and
 8    information, as to whether consideration should be given to retaining or revising the current
 9    primary Cb standard.  Staffs preliminary review of the adequacy of the current standards begins
10    by considering whether the currently available body of evidence assessed in the draft CD
11    suggests that revision of any of the basic elements of the standards would be appropriate. More
12    specifically, mis evaluation of the adequacy of the current standard involves addressing
13    questions such as the following:
14         •  To what extent does newly available information reinforce or call into question
15            evidence of associations with effects identified in the last review?
16         •  To what extent does newly available information reinforce or call into question any of
17            the basic elements  of the current standards?

18         •  To what extent have important uncertainties identified in the last review been reduced
19            and have new uncertainties emerged?
20    To the extent that the evidence suggests that revision of the current standards would be
21    appropriate, staff then considers whether the currently available body  of evidence supports
22    consideration of standards that are either more or less protective by addressing the following
23    questions:
24         •  Is mere evidence that associations, especially likely causal associations, extend to air
25            quality levels mat are as low as or lower than had previously been observed, and what
26            are the important uncertainties associated with that evidence?
27         •  Are exposures of concern and health risks estimated to occur in areas that meet the
28            current standard; are they important from a public health perspective; and what are the
29            important uncertainties associated with the estimated risks?
30    To the extent that mere is support for consideration of revised standards, staff then identifies
31    ranges of standards (in terms of indicators, averaging times, levels and forms) that would reflect
32    a range of alternative public health policy judgments, based on the currently available evidence,
33    as to the degree of protection that is requisite to protect public health with an adequate margin of
34    safety.  In so doing, staff addresses the following questions:
35         •  Does the evidence provide support for  considering a different Os indicator?

      November 2005                            6-3               Draft - Do Not Quote or Cite

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 1         •  Does the evidence provide support for considering different averaging times?

 2         *  What ranges of levels and forms of alternative standards are supported by the evidence,
 3            and what are the uncertainties and limitations in that evidence?

 4         •  To what extent do specific levels and forms of alternative standards reduce the
 5            estimated exposures of concern and risks attributable to Oa, and what are the
 6            uncertainties in the estimated exposure and risk reductions?
 7    In this draft Staff Paper, staff develops preliminary recommendations on alternative standards to
 8    be analyzed in additional exposure and risk assessments that will in turn be considered in the
 9    next draft Staff Paper to help inform staff conclusions and recommendations as to whether
10    consideration should be given to retaining or revising the primary Oa NAAQS.  The primary
11    standard for Oa is addressed in section 6.3 below, beginning with staffs consideration of the
12    adequacy of (he current primary Os standard in subsection 6.3.1. Subsequent subsections address
13    each of the major elements that define the Oa standard: pollutant indicator, averaging time, form
14    and level. This chapter concludes with a summary of alternative standards to be considered in
15    additional exposure and risk assessments in section 6.3.6. An additional section summarizing
16    key uncertainties and recommendations for additional research related to setting a primary  0^
17    standard will be included in the next draft Staff Paper.

18    63    PRIMARY O3 STANDARD

19          6.3.1   Adequacy of Current O3 Standard
20          In me last review, an important input to the primary NAAQS decision was the evidence
21    from human controlled exposure studies of healthy young subjects exposed for 1 to 8 hours.  The
22    best documented health endpoints in these studies were decrements in forced expiratory volume
23    (FEV), also known as lung function decrements, and respiratory symptoms,  such as cough  and
24    chest pain on deep inspiration.  For short-term exposures of one to three hours, group mean FEV
25    decrements were statistically significant for Oa concentrations only at and above 0.12 ppm, but
26    only when subjects engaged in very heavy exercise. By contrast, prolonged exposures of six to  ,
27    eight hours can produce statistically significant FEV decrements at the lowest Oa concentrations
28    evaluated in studies, 0.08 ppm,  even when  experimental subjects are engaged in more realistic
29    intermittent moderate exercise levels.  The health significance of this newer evidence led to the
30    conclusion in the 1997 final decision (62 FR 38856) that "the 8-hour averaging time is more
31    directly associated with health effects of concern at lower Oa concentrations than is .the 1 -hour
32    averaging time."
33          Also of particular importance in the last review were the following observations: (1) the
34    then-existing 1-hour standard provided little, if any, margin of safety for public health protection;
     November 2005
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 1    (2) there was clinical evidence of statistically significant responses at 6- to 8-hour exposures to
 2    the lowest concentration evaluated, 0.08 ppm Oa, at moderate exertion, including: lung function
 3    decrements, respiratory symptoms (e.g., cough, pain on deep inspiration), nonspecific bronchial
 4    responsiveness, and biochemical indicators of pulmonary inflammation; (3) there was
 5    epidemiological evidence of associations between ambient Os and increased respiratory hospital
 6    admissions and emergency room visits; (4) toxicological evidence suggested that repeated long-
 7    term exposures to Oa-induced lung tissue damage in experimental animals; however, uncertainty
 8    regarding dosimetry and species sensitivity differences limited the quantitative use of these data;
 9    and (5) concentration-based forms, within the range considered up to the fifth-highest
10    concentration form, were considered appropriate for a health-based primary Oj standard.  This
11    form of the standard reflected recognition "... that Oa exhibits a continuum of effects, such that
12    there is no discernible threshold above which public health protection requires that no exposures
13    be allowed or below which all risks to public health can be avoided." (62 FR 38856) In making
14    the final decision in the last review, the Administrator recognized that important uncertainties
15    remained with regard to interpreting the role of other pollutants co-occurring with Oa, biological
16    mechanisms of health effects, human exposure, and quantitative risk assessment of the health
17    endpoints analyzed.
18           63.1.1      Evidence-based Considerations
19           Since the last review, important new information on O3-related health effects has
20    emerged, including new findings from:
21        ' •  Dosimetry studies that clarify factors potentially affecting the regional distribution of
22            Oa in the respiratory tract and that provide improved bases for animal-to-human
23            extrapolation of experimental results.
24         •  Experimental toxicological studies using controlled exposures of humans and
25            laboratory animals to  delineate exposure-response relationships and the biochemical
26            mechanisms underlying the toxic effects, pathology and susceptibility.

27         •  Epidemiological studies that provide important information about real-world exposures
28            and the effects of Os, including premature mortality, hospital admissions, emergency
29            room and doctors visits, on the general population, as well as in susceptible
30            populations, and that address many research needs identified during the last review.
31    The new evidence about (Vrelated effects on respiratory morbidity, cardiovascular morbidity
32    and total, as well as cardiovascular and respiratory, mortality is discussed below.
33             6.3.1.1.1   Respiratory Morbidity
34           As described in the draft CD (CD, section 8.4) and in Chapter 3 above, the integrative
35    assessment of these studies continues to support a causal association between short-term Oa
      November 2005                            6-5                Draft - Do Not Quote or Cite

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 1    exposures and lung function decrements, respiratory symptoms and pulmonary inflammation that
 2    were the most important basis for revising the 63 NAAQS in 1997. Statistically significant
 3    associations between of lung function decrements and respiratory symptoms were found in
 4    epidemiological studies even where the 98ttl/99lh percentile1 air quality values are well below the
 5    level of the current standard.  Not only are the newer findings consistent with the previous
 6    review, but also there is better evidence about the physiological mechanisms by which Os causes
 7    these effects.  For all of these health endpoints, there exist considerable inter-individual
 8    differences  in the magnitude of responses to 0$.  Inter-individual differences in lung function
 9    and, to a lesser extent, respiratory symptoms are reproducible over a period of time, indicating
10    that some individuals are.consistently more responsive than others to Os. Identification of
11    population groups that are at increased risk to 0% due to either increased susceptibility or
12    increased potential for exposure, is based on their (1) biological responses to Oa, (2) existing
13    lung disease, (3) activity patterns, and/or (4) personal factors (e.g., age, nutritional status).
14          Newer information expands understanding of the physiological basis for increased
15    sensitivity in people with asthma. Newer studies continue to indicate that, relative to healthy
16    controls, people with asthma have somewhat larger decreases in pulmonary function in response
17    to Os. (CD, p. 8-27) New evidence also indicates that people with asthma may have increased
18    occurrence and duration of nonspecific airway responsiveness, and that people with pre-existing
19    allergic asthma may have increased airway responsiveness to allergens following Os exposure.
20    (CD, p. 8-29) Newly available human exposure studies suggest that people with asthma may
21    also have increased inflammatory responses relative to non-asthmatic subjects. (CD, p. 8-73)
22    The majority of epidemiological panel studies that evaluated respiratory symptoms and
23    medication  use related to Os exposures focused on children. (CD, p. 8-44) These studies
24    suggest that Ch exposure may be associated with increased respiratory symptoms and medication
25    use in children with asthma. Taken together, these findings suggest that 63 exposure may be a
26    clinically important factor for people with asthma that can exacerbate the response to ambient
27    bronchoconstrictor substances and increase respiratory morbidity and possibly mortality (as
28    discussed further below).
29          At the time of the last review there was some epidemiological evidence of associations
30    between ambient Os and increased respiratory hospital admissions and emergency room visits
31    and only very limited evidence of associations for school absences and premature mortality.
32    Since the last review of the O3 standard, additional epidemiological studies have evaluated the
33    association  between short-term exposures to Os  and hospital admissions for respiratory causes.
             1 The reason for using percentile values to describe maximum concentrations in the data from ozone studies
      is discussed more fully in the footnote to Appendix 3A and in the section on the form of the standard below.

      November 2005                             6-6                Draft - Do Not Quote or Cite

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 1    Large multi-city studies as well as several individual city studies (CD, Figure 8-5) have reported
 2    positive, often statistically significant associations with total respiratory, asthma and COPD
 3    hospitalizations, with statistical significance more often found in those studies that analyzed the
 4    effect of 63 during the warm season.  The draft CD indicates 1hat despite some inconsistencies
 5    noted across the studies, the collective evidence supports the finding of significant and robust
 6    effects of Os on respiratory hospitalization outcomes.
 7          Although many new studies have evaluated the association between ambient 63 levels
 8    and emergency department visits for respiratory causes, the evidence is still unclear.  In general,
 9    Os effect estimates from summer only analyses tended to be positive and larger, and the
10    estimates were more likely to be statistically significant, compared to results from cool season or
11    all year analyses. (CD, section 7.3.2, Figure 8-5) While several studies observed significant
12    associations between Os concentrations and emergency department visits for respiratory causes,
13    inconsistencies were observed which were at least partially attributable to differences in model
14    specifications and differences in the analyses.  Because of this, the draft CD concludes that the
15    evidence remains inconclusive regarding effects of Os on the risk of emergency department
16    visits.
17          With regard to school absenteeism, two large U.S. studies and one study from Seoul,
18    Korea have investigated the relationship between ambient Os and this effect.  All of the studies
19    found statistically significant positive associations between Os levels and absences from school.
20    Because of differences in the analyses, the draft CD concludes that results from these three
21    studies suggest that ambient Os concentrations may be associated with school absences,
22    especially illness-related absences. Additional studies and analyses using similar lag periods are
23    needed to more clearly delineate quantitative relationships between ambient Os and school
24    absences. (CD, p. 8r45)
25             6.3.1.1.2          Cardiovascular Morbidity
26          There is limited, new evidence supporting associations between short-term Os exposures
27    and a range of effects on the cardiovascular system.  An increasing body of animal toxicology
28    evidence suggests that hematological and thermoregulatory alterations (in heart rate variability
29    and/or core body temperature) may mediate acute cardiovascular effects. A few controlled
30    human exposure studies have examined the potential effects,of O3 exposure on cardiovascular
31    functions.  These studies have reported impairment of alveolar-arterial oxygen transfer and Os-
32    induced ventilation-perfusion mismatch, suggesting gas exchange abnormalities that  could affect
33    cardiac function. Some but not all, epidemiological studies have reported associations between
34    short-term Os exposures and the incidence of myocardial infarction and more subtle
35    cardiovascular health endpoints, such as changes  in heart rate variability and cardiac  arrhythmia.
      November 2005                            6-7                Draft - Do Not Quote or Cite

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 1    Based on epidemiological study results, the draft CD concludes that the current evidence from
 2    field studies is rather limited but supportive of a potential effect of short-term 03 exposure and
 3  *  heart rate variability, cardiac arrhythmia and incidence of myocardial infarction (CD, p. 7-57).
 4          A subset of hospital admission studies examined the effect of Oa exposure on
 5    cardiovascular outcomes. The evidence is inconclusive on the association between Os exposure
 6    and cardiovascular hospitalizations with regard  to year-round data. However, the draft CD
 7    concludes that in studies that adjusted for  seasonal or meteorological factors, there is suggestive
 8    evidence that 63 is associated with increased risk for cardiovascular hospital admissions in the
 9    warm season. (CD, p. 8-48) Studies also report associations between short-term Oa exposure and
10    mortality from cardiovascular or cardiopulmonary  causes (as discussed further below).
11             6.3.1.1.3   Mortality
12          The 1996 CD concluded that an association between daily mortality and Oa concentration
13    for areas with high Oa levels (e.g., Los Angeles) was suggested.  However, due to a very limited
14    number of studies  available at that time, the magnitude of rne effect was unclear. Since 1996,
15    newly available large multi-city studies designed specifically to examine the effect of Oa on
16    mortality have provided much more robust and  credible information. New data are also
17    available from several single-city studies conducted all over the world, as well as from several
18    meta-analyses that have combined information  from multiple studies. The majority of these
19    studies suggest an  elevated risk of total non-accidental mortality associated with acute exposure
20    to Oa, especially in the summer or warm season when Oa levels are typically high, with
21    somewhat larger effect estimate sizes for associations  with cardiovascular mortality. (CD, p. 7-
22    149) Some of the  single city studies with  positive and statistically significant results have 98th or
23    99th percentile air quality values well below the level of the current 8-hour Oa standard.
24    (Appendix 3A) The draft CD finds that the results from U.S. multi-city time-series studies,
25    along with the meta-analyses, provide strong evidence for associations between short-term Oa
26    exposure and mortality.  (CD, p. 7-84) The results of these analyses show that the effects  of
27    ozone on mortality are generally robust to confounding by copollutants. (CD, p. 7-149, 8-54)
28    For cardiovascular mortality, the draft CD reports that effect estimates are consistently positive,
29    and are more likely to be larger and statistically significant in the warm season analyses. (CD, p.
30    7-108, Figure 7-22)  The findings regarding the effects size for respiratory mortality have been
31    less consistent, possibly  due to lower statistical  power in this group.  (CD, p. 7-94)  Overall, the
32    draft CD concludes that these findings suggest a causal association between short-term Oa
33    exposure and mortality particularly in the  warm season.  (CD, p. 8-84)

34            6.3.1.2      Risk-based Considerations
35          In discussing risk-based considerations,  this section will focus first on the results of the
36    exposure assessment and then on the results of the risk assessments that were based on clinical   .
37    and epidemiological evidence.  As described in  Chapter 4, for this review estimates of exposures
     November 2005
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 1   were calculated for active people of all ages, school age children (ages 5-18), and "active" school
 2   age children.2 For the initial exposure analyses in this review, an "exposure of concern" was
 3   defined the same way as in the previous review. -An "exposure of concern," as defined in the
 4   1997 review of the O3 standard, is an 8-hour average exposure to 0.08 ppm O3 while
 5   intermittently at moderate or greater exertion levels. (62 FR 38860) Exposure results are
 6   displayed in Tables 4-7 and 4-8 for daily maximum 8-hour average exposures above 0.08 ppm
 7   O3, in 12 urban areas across the U.S., for two cases (i.e., recent (2004) air quality, and just
 8   meeting Hie 8-hour primary standard), at moderate or greater exertion levels for three groups:
 9   active people of all ages; all school age children; and active school age children. Estimates,
10   aggregated across these 12 urban areas of the number of people exposed, in each of the three
11   groups, and the number of person-days (occurrences) of exposures, with daily maximum 8-hour
12   average exposures above 0.08 ppm while at moderate or greater exertion, are shown in Table 6-1
13   below.3
14          Under the recent (2004) air quality scenario, 1.6 million people, or 2 % of the total
15   population of the 12 urban areas, are estimated to experience one or more exposures of concern.
16   More than' 600,000 children, or'3% of the total number of children ages 5-18, and almost
17   400,000 active children, or 4 % of active children ages 5-18, are estimated to experience one or
18   more exposures of concern. When air quality is adjusted  to simulate just meeting the  8-hour
19   standard, the number of people exposed drops substantially.  Approximately 50,000 people, or
20   less than 0.1% of the total population of the 12 urban areas, are estimated to experience  one or
21   more exposures of concern. Approximately 17,000 children (< 0.1 % of all children) and 11,000
22   active children (0.1 % of active children) are estimated to experience exposures of concern when
23   air quality just meets the 8-hour standard. These results suggest a substantial reduction in
24   estimated 8-hour average exposures above 0.08 ppm when the current 8-hour O3 standard is just
25   met. The estimated reduction in the number of total occurrences of exposures of concern in
26   these 12 urban areas was more than 97% in each of the three population groups. Moreover, a'
27   comparison of the number of people exposed with the number of occurrences indicates that very
28   few people are likely to be exposed more than one time during the O3 season. Under the current
29   standard it is estimated to be rare for individuals to experience more than one 8-hour exposure
30   above 0.08 ppm O3 while at moderate or greater exertion levels in these 12 urban areas during an
31   O3 season with air quality similar to 2004.
             2As indicated in section 4.4.3 above, "active" school age children were defined as those with a physical
      activity index>\.75.
             3For greater discussion of the analyses and a breakdown of exposures by city, see Chapter 4.

      November 2005                             6-9                Draft - Do Not Quote or Cite

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 1          Several aspects of the risk information presented are important to consider. The first is
 2   that there is some degree of consistency in the estimated population risk across the 12 urban
 3   areas, as indicated by the percent of the population estimated to be affected, which describes the
 4   risk normalized across the populations. In Table 6-2, the percent of the all children likely to
 5   experience one or more moderate or greater lung function responses under recent (2004) air
 6   quality and when air quality just meets the current 8-hour standard are 10% and 6%,
 7   respectively. The range across the 12 urban areas, from Table 5-5, is about 7% to 13% under the
 8   recent (2004) air quality, and about 5% to 8 % when air quality just meets the current 8-hour
 9   standard. More than one million children are estimated to experience one or more moderate or
10   greater lung function responses in these 12 urban areas when the current 8-hour primary standard
11   is met.  Many of these children will experience repeated occurrences of moderate or greater lung
12   function responses. These results indicate that each of these children is likely to .experience, on
13   average, 7 occurrences of moderate or greater lung function responses during an Os season.4
14   However, based on the distribution of exposures estimated from the 1997 review, the more likely
15   distribution will be that many children will experience one or a just few moderate or greater lung
16   function responses, while a smaller number of children will experience large numbers of such
17   responses. This range of estimated number of occurrences (i.e., from one to many, with a mean
18   of approximately 7) of moderate or greater lung function decrements in an Os season is
19   important in considering the implications for the health status of individuals likely to experience
20   these effects. Moderate or greater lung function decrements are transient and reversible, so the
21   extent to which such effects are considered to be adverse to the health status of the individual
22   depends not only on the severity and duration of the effect, but also on the frequency with which
23   an individual experiences such effects throughout an Os season. (62 FR 38864)
24          For non-accidental mortality associated with "as is" O3 concentrations (Table 5-7), the
25   estimates of the percent of total mortality attributable to Os exposure ranges from 0.1 to 1.9%;
26   with an incidence per 100,000 relevant population ranging from 0.4 to 7.3.  Estimated non-
27   accidental mortality associated with Os concentrations that just meet the current 8-hour standard
28   (Table 5-10) ranges from 0.1 to 1.5% of total incidence; with an incidence per 100,000 relevant
29   population ranging from 0.3 to 5.7. Estimated cardiovascular and respiratory mortality shows a
30   similar pattern (Tables 5-8, 5-11).  For a recent year (2004) of Os  concentrations, the estimates of
31   the percent of cardiovascular and respiratory mortality attributable to 63 ranges from 0.4 to
32    1.6%; the incidence per 100,000 relevant population ranges from  0.4 to 1.3. Estimated
33   cardiovascular and respiratory mortality associated with 63 concentrations that just meet the
             4 This number is estimated for example for all children, by dividing the estimated number of children
      (1,156,000) into the estimated number of occurrences (7,640,000) resulting in an average of 7 occurrences per child.

      November 2005                            6-13               Draft - Do Not Quote or Cite

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 1    current 8-hour Os standard ranges from 0.2 to 0.8% of total incidence; with the incidence per
 2    100,000 relevant population ranging from 0.2 to 0.9.
 3           For unscheduled hospital admissions, risk estimates for the New York City area are
 4    shown in Table 5-9 .for recent (2004) air quality, and Table 5-12 for just meeting the current 8-
 5    hour standard. Table 5-9 shows estimates of unscheduled hospital admissions for respiratory
 6    illness in the New York City area associated with Oj levels above background of about 450 cases
 7    or 5.6 cases per 100,000 relevant population, which represents 1.3% of total incidence for recent
 8    (2004) Oa levels. For asthma-related hospital admissions, the estimates are about 380 cases or
 9    4.8 cases per 100,000 relevant population,- which represents about 2.9% of total incidence. Table
10    5-12 shows estimates of unscheduled hospital admissions for both respiratory illness and asthma
11    in New York City associated with Oj levels above background for the period from April to
12    September with air quality adjusted to just meet the current 8-hr standard.  For total respiratory
13    illness, Table 5-12 shows about 450 cases or 5.6 cases per 100,000 relevant population, which
14    represents 1.3% of total incidence for recent (2004) Os levels.  For asthma-related hospital
15    admissions, which are a subset of total respiratory illness admissions, the estimates are about 380
16    cases or 4.8 cases per 100,000 relevant population, which represents about 2.9% of total
17    incidence.  The reduction in incidence for both total respiratory illness and asthma admissions
18    from the recent O? levels to air quality just meeting the current 8-hr standard is about 19%.
19            6.3.1.3       Summary
20           These initial analyses suggest that meeting the current 8-hour C*3 standard would likely
21    result in substantial reductions in exposures of concern and associated risks of serious health
22    effects above a level of 0.08 pprh 03. On the other hand, these analyses also suggest that there is
23    risk of moderate or greater lung function decrements in children, hospital admissions, and
24    mortality from Os resulting from exposures  across the range of levels allowed by the current
25    standard. Staff concludes that the estimates discussed above are indicative of risk that some
26    might reasonably judge to be important from a public health perspective. Thus, staff believes
27    that it is appropriate to perform additional analyses so as to be able to consider the potential
28    reduction in exposures and risks from alternative standards that may provide more health
29    protection beyond that afforded by the current Os primary standard.
30           6.3.2  Indicator
31           The staff believes that the conclusions on the appropriate indicator for the primary Oa
32    NAAQS that were reflected in the 1996 Staff Paper remain valid today. It is generally
33    recognized that control of ambient Os levels provides the best means of controlling
34    photochemical oxidants of potential health concern.  Further, among the photochemical oxidants,
35    the acute exposure chamber, panel and field epidemiological human health database raises   .
      November 2005
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 1    concern only for Os at levels of photochemical oxidants commonly reported in the ambient air.
 2    Thus the staff does not believe that it is appropriate to consider any other indicator for additional
 3    analyses.

 4          6.3.3   Averaging Time

 5           63.3.1      Short-Term and Prolonged (1 to 8 hours)
 6          The current 8-hour averaging time for the primary Oj NAAQS was set in 1997.  The
 7    decision to revise the averaging time of the primary standard from 1 to 8 hours was supported by
 8    the following key observations and conclusions (62 FR 38861):
 9          (1) The 1-hour averaging time of the previous NAAQS was originally selected on the
10    basis of health effects associated with short-term (i.e., 1 - to 3-hour) exposures.
11          (2) Substantial health effects information was available for the 1997 review that
12    demonstrated associations between a wide range of health effects (e.g., moderate to large lung
13    function decrements, moderate to severe symptoms and pulmonary inflammation) and prolonged
14    (i.e., 6- to 8-hour) exposures below the level of the NAAQS.
15          (3) Results of the quantitative risk analyses showed that the reductions in risks from both
16    short-term and prolonged exposures could be achieved through a primary  standard with an
17    averaging period of either 1 or 8 hours.
18          (4) The 8-hour averaging time is more directly associated with health effects of concern
19    at lower Os concentrations than the 1 -hour averaging time. It was thus the consensus of CAS AC
20    "that an 8-hour standard was more appropriate for a human health-based standard than a 1-hour
21    standard." (Wolff, 1995b)
22          In looking at the new information that is discussed in section 7,6.2 of the draft CD,
23    epidemiological studies have used various averaging periods for  Os  concentrations, most
24    commonly 1-hour,  8-hour and 24-hour averages. As described more specifically below, in
25    general the results presented from U.S. and Canadian studies (Appendix 3A) show no consistent
26    difference for various averaging times in different studies.
27          Only a few studies presented results for different Os averaging periods using the same
28    data set. Two of the recent multi-city mortality studies reported associations for multiple
29    averaging times (Bell et al., 2004; Gryparis et al., 2004). Both reported that the effect estimates
30    for different averaging times were not statistically different, though the effect estimates for
31    associations with 1-hour daily maximum OB concentrations were somewhat larger than those for
32    longer averaging times, especially 24-hour average Os.  In addition, Gent  et al., (2003) reported
33    that associations for 1-hour and 8-hour average OB with respiratory symptoms were not
34    significantly different.
     November 2005                           6-15              Draft - Do Not Quote or Cite

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  1          Among the single-city epidemiological studies, Peters et al. (2001) reported positive, but
  2    not statistically significant associations between Os and the incidence of myocardial infarction
  3    (CD, p. 7-55); this study differs from most since the short-term Os concentration used was the
  4    time period preceding the health event, not the highest daily short-term average concentration.
  5    The effect estimate for the association with Os averaged over 2 hours prior to the myocardial
  6   .infarction was substantially larger than that reported for an association with 24-hour average Os
  7    (Peters et al., 2001).  The draft CD reports results for a number of single-city results that
  8    generally reported effect estimate sizes that were larger when comparing 1-hour or 8-hour daily
  9    maximum Os concentrations with 24-hour concentration, but the results did not differ
10    statistically (CD, p. 7-120).
11          The CD observes that the various Os average concentrations were generally very highly
12   'correlated with one another, so it is not surprising that effect estimates would be similar. The •
13    draft CD concludes that the epidemiological study results were generally comparable for the
14    three Os averaging times (CD, p. 7-120). Given that the 8-hour averaging time continues to be
15    more directly associated with health effects of concern from controlled human exposure studies
16    at lower concentrations than do shorter averaging periods, staff concludes that it is appropriate to
17    continue to base any  additional exposure and risk analyses for short-term or prolonged effects on
18    8-hour average Os concentrations.

19           63.3.2      Long-Term
20      •    For consideration during the last review, there was a large animal toxicological database
21    providing clear evidence of associations between long-term (e.g., from several months to years)
22    exposures and lung tissue damage, with additional evidence of reduced lung elasticity and
23    accelerated loss of lung function, but there was no corresponding evidence for humans.
24    Furthermore, the state of the science had not progressed sufficiently to allow quantitative
25    extrapolation of the animal study findings to humans. For these reasons, consideration of a
26    separate long-term primary Os standard was not judged to be appropriate at that time.
27          In the current review, long-term animal toxicological studies continue to support the
28    relationship between Os exposure and structural alterations in several regions of the respiratory
29    tract and identify the CAR as the most affected region. In addition, animal'toxicological studies
30    that utilized exposure regimens to simulate seasonal exposure patterns also report increased lung
31    injury compared to conventional long-term, stable exposures. (CD, p. 8-85) Collectively, the
32    evidence from animal studies strongly suggest that Os is capable of damaging the distal airways
33    and proximal alveoli, resulting in lung tissue remodeling leading to apparently irreversible
34    changes. Compromised pulmonary function and structural changes due to persistent
35    inflammation may exacerbate the progression and  development of chronic lung disease. (CD, p.
     November 2005                           6-16              Draft - Do Not Quote or Cite

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 1    8-70)  There is also some new information about the effects of long-term exposures in humans.
 2    Epidemiological studies investigating chronic effects in humans following long-term exposures
 3    to Os previously provided only limited suggestive evidence; however, recent studies of
 4    pulmonary function changes observed in children living in cities with high Os levels as well as
 5    alterations in lung structure reported in an autopsy study in Los Angeles and Miami provide
 6    additional evidence that long-term Os exposure may play a role in causing irreversible lung
 7    damage. However, the strength of the evidence overall does not allow establishment of a likely
 8    causal relationship between long-term Os exposures and increased respiratory morbidity and
 9    mortality. In addition, although there have been recent advancements of do'simetry modeling,
10    providing a better basis for extrapolation, especially of long-term exposures, from animals to
11    humans (CD, p. 8-11), further research must be conducted before quantitative linkages to
12    specific health effects in humans can be established with sufficient certainty to include in a
13    quantitative manner in the review. For these reasons, staff concludes that it is not appropriate at
14    this time to base any exposure or risk assessments on long-term exposures to Os.

15           63.4   Form
16           In evaluating alternative forms for the  primary standard, the adequacy of the public health
17    protection provided is the foremost consideration. Staff recognizes that it is important to have a
18    form of the standard that is stable and insulated from the impacts of extreme meteorological
19    events that are conducive to Os formation. Instability can have the effect of reducing public
20    health protection, because when areas are subject to shifting in and out of attainment simply
21    because of meteorological conditions it can disrupt  ongoing implementation plans and associated
22    control programs. Providing more stability is  one of the reasons that in 1997 the primary Os
23    NAAQS was changed from a "1-expected-exceedance" form5 to a less extreme, concentration-
24    based statistic, specifically the 3-year average of the annual fourth-highest daily maximum 8-
25    hour concentrations. The principal advantage of the concentration-based form is that it is more
26    directly related to the ambient Os concentrations that are associated with the health effects. With
27    a concentration-based form, days on  which higher Os concentrations  occur would weigh
28    proportionally more than days with lower concentrations, since the actual concentrations are
29    used in determining whether the standard is attained. That is, given that there is a continuum of
30    effects associated with exposures to varying levels of Os, the extent to which public health is
31    affected by  exposure to ambient Os is related to the actual magnitude of the Os concentration, not
32    just whether the concentration is above a specified level.
             The 1-expected-exceedance form essentially requires that the fourth-highest air quality value in 3 years,
      based on adjustments for missing data, to be less than or equal to the level of the standard for the standard to be met
      at an air quality monitoring site.

      November 2005                            6-17              Draft - Do Not Quote or Cite

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 1          During the 1997 review, consideration was given to a range of alternative forms,
 2   including the second-, third-:, fourth- and fifth-highest daily maximum 8-hour concentrations,
 3   recognizing that the public health risks associated with exposure to a pollutant without a clear,
 4   discernable threshold are best addressed through a standard that allows for multiple exceedances
 5   to provide increased stability, but that also significantly limits the number of days on which the
 6   level may be exceeded and the magnitude of such exceedances.  Consideration was given to
 7   setting a standard with a form at the lower end of the range to provide a margin of safety  against
 8   possible, but uncertain chronic effects, or at the upper end of the range to provide greater
 9   stability to ongoing control programs.  The fourth-highest daily maximum was selected because
10   it was decided that the difference between the protection against potential chronic effects
11   afforded by the alternatives within the range was not well enough understood to. use as a basis for
12   choosing the most restrictive forms. On the other hand, the relatively large percentage of sites
13   that would experience Os peaks well above 0.08 ppm and the number of days on which the level
14   of the standard may be exceeded even when attaining a fifth-highest 0.08 ppm concentration
15   standard, argued against choosing that form.
16          For the purposes of making recommendations of alternative standards for additional
17   exposure and risk analyses, staff considered two concentration-based forms, the nth highest
18   maximum concentration and the percentile-based form of the standard. A percentile-based
19   statistic, as is used in Figure 6-la and b, is useful for comparing datasets of varying length
20   because it samples approximately the same place in the distribution of air quality values, whether
21   the dataset is several months or several years long. However, a percentile-based form would
22   allow more days with higher air quality values in locations with longer Os seasons relative to
23   places with shorter Os seasons.  An nth highest maximum concentration form would do a better
24   job of ensuring that people who live in areas with different length Os seasons receive the same
25   degree of public health protection.  For this reason, the staff recommends that further analyses be
26   based on a form specified in terms of an nth-highest concentration over a three-year period, with
27   n ranging from 3 to 5.  Staff believes that his range is sufficiently broad to allow for
28   consideration of the degree of protection requisite to protect public health and also to ensure
29   stability  of the standard.                          ;

30          6.3.5  Level
31          Since the last review, the body of evidence from animal toxicology and dosimetry
32   studies, controlled human exposure and epidemiological studies has confirmed associations
33   between exposure to Os and the effects that were the basis for the 1997 Os standard: lung
34   function decrements; symptoms; airway hyper-responsiveness; pulmonary inflammation; and
35   respiratory-related hospital admissions. New evidence has provided a better understanding of


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 1    the pathophysiological mechanisms of these effects.  This information has also provided new
 2    evidence of likely causal associations with more serious effects including associations between
 3    increasing Os concentrations and hospital admissions for respiratory causes and all cause (non-
 4    accidental) mortality. Positive, but inconclusive associations have been found, between ambient
 5    Os concentrations and respiratory symptoms, school absences, emergency department visits,
 6    cardiovascular system effects, and cardiovascular and respiratory mortality.
 7          Although it is reasonable to expect that there are biological thresholds for different health
 8    effects in individuals or groups of individuals with similar health status, most studies designed to
 9    evaluate the existence of a threshold have observed no deviation from a linear function across the
10    range of Os measurements from the study, as discussed above in Chapter 3^ section 3.4.6.  One
11    study found a potential threshold level of about 45 ppb (1 -hour maximum concentration) for an
12    association between mortality and short-term Oa exposure during the summer months. -Another
13    found some evidence of a threshold at about 30 ppb (1-hour maximum concentration) for the
14    association between Os concentrations and both respiratory and cardiovascular hospital
15    admissions. Other studies, such as ones that have removed days with higher concentrations of
16    Os from the data set to test the association between Os at lower levels and health outcomes have
17    found that associations remain or  are increased in magnitude. In summary, many
18    epidemiological studies have suggested that no threshold levels can be found. In those studies
19    that provide suggestive evidence of threshold, the potential thresholds are at low concentrations,
20    much lower than the current 8-hour standard.
21          Staff concludes that the results from the initial quantitative exposure and risk assessments
22    done to date suggest that sufficient population exposures and risk  of various health endpoints
23    (including pulmonary function decrements, all cause (non-accidental) and respiratory and
24    cardiovascular mortality, and respiratory hospital admissions) remain after meeting the current 8-
25    hour standard that additional analyses for standards below the level of the current 8-hour
26    standard are appropriate.  In addition to consideration of exposures and effects that are
27    quantifiable in population exposure and risk assessments, staff believes that it is also appropriate
28    to consider effects that it is not currently possible to quantify, for example the effects of chronic
29    Os exposure or the effects on people with asthma, to the extent these considerations would
30    ultimately cause closer examination of the lower end of the range, in developing
31    recommendations about alternative standards for further exposure and risk assessment.
32.         The question then becomes, what level or levels should be evaluated? To answer this
33    question, staff turns to epidemiological studies of associations between O3 and respiratory
34    symptoms and hospital admissions for respiratory causes from warm season analyses. (Figures
35    6-1 a and b) Not included in Figure 6-1, but also considered are the reported associations
36    between 8-hour average Oa levels and daily mortality (Appendix 3 A). All of these effects

      November 2005                            6-19              Draff -Do Not Quote or Cite

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 1    estimates are consistently positive and many of the reported associations are statistically
 2    significant.  In this body of evidence, small but statistically significant effects estimates have
 3    been reported in studies with 98th/99th percentile values as.low as approximately 0.06 ppm Oa, 8-
 4    hour average.  The information is presented in terms of the 98th and.99th percentile values
 5    because in the studies being  compared, the data spanned widely varying periods of time
 6          After consideration of the entire body of experimental and epidemiological evidence, the
 7    results of exposure and risk assessments and the consideration of non-quantifiable effects, such
 8    as the effects of repeated exposures-and potentially greater effects on people with asthma, it is
 9    staffs view that it is appropriate to conduct additional exposure and risk assessments down to an
10    alternative standard level as  low as 0.06 ppm.  The level of 0.06 ppm represents the lowest air
11    quality statistic credibly and significantly associated with increased respiratory morbidity effects
12    such as symptoms and hospital admissions, and also with daily mortality.
     November 2005
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1 Figui
2 (a)
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19 (b)
re 6-1 a and b
Odds Ratios (with 95% confidence intervals) for associations between O3
and respiratory symptoms, from warm season analyses, in order of
increasing 98th and 99th percentile 8-hr O3 concentrations (in boxes)
?5IJ
2.00
1.50 .
1.00
0.60
LEGEND:
S = asthma symptoms
MS= morning symptoms
ES = evening symptoms
MD = med use
CT = chest tightness
SB = shortness of breath
C = cough
W = wheeze
Effect estimate

64.3
66
.T
85.3
I 98

68.8 90''
75
. , \
S MS ES MD CT
C

107
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121

^
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-y- Mortimer et al., 2002. 6 US cities
W
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i s ill 1
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95% confidence intervals) for associations betwee
          O3 and hospitalization for respiratory diseases, in warm season analyses, in

          order of increasing 98th and 99th percentile 8-hr O3 concentrations (in boxes)


40 -

30 .


10 -
0 .
-10 .



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                                                                               ra
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                             + 98" percentile values not available; are ikely high-end concentrations based on data provided In study
November 2005
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 2          6.3.6  Summary of Alternative Standards to Be Considered in Additional Exposure
 3                and Risk Analyses
 4          Staff has considered the evidence from animal toxicology, epidemiological and
 5   controlled human exposure studies, estimates of exposures and risk for a recent (2004) year and a
 6   year when air quality is estimate to just meet the current 8-hour standard, and the related
 7   limitations and uncertainties. For the reasons described above, staff provisionally concludes that
 8   it is appropriate to conduct additional assessments of exposure and risk associated with
 9   alternative standards that may provide increased protection beyond that afforded by the current
10   8-hour primary Os standard.  Staff recommends that additional exposure and risk assessments be
11   conducted for alternative, 8-hour average standards at Os levels of 0.08 ppm, third-highest
12   concentration, 0.07 ppm third- through fifth-highest concentration, and if appropriate based on
13   these results, 0.06 ppm, third- through fifth-highest concentration, over a three-year period. This
14   combination of alternative levels and forms will provide a more complete picture of the risk from
15   lower concentrations where the public health risks are relatively small and more uncertain to
16   higher concentrations where the public health risks are greater, but the effects are more certain.
17   The results of these additional assessments will then be used to inform staff recommendations to
18   be included in the next draft Staff Paper on the primary Os NAAQS.

19   6.4    SUMMARY OF KEY UNCERTAINTIES AND RESEARCH
20          RECOMMENDATIONS RELATED TO SETTING A PRIMARY O3 STANDARD
21          [To be included in the next draft Staff Paper]
     November 2005
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 1    REFERENCES
 2
 3    Bell, M. L.; McDerraott, A.; Zeger, S. L.; Samet, J. M.; Dominici, F. (2004) Ozone and short-term mortality in 95
 4          US urban communities, 1987-2000. JAMA J. Am. Med. Assoc. 292: 2372-2378.
 5
 6    Gent, J. F.; Triche, E. W.; Holford, T. R.; Belanger, K.; Bracken, M. B.; Beckett, W. S.; Leaderer, B. P. (2003)
 7          Association of low-level ozone and fine particles with respiratory symptoms in children with asthma. JAMA
 8
 9    Gryparis, A.; Forsberg, B.; Katsouyanni, K.; Analitis, A.; Touloumi, G.; Schwartz, J.; Samoli, E.; Medina, S.;
10          Anderson, H. R.; Niciu, E. M.; Wichmann, H.-E.; Kriz, B.; Kosnik, M.; Skorkovsky, J.; Vonk, J. M.;
11          Ddrtbudak, Z. (2004) Acute effects of ozone on mortality from the "air pollution and health: a European
12          approach" project. Am. J. Respir. Grit. Care Med. 170:1080-1087.
13
14    Peters, A.; Dockery, D. W.; Muller, J. E.; Mittleman, M. A. (2001) Increased particulate air pollution and the
15          triggering of myocardial infarction. Circulation 103:  2810-2815.
16
17    U.S. Environmental Protection Agency (I996b) Review of the national ambient air quality standards for ozone:
18          assessment of scientific and technical information. OAQPS staff paper. Research Triangle Park, NC: Office
19          of Air Quality Planning and Standards; EPA report no. EPA-^52/R-96-007, Available from: NTIS,
20          Springfield, VA; PB96-203435.
21
22    Wolff, G. T., (1995b) Letter from Chairman of Clean Air Scientific Advisory Committee to the EPA Administrator,
23          dated November 30,1995. EPA-SAB-CASAC-LTR-96-002.
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  1       7.    POLICY-RELEVANT ASSESSMENT OF WELFARE EFFECTS
  2                                       EVIDENCE
 3    7.1    INTRODUCTION
 4          This chapter presents critical information for the review of the secondary NAAQS for Os.
 5    Welfare effects addressed by a secondary NAAQS include, but are not limited to, effects on
 6    soils, water, crops, vegetation, man-made materials, animals, wildlife, weather, visibility and
 7    climate, damage to and deterioration of property, and hazards to transportation, as well as effects
 8    on economic values  and on personal comfort and well-being. Of these welfare effects categories,
 9    the effects of Os on vegetation, including agricultural crops, trees in managed and unmanaged
10    forests, herbaceous and woody species growing in natural settings are of most concern at
11    concentrations typically occurring in the U.S. As stated in earlier reviews, "of the phytotoxic
12    compounds commonly found in the ambient air, Os is the most prevalent, impairing crop
13    production and injuring native vegetation and ecosystems more than any other air pollutant"
14    (U.S. EPA, 1989,1996).
15          Ozone can also affect other ecosystem components such as soils, water, animals, and
16    wildlife, either directly, or indirectly through its effects on vegetation.  These individual
17    ecosystem components are associated with one or more of six essential ecological attributes
18    (EEAs) recently described in A Framework for Assessing and Reporting on Ecological
19    Condition: an SAB report (Young and Sanzone, 2002) as part of a conceptual framework useful
20    for assessing and reporting on ecological condition (see 7.4). This framework can be used to link
21    ozone effects at the species level to potential impacts at higher levels in the hierarchy (e.g.,
22    EEAs). Some of these species level impacts have direct, quantifiable economic value, while
23    others are currently not quantifiable, but still have societal value. In the absence of sufficient
24    research to allow quantification of Os impacts at the ecosystem level, including impacts on
25    ecosystem goods and services, only a qualitative discussion is included. However, the staff
26    infers, based on the linkages described in the SAB framework, that increasing protection for
27    vegetation from ozone related effects would also improve the protection afforded to ecosystems
28    and their related public welfare categories.
29          Other welfare effects categories affected by Os  include  damage to certain manmade
30    materials (e.g., elastomers, textile fibers, dyes, paints, and pigments) and effects on and by
31    climate. The amount of damage to actual in-use materials and the economic consequences of
32    that damage are poorly characterized, however, and the scientific literature contains very little
33    new information to adequately quantify estimates of materials damage from photochemical
34    oxidants (EPA, 1996a,b, 2005b). Therefore, staff judges that there is insufficient information in
     November 2005
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 1   the materials damage literature to inform secondary standard setting and so will not be further
 2   discussed.  Interested readers are referred to chapter 11 in the draft CD (EPA, 2005b).  In
 3   contrast, the welfare impact of Os on local, regional and global climates has received more
 4   attention in recent years. Ozone enhances the heat capacity of the atmosphere.  The overall body
 5   of scientific evidence suggests that high concentrations of Oa on a regional scale could have a
 6   discernable influence on climate, leading to surface temperature and hydrological cycle changes.
 7   However, the CD states that confirming this effect will require further advances in monitoring
 8   and improvement in chemical transport and regional-scale modeling.  Thus, staff concludes that  .
 9   insufficient information is available at this time to quantitatively inform the secondary NAAQS
10   process.  Though this topic will not be addressed further, its corollary, e.g., climate change
11   impacts on plant response to Os, will be considered under the discussion of factors that can
12   modify the vegetation responses to 0)3 and the implications of these interactions for future field
13   exposure conditions. Thus, this chapter will focus primarily on the well established  body of
14   science regarding Os-related effects on vegetation, as discussed both in the last review and
15   summarized along with relevant new research in the current draft CD (EPA, 2005b).
16          Included in this discussion are plans for a number of analyses that update the exposure,
17   risk and benefits assessments conducted in the last review (EPA, 1996b).  The EPA  held a
18   consultation with the CAS AC 63 Panel on October 3, 2005 on the scope and methods being
19   considered in the planned assessments. The planned assessments described in this chapter take
20   into account the range of comments received from individual Panel members and the discussion
21   that occurred during the consultation. Staff recognizes that while these updated assessments
22   incorporate newer data, models,  and approaches, and take into account current and alternative
23   ozone air quality scenarios under consideration, they are still limited by important data gaps and
24   uncertainties in currently available models and approaches. Due to the limitations of time and
25   staff resources, this first draft Staff Paper includes only descriptions of the planned assessments.
26   The second draft Staff Paper will contain results from the assessments, a more complete
27   discussion of the associated uncertainties and limitations, and staff conclusions and
28   recommendations with regard to the secondary O^ NAAQS.

29   7.2    EFFECTS ON VEGETATION
30                 Science published since the conclusion of the 1996 review has not fundamentally
31   altered the understanding and conclusions regarding ozone effects on vegetation and ecosystems
32   found in the previous CD, though in some cases, recent work has expanded or clarified our
33   understanding, especially at the level of plant cell and tissue response (EPA, 2005b). In addition,
34   only a few new studies focus on addressing the data gaps or uncertainties identified  in the last
35   review.  Some notable exceptions within the U.S. include a shift and slight increase  in research


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 1   designed to examine the joint interaction'of elevated COi and Os on the productivity of U.S.
 2   vegetation, and the expansion of data collection and analysis of O3-induced visible foliar injuiy
 3   occurrences at United States Department of Agriculture Forest Service Forest Inventory and
 4   Analysis (USDA FS FIA) biomonitoring sites. In Europe, Os vegetation research has continued,
 5   though with a shift in focus from the use of ambient exposure measures to modeled Os uptake by
 6   vegetation in the context of developing an exposure index that can be used as a planning tool
 7   (i.e., critical levels).
 8          Significantly, however, a number of recent advances in the development and use of
 9   mechanistic process models, leaf and canopy flux models, and improved understanding of the
10   relationships between impacts to vegetation and impacts to ecosystem structure and function, can
11   be linked to this expanded and further elucidated scientific base underpinning these
12   developments. Specifically, the expanded understanding regarding Os impacts at the genetic,
13   physiological, and mechanistic levels informs the interpretation of risk associated with
14   vegetation response at current Os levels. For example, staff is increasingly aware that Os
15   impacts at the genetic and cellular level may hold the key to understanding the more subtle but
16   equally important implications of rising C02 levels, temperature, and Os levels on plant
17   adaptability under conditions of climate change. Therefore, this section reviews the key  scientific
18   conclusions identified in 1996 Os CD (EPA, 1996a), and incorporates new information from the
19   current draft CD where it expands or changes our understanding of the Os-plant interactions.

20          7.2.1       Exposure Methodologies Used in Vegetation Research
21          In the 1996 review, Os exposure studies were dominated by the use of various versions of
22   the open-top chamber (OTC), first described  by Heagle et al. (1973) and Mandl et al. (1973).
23   Most OTC's consist of a cylindrical aluminum frame covered with transparent film and  are
24   approximately 3m in diameter with 2.5-m-high walls. Charcoal filtered air, non-filtered air or
25   Os-supplemented  air is blown through a perforated panel at the bottom of the chamber, into the
26   plant canopy and then escapes through the top of the chamber.  Hogsett et al. (1987a) described
27   in detail many of the various modifications to the original OTC designs that appeared
28   subsequently, e.g., the use of larger chambers to permit exposing small trees (Kats et al., 1985)
29   and grapevines (Mandl  et al., 1989).  Several other modifications were made over the years to
30   improve ventilation reduce ambient air incursions, and a plastic rain-cap to exclude precipitation
31   (Hogsett et al., 1985).
32          Chambered systems, including open-top chambers, have several advantages. For
33   instance, they can provide a range of treatment levels including charcoal-filtered (CF), clean-air
34   control, and above ambient for Os experiments. Depending on experimental intent, a replicated,
35   clean-air control treatment is an essential component in many experimental designs. OTCs can
      November 2005
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 1    provide a consistent, definable exposure because of the constant wind speed and delivery
 2    systems.  From a policy prospective, the statistically robust C-R functions developed using such
 3    systems are necessary for evaluating the implications of various alternative air quality scenarios
 4    on crop response.
 5          Nonetheless, there are several characteristics of the OTC design and operation that can
 6    lead to unrealistic exposures.  First, the plants are subjected to constant turbulence, which, by
 7    lowering the boundary layer resistance to diffusion, results in increased uptake. This may lead to
 8    an overestimation of the cause-effect relationships (Krupa et al., 1995; Legge et al., 1995).
 9    However, in at least one case where canopy resistances were quantified in OTCs and in the field,
10    it was determined that gaseous pollutant exposure to crops in OTCs was similar to that which
11    would have occurred at the same concentration in the field (Unsworth et al., 1984a, 1984b). A
12    second concern is that the introduction of the (Venriched air into the lower part of chambers as
13    described by Heagle et al. (1973) and Mahdl et al. (1973) results in a Os concentration gradient
14    that decreases with increasing height, the converse  of the situation observed in ambient air in
15    which the Os concentration decreases from above a plant canopy to ground level (Grunhage and
16    Jager, 1994; Pleijel  et al., 1995,1996). Finally, as with all methods that expose vegetation to
17    modified 63 concentrations in the field, OTCs create internal environments that differ from
18    ambient air. For OTC's the so-called "chamber effect" refers to the modification of
19    microclimatic variables, including reduced and uneven light intensity, uneven rainfall, constant
20    wind speed, reduced dew formation, and increased  air temperatures (Fuhrer, 1994; Manning and
21    Krupa, 1992). However, staff notes that the uncertainties associated with the influence  of other
22    modifying factors occurring in the field such as water and nutrient availability are likely to be
23    greater than the uncertainties in the data due to the influence of OTCs. Because of the
24    standardized methodology and protocols used in NCLAN, the database can be assumed to be
25    internally consistent.
26          While  it is clear that OTCs can alter some aspects of the microenvironment and  plant
27    growth, the question to be answered is whether or not these differences affect the plant's
28    response to OB. As  noted in the 1996 Os CD (EPA, 1996a), evidence from a number of
29    comparative studies of OTCs and other exposure systems suggested that, responses were, in
30    general, essentially the same regardless of exposure system used and  chamber effects did not
31    significantly affect response. A recent example is the study of chamber effects examined the  -
32    responses of tolerant and sensitive white clover clones (Trifoliwn repens) to ambient Oa in
33    greenhouse, open-top, and ambient plots (Heagle et al., 1996). The response found in OTCs was
34    the same as in ambient plots.
35          Though the OTC method has remained a widely used technique in the U.S. and Europe
36    for exposing plants to varying levels of Os (EPA, 2005b), in recent years, a few studies  have

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 1   employed a modified Free Air COa Enrichment (FACE) method to expose vegetation to elevated
 2   Os. This is an exposure methodology originally developed to expose vegetation without
 3   chambers to elevated levels of COa. FACE has been modified in Illinois and Wisconsin to
 4   include exposure of soybean and deciduous trees to Os, respectively (Dickson et al., 2000;
 5   Morgan et al., 2004). The FACE method releases gas (e.g., CO2, Os) from a series of orifices
 6   placed along the length of the vertical pipes surrounding a circular field plot and uses the
 7   prevailing wind to distribute it. This exposure method may more closely replicate conditions in
 8   the field and, more importantly for tree/forest research, has the benefit of being able to expand
 9   vertically with the growth of the trees, allowing for exposure experiments to span numerous
10   years.  The FACE methodology has a different set of limitations.  Specifically, it is not possible
11   to produce a number of replicated treatment levels, including Os concentrations below ambient,
12   or a control where ambient Os levels are already at phytotoxic levels. Thus, FACE sites cannot
13   be used to build the statistically robust C-R functions like those produced with OTCs and is of
14   limited value in developing empirical models for predicting Os effects.  In addition, FACE
15   systems are relatively expensive to operate, likely limiting the number of new sites that will
16   employ these systems and the variety of species studied.
17          Despite the differences in these two exposure methods, recent evidence obtained using
18   FACE and OTC systems appear to support the results observed in OTC studies used in the 1996
19   review. Specifically, a series of studies undertaken using free-air Os enrichment in Rhinelander,
20   WI (Isebrands et al., 2000,2001) showed that Os-symptom expression was generally similar in
21   OTCs, FACE, and ambient-Os gradient sites, supporting the previously observed variation
22   among trembling aspen clones (Populus tremuloides L.) using OTCs (Karnosky et al., 1999).
23   The FACE study also evaluated the effects of 3 years of exposure to combinations of elevated
24   COa and Os on growth responses in mixtures of five trembling aspen clones (Isebrands et al.,
25   2000,2001).  Height, diameter, and stem volume (diameter2 * height) were decreased by
26   elevated Os. On average for all clones, stem volume was decreased  by 20% over the 3 years in
27   the elevated Os treatment as compared with the Ix-ambient treatment. These results also appear
28   to show similar response patterns reported previously with the same clones grown in soil in pots
29   or the ground in OTCs without the alterations of microclimate induced by chambers (EPA,
30   2005b). As more FACE data become available, a more quantitative comparison of findings from
31   these two systems would be useful.
32          Staff recognizes there are other exposure methods described  both in the 1996 CD and in
33   the current draft CD that have and can provide useful information on plant responses to Os
34   exposure including, chemical protectants, exclusion, passive monitors and naturally occurring
35   gradients. However,  based on the considerations described above, especially the policy need for
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 1   robust C-R functions, staff concludes that the OTC methodology is currently the most useful in a
 2   policy context.

 3          7.2.2       Species (Intra-Plant) Response/Mode of Action
 4          This section emphasizes reactions of Oa with the plant cell and tissue, rather than the
 5   whole plant, to describe the fundamental mechanisms known to govern the response of the plant
 6   to Os exposure. This section discusses the movement of Oj into plant leaves and their
 7   biochemical and physiological responses to Os.  In most cases, the mechanisms of response are
 8   similar regardless of the degree of sensitivity of the species.  The information assessed in the
 9   1996 CD regarding the fundamental hypotheses concerning Os-induced changes in physiology
10   continues to be valid.  However, during the last decade, this understanding of the cellular
11   processes wimin plants has been further clarified and enhanced. This section describes: (l)the
12   regulation of Oa entry into the leaf, (2) reactions of Os or its reaction products at the cell surface,
13   (3) movement and/or transformation of reaction products into the cell, (4) Os -triggered wound or
14   pathogen attack response, (5) plant defense and compensation mechanisms, (6) Os-induced
15   changes to plant metabolism, and (7) delayed expression of plant response.

16           7.2.2.1    Entry of Ozone into the Leaf
17          To cause injury, Os must first enter the plant. Ozone-induced changes to a leafs cuticle
18   (the outer layer of the leaf surface) are minimal, and Os does not penetrate the cuticle (Kerstiens
19   and Lendzian, 1989).  Thus, only the 63 that diffuses into a plant through the stomata (which
20   exert some control on Os uptake) to the active sites within a leaf has the potential to impair plant
21   processes or performance. Once inside the leaf, a phytotoxic effect .will occur only if sufficient
22   amounts of Os reach sensitive cellular sites that are subject to the various physiological and
23   biochemical controls within the leaf cells. Ozone injury will not occur if (1) the rate and amount
24-  of Os uptake is small enough for the plant to detoxify or metabolize Os or its metabolites or (2)
25   the plant is able to repair or compensate for the Os impacts (Tingey and Taylor, 1982; EPA,
26   1996).
27          For Os to be absorbed into a leaf, it must first reach the stomatal openings in the leaf.
28   Foliar absorption is controlled by the leaf boundary layer and stomatal conductances, which
29   together determine leaf conductance.  Although the movement of pollutants through a boundary
30   layer into the stomata region is known to be important, and even rate limiting in many cases of
31   low wind velocity, its description has been defined from aeronautical concepts and usually
32   relates to smooth surfaces that are not typical of leaf-surface morphology; however, it is nearly
33   the only treatment available (Gates, 1968). Once through the boundary layer, the gas must enter
34   the leaf through the stomata.
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 1          The entry or flux of gases through the stomata into a leaf is dependent upon the physical
 2   and chemical processes of gas phase and surfaces and has been well-defined. In the past, the
 3   internal concentration of Os has been assumed to be zero (Laisk et al., 1989), due to early studies
 4   that found that virtually no Os could pass through a leaf.  That was expected because Os is
 5   extremely reactive with cellular biochemicals. However, a recent study by Moldau and Bichele
 6   (2002) indicated that the internal Os concentration may not be zero as previous assumed.
 7   However, because Os has no easily measured isotope, virtually no measurements have been done
 8   on an actual dose of Os, i.e., the amount of Os which reacts with individual biochemicals inside
 9   the leaf.  In addition, only a limited number of studies have measured Os concentration or its •
10   reaction products within the leaf (e.g., Moldau and Bichele (2002)), and only a few instances of
11   direct measures of Os flux to foliage in the field are reported.
12          Several factors complicate  estimates of flux into leaves and at the whole plant and canopy
13   scales. First, in some species, Os.modifies the opening of the stomata, usually closing it
14   partially, so that the flux rate will change (see next section for more discussion). Secondly,
15   leaves exist as part of a three dimensional canopy. Thus, the relationship of any given leaf.to the
16   ambient air is unique so that the amount of Os absorbed can vary from leaf to leaf, making  it
17   difficult to extrapolate uptake from the level of an individual leaf to that of a whole plant or
18   canopy.  Thirdly, Os uptake in a plant canopy is a complex process involving Os adsorption to
19   surfaces e.g., leaf cuticles, stems, and soil (termed non-stomatal deposition) and scavenging
20   reactions of Os with intra-canopy biogenic VOCs and naturally occurring NOx emissions from
21   soils, so that less Os is ultimately available for absorption into leaves.
22          Not surprisingly, as understanding of these complicating factors has grown, the issue of
23   how to characterize and define uptake or flux has received more attention.  Specifically, interest
24   has been increasing in recent years, particularly  in Europe, in using mathematically tractable flux
25   models for Os assessments at the regional and national scale (Emberson et al., 2000a,b).
26   Uptake or flux models have to distinguish between stomatal and non-stomatal components  of Os
27   deposition to adequately estimate actual concentration reaching the interior of a leaf.
28   Determining this Os uptake via canopy and stomatal conductance by necessity relies on models
29   to predict total flux and ultimately  the "effective" flux (Grunhage et al., 2004; Massman et  al.,
30   2000; Massman, 2004). "Effective flux" has been defined as the balance between the Os flux and
31   the detoxification process (DSmmgen et al., 1993; Grunhage and Haenel, 1997; Musselman and
32   Massman, 1999). The time-integrated "effective flux" is termed "effective dose".
33   As described more fully below, and in the  CD, scientific understanding of the detoxification
34   mechanisms is not yet complete so that the ability to model this component of flux would require
35   an intensive research effort.
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 1          The current state of the science with respect to flux models and their relevance to the
 2   standard setting process will be revisited in greater detail in section 7,2.4, on Indices.

 3           72.2.2     Reactions of 03 and possible reaction product(s) at cell surfaces
 4          Ozone diffuses into the leaf air spaces and reacts either with varied biochemical
 5   compounds that are exposed to the air (path 1) or is solubilized into the water lining the cell wall
 6   of the air spaces'(path 2). Each reaction has the possibility of transforming Os into another
 7   chemical species (a toxicant) which, in turn, may react with other chemical species and lead to a
 8   cascade of reactions.
 9          Within the stomata, gases react with the water at the cell's surface  and generate new
10   species with the components within the cell wall region. Although these chemical reactions are
11   poorly understood, some of the fundamentals are known (Heath, 1987,1988; Wellburri, 1990).
12   Ozone reacts with organic molecules at the double bonds to form carbonyl groups and, under   •
13   certain circumstances, generates peroxides, including hydrogen peroxides  (^02). The role of
14   hydrogen peroxide as a signaling molecule in plants, is now better understood. One example is
15   its link to the hormone ABA-induced closure of the stomata (Pel et al., 2000). Pel etal. (2000)
16   also found that ABA induced the production of H2O2 through Reactive Oxidative Species (ROS)
17   accumulation. This complex interaction between H2O2 and ABA could help explain why Os
18   would often decrease conductance in some cases, but not always (Heath, 1994b). Other
19   chemicals present in the water phase can lead to many other oxygenated moieties. Each of the
20   steps is generally pH dependent (Jans and Hoigne, 2000; Walcek et al., 1997. Effective
21   detoxification reactions can occur here via antioxidant metabolites and enzymes if they are •
22   present at high enough concentrations (Castillo et al., 1987; Matters and Scandalios, 1987).
23           7.2.2.3     Movement of an O3 reaction produces) into the cell with enzymatic or
24                      chemical transformation of those products  in the cell
25          It is believed that the initial site of 63 injury is near or within the plasma membrane.
26   Ozone is soluble in water and once having entered the aqueous phase, it can be rapidly altered to
27   form oxidative products that can diffuse more readily into and through the cell and react with
28   many biochemicals. A toxic product of 03 may migrate through the cytoplast to react with
29   photosynthetic processes, or a spurious signal generated at the membrane may affect some
30   control process or signal transduction pathway (Schraudner et al., 1998; Overmyer et al., 2000,
31   2003; DeCaria et al., 2000; Rao et al., 2002; Booker  et al., 2004; Leitao et al., 2003; Rao and
32   Davis, 2001; Sandermann, 2000; Vahala et al., 2003). Certainly, membrane functions, such as
33   membrane fluidity (Pauls and Thompson, 1980), permeability (Elkiey and Ormrod, 1979), K+-
34   exchange via ATPase reactions (Dominy and Heath,  1985), and Ca2+ exclusion (Castillo and
35   Heath, 1990), are changed. The initial sites of membrane reactions seem to involve transport


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 1   properties and, possibly, the external signal transducer molecules. It would seem that one of the
 2   primary triggers of Os-induced cell responses is a change in internal Ca2+ levels (CD, 2005). The
 3   ' presence of an internal antioxidant would be critical to reduce the concentration of most
 4   oxidants.
 5           7.2.2.4    Ozone Initiated Wounding and Pathogen Attack Response
 6          The primary set of metabolic reactions that Os triggers now clearly includes those typical
 7   of "wounding" responses generated by cutting of the leaf or by pathogen/insect attack.  The
 8   similarity of wounding responses (Langebartels et al., 1991) and Os-induced membrane
 9   disruption suggests the induction of normal wound-regulated genes (Mehlhorn et al., 1991;
10   Sandermann, 1998). The sequence of the plant response to a pathogen is (1) recognition of the
11   gene products of the pathogen by the plant (elicitor), (2) generation of an immediate
12   phytoresponse to attempt to localize the attack and its products, and (3) generation of a systemic
13   acquired resistance (SAR) to subsequent attack by the pathogen. One aspect of this total response
14   is the production of O? and HbC^ by the cell (Lamb and Dixon, 1997).
15          Ozone per se does not generate the I-tOi, but rather triggers stress-related H2O2
16   formation ^similar to what occurs in a pathogen attack (ROS reaction). The presence of higher
17   than normal levels of HaO2 within the apoplastic space is a potential trigger for the normal, well-
18   studied pathogen defense pathway.  SAR has been heavily investigated, and DNA probes have
19   existed for some time  for a series of expressed genes. Several enzyme classes are associated with
20   Os injury, including glucanases and peroxidases and others. Thus, strong evidence exists from
21   enzyme function and genetic material that Os induces an activation of a SAR-like response.
22          Ethylene (ET) is another compound produced when plants are subj ected to biotic
23   stressors, e.g., attacks  by insects, fungi, and bacteria or abiotic stressors such as wounding or
24   environmental stressors such as heat, cold, or oxidative stress and Os.  Increased ET production
25   by plants exposed to Os stress was identified as a consistent marker for Os exposure decades ago
26   (Tingey et al., 1976).  These studies suggested that increased production of stress-ET correlated
27   well with the degree of foliar injury that developed within hours or days after Os exposure. The
28   amount of ET released was exponentially related to the Os exposure, with peaks of high Os
29   (rather than accumulated dose) generating a higher rate of ET release, at least for a single Os
30   exposure under an acute dose.  Furthermore, the amount of Os-induced ET declined with
31   repeated exposure, indicating an acclimatization to Os. This acclimatization effect associated
32   with repeated wounding has not yet been well described. Thus, one could postulate that Os
33   generates a wounding response with a production of ET, which would, in turn, generate a change
34   in stomatal conductance and photosynthesis. Clearly, these multiple events may have
35   confounded some earlier studies.
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 1            7.2.2.5    Defense and Compensation Mechanisms
 2          The first line of defense against Os is a closure of the stomata to exclude its uptake. This
 3    is counterproductive for efficient photosynthesis, but some amount of closure limits the rate of
 4    Os deposition into the leaf tissue to allow for a secondary line of defense to detoxify the 03. The
 5    secondary line of defense involves a range of antioxidants, including ascorbate, glutathione
 6    peroxidase (GSH-Px), and sulfuroxide dimutase (SOD) which are highly reactive to the types of
 7    chemicals that can be generated by Os. The timescales for changes in their levels vary: some rise
 8    rapidly, while others rise more slowly. The pattern of changes in these particular proteins varies
 9    greatly among different species and conditions.
10          Since 1996, the role of detoxification in providing a level of resistance to Os has been
11    further investigated. For example, most recent reports indicate that ascorbate within the cell wall
12    is the real first line of all defense.  Ascorbate is water soluble, present in the solution where Os
13    can dissolve, and is highly reactive. Ascorbate concentration declines when the tissue is exposed
14    to Os (Luwe et al.,1993; Moldau, 1998), and appears to be closely linked to the amount of Os
15    penetrating the leaf tissue. Ascorbate is present within the cell wall, cytoplasm, and chloroplasts
16    (Burkey, 1999; Moldau, 1998); and can move between the cytoplasm and the cell wall with
17    relative ease (Bichele et al., 2000. It is likely that ascorbate is in higher concentration than ET,
18    and that the rate reaction of ascorbate with Os would therefore greatly dominate any -possible
19    reaction of Os with ET.
20          In spite of the new research, however, it is still not clear as to what extent detoxification
21    can protect against Os injury. Data are needed especially on the potential rates of antioxidant
22    production and on the subcellular location of the antioxidants. Potential rates of antioxidant
23    production are needed to assess whether they are sufficient to detoxify the Os as it enters the cell.
24    The subcellular location(s) is needed to assess whether the antioxidants are in cell wall or
25    plasmalemma locations that permit contact with the Os before it has a chance to damage
26    subcellular systems. Although these detoxification and compensation processes divert resources
27    away from other sinks and expend energy, they may counteract the reduction in canopy carbon
28    fixation caused by Os.  The quantitative importance of these processes requires further
29    investigation.

30            7.2.2.6     Changes to Plant Metabolism
31          Ozone-related physiological effects within the leaves can 1) inhibit photosynthesis; 2)
32    alter the assimilation of photosynthate and shift its allocation patterns; and 3)  can lead to reduced
33    biomass production, growth, and yield (EPA, 1986,1996a). The working hypothesis is that Os
34    which is not eliminated by antioxidants in the cell wall alters the properties of the plasma
35    membrane. Once this membrane disruption occurs, the cell must mobilize repair systems to
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 1    overcome the injury. Thus, carbon and energy sources once destined for productivity, must be
 2    used in repair processes. Some of these repairs are thought to result from the induction of
 3    specific genes.
 4          Photosynthesis is inhibited by exposure to 63.  A large body of literature published since
 5    1996 has further elucidated the mechanism of mis effect.  Pell et al., 1997 show that Oa exposure
 6    results in a loss of Rubisco, the central carboxylating enzyme that plays an important role in the
 7    production of carbohydrates. Due to its central importance, any loss of Rubisco may have severe
 8    consequences for the plant's productivity. Several studies have found that Os had a greater effect
 9    as leaves aged, with greatest impact of Os on the oldest leaves (Fiscus et al., 1997; Reid and
10    Fiscus, 1998; Noormets et al., 2001; Morgan et al., 2004).  The results of these studies and others
11    suggest that alterations to the dark reactions are much more common than to light reactions
12    (Farage et al., 1991; Farage and Long, 1999).
13          The rate of leaf senescence has been shown to increase as a function of increasing Os
14    exposure. The loss of Rubisco and its messenger RNA is linked to an early senescence or a
15    speeding up of normal development leading to senescence. However, the mechanism of the
16    increased senescence is not known, and, hence, deserves further study. Most studies have shown
17    that 63 decreases allocation of photosynthate to roots. In some cases, allocation to leaf
18    production has increased. Whether these changes are driven entirely by changes in carbohydrate
19    availability or are controlled by other factors (e.g., hormones) is not known. The loss of
20    productivity is not yet clearly explained.  However, several studies provide some insight into
21    possible mechanisms. A study by Grantz and Yang (2000) suggests that Os can trigger a plant-
22    wide response that may be linked to alterations in signal transduction and the generation of
23    whole plant signals. Stitt (1996) suggested that"... allocation is regulated by long-distance
24    signals that act to influence growth of selected sinks and to modify the delivery of resources to
25    these sinks in parallel."  In addition, Cooley and Manning (1987), citing McLaughlin and
26    McConathy (1983), suggested three possible ways that Oa fumigation might alter translocation:
27    (1) malfunction of the phloem loading process, (2) increased translocation to leaf injury repair,
28    and (3) an altered balance between the leaf and sinks caused by reduced carbon fixation and a
29    greater demand for assimilate in the leaf.  Alternatively, ethylene appears to be able to repress
30    the expression of extracellular invertase, which is critical for control and downloading of sucrose
31    derived from the translocational stream (Roitsch, 1999). More work is needed on the
32    interactions between assimilation, translocation,  and source/sink relations with Os exposure. In
33    these interactions, one must be aware of the developmental age of the plants and their
34    phytohormonal status.
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 1            7.2.2.7    Relationships Between Age and Size and Ozone Response
 2          Many changes that occur with Os exposure can be observed within hours, or perhaps
 3    days, of the exposure, including those connected with wounding and elicitor-induced changes in
 4    gene expression.  Other effects due to 63, however, take longer to occur and tend to become
 5    most obvious under long periods of low-Cb concentrations. These have been linked to '
 6    senescence or some other physiological response very closely linked to senescence. The
 7    understanding of how CH affects long-term growth and resistance to other biotic and abiotic
 8    insults in long-lived trees is unclear. Often, the conditions to which a tree is subjected in one
 9    year will affect the response of that tree in the next year. This has been called "memory effect",
10    although the term "carry-over" is preferred. In other words, a condition in an earlier year sets the
11    stage for a reaction in the next year; thereby giving a "cause-effect" scenario.  In perennial plant
12    species, growth affected by a reduction in carbohydrate storage may result in the limitation of
13    growth the following year (Andersen et al., 1997). Carry-over effects have been documented in
14    the growth of tree seedlings (Hogsett et al., 1989; Sasek et al., 1991; Temple et al., 1993; U.S.
15    Environmental Protection Agency, 1996) and in roots (Andersen et al., 1991; EPA, 1996a).
16    Accumulation of carry-over effects over time will affect survival and reproduction.
17          It is important to note that while understanding of how Os interacts with the plant at a
18    cellular level has dramatically improved in recent y ears, the translation of those mechanisms into
19    how Os is involved with altered cell metabolism, with whole plant productivity, and with other
20    physiological facts remain to be more fully elucidated.

21          7.2.3      Factors That Modify Functional and Growth Response
22          The caveat that must be placed on results from any experimental study on the response of
23    living organisms to a stressor in a specific setting is that uncertainty is introduced when
24    attempting to extrapolate or apply those results outside that specific setting (e.g., to a different set
25    of organisms, scales, or exposure/growing conditions). The description of plant response to Oa
26    is no different.  Because staff must necessarily rely on experimental data produced under very
27    specific sets of conditions in conducting this assessment, it is important to understand the range
28    of factors that can influence plant response to Os and the magnitude and direction of that
29    response, in order to better assess the likelihood of observing the experimentally predicted
30    response in the ambient environment.
31          The 1996 O3 CD (EPA, 1996) concluded with a statement that our understanding
32    regarding modifying factors was too fragmented to permit drawing many general conclusions.
33    Unfortunately, in the interval since the 1996 criteria document, rigorous, systematic
34    investigations of interactions have been rare, and most of the new information is as fragmented
35    as before. This is inevitable, partly in view of the vast scope of the possible  interactions between


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 1   Os and other environmental variables and partly due to the overall lack of funding for research in
 2   these areas (EPA, 2005b). Therefore, only a brief overview of the current understanding from
 3   this research is provided. The reader is referred to the 1996 03 CD and the current draft CD for
 4   further information.
 5          Plant response to Os exposure is a function of the plant's ongoing integration of genetic,
 6   biological, physical and chemical factors both within and external to the plant.  The corollary is
 7   also true that Os exposure can modify the plant's subsequent integrated response to other
 8   environmental factors, both by influencing the plant response directly, and by contributing to
 9   altered climatic factors that influence plant response through its greenhouse gas forcing
10   properties..

11            7.23.1    Genetics
12          Plant response to Os is determined by genes that are directly related to oxidant stress and
13   to an unknown number of genes that are not specifically related to oxidants but instead mat
14   control leaf and cell wall thickness, stomatal conductance, and the internal architecture of the air
15   spaces. Because the genetic code is species specific, species vary greatly in their responsiveness
16   to Os. Even  within a given species, individual genotypes or populations can also vary
17   significantly with respect to Os  sensitivity. Thus, caution should be taken when ranking species
18   categorically as having an absolute degree of sensitivity to Os.
19          Recent studies using molecular biological tools and with transgenic plants have begun to
20   positively verify the role of various genes and gene products in Os tolerance and are beginning to
21   increase the understanding of Os toxicity and differences in Os sensitivity.  Specifically, Os has
22   been shown to trigger the production of a number of compounds (e.g. salicylic  acid, ethylene and
23   jasmonic acid) and the signaling of these molecules determines in some cases the Os
24   susceptibility of plants (CD, 2005).  It is unlikely that single genes are responsible to Os
25   tolerance responses, except in rare cases (Engle and Gabelman, 1966).

26            7.2.3.2    Biological Factors
27          The biological factors within the plant's environment that may directly or indirectly
28   influence its response to Os in a positive or negative manner encompass insects, other animal
29   pests, diseases, weeds, and other competing plant species. Ozone and other photochemical
30   oxidants may influence the severity of a disease or infestation by either direct effects on the
31   causal species, or indirectly by  affecting the host, or both. • Likewise, mutually beneficial
32   relationships or symbioses involving higher plants and bacteria or fungi may also be affected by
33   Os.  Ozone can also have indirect effects on higher herbivorous animals  due to Os-induced1
34   changes in feed quality.
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 1          New evidence with regard to insect pests and diseases has done little to remove the
 2    uncertainties noted in the 1996 CD. "Most of the large number of such interactions that may
 3    affect crops, forest trees, and other natural vegetation have yet to be studied. The trend suggested
 4    previously that Oa increases the likelihood and success of insect attack has received some
 5    support from recent studies, but only with respect to chewing insects. With the economically
 6    important group of sucking insects such as the aphids, no clear trends have been revealed by the
 7    latest studies.  We are still far from being able to predict ihe nature of any particular Oa plant
 8    insect interaction, its likelihood, or its severity.
 9       .   The situation is a little clearer with respect to interactions involving facultative
10    necrotrophic plant pathogens with Oa, generally leading to increased disease. With obligate
11    biotrophic fungal, bacterial, and nematode diseases, there are twice as many reports indicating
12    Oa-induced inhibitions than enhancements. The frequent reports that infection by obligate
13    biotrophs reduces the severity of Oa-induced foliar injury should not be interpreted as
14    "protection", because of the negative effects on the host plant of the disease per se. With
15    obligate biotrophs, the nature of any interaction with Oa is probably dictated by the unique,
16    highly specific biochemical relationships between pathogen and host plant. At this time,
17    therefore, although some diseases may become more widespread or severe as a result of
18    exposure to Oa, it is still not possible to predict which diseases are likely to present the greatest
19    risks to crops and forests.
20          Several studies have indicated that the functioning of tree root symbioses with
21    mycorrhizae may be adversely affected-by Oa,  but there is also evidence that the presence of
22    mycorrhizae may overcome root diseases stimulated by Oa and that Oa may encourage the spread
23    of mycorrhizae to the roots of uninfected trees. The latest studies, therefore, present no clearer
24    picture of the likely nature  of simple interactions of Oa and root symbionts.
25          The few recent studies of the impact of Oa on intraspecific plant competition have again
26    confirmed that grasses frequently show greater resilience than other types of plants. In grass-
27    legume pastures, the leguminous species suffer greater growth inhibition. And the suppression of
28    Ponderosa pine seedling growth by blue wild-rye grass  was markedly increased by Oa. However,
29    we are far from being able to predict the outcome of the impact of Oa on specific competitive
30    situations, such as successional plant communities or crop-weed interactions.
31            7.2.3.3    Physical Factors
32          Light, a component of the plant's physical environment, is an essential "resource" whose
33    energy content drives photosynthesis and COi assimilation. It has been suggested that increased
34    light intensity may increase the sensitivity to Oa of light-tolerant species while decreasing that of
35    shade-tolerant species, but this appears to be an oversimplification with many exceptions.
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 1          Temperature affects the rates of all physiological processes based on enzyme-catalysis
 2    and diffusion, and each process and overall growth (the integral of all processes) has a distinct
 3    optimal temperature range. Although some recent field studies have indicated that Os impact
 4    significantly increases with increased ambient temperature, olher studies have revealed little
 5    effect of temperature. But temperature is unquestionably an important variable affecting plant
 6    response to Os in the presence of the elevated CO2 levels contributing to global climate change
 7    (see below). In contrast, evidence continues to accumulate to indicate that exposure to Os
 8    sensitizes plants to low temperature stress by reducing below-ground  carbohydrate reserves,
 9    possibly leading to responses in perennial species ranging from rapid  demise to impaired growth
10    in subsequent seasons,
11          Although the relative humidity of the ambient air has generally been found to increase the
12    adverse effects of Oa by increasing stomatal conductance and thereby increasing Oa flux,
13    abundant  evidence indicates that the ready availability of soil moisture results in greater
14    sensitivity to Oa.  The partial "protection" against the adverse effects of Oa afforded by drought
15    has been observed in field experiments and modeled in computer simulations. There is also
16    compelling evidence that Oa can predispose plants to drought stress. Hence, the response will
17    depend to some extent upon the sequence in which the stresses occur, but, even though the nature
18    of the response is largely species-specific, successful applications of model simulations will lead
19    to larger-scale predictions of the consequences of Oa x drought interactions. However, it must be
20    recognized that regardless of the interaction., the net result on growth in the short-term is
21    negative,  although in the case of tree species, other responses such as  increased water use
22    efficiency could be a benefit to long-term survival.
23          Wind speed and air turbulence, affects the thickness of the boundary layers over leaves
24    and canopies and, hence, affects gas exchange rates.  These factors can have a significant impact
25    on the relationship between ambient air exposures and actual exposure concentrations at the leaf
26    or canopy surface.

27           7.2.3.4    Chemical Factors
28          Mineral nutrients in the soil, other gaseous air pollutants, and agricultural chemicals
29    constitute chemical factors in the environment. The  evidence regarding interactions with specific
30    nutrients is still contradictory. Some experimental evidence indicates  that low general fertility
31    increases  sensitivity to Oj, while simulation modeling of trees suggests that nutrient deficiency
32    and Oa act less than additively; however there are too many examples of contrary trends to
33    permit any sweeping conclusions. Somewhat analogously with temperature, it appears that any
34    shift away from the nutritional optimum may lead to greater sensitivity, but the shift would have
35    to be substantial before a significant effect on response to Oa was observed.
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 1          Interactions of Oa with other air pollutants have received relatively little recent attention.
 2    The situation with SC>2 remains inconsistent, but seems unlikely to pose any additional risk to
 3    those related to the individual pollutants. With NO and NO2, the situation is complicated by their
 4    nutritional value as N sources. In leguminous species, it appears that NO2 may reduce the impact
 5    of Oa on growth, with the reverse in other species, but the nature of the exposure pattern, i.e.,
 6    sequential or concurrent, also determines the outcome. Much more investigation is needed before
 7    we will be able to predict the outcomes of different Os-NO-NCh scenarios. The latest research
 8    into Oa * acid rain interactions has confirmed that, at realistic acidities, significant interactions
 9    are unlikely. A continuing lack of information precludes offering any generalizations about
10    interactive effects of Oa with NHa, HF, of heavy metals. More evidence has been reported that
11    the application of fungicides affords some protective effects against Oa.
12          Over the last decade, considerable emphasis has been placed on research into Oa
13    interactions with two components of global climate change: increased atmospheric COa and
14    increased mean global temperature. Most of these studies, however, have tended to regard
15    increased CO2 levels and increased mean temperatures as unrelated phenomena, in spite of the
16    crucial role of temperature as a climatic determinant (Monteith and Elston,  1993). Thus,
17    experiments that examime the effects of doubled COa levels at today's mean ambient
18    temperatures are not particularly helpful in trying to  assess the impact of climate change on
19    responses to Oa, since most of the biotic and chemical interactions with oxidants (as discussed in
20    7.2.3 above) may be modified by these climatic changes. Though it is now known from limited
21    experimental evidence and evidence obtained by computer simulation that an atmosphere
22    sufficiently enriched with CO2 (e.g., 600 + ppm) would more than offset the impact of Oa on
23    responses as varied as wheat yield or the growth of young Ponderosa pine trees, the concurrent
24    increase in temperature would reduce, but probably not eliminate, the net gain.
25          Little if any experimental evidence exists related to three-way interactions, such as Oa *
26    CO2 x disease or Oa * CO2  x nutrient availability, although such interactions cannot be predicted
27    from the component two-way interactions.  Increased use of computer simulations may be
28    important in suggesting outcomes of the many complex interactions of Oa and various
29    combinations of environmental factors.  However, the results obtained will only be as reliable as
30    the input data used for their parameterization. Thus, additional data from organized, systematic
31    study is needed.
32          It is important to recognize that wide variations in net impacts of climate change in
33    different geographic areas are expected. Although many regions are predicted to experience
34    severe, possibly irreversible, adverse effects due to climate  change, beneficial changes may also
35    take place. Findings from the U.S. Global Change Research Program (USGCRP) (NAST, 2000)
36    and related reports illustrate the considerable uncertainties and difficulties in projecting likely

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 1   climate change impacts at the regional or local scale. The USGCRP findings also reflect the
 2   mixed nature of projected potential climate change impacts, i.e., combinations of deleterious and
 3   beneficial effects, for U.S. regions and the variation of projected impacts across different
 4   regions.  The EPA is currently leading a research effort that uses regional-scale climate models
 5   with the goal of identifying changes to OB and PM concentrations that may occur in a warming
 6   climate.  An assessment of the results of this effort is expected to be available for consideration
 7   in the next review of the OsNAAQS.

 8          7.2.4       Effects-Based Air Quality Exposure Indices
 9          The language in sections 108 and 109 of the Clean Air Act indicates that the.secondary
10   NAAQS is to specify a level of ambient air quality that when met, will protect the public welfare
11   from any known or anticipated adverse effects associated with the presence of such air pollutant
12   in the ambient air. Since those words were written, Ihe vegetation and ecosystem science has
13   evolved to demonstrate that the presence of a pollutant (Oa) in ambient air is only one of a
14   multitude of factors influencing the likelihood of an adverse vegetation and/or ecosystem effect
15   occurring as a result of exposure to a pollutant. However, since most of the other factors that
16   play a role in regulating the potential impact of an air pollutant on vegetation are outside of
17   human control, except in controlled experiments or heavily managed agricultural settings, it
18   seems reasonable to continue to focus on the potential contribution of anthropogenically derived
19   ambient air concentrations of Os in producing adverse effects to vegetation, recognizing that it is
20   not possible to predict for all plants occurring in the U.S. at any given time and ambient pollutant
21   concentration, which and to what degree modifying factors are influencing either the rate of that
22   pollutant uptake from the ambient air or the plant's response to that uptake. Thus, any ambient
23   air quality exposure index will by necessity be a simplification of the actual relationship between
24   pollutant concentrations in the ambient air and plant response. That said, there may be ways to
25   improve upon or more carefully focus the application of existing air quality exposure indices to
26   improve their predictive power.
27          Most of what is known about vegetation response to Os is a result of controlled
28   experiments that sought to minimize the influence of other confounding variables so that a clear
29   Os signal could be measured. Experimental exposure profiles were typified by the episodic
30   occurrence of a large number of higher Os concentrations. Though not atypical, growth or yield
31   effects may be over- or underestimated in regions of the country where a different type of
32   temporal pattern is prevalent. Therefore, it should be recognized that the conclusions drawn
33   about the importance of different exposure features are heavily influenced by the nature of the
34   experiments conducted.
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 1          In the last review, the aspects of exposure known to affect plant response included a)
 2    exposure duration (i.e., Oa effects are cumulative); b) higher concentrations appear to be more
 3    important than lower; c) plant sensitivity to Os varies with time of day and crop development
 4    stage.  Exposure indices that accumulate the hourly Os concentrations and preferentially weight
 5    the higher concentrations had better statistical fits to growth/yield response than did the mean
 6    and peak indices. No experiments were conducted to test the performance of these indices in the
 7    field. Instead, the testing of adequacy of available indices was accomplished through regression
 8    analyses of earlier studies.  Therefore, indices selected for further consideration based on the
 9    regression analysis were those mat could best quantify growth and yield effects in crops,
10    perennials and trees (primarily seedlings) and were cumulative and peak weighted (e.g., SUM06,
11    Wl 26, and AOT40). These indices are also known as "concentration based" as they only
12    consider ambient concentrations in deriving the value of the index.
13          Other issues raised during the last review regarding the most relevant aspects of exposure
14    for inclusion in an air quality exposure index included the question of the relative importance of
15    cumulative peak (>0.10 ppm) versus mid-range (0.05-0.099 ppm) concentrations, given the
16    concern mat higher concentrations do not always occur at the time of maximum plant uptake in
17    the field.  This coincidence was considered to be the critical factor in determining peak
18    concentration impacts on plants. Based on evidence at that time, it was not possible to resolve
19    this issue and no experimental studies had  addressed this question. A multicomponent index was
20    suggested that combined a concentration-weighted, cumulative index with the number of
21    occurrences of hourly averaged concentrations >=0.10 ppm but no direct experimental  studies
22    have been conducted to address the usefulness of this approach in reducing uncertainty. Another
23    element considered was the appropriate diurnal window (e.g.,  7,12  or 24 hours) over which to
24    cumulate exposures.  At that time, staff concluded that the 12 hour, daylight period Was the most
25    appropriate, and widely applicable based on the information available at that time that the
26    majority of plants, although not all, have significantly reduced stomatal conductance at night, so
27    that the potential for significant impacts from nighttime Os exposures was considered low.
28            7.2.4.1    Concentration-based Forms
29          Concentration-based air quality exposure indices focus on a particular feature or features
30    (e.g., concentration, duration, and exposure patterns) of the ambient pollutant profile that has
31    been experimentally shown to be predictive of plant response. A few recent studies have focused
32    on the role of these different components of Oa exposure and have substantiated the earlier
33    conclusions in the 1996 CD and Staff Paper of the importance of higher concentration,  shape of
34    the peak, and the episodicity of peak occurrence in eliciting the plant response to Os exposure.  A
35    few studies have also further clarified the role of nocturnal conductance. Because it has
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 1   implications for selecting the appropriate diurnal timeframe over which to cumulate exposures,
 2   this latter topic is reviewed in more detail below.
 3          Musselman and Minnick (2000) performed an extensive review of the literature and
 4   reported that a large number of species had varying degrees of nocturnal stomatal conductance
 5   (Musselman and Minnick, 2000).  Although stomatal conductance was lower at night than
 6   during the day for most plants, nocturnal conductance could result in some measurable 63 flux
 7   into the plants. In addition, plants might be more susceptible to 63 exposure at night than during
 8   the daytime, because of possibly lower plarit defenses at night (Musselman and Minnick, 2000).
 9   Nocturnal O? flux also depends on the level of turbulence that intermittently occurs at night.
10   Based on their review, Musselman and Minnick (2000) recommended that any O$ exposure
11   index used to relate air quality to plant response should use the 24-h cumulative exposure period
12   for both exposure-response and effective flux models.
13          The role of nighttime stomatal conductance and Oa exposure was demonstrated
14   experimentally as well. Grulke et al. (2003) showed that the stomatal conductance at night for
15   Ponderosa pine in the San Bernardino NF (CA) ranged from 10% to 25% that of maximum
16   daytime gas exchange. In June, at tile high-elevation site, 11% of the total daily Os uptake of
17   pole-sized trees occurred at night.  In late summer, however, Os uptake at night was negligible.
18   Birch seedlings exposed to OB at night show greater reductions in growth than those exposed to
19   Os in daylight (Matyssek et al., 1995).  Massman (2004) suggested that nocturnal stomatal Oa
20   uptake accounted for about 15% of the cumulative daily effective 63 dose that was  related to
21   predicted injury.
22          A number of findings, however, confound the generalization of the importance of
23   nocturnal exposures.  For example, field mustard (Brassica rapa L.) plants exposed  to Os during
24   the day or night showed little significant difference in the amounts of injury or reduced growth
25   response to Os treatment, and the stomatal conductance was 70 to 80% lower at night (Winner .et
26   al., 1989). Tissue biomass of Ponderosa pine seedlings was significantly reduced when seedlings
27   were exposed to either daytime or nighttime episodic profiles (Lee and Hogsett, 1999) and the
28   biomass reductions were much greater with daytime peak concentrations than with  nighttime
29   peak concentrations. In an evaluation of a very large number of indices that described the Os
30   impact on spring wheat, Finnan et al. (1997) did not find any improvement in performance of the
31   cumulative concentration-weighted indices by weighting those concentrations occurring during
32   sunlight hours. Thus, it would appear that the importance of nocturnal conductance is species
33   specific.
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 1            7.2.4.2    Flux-based forms
 2          A large number of recent studies have focused on the development of a flux-based index
 3    to better relate ambient Os to observed vegetation effects.  Though a few such studies were
 4    published prior to 1996 and reviewed in the 1996 O3 CD (U.S. Environmental Protection
 5    Agency, 1996b), a large body of recent literature has further highlighted and elucidated the
 6    multiple controlling factors and complexities (outlined below) that are associated with linking
 7    ambient ozone concentrations to observed plant response.  Specific factors that influence
 8    stomatal uptake and subsequent plant response to OB include:
 9
10          (1) The potential for maximum flux of Os into a leaf depends on synchronicity between
11    the timing of peak exposure events and maximal stomatal  conductance. In cases where there is
12    disconnect between these two diunal patterns, the predicted effect of the exposure for that
13    species/individual is an overestimation.  This concern is especially apparent when assessing the
14    impact of Os across all the varied climatic regions and species occurring within the U.S..
15
16          (2) Multiple meteorological, species-and site-specific factors influence Os uptake. In
17    order to integrate those factors that drive the patterns  of stomatal conductance and exposure,
18    some studies use stomatal (Ashmore et al., 2004a) or physiological process-based models
19    (Laurence et al., 2001).  However, the species- and site-specific scope of these models limits
20    their usefulness in national or regional scale risk assessments.
21                          ;•
22          (3) Not all 63 stomatal uptake results in a reduction in yield.  This nonlinear relationship
23    between Os uptake and plant injury (not growth alteration) response depends to some degree on
24    the amount of internal detoxification occurring with each particular species; species having high
25    amounts of detoxification potential may show less of a relationship between 63 stomatal uptake
26    and plant response. Because detoxification potential is genetically determined, it cannot be
27    generalized across species.  Much more needs to be learned about the detoxification processes
28    available to plants and to what extent they modify the potentially phytotoxic dose in the leaf
29    interior before this factor can be meaningfully considered  in a biologically-relevant index.
30
31          It is anticipated that, as the overlapping mathematical relationships of conductance,.
32    concentration, and defense mechanisms are better defined, Os-flux-based models may be able to
33    predict vegetation injury and/or damage at least for some categories of canopy-types with more
34    accuracy than the currently available exposure-response models. The results of these studies and
35    reviews indicate the need to continue to develop indices that are more physiologically and
36    meteorologically connected to the actual dose of Oa the plant receives. The  flux approach should

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 1    provide an opportunity to improve upon the concentration-based exposure index in the future,
 '2    recognizing that a concerted research effort is needed to develop the necessary experimental data
 3    and modeling tools that will provide the scientific basis for such critical levels for Og (Dammgen
 4    et al., 1994; Fuhrer et al, 1997; Grunhage et al., 2004).

 5            7:2.4.3    The Critical Level Approach
 6          Both the concentration-based and flux-based exposure index forms can be used to
 7    establish "a "critical level" for plant exposure to 63. One definition of a critical level is "the
 8    concentration of pollutant in the atmosphere  above which direct adverse effects on receptors,
 9    such as plants, ecosystems, or materials may occur according to present knowledge" (UNECE,
10    1988). As used by the United Nations Economic Commission for Europe International
11    Cooperative Programme (UNECE ICP), the critical levels are not air quality regulatory standards
12    in the U.S. 'sense, but rather planning targets  for reductions in pollutant emissions to protect
13    ecological resources. Critical levels for Os are intended to prevent long-term deleterious effects
14    on the most sensitive plant species under the most sensitive environmental conditions, but not to
15    quantify Os effects.  The nature of the "adverse effects" was not specified in the original
16    definition, which provided for different levels for different types of harmful effect (e.g., visible
17    injury  or loss of crop yield). There are also different levels for crops, forests, and seminatural
18    vegetation.  The caveat,  "according to present knowledge," is important because critical levels
19    are not rigid; they are revised periodically as new scientific information becomes available. To
20    date, critical levels (Level I) have been set for agricultural crops, for foliar injury symptoms in
21    the field and for forest trees (see section 7.2.5 and EPA, 2005b). Level I critical levels are
22    currently used to map and identify areas in Europe in which the levels are exceeded, and that
23    information is then used to plan optimized and effects-based abatement strategies.
24          In the 1990s, however, many exposure studies demonstrated that the simple, exposure-
25    based approach led to the overestimation of effects in some regions and underestimation in
26    others (Fuhrer et al., 1997; Karenlampi and Skarby, 1996) because it did not differentiate
27    between plant species, and it did not include  modifying site and micrometeorological factors of
28    Os uptake such vapor pressure deficit (VPD), water stress, temperature, and light and variation in
29    canopy height. At that time, a decision was made by the UNECE ICP to work towards a flux- •
30    based approach for the critical levels ("Level II"), with the goal of modeling Os flux-effect
31    relationships for three vegetation types: crops, forests, and seminatural vegetation (Grunhage and
32    Jager, 2003). Progress has been made in modeling flux (Ashmore et al., 2004a,b) and the
33    Mapping Manual is being revised (Ashmore  et al., 2004a,b; Grennfelt, 2004; Karlsson et al.,
34    2003). The revisions may include a flux-based approach for three crops:  wheat, potatoes, and
35    cotton. However, because of a lack of flux-response data, a cumulative, cutoff concentration-
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  1   based (AOTx) exposure index will remain in use for the near future for most crops and for
  2   forests and seminatural herbaceous vegetation (Ashmore et al., 2004a).

  3           7.2.4.4    Summary
  4          From the above discussion, several cautionary statements emerge that must be kept in
  5   mind when considering the most appropriate and useful concentration- or flux-based forms for
  6   characterizing the air quality that is associated with adverse vegetation effects (e.g., when
•  7   defining a critical level). First, current understanding of the important components of exposure
  8   in eliciting plant response are based on exposure regimes that favored Os uptake, contained large
  9   numbers of peak concentrations, and closely controlled other environmental factors.  In the
 10   absence of further study, it is unclear how well indices selected on this basis perform under
 11   different exposure and growth scenarios. Second, flux-based models are currently limited by the
 12   species-specific information required and by the observed nonlinearity between total flux and
 13   plant response.  Better understanding of the detoxification and compensation processes would be
 14   required to account for this nonlinearity in future models. In some cases, Os exposure has been
 15   shown to explain 63 effects as well or better than calculated internal Os dose (Grulke, et al.
 16   2002; Hanson et al., 1994).
 17          Other relevant information that should be evaluated include the extent to which: (1)
 18   nighttime exposures represent a significant percentage of total diurnal exposures, and whether
 19   their impact on growth or foliar injury effects are proportional; (2) elevation and nocturnal
 20   turbulence effects may alter actual nocturnal uptake; and (3) plant defense mechanisms and other
 21   processes may differ at night, leading to either more or less susceptibility than that associated
 22   with daytime exposures. Staff will take into account the expanded evidence on the importance of
 23   nocturnal conductance/exposures that has become available since the last review, along with the
 24   associated caveats, in its consideration of appropriate averaging time windows.
 25          Until such research can be done, the current draft CD concludes that, at this time, based
 26   on the current state of knowledge, exposure indices that differentially weight the higher hourly
 27   average Os concentrations but include the mid-level values still represent the best approach for
 28   relating vegetation effects to Os exposure in the U. S.. This is due in part to the existence of a
 29   large database that has been used for establishing exposure-response relationships. Such a
 30   database does not yet exist for relating Oj flux to growth response. The draft CD further
 31   concludes that the disconnects between period of maximum uptake and peak 63 occurrence,, as
 32   well as the potential for nocturnal uptake, should be considered by adding some weighting
 33   functions into the currently used exposure indices. Of particular consideration would be their
 34   inclusion in regional-to-national estimations of 03 impacts on vegetation. In evaluating the
 35   information now available and described in the current CD, staff will consider whether and how .
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 1    additional flux/uptake-related factors could be combined with, existing cumulative, peak
 2    weighted indices in order to develop an air quality index that is a better surrogate predictor of
 3    vegetation risk.
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       7.2.5  *    Ozone Exposure-Plant Response Relationships
       Much of what is known about Os exposure-plant response relationships, as summarized
below, is based.on research that was available in the last review. Thus, the present discussion is
largely based on the conclusions of the 1978,1986, and 1996 CDs EPA, 1978,1986,1996a).
These earlier conclusions were derived from basically two types of studies:  (1) studies that
developed predictive equations relating Osexposure to plant response, and (2) studies that
compared the effects of discrete treatment level(s) to a control.  The advantage of the regression
approach is that exposure-response models can be used to interpolate results between treatment
levels.  During the 1980s, the most commonly used indices for expressing Oa exposure were 7-,
8-, or 12-h daytime average values over the duration of Os exposure, which was often 3 months
or somewhat less for experimental studies with crops.  Studies into the 1990's also began to use
cumulative, peak weighted forms.

       (1) Ozone can cause a range of effects, beginning with individual cells, leaves, and
plants,  and proceeding to plant populations and communities. These effects may be classified as
either "injury" or "damage". Injury encompasses all plant reactions, such as reversible changes
in plant metabolism (e.g., altered photosynthetic rate), altered plant quality, or reduced growth
that does not impair yield or the intended use or value of the plant (Guderian, 1977).  In contrast,
damage includes all effects that reduce or impair the intended use or value of the plant. Damage
includes reductions in aesthetic values (e.g., foliar injury in ornamental species) as well as losses
in terms of weight, number, or size of the plant part that is harvested (yield loss). Yield loss also
may include changes in crop quality, i.e., physical appearance, chemical composition, or the
ability to withstand storage.

       (2) Research results since 1978 did not invalidate EPA conclusions (EPA, 1978,1986)
that foliar symptoms due to Os exposures reduce the market value of certain crops and
ornamentals where leaves are the product (such as spinach, petunia, geranium, and poinsettia)
and that such damage occurs at ambient Os concentrations observed in the U.S.. In addition, the
results  of OTC studies that compared yields at ambient Os exposures with those in filtered air
and retrospective analyses of crop data also established that ambient Os concentrations were
sufficient to reduce the yield of maj or crops in the U. S:.'  .
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       (3)  A 3-month SUM06 exposure of 24.4 ppm h, corresponding to a 7-h mean of 49 ppb
and a 2HDM of 94 ppb O3 may prevent a 10% loss in 50% of the 49 experimental cases analyzed
by Tingey et al. (1991). A 12-h growing season mean of 0.045 ppb should restrict yield losses to
10% in major crop species (Lesser et al., 1990).

       (4)  Depending on duration, concentrations of Oa and SUM06 exposures currently in the
United States are sufficient to affect the growth of a number of tree species. Given the fact that
multiple-year exposures may cause a cumulative effect on the growth of some trees (Simini et
al., 1992; Temple et al., 1992), it is likely that a number of species currently are being impacted,
even at ambient Os exposures.

       (5)  Exposure-response functions for 51 cases of seedling response to O3 (Hogsett et al.,
1995), including  11 species representing deciduous and evergreen growth habits, suggest that a
SUM06 exposure for 5 months of 31.5 ppm h would protect hardwoods from a 10% growth loss
in 50% of the cases studied.  A SUM06 exposure of 42.6 ppm h should provide the same level of
protection for evergreen seedlings. These conclusions do not take into the account the possibility
of effects on growth in subsequent years, an important consideration in the case of long-lived
species.

       (6) Studies of the response of trees to Os have established that, in some cases (for
instance, poplars and black cherry), trees are as sensitive to Oa as are annual plants, in spite of
the fact that trees are longer-lived and generally have lower gas exchange rates, and, therefore,
lower Os uptake.

       (7) Use of the chemical protectant, EDU, is of value in estimating Oa-related losses in
crop yield and tree growth, provided that care is exercised in establishing appropriate EDU
dosages to protect the plants without affecting growth.

       Studies conducted since the conclusion of the last review have not fundamentally altered
the conclusions stated above. Unfortunately, no single exposure index has been used
consistently in the recent literature.  Of the cumulative indices that preferentially weight higher
concentrations, the SUM06 index has been used most commonly in the U.S. literature, while the
use of the AOT40 index has become quite common in Europe. This lack of consistency makes it
difficult to compare experimentally derived exposure-response data expressed as AOT40 to
ambient U.S. Os exposures.  The paragraphs below touch on areas where new research has
confirmed or expanded the knowledge base that existed in the last review.
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       (1) Much of the research on the effects of Os on growth, biomass, and yield effects in
annual and biennial species during the last decade has been conducted in Europe. Substantial
effort has gone into developing a Level-I critical level for crops. Based on regression analysis of
15 OTC studies of spring wheat, an AOT40 value of 2.8 ppm-h corresponded to a 5% yield loss
(Fuhrer et al., 1997). Because a 4 to 5% decrease could be detected with a 99% confidence level,
a critical level of an AOT40 value of 3 ppm-h was selected in 1996 (Karenlampi and SkSrby,
1996).

       (2) Several studies during recent decades have further demonstrated Os effects on
different stages of reproduction. Effects of Os have been observed on pollen germination, pollen
tube growth, fertilization, and abortion of reproductive structures, as reviewed by Black et al.
(2000). Reproductive effects will culminate for seed-bearing plants in seed production.  The
recent scientific literature supports the conclusions of the  1996 CD that ambient Cb
concentrations are reducing the yield of major crops in the U. S. and that there may be
economically important effects of ambient Ch on the quality of crop and forage species.  For
example, the yield reductions for soybean are generally similar to those reported previously
(EPA, 2005b). Ozone may also reduce the quality or nutritive value of annual species.  Foliar
symptoms are important if they reduce the marketability of the crop. In Europe, Level I critical
levels have been determined for such effects.

       (3) During the past 10 years, much of the research in the U.S. has focused on perennial
species, including forage crops. Recent results confirm that yields and quality of multiple-year
forage  crops are reduced at sufficient magnitude to have nutritional and possibly economic
implications to their use for ruminant animal feed at Oa exposures that occur in some years over
large areas of the U.S.. When species are grown in mixtures, Qa exposure can increase the
growth of O3-tolerant species while exacerbating the growth decrease of Ch-sensitive species.  In
Europe, a provisional critical level for perennials of an AOT40 value of 7 ppm-h over 6 months
has been proposed to protect sensitive plant species from the adverse effects of Os.

       (4) A few investigations reported since the last review have examined saplings or mature
trees, notably of oak species in the southern Appalachian Mountains and pine species in
California. Most of these studies have been of natural (uncontrolled) Os exposures. Additional
studies have examined foliar symptoms on mature trees, and in recent years such surveys have
become more common and with greater attention to the standardization of methods and the use
of reliable indicator species (Campbell et al., 2000; Smith et al., 2003). Previous CDs have
     November 2005
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 1   noted the difficulty in relating foliar symptoms to effects on individual tree growth, stand
 2   growth, or ecosystem characteristics (EPA, 1996a). This difficulty remains to the present day.
 3
 4          (5) Some investigators have suggested that a comprehensive risk assessment of the
 5   effects of Os on mature tree species might best be accomplished by extrapolating measured
 6   effects of Oaon seedlings to effects on forests using models based on tree physiology and forest
 7   stand dynamics (Chappelka and Samuelson, 1998; Laurence et al.3 2000, 2001).
 8
 9          (6) An ongoing study was undertaken using a FACE carbon dioxide and Oa enrichment
10   facility in Rhinelander, WI (Isebrands et al., 2000, 2001). These studies showed that Ch-
11   symptom expression was generally similar in OTCs, FACE, and gradient sites, supporting the
12   previously observed variation among aspen clones (Karnosky et al., 1999).
13
14          (7) Many studies have demonstrated that root growth is more sensitive to Cbexposure
15   than is stem growth.  In Finland, reduced root growth was found for a number of clones of silver.
16   birch (Oksanen and Saleem, 1999). After 5 years, root growth was decreased by 33%, but shoot
17   growth was not affected by Cb exposures of a 7-h mean of 15 ppm-h over 5 years in a FACE
18   system (Oksanen, 2001). Data from a long-studied pollution gradient in the San Bernardino
19   Mountains of southern California suggests that Cb substantially reduces root growth in natural
20   stands of ponderosa pine.  Root growth in mature trees was decreased at least 87% in a high
21   pollution site as compared to a low pollution site (Grulke et al., 1998), and a similar pattern was
22   found in a separate study with whole tree harvest along this gradient (Grulke and Balduman,
23   1999). In contrast, a study in Great Smoky Mountains National Park in Tennessee (Neufeld et
24   al., 2000) found no statistically significant effects of Cb exposure on stem or root biomass for
25   several tree species.
26
27          (8) European beech was selected for development of a Level I critical level, because data
28   from several studies were available for this species and because deciduous tree species were
29   judged to be more sensitive to Cb compared to evergreen tree species (Fuhrer et al., 1997;
30   Karenlampi and Skarby, 1996). A critical level was defined as an AOT40 value of 10 ppmh for
31   daylight hours for a 6-month growing season (Karenlampi and Skarby, 1996). However, other
32   studies have shown that other species such as silver birch may be more sensitive to Cb than beech
33   (Paakkonen et al., 1996).
34
               x
35          (9)  Recent results support the conclusions of the 1996 CD (EPA, 1996) that individual
36   deciduous trees are generally less sensitive to Cb than are most annual plants, with the exception

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 1   of a few. genera such as Populus, which are highly sensitive. However, the data suggest that
 2   ambient exposures that occur in different regions of the U.S. can sometimes reduce the growth of
 3   seedlings of deciduous species. The (^sensitivity of seedlings and mature trees within species
 4   and between species varies widely.  In general, mature deciduous trees are likely to be more
 5   sensitive to Os compared to seedlings, while mature evergreen trees are likely to be less sensitive
 6   than seedlings.  Based on these results, stomatal conductance, Chuptake, and Os effects cannot be
 7   assumed to be equivalent in seedlings and mature trees.
 8    73
VEGETATION IMPACT ASSESSMENT
 9          7.3.1       Overview
10          The planned assessments for the current review are outlined in Figure 7.1(a-c). These
11    assessments build upon the 1996 review and ozone response relationships contained in that
12    review. This section is organized based on each of the main components of the assessment.
13    First, the air quality data, modeling and interpolation analyses that will be input into the rest of
14    the vegetation assessment are discussed. A description then follows of the four areas in which
15    Os exposures and impacts will be assessed. The vegetation exposure and risk discussion is
16    divided between the crop and tree analyses. The crop part of the analysis will focus on the
17    estimated effect of current Os on crop yield and how this, in turn, affects modeled economic
18    parameters for the agriculture sector. The tree analyses have three parts: (1) seedling growth
19    will be updated to estimate growth loss under estimated 2001 Os conditions; 2.) foliar injury will
20    be linked to current monitored and estimated air quality levels; and (3) the TREGRO model will
21    be used to model ponderosa pine growth under recent air quality data and under scenarios where
22    alternative standards are just met. The plans discussed in the following sections take into
23    account the range of views that were expressed during the recent consultation with the CASAC
24    Os Panel. Differing views were expressed in some areas by Panel members and the description
25    of the assessments has addressed the comments to the extent possible.  Generally the comments
26    were concerned with better characterization of uncertainties in the 63 exposure interpolation for
27    2001, Os concentration measurements at the height of monitor inlets relative to the actual Os
28    concentration at the vegetation height, the continued relevance of C-R functions from NCLAN
29    studies and their incorporation into the agricultural model used in the crop analysis.  This first
30    draft Staff Paper acknowledges and seeks to identify all the potentially relevant sources of
31    uncertainty that will be more fully quantitatively and qualitatively characterized in the second
32    draft Staff Paper.
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1   Figure 7. l(a-c).  Major Components of Planned Environmental Assessment
2
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 1          73.2       Air Quality Analysis
 2          To accomplish an assessment of the effects of ambient Os exposures on vegetation and
 3   ecosystems, it is important to characterize recent Os air quality over broad geographical areas of
 4   concern. This presents a great challenge since vast rural areas of the U.S., where important crops
 5   and natural vegetation occur, do not have Os monitors. Thus, staff is currently evaluating a
 6   variety of approaches for estimating potential Os exposures in these non-monitored areas. Three
 7   main approaches available for characterizing ozone exposures in non-monitored areas are: (1)
 8   use of sophisticated models of air quality to model the entire U. S.; (2) use of data collected from
 9   monitors to interpolate non-monitored areas; and (3) combining monitored and modeled
10   information into an interpolated surface. The section below describes the main approach staff
11   plans to use to combine monitored observations and modeled 63 predictions from CMAQ to.
12   estimate Oa exposures in many areas as possible. Staff also intends to evaluate a whether
13   interpolation without modeled data would be adequate in areas with relatively, dense monitoring
14   coverage. As suggested during the CASAC consultation, staff will also interpolate across
15   smaller, more homogeneous regions rather than across the entire contiguous U.S. The staff also
16   plans to rely on monitoring  data where possible (see sections 7.2.4)

17            73.2.1    Monitor coverage
18          EPA monitored data is currently available through 2004. The monitored hourly Os data
19   is available from two networks: (1) Air Quality System (AQS;
20   http://www.epa.gov7ttn/airs/airsaqs) and (2) Clean Air Status and Trends Network (CASTNET;
21   http://www.epa.gov/castnetA. The locations of these monitors are presented in Figure 7.2a-b and
22   are described in section 2.3.1 and 2.3.2 of Chapter 2.  The AQS monitoring network currently
23   has over 3000 monitors measuring Os concentrations and monitors are generally  sited near
24   population centers. However, there are approximately 36 monitored located in National Parks.
25   CASTNET is the nation's primary source for data on dry acidic deposition and rural, ground-
26   level ozone. It consists of over 80 sites across the eastern and western U.S. (see Figure 7-2b).
27          During the recent CASAC consultation, the question was raised about how 63
28   concentrations measured by the monitoring network compare to concentrations occurring at the
29   surface of vegetation.  Inlets to ambient monitors are typically  at heights of 3 to 5 meters, and
30   thus are located in the inner part of the planetary boundary layer (EPA, 2005b). It is well known
31   that within this  layer 03 reacts with vegetation and other surfaces on the ground and can create
32   vertical gradient of decreasing Os concentration from the inlet height of the monitors to the
33   surface of vegetation and crops (Regener, 1957). The magnitude of the gradient is determined
34   by the intensity of turbulent mixing in the surface layer. During the daytime hours the vertical
35   Os gradient is relatively small because turbulent mixing maintains the downward flux of Oj. For
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 1    example, Hovath et al. (1995) calculated a 7% decrease in Os going from a height of 4 meters
 2    down to 0.5 meters above the surface during unstable (or turbulent) conditions in a study over
 3    low vegetation in Germany. This is compared to a 20% decrease during stable conditions which
 4    usually occur during the night. While staff acknowledges there is likely to be bias in using Oa
 5    data from inlets of ambient monitors to characterize Os exposures close to the surface, this bias is
 6    likely to be relatively small under typical turbulent mixing during the day. The day-time versus
 7    the night-time bias is an important distinction considering the assessments outlined below will
 8    rely heavily on daytime metrics such as the!2hr SUM06.

 9           7.3.2.2    Modeling tools
10          Staff plans to use 03 outputs from the EPA/NOAA CMAQ model system
11    (http://www.epa.gov/asmdnerl/CMAO. Byun and Ching, 1999; Arnold et al. 2003; Hogrefe et al.
12    2004;,Eder and Yu, 2005) to spatially scale an interpolation of 63 monitoring data for different
13    regions of the U.S.. The CMAQ modeling system has undergone two external peer reviews
14    through the Community Modeling and Analysis System (CMAS) based at the University of
15    North Carolina at Chapel Hill (UNO Carolina Environmental Program (Amar et al. 2005,2004).
16    The CMAQ model is a multi-pollutant, multiscale air quality model that contains state-of-science
17    techniques for simulating all atmospheric and land processes that affect the transport,
18    transformation, and deposition of atmospheric pollutants and/or their precursors on both regional
19    and urban scales.  It is designed as a science-based modeling tool for handling many major
20    pollutants (including photochemical oxidants/Os, PM, and nutrient deposition) holistically. The
21    CMAQ model incorporates output fields from emissions and meteorological modeling systems
22    and several other data sources through special interface processors into the CMAQ Chemical
23    Transport Model (CCTM).  Currently, the Sparse Matrix Operator Kernel Emissions (SMOKE)
24    System produces the emissions factors and the Fifth Generation Perm State University/ National
25    Center for Atmospheric Research Mesoscale Model (MM5) provides the meteorological fields.
26    CCTM then performs chemical transport modeling for multiple pollutants on multiple scales.
27          The CMAQ model can generate estimates of hourly Os concentrations for the contiguous
28    U.S., making it possible to express model outputs in terms of a variety of exposure indices (e.g.,
29    SUM06, 8-hr average). Due to the significant resources required to run CMAQ, however, model
30    outputs are currently only available for limited years.  Currently, 2001 outputs from CMAQ
31    version 4.5 are the most recent data available. This version of CMAQ utilizes the more refined
32    12 km x 12 km grid for the eastern U.S., while using the 36 km x 36 km grid for the western U.S.
33    The 12 km x 12 km domain covers an area from roughly central Texas, north to North Dakota,
34    east to Maine, and south to central Florida Emission inventories of SO2, CO, NOx, and VOCs
35    are based on EPA's 2001 National Emission Inventory (NEI) and are consistent with inventories
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 1   used for the analysis of the Clean Air Interstate Rule (CAIR) rule (EPA, 2005c). Biogenic
 2   emissions were processed using the Biogenic Emissions Inventory .System (BEIS) version 3.13.
 3   The staff recognizes that 03 exposures vary between years depending on meteorology and other
 4   factors. Therefore, staff will add additional years for comparison if more CMAQ outputs
 5   become available.
 6          Recently EPA/NOAA conducted an initial evaluation of the eastern U.S. domain of
 7   CMAQ version 4.5 (Appeletal., 2005;
 8   http://www.cmascenter.org./docs/CMAO/v4.5/CMAOv4.5 EvaluationDocument-Final2005.pdf).
 9   This evaluation used the same metrics published by Eder and Yu (2005) for the CMAQ version
10   4.4 model release.  For the modeled summer months of June, July and August of 2001, CMAQ
11   version 4.5 predictions were compared to AQS monitor sites.  The prediction of daily 8hr-max
12   Os was relatively good, showing a slight positive normalized mean bias of 1.62% and a
13   normalized mean error of 17.4%. Hourly ozone patterns are predicted well during the daytime.
14   However, the CMAQ consistently over-predicted hourly Os at night. Nighttime over-predictions
15   in Os have been improved over CMAQ version 4.4 by modifications to the minimum Kz
16   approximation in CMAQ version 4.5, but additional investigations are needed. Again, since
17   many of the assessments outlined below rely daytime Os accumulated in the 12hr SUM06 (8AM-
18   8PM), the night-time over-prediction is less of an issue. Overall, CMAQ predictions of daily 8hr
19   Os averages were improved in the 12km x 12km grid size when compared to the 36km x 36krn
20   grid size.
21          Since CMAQ output is averaged over large square blocks and monitor observations are
22   effectively averages over much smaller regions, CMAQ output and monitor observations have a
23   mismatch in spatial resolution. (Fuentes and Rafterty 2005). The problem is well known, but is
24   often ignored since there are not standard operational methods that can be applied to the CMAQ
25   model output to deal with this problem. The CMAQ version 4.5 evaluation described above
26   ignores the mismatch of spatial resolution and treats CMAQ output as a point-value. The staff
27   believes this simplification is reasonable because Os is a secondary pollutant and its
28   concentration generally varies fairly  smoothly in flat rural areas where important crops and
29   vegetation grow.  However, Q$ is notably variable in complex terrain, across in urban/rural
30   gradients and along coastal areas.  In these cases significant differences in Os concentration
31   could occur with a 12xl2km call and the uncertainties associated with areas are unknown.  The
32   current assessment is most concerned with rural areas and it is recognized that any estimates of
33   Os exposure in complex terrain are very uncertain.
     November 2005
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 Figure 7.2 Locations of AQS monitors (top) and CASTNET monitoring stations
 a.
  3  illtlllJi III 11:1 111 plBISS llfll
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 1            7.3.2.3    Generation of Potential Ozone Exposure Surfaces
 2          Staff will interpolate Oa exposures on a regional basis rather than a continuous surface for
 3    the US. The result of these interpolations will be the creation of regional Potential Ozone
 4    Exposure Surfaces (rPOES). First staff will separate the eastern and western regions of the U.S.
 5    based on the 12km and 36km CMAQ model domains.  The eastern domain will be partitioned
 6    into homogeneous sub-regions as defined by Eder et al. (1993). For the western domain, staff
 7    will follow Hie subregions as defined by Lee et al (2001).
 8          To estimate a rPOES for different regions of the contiguous U.S., staff plans to primarily
 9    use the interpolation module in BenMAP, which uses the enhanced Voronoi Neighbor Averaging
10    (eVNA) interpolation method to combine monitored data with spatial scaling from CMAQ
11    model outputs (see appendix C.3.2 ofhttp://w^y\^epa.gpv/1te/ecas/models/mQd8idoc,pdft.  This
12    method employs inverse-distance weighting of monitoring data scaled by the CMAQ model.
13    This method makes the implicit assumption that CMAQ adequately characterizes the general
14    spatial pattern of 63 exposures. It also retains the true  monitored values at monitored sites.
15    Exceptions to this approach might be warranted in certain cases. For example, in areas with
16    fairly dense monitor coverage (e.g., northeastern U.S.) staff will investigate whether
17    interpolation without spatial scaling would be a satisfactory. Likewise, in areas of the country
18    with little or no monitor coverage, where an interpolation would depend on data from distant
19    monitors that may have very little correlation with the true Os exposure at the unmonitored cell,
20    staff is evaluating the benefit of identifying criteria that could be used to define the appropriate
21    spatial "window" within which monitored sites can be  used to interpolate values for the non-
22    monitored area and/or whether it is more suitable in these cases to use CMAQ modeled 63
23    exposures only, instead of relying on interpolated Oj values. At a minimum, staff plans to
24    generate the rPOES in terms of both the 12-hr (8 am to 8 pm), maximum 3-month SUM06 index
25    and  the 8-hr average index that reflects the form of the current secondary standard.
26          Staff recognizes there are inherent uncertainties in the interpolation that must rely on
27    sparse data representative of urban and near-urban areas with little representation of rural areas.
28    This network could bias the picture of the ozone exposure estimate. This limitation will be noted
29    when results are presented in the second draft of the  staff paper. It is expected that this eVNA
30    with spatial scaling from CMAQ approach will be an improvement over a simple interpolation
31    between monitors that does not use spatial scaling from an air quality model. The interpolation
32    technique will be run without spatial scaling to test this expectation and to determine if
33    interpolation without CMAQ scaling could be used to characterize Os exposures in regions with
34    relatively dense monitoring coverage. This will allow  for characterization of ozone exposures in
35    other years besides 2001.  Finally, the uncertainties associated with estimating exposures at non-
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 1    monitored areas will be quantified by removing a subset of monitors and interpolating the
 2    missing monitors with the remaining data.
 3          During the recent CASAC consultation, the question was raised as to whether other
 4    approaches, such as kriging, would be appropriate for the interpolation of Os exposures in non-
 5    monitored areas. The eVNA approach outlined above is simple, but does not allow for
 6    calculation of the model error in the same way kriging does. While staff agrees that kriging may
 7    be an appropriate interpolation method in general, it is not available as an option in the BenMAP
 8    model that will be used for this assessment,

 9            7.3.2.4    Alternative Air quality scenarios
10          The following air quality scenarios will be generated:

11         •  "As is" air quality (using base year 2001)
12         •  Meeting the current standard: 4th highest daily maximum 8-hr average of 0.084 ppm
13         •  Meeting alternative Os standards
14          In conjunction with work being done as part of the health risk assessment, the quadratic
15    air quality adjustment that was used in the last review will be used to simulate just meeting the
16    current and alternative standards (Johnson, 1997).  This technique combines both linear and
17    quadratic elements to reduce larger Oa concentrations more than smaller ones. In this regard, the
18    quadratic method attempts to account for reductions in emissions without greatly affecting lower
19    concentrations near  ambient background levels. EPA has recently evaluated the implementation
20    of this method on a subset of monitors and found that when this method is used to roll-back Os
21    values from "high" years, it yields a similar distribution of hourly Os values to that of "low" Oj
22    years (Rizzo, 2005).  Further, the quadratic method performs better than proportional and peak-
23    shaving methods when compared to monitor data.  In addition, EPA NHEERL-WED lab is
24    conducting an evaluation of the quadratic method for the rural Crestline monitor in the San
25    Bernardino Mountains of Southern California. Results of that evaluation will be included in the
26    next draft Staff Paper.

27          7.3.3      Crop Risk/Benefits Assessments
28          In light of a number of developments since the last review, including the potential to
29    better characterize Os exposures in crop growing regions using the CMAQ model, changes in air
30    quality, updated crop planting information, and an alternative agricultural economic model that
31    reflects the most up-to-date market forces, staff plans to update the previous review/s crop risk
32    and economic benefits assessments in order to better evaluate the adequacy of the level of
33    protection afforded by the current standard.

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  1          One element of the analysis that has not changed since the last review is the source of the
  2   crop yield loss concentration response (C-R) functions. The 1996 crop assessment was built
  3   upon the NCLAN (National Crop Loss Assessment Network) Os C-R functions. Since very few
  4   new studies have published C-R functions that would be useful in an updated assessment, C-R
  5   functions from NCLAN remain the best data available for a national assessment of crop loss
  6   under various Os air quality scenarios. The NCLAN protocol was designed to produce crop C-R
  7   data representative of the areas in which the crops were typically grown. The U.S. was divided
  8   into 5 regions over which a network of field sites was established. In total, 15 crop species
  9  , (com, soybean, winter wheat, tobacco, sorghum, cotton, barley, peanuts, dry beans, potato,
 10   lettuce, turnip, and hay [alfalfa, clover, and fescue]), were studied.  The first 12 of these 15 listed
 11   species were analyzed for the .1996 review and included 38 different cultivars and were studied
 12   under a variety of unique combinations of sites, water regimes, and exposure conditions,
 13   producing a total of 54 separate cases. According to the most recent USDA National
 14   Agricultural Statistical Survey (NASS) data, these 12 species account for greater than 70% of
 15   principal crops acreage planted in the U.S. in 2004.1 Com, soybean, and winter wheat alone
 16   accounted for 61% of principal crops  acreage planted.
 17          Since the NCLAN studies were performed in 1980-1988 there is some uncertainty
 18   whether the crop cultivars tested in NCLAN are representative of crops grown today.  In general,
 19   new crop varieties are not specifically bred for Os tolerance. The fact that Os levels are not
 20   consistent from year to year does not allow crop breeders to select for ozone tolerance under
 21   natural conditions. Since the last review there has been little evidence that crops are becoming
 22   more tolerant or more sensitive to ozone (EPA, 2005b). Crops are bred for higher yield and this
 23   may even make them more susceptible to Os through higher stomatal conductance.  In cotton,
 24   some newer varieties have been found to have higher yield loss to ozone compared to older
 25   varieties (Olszyk et al. 1993, Grantz and McCool  1992). In a meta-analysis of 53 studies
 26   Morgan et al. (2003), found consistent deleterious effects of Os exposures on soybean from
, 27   studies published between 1973 and 2001. Further, early results from the Soy FACE experiment
 28   in Illinois indicate a lack of any apparent difference in the Os tolerance of old and recent
 29   cultivars of soybean in a study of 22 soybean varieties (Long et al. 2003). Given the limited
 30   amount of information available on the Os sensitivity of current cultivars of different crops, staff
 31   plans to focus this analysis most heavily on crops (such as soybean, cotton, and wheat) with
 32   information on Os sensitivity of different cultivars.
             1 Principal crops as defined by the USDA include com, sorghum, oats, barley, winter wheat, rye, Durum
      wheat, other spring wheat, rice, soybeans, peanuts, sunflower, cotton, dry edible beans, potatoes, sugar beets, canola,
      proso millet, hay, tobacco, and sugarcane. Acreage data for the principal crops was taken form the USDA NASS
      2005 Acreage Report ftii
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 1           73.3.1     Exposure Assessment
 2          In the last review, C-R functions were developed in terms of the SUM06 and Wl 26
 3   indices for most NCLAN crops (Lee and Hogsett, 1996). Currently, work is underway to re-
 4   analyze the NCLAN database to recalculate the C-R functions in terms of an 8-hr average index.
 5   Specifically, staff plans to plot relative crop yield loss against an 8-hr average index calculated
 6   from the 1-hr averages contained in the NCLAN database.  The benefits of this re-analysis are
 7   two-fold:  (1) it permits evaluation of the appropriateness of the 8-hr average index for predicting
 8   growth effects of the NCLAN studies as compared to a SUM06 index, and (2) it permits direct
 9   evaluation of estimated yield effects expected to occur under air quality scenarios expressed in
10   terms of the current 8-hr, 0.08 ppm standard level.

11           73,3.2     Crop yield loss Assessment
12          County-level crop planting data will be obtained from USDA-NASS (National
13   Agricultural Statistics Service; http://www.asda.gov/nass) for 2001 for each NCLAN crop as
14   available (Figure 7-3). This information will be used to create GIS maps containing the planting
15   data for each species/cultivar of commodity crop. Staff plans to overlay the rPOES (as discussed
16   in section 7.3.2) with GIS maps of the crop growing regions and then calculate yield loss using
17   the relevant C-R functions. This combination of data will result in an estimate of county-level
18   percent yield loss for each selected NCLAN crop. Staff plans to create GIS maps of percent
19   yield loss of each crop for the counties in which they were planted in 2001. This analysis will
20   also be performed for just meeting the current standard and other alternative standards. The
21   change in crop county-level percent yield loss estimates between 'as is' 2001 air quality and
22   meeting various standards will serve as inputs to the AGSIM agricultural economic benefits
23   model.
     November 2005
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 I

 2            73.3.3    Economic Benefits Assessment -AGSIM
 3          The Agriculture Simulation Model (AGSIM) model (Taylor 1994, Taylor et al., 1993)
 4   has been utilized recently in many major policy evaluations.2 AGSIM is an econometric-
 5   simulation model used to calculate agricultural benefits of changes in Os exposure and is based
 6   on a large set of statistically estimated demand and supply equations for agricultural
 7   commodities produced in the U.S.. A number of updates to AGSIM will be performed before
 8   running the analysis: (1) an update of the commodity data for 2001, (2) incorporation of the
 9   most recent version of the official USD A baseline model, (3) an econometric component added
10   to AGSIM to compute total farm program payments for different levels of farm program
11   parameters, and (4) farm payment program component added to the economic surplus module.
12   Initially, AGSIM will be used to calculate the economic benefits of yield changes between the
13   'as is' and 'just meet' scenarios for base year 2001. This approach will also be used to calculate
14   benefits from any alternative standards under consideration.   If data are available, the same
15   analysis will be performed using  air quality data from other years.  Information will be used from
16   a range of crop cultivars as they are available for each crop.  This will allow for some bounding
17   of possible effects of tolerant and sensitive cultivars.

18          7.3.4       Tree Seedling/Mature Tree/Forest Species Quantitative/Qualitative Risk
19                    Assessments
20          In the last review, analyses of the effects of Os on trees were limited to 11 tree species for
21   which C-R functions for the seedling growth stage had been developed from OTC studies
22   conducted by NHEERL-WED. Since the last review, only a few studies have developed C-R
23   functions for additional tree seedling species (EPA, 2005b).  Section 7.2.4.1 outlines plans to re-
24   analyze the OTC C-R functions in terms of an 8-hr average index.  Section 7.2.4.2 describes how
25   staff plans to update the tree seedling risk analysis performed in the last review.  Section 7.2.4.4
26   discusses the planned approach for modeling Oa impacts  on mature trees.  Section 7.2.4.3
27   discusses the planned approach for assessing Os effects on vegetation in natural settings  using
28   visible foliar injury data.  The tree and/or forest analyses outlined below will enable staff to
29   begin to assess important long-term effects of various secondary standard levels on'forest
30   ecosystem health and services.
            2 For example, AGSIM© has been used in EPA's prospective study of the benefits deriving from the Clean
      Air Act Amendments of 1990 required by section 812-B of the Clean Air Act, non-road land-based diesel engine
      rule, and proposed Clear Skies legislation.
     November 2005
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 1            7.3.4.1    Selected Species Exposure Assessment
 2          Similar to crops (section 7.3.3), C-R functions for tree seedling biomass loss due to Os
 3    exposures have not been reported in terms of an 8-hr average index.  Staff plans to re-analyze the
 4    11 OTC tree seedling C-R functions described in the 1996 0$ Staff Paper in terms of the current
 5    8-hr exposure metric. This re-analysis will enable staff to evaluate the appropriateness of using
 6    an 8-hr average index as a predictor of tree seedling growth/biomass losses and to directly
 7    evaluate estimated seedling biomass loss values expected to occur under air quality, exposure
 8    scenarios expressed in terms of the current 8-hr, 0.08 ppm secondary standard.

 9            7.3.4.2    Selected Tree Seedling Biomass Loss
10          In the 1996 03 Staff Paper, information on tree species growing regions was derived from
11    the USDA Atlas of United States Trees (Little,  1971). Staff plans to use more recent information
12    from the USDA Forest Service FIA database in order to update tree growing ranges for the 11
13    tree species studied by NHEERL-WED.  In a process similar to that used for crops staff plans to
14    combine the POES with the C-R function for each of the tree seedling species and information
15    on each tree species growing region to produce estimates of biomass loss for each of the 11 tree
16    seedling species.  From this information, staff plans to generate GIS maps depicting these results
17    for each POES scenario.          .                               ,

18            7.3.4.3    Foliar Injury Incidence/Epidemiology-FIA Data
19          Since the last review, there have been large amounts of data generated regarding visible
20    foliar injury to native plant species resulting from ozone exposure. The current draft CD
21    discusses the breadth of this new information.
22        •  Foliar injury is a valuable indicator of phytotoxic concentrations of ozone in ambient air
23    which, at high enough concentrations, can have wide ranging effects from altering plant fitness
24    and aesthetics, possibly altering species composition of natural systems, and reducing the
25    marketability and yield of commercially valuable species. The degree of visible foliar injury is
26    dependent on a range of environmental and genetic factors and may vary widely even among co-
27    members of a population at similar exposure levels. While sensitivity to ozone may vary
28    considerably between and within taxonomic groups, common patterns of injury have been
29    discovered. There are generally four types of lesions that form on leaves and needles as a result
30    of ozone exposure in sensitive species: pigmented lesions (stippling), surface bleaching, bifacial
31    necrosis, and chlorosis.
32          The Unites States Forest Service, first as the Forest Health Monitoring Program (FHM)
33    and then as the Forest Inventory and Analysis (FIA) Program, has been collecting data since
34    1990 regarding the incidence and severity of visible foliar injury to several plants throughout ihe
35    U.S. shown to be sensitive to ozone (Coulston et al. 2003, 2004; Smith et al. 2003).  This injury
      November 2005
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 1    has been well documented as an effect of ozone on these species and is as such a useful indicator
 2    of elevated ozone concentrations.  Biomonitoring sites are located throughout the country and
 3    analysis of foliar injury within these sites follows an established and rigorous protocol which
 4    records the incidence of characteristic stippling on the leaves of species known to exhibit
 5    sensitivity to ozone. The relative severity of injury is calculated based on the percentage of
 6    leaves showing characteristic injury for multiple individual plants of several species per site.
 7    These values are then used to give Biotic Index values for each site and each species for each
 8    year (Smith et al., 2002).
 9           Staff intends to compare the incidence and severity of visible foliar injury attributable to
10    ozone with available EPA maps of counties considered to fall below the level of Hie current 8hr.,
11    0.08 ppm secondary ozone standard (See Figure  7.4) for the same period to determine the extent
12    to which foliar injury continues to occur at levels below the current standard.  Because the EPA
13    definition of attainment for these counties incorporates a three-year average of ambient air
14    concentration that does not capture year-to-year changes in ozone concentrations, this analysis
15    will compare year-to-year data to account for anomalous years in the ambient average.
16    Similarly, staff will also compare yearly county-level 12-hour SUM06 to incidence of foliar
17    injury (See Figure 7.5).  Particular attention will  be paid to visible foliar injury in national parks
18    (Class I areas) and other areas of aesthetic interest since the perception of visible injury in these
19    areas may be more valued by the public.
20           Interpolation of ozone monitors for 2001 will be done using the CMAQ model for spatial
21    scaling. This potential ozone exposure surface (rPOES), as described in section 7.2.2, will then
22    be used to determine the amount of correlation between modeled Os exposures, interpolated FIA
23    Os exposures, and visible foliar injury as measured in the FIA data for that year. If a close
24    correlation exists, further analysis of foliar injury for additional years using FIA interpolated
25    ozone values may be possible using site or species specific data to determine the extent of
26    impacts under the current ambient air quality.  An analysis of this exposure surface will also
27    compare the degree to which the POES generated by EPA predicts relative changes in the
28    severity of foliar inj ury.
29           Important uncertainties associated with this approach of comparing 63 exposures to foliar
30    injury data include the following:
31         •  The monitoring protocol used by the FIA changed significantly between the 2001 and
32            2002 data collection seasons.  These changes added to the robustness of the data set
33            and increased the number of sites and species for which visible foliar injury is
34            collected. Due to the availability of CMAQ data, EPA must use 2001  data to generate
35            the POES.  Since the FIA data for 2001 is concentrated in the northeast and north-
36            central regions of the US, those are the regions for which a comparison can be made.
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1
2
3
4
5.

6
7
8
The geographical locations of the FIA biomonitoring sites are considered confidential
by the Forest Service. The data provided to EPA may have the coordinates "fuzzed"
up to 8.5 miles to maintain this confidentiality. This introduces some error in
determining the actual location of the foliar injury with relation to county boundaries
and relative elevations.

The SUM06 values calculated by the FIA program include all air quality monitors in
the AQS but do not include CASTNET monitors. In addition, the elevation of the
monitors has not been considered.
    November 2005
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 1            73.4.4    Ponderosa Pine case study for mature tree
 2          In the 1996 Os Staff Paper, analyses on trees were limited to the seedling growth stage.
 3    Recent experiments using the FACE methodology have been able to expose 3 tree species to Os
 4    beyond the seedling growth stage. However, this methodology has not yielded C-R functions at
 5    this time. Therefore, in order to go beyond the seedling stage, staff is planning to use a tree
 6    growth model as a tool to evaluate the effect of changing Os air quality scenarios from just
 7    meeting alternative Os standards on the growth of ponderosa pine.  This method offers a means
 8    to evaluate effects on mature trees capturing the interaction of Os uptake climate and
 9    meteorology. .
10          A tree growth simulation model, TREGRO (Weinstein et al, 1990) has been used to
11    evaluate the effects of a variety of Os scenarios and linked with concurrent climate data to
12    account for ozone and climate/metorology interactions on several species of trees in different
13    regions of the US (Tingey et al., 2001; Weinstein et al., 1991; Retzlaff et al., 2000; Laurence et
14    al., 1993; Laurence et al., 2001; Weinstein et al., 2005). Staff is collaborating with the EPA
15    NHEERL-WED lab to use the TREGRO to assess long-term ponderosa pine growth at the
16    Crestline site in the San Bernardino Mountains of California associated with 'as is' air quality,
17    and air quality adjusted to j ust meet alternative Os standards. An earlier assessment of the
18    effectiveness of national air quality standards in place since the early 1970s took advantage of 40
19    years of air quality and climate data for this site  to simulate ponderosa pine growth over time
20    with the improving air quality using TREGRO (Tingey etal., 2004).
21          Staff and NHEERL-WED scientists plan to use Crestline air quality and climate data
22    from the years 1995 to 2000 and 1980 tol 985. The years 1980 to 1985 will be used to represent
23    "bad" air quality years and 1995 to 2000 will represent recent improved air quality. Air quality
24    from each year will be rolled back using the quadratic method to 'just meet' the current 8-hr
25    secondary standard (4* highest maximum average = O.OSppm).  TREGRO will be run for "as is"
26    and "just meet" in four 3 year increments to increase the accountability of climate variability and
27    the annual average biomass determined from these 4 simulations to yield an annual average
28    biomass change over the 6 years of ozone exposure. The differences between growth under 'just
29    meet' air quality and "as is" air quality will be compared and allow for the evaluation of the
30    potential effectiveness of the current secondary standard in protecting ponderosa pine as an
31    ecological resource.  The comparisons between the annual average biomass change under the
32    two different 6 year periods (1980-1985 and 1995-2000) will allow staff to evaluate the
33    additional potential benefits from the current 8-hour standard compared to the indicated
34    improved growth achieved with the previous secondary standard put into place in the late 1970s.
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 1    7.4    ECOSYSTEM CONDITION, FUNCTION AND SERVICES
 2          Ecosystems are comprised of complex assemblages of organisms that provide distinct
 3    ecological attributes, many of which may be adversely affected by ozone (EPA, 2005b). A new
 4    effort has been initiated within the Agency to identify indicators of ecological condition whose
 5    responses can be clearly linked to changes in air quality and be used to track improvements in
 6    environmental protection attributable to environmental program actions/implementation.
 7    Moreover, a recent critique of the secondary N AAQS review process published in the report by
 8    the National Academy of Sciences on Air Quality Management in the United States (NRC, 2004)
 9    stated that "EPA's current practice for setting secondary standards for most criteria pollutants
10    does not appear to be sufficiently protective of sensitive crops and ecosystems...." This report
11    made several specific recommendations for improving the secondary NAAQS process and
12    concluded that "There is growing evidence that tighter standards to protect sensitive ecosystems
13    in the United States are needed	" However, the vast majority of information regarding the
14    effects of ozone involves the sensitivity of individual species. Therefore, this section lays out
15    some examples of our current understanding of how the O? may be affecting ecosystems and
16    identifies areas of research needed to address this issue,
17          An ecosystem is defined as comprising all of the organisms in a given area interacting
18    with the physical environment, so that a flow of energy leads to a clearly defined trophic
19    structure, biotic diversity, and cycling  of materials between living and nonliving parts (Odum,
20    1963). Individuals within a species and populations of species are the building blocks from
21    which communities and ecosystems are constructed. Classes of natural ecosystems, e.g., tundra,
22    wetland, deciduous forest, and conifer forest, are distinguished by their dominant vegetation
23    forms. Ecosystems boundaries are delineated when an integral unit is formed by their physical
24    and biological parts. Defined pathways for material transport and cycling and for the flow of
25    energy are contained within a given integrated unit."
26          Each level of organization within an ecosystem has functional and structural
27    characteristics. At the ecosystem level, functional characteristics include, but are not limited to,
28    energy flow; nutrient, hydrologic, and  biogeochemical cycling; and maintenance of.food chains.
29    The sum of the functions carried out by ecosystem components provides many benefits to
30    mankind, as in the case of forest ecosystems (Smith, 1992).  Some of these benefits include food,
31    fiber production, aesthetics, genetic diversity, and energy exchange.
32          A conceptual framework for discussing the effects of Os on ecosystems was developed
33    by the EPA Science Advisory Board (Young and Sanzone, 2002). Their six essential ecological
34    attributes (EEAs) include landscape condition, biotic condition, organism condition, ecological
35    processes, hydrologjcal and geomorphological processes, and natural disturbance regimes.
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 1    Figure 7.6 outlines the how common anthropogenic stressors, including tropospheric 63, might
 2    affect the essential ecological attributes outlined by the SAB.
 3          There is evidence that tropospheric Os is an important stressor of ecosystems, with
 4    documented impacts on the biotic condition, ecological processes, and chemical/physical nature
 5    of natural ecosystems (EPA, 2005b).  Most of the effects on ecosystems must be inferred from
 6    Os exposure to individual plants and processes that are scaled up through the ecosystem affecting
 7    processes such as energy and material flow, inter- and intraspecies competition, and net primary
 8    productivity (NPP). Thus, effects on individual keystone species and their associated microflora
 9    and fauna, which have been shown experimentally, may cascade through the ecosystem to the
10    landscape level.  By affecting water balance, cold hardiness, tolerance to wind and by
11    predisposing plants to insect and disease pests, 03 may even impact the occurrence and impact of
12    natural disturbance (e.g., fire, erosion).
13          Another approach to assessing Oa effects on ecosystems is the identification and use of
14    indicators. For example, the main indicators of phytotoxic Oj exposures used for forest
15    ecosystems are visible foliar injury (as described in section 7.3.4.3 above) and radial growth of
16    trees. Systematic injury surveys demonstrate that foliar injury occurs on Os-sensitive species in
17    many regions of the United States. However, there is not always a direct relationship between
18    the severity of the visible foliar symptoms and growth. This essentially means  it is difficult to
19    quantify or characterize the degree which EEAs may be impacted when foliar injury is found in
20    the field. Investigations of the relationship between changes in radial growth of mature trees and
21    ambient Os, in combination with data from many controlled studies with seedlings, suggest that
22    ambient Os is reducing the growth of mature trees in some locations.  However, definitively
23    attributing growth losses in the field to 63 in a wide array of ecosystems is often difficult
24    because of confounding factors with other pollutants, climate, insect damage and disease.
25          The draft CD (EPA, 2005b) outlines seven case studies where O3 effects on ecosystems
26    have either been documented or are suspected. However, in most cases, only a few components
27    in each of these ecosystems have been examined and characterized for ozone effects, and
28    therefore the full extent of ecosystem changes in these example ecosystems is not fully
29    understood.  Clearly, there is a need for highly integrated ecosystem studies that specifically
30    investigate the effect of Os on ecosystem structure and function in order to fully determine the
31    extent to which ozone is altering ecosystem services.
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1
2
3
Figure 7.6  Common anthropogenic stressors and the essential .ecological attributes they affect.
              Modified-from Young and Sanzone (2002)
                                             ;Hydro
                                             iKabUat Conversion
                                              Climate Change
                                             ibver-Hafvestins
                                                        invssive
                                                Spfrcies IrttrcducJion
                                              Large-Scale Disease/Pest
                                                Outbreaks
                                                                             Habitat Conversion
                                                                               Climate Change
                                                                      Over-Harvesting Vegttation
                                                                        Di**s$e/Pe$t Outbreaks
                                                                            Altered Fife Regime
                                                                          Altered Flood Regime
                                                                       Hy
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 1          7.4.1      Evidence Demonstrating the Potential for Ozone to Alter Ecosystem
 2                     Structure and Function
 3          The seven case studies listed in the draft CD demonstrate the potential for Os to alter
 4    ecosystem structure and function. The oldest and best example involves the San Bernardino
 5    Mountain forest ecosystem. In this  example, Os appeared to be a,predisposing factor leading to
 6    increased drought stress, windthrow, root diseases, and insect infestation (Takemoto et al., 2001).
 7    Increased mortality of susceptible tree species including ponderosa and Jeffrey pine resulting
 8    from these combined stresses has shifted community composition towards white fir and incense
 9    cedar and has altered forest stand structure (Miller et al., 1989). Although the role of Os was
10    extremely difficult to separate from other confounding factors, such as high N deposition, there
11    is evidence that this shift in species  composition has altered trophic structure and food web
12    dynamics (Pronos et al., 1999) and C and N cycling (Arbaugh et al., 2003). Ongoing research in
13    this important ecosystem will reveal the extent to which ecosystem services have been affected.
14          One of the most well-documented studies of population and community response to Os
15    effects are the long-term studies of sunflower (Plantago major) in native plant communities in
16    the United Kingdom (Davison and Reiling, 1995; Lyons et al., 1997; Reiling and Davison, .
17    1992c).  Sensitive populations of sunflower had significant growth decreases in elevated Os
18    (Pearson et al.,  1996; Reiling and Davison, 1992a,b; Whitfield et al., 1997) and reduced fitness
19    as determined by decreased reproductive success (Pearson et al., 1996; Reiling and Davison,
20    1992a).  While spatial comparisons of population responses to Os are complicated by other
21    environmental factors, rapid changes in Os resistance were imposed by ambient levels and
22    variations in Os exposure (Davison  and Reiling, 1995). At the site of sunflower seed collection
23    the highest correlations occurred between Os resistance and ambient Os concentrations (Lyons et
24    al., 1997).  In this case study, it appears that Os- sensitive individuals are being removed by Os
25    stress and the genetic variation represented in the population could be declining. If genetic
26    diversity and variation is lost in ecosystems, there may be increased vulnerability of the system
27    to other biotic and abiotic stressors, and ultimately a change in the services provided by those
28    ecosystems.
29          Reconstructed ecosystems in artificial exposure experiments have also provided new
30    insight into how ozone may be altering ecosystem structure and function (Karnosky et al, 2005).
31    For example, the Aspen Free-Air CO2 Enrichment facility was designed to examine the effects of
32    both elevated CO2and Oson aspen (Populus tremuloides), birch (Betulapapyrifera), and sugar
33    maple in a simple reconstructed plantation characteristic of Great Lakes Aspen-dominated
34    forests (Karnosky et al., 2003b; Karnosky et al., 1999). They found evidence that the effects  on
35    above- and below-ground growth and physiological processes have cascaded through the
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 1    ecosystem, even affecting microbial communities (Larson et al., 2002; Phillips et al., 2002),
 2    This study also confirmed earlier observations of Os-induced changes in trophic interactions
 3    involving keystone tree species, as well as important insect pests and their natural enemies
 4    (Awmack et at., 2003; Holtonetal., 2003; Percy etal., 2002).
 5          Collectively these examples suggest that Os is an important stressor in natural
 6    ecosystems, but it is difficult to quantify the contribution of Os due to the combination of stresses
 7    present in ecosystems.  Continued research, employing new approaches, will be necessary to
 8    fully understand the extent to which 63 is affecting ecosystem services.

 9          7.4.2      Effects on Ecosystem Products and Services
10          Since it has been established that 63 affects photosynthesis and growth of plants, Os is
11    most likely affecting the productivity of crop and forest ecosystems.  Therefore, it is desirable to
12    link effects on growth and productivity to essential ecosystem services. However, it is very
13    difficult to quantify ecosystem-level productivity losses because of the amount of complexity in
14    scaling from the leaf-level or individual plant to the ecosystem level, and because not all
15    organisms in an ecosystem are equally affected by ozone. Below is a discussion of potential
16    effects of Oa on two important ecological services.

17            7.4.2.1    Carbon Sequestration
18          Terrestrial ecosystems are important in the Earth's carbon (C) balance and potentially
19    have a role in offsetting emissions of CCh by humans.  Temperate forests of the northern
20    hemisphere have been estimated to be a net sink of 0.6 to 0.7 Pg of C per year (Goodale et al.'
21    2002). COj enters vegetation through stomates and is used in photosynthesis to produce
22    carbohydrates that form plant tissues. Ozone interferes with photosynthesis, causes some plants
23    to senesce leaves prematurely and in some cases, reduces allocation to stem and root tissue.
24    Thus, 03 decreases the amount of net productivity and C sequestration of the individual plants
25    and entire ecosystems.  One issue in the O3 effects on C sequestration is the interaction of rising
26    Os pollution and rising CO2 concentrations in the coming decades. Models generally predict that
27    in the future C sequestration will increase with increasing CO2, but often there is not an
28    accounting of the decrease in productivity due to the local effects of tropospheric 0$.  In some
29    cases, the stimulatory effect of rising COi concentrations on forest productivity has been
30    estimated to be reduced by more that 20% (Tingey et al 2001; Ollinger et al. 2002; Karnosky et
31    al. 2003). Another issue, separate from the stimulation of productivity by COi, is how Os is
32    currently affecting C sequestration. In a study including all ecosystem types, Felzer et al. (2004),
33    estimated that US Net Primary Production (NPP) was decreased by 2.6-6.8% due to Os pollution
34    in Ihe late 1980's to early 1990's.  Ozone not only reduces C sequestration in existing forests, it
35    can also affect reforestation projects. This effect, in turn, has been found to ultimately inhibit C
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 1    sequestration in forest soils which act as long-term C storage (Loya et al., 2003; Beedlow et al.
 2    2005).

 3            7.4.2.2    Water Resources
 4          At present, there are no publications on the effects of Oa exposure that are carried through
 5    at the ecosystem level to changes in mass water flow, channel morphology, riparian habitat
 6    complexity, or sediment movement.  It is possible that processes occurring at smaller scales are
 7    affecting geomorphological processes in ecosystems; however, difficulties in scaling these
 8    responses spatially and temporally have made this challenging to show experimentally. It is
 9    possible that Oj exposure affects water quality through changes in energy and material flows.
10    One mechanism for how the amount of water quantity may be affected by Os exposure at the
11    landscape level is through loss of tight stomatal control. Moderately high Os exposure may
12    affect the mechanism of stomatal opening (McAinsh et al., 2002), resulting in sluggish stomatal
13    opening and closing (Reich and Lassoie, 1984). During moderately high Os exposure in a
14    drought year, canopy transpiration was greater for yellow poplar than on adjacent days with
15    lower Os exposure, which could alter water use at the landscape level. Oxidant exposure (Oa and
16    NOx) may decrease the ability of exposed plants to close stomata at night (Grulke et al., 2004),
17    thus increasing water loss from the landscape.  Ecosystem models should aid in interpreting Os-
18    exposure effects at the landscape level.

19          7.4.3      Research needs
20          The knowledge base for examining the range of ecological effects of Oa on natural
21    ecosystems has changed little from the last review, however there is currently greater recognition
22    that ecosystem response to ozone needs to be examined in a more holistic way mat include
23    recognition of important ecosystem services and how to quantify and value changes to these
24    services.  Below are listed areas of research that would improve our understanding of the role  of
25    ozone, and how important ecosystem attributes may be protected. For example, there is a need
26    for information on the following ecosystem-level responses:
27         •  Ecosystem Processes. Little is known about the effects of Os on water, C, and nutrient
28            cycling, particularly at the stand and community levels. Effects on below-ground
29            ecosystem processes in response to Os exposure alone and in combination with other
30            stressors are critical to projections  at the watershed and landscape scales. Little is yet
31            known about the effects of Os on structural or functional components of soil food
32            webs, or how these impacts could affect plant species diversity (Andersen, 2003).
33         •  Biodiversity and Genetic Diversity. The study of genetic aspects of Os impacts on
34            natural ecosystems has been largely correlational in nature and it remains to be shown
35            conclusively whether Os affects biodiversity or genetic diversity (Davison and Barnes,
36             1998; Pitelka; 1988; Winner et al., 1991).  Studies of competitive interactions under
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 1            elevated Os levels are needed (Laurence and Andersen, 2003), and reexamination via
 2            new sampling of population studies to bring in a time component to previous studies
 3            showing spatial variability in population responses to 03 are needed.  These studies
 4            could be strengthened by modern molecular methods to quantify impacts on diversity.

 5         •  Natural Ecosystem Interactions with the Atmosphere,  Little is known about feedbacks
 6            between Oa and climate change on VOC production, which in turn., could affect Os
 7            production (Fuentes et al., 2001).  At moderate-to-high Os exposure sites, aberrations
 8            in stomatal behavior could significantly affect individual tree water balance of sensitive
 9            trees, and if the sensitive tree species is dominant, hydrologic balance at the watershed
10   ,         and landscape level could be affected.  This has not been addressed in any model
11            because Os exposure effects, if included in the modeling effort have assumed a linear
12         '   relationship between assimilation and stomatal conductance.

13         *  Below-Ground Interactions. While the negative effects of Os on below-ground growth
14            are well characterized, interactions of roots with the soil or microorganisms are not

15         •  Other interactive Effects. Interaction studies with other components of global change
16            (e.g., warming, increasing atmospheric CC>2, N deposition) or with various biotic
17            stressors are needed to belter predict complex interactions likely in the future
18            (Laurence and Andersen, 2003). Whether 63 will negate the positive effects of an
19            elevated C(>2 environment on plant carbon and water balances is not yet known; nor is
20            it known if these effects will scale up through the ecosystem. How Os might affect the
21            progress of pest epidemics and insect outbreaks as concentrations increase is unclear
22            (Ball et al., 1998).

23         •  Reproduction Effects.  Information concerning the impact of Os on reproductive
24            processes and reproductive development under realistic field or forest conditions are
25            needed, as well as examination of reproductive effects under interacting pollutants
26            (Black et al., 2000).

27         •  Comparative Extrapolation. The vast majority of O3 studies of trees have been
28            conducted with young, immature trees and in trees that have not yet formed a closed
29            canopy. Questions remain as to the comparability of O3 effects on juvenile and mature
30            trees and on trees grown in the open versus those in a closed forest canopy in a
31            competitive environment (Chappelka and Samuelson, 1998; Kolb and Matyssek, 2001;
32            Samuelson and Kelly, 2001).

33         •  Scaling-Up Issues. Scaling the effects of Os from the responses of single or a few
34            plants to effects on communities and ecosystems is a complicated matter that will
35          .  require a combination of manipulative experiments with model ecosystems,
36            community and ecosystem studies along natural Os gradients, and extensive modeling
37            efforts to project landscape-level, regional, national and international impacts of Oa.
38            Linking these various studies via impacts on common research quantification across
39            various scales using measures of such factors as leaf area index or spectral reflective
40            data, which could  eventually be remotely sensed (Kraft et al., 1996; Panek et al., 2003),
41            would provide powerful new tools for ecologists.

42         •  Comparative Risk Assessment Methodologies. Methodologies to determine the
43            important values of services and benefits derived from natural ecosystems such that
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1
2

3
4
5
these could be used in comprehensive risk assessment for 63 effects on natural
ecosystems (Heck et al.} 1998).

Economic Valuation.  There is a critical need for research to support the development
of methods to value ecosystem services affected by Os in order to estimate the potential
economic and non-monetized benefits accruing from Os reductions.
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 1           APPENDIX 4A. MICROENVIRONMENT MODELING PARAMETERS
 2   Air Exchange Rates for Indoor Residential Environments

 3          Distributions of AERs for the indoor microenvironments were developed using data from
 4   several studies. The analysis of these data and the development of the distributions used in the
 5   modeling is described in detail in the draft Exposure Analysis TSD. This analysis showed that
 6   the AER distributions for the residential microenvironments depend on the type of air
 7   conditioning (A/C) and on the outdoor temperature, as well as other variables for which we do
 8   not have sufficient data to estimate. This analysis clearly demonstrates that the AER
 9   distributions vary greatly across cities and A/C types and temperatures, so that the selected AER
10   distributions for the modeled cities should also depend upon the city, A/C type and temperature.
11   For example, the mean AER for residences with A/C ranges from 0.39 for Los Angeles between
12   30 and 40 °C to 1.73 for New York between 20 and 25 °C. The mean AER for residences without
13   A/C ranges from 0.46 for San Francisco between 10 and 20 °C to 2.29 for New York between 20
14   and 25 °C. The need to account for the city as well as the A/C type and temperature is illustrated
15   by the result that for residences with A/C and between 20 and 25  °C, the mean AER ranges from,
16   0,52 for Research Triangle Park to 1.73 for New York. For each  combination of A/C type, city,
17   and temperature with a minimum of 11 AER values, exponential, lognormal, normal, and
18   Weibull distributions were fit to the AER values and compared. Generally, the lognormal
19   distribution was the best-fitting of the four distributions, and so, for consistency, the fitted
20   lognormal distributions are used for all the cases.
21          One limitation of this analysis was that distributions were available only for selected
22   cities, and yet the summary statistics and comparisons demonstrate that the AER distributions
23   depend upon the city as well as the temperature range and A/C type.  Another important
24   limitation of the analysis was that distributions were not able to be fitted to all of the temperature
25   ranges due to inadequate data. A description of how these limitations were addressed can be
26   found in the draft Exposure Analysis TSD.
27          City-specific, AER distributions were used where possible; otherwise data for a similar
28   city were used. We obtained estimates of A/C prevalence from the American Housing Survey
   29(AHS, 2003) for each metropolitan area (Table A-l).  The final AER distributions used
      for the exposure modeling are given in Table A-2.
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Table .A-l. City-specific air conditioning prevalence rates (percentage of
          residences with central or room A/C)  .
City
Atlanta
Boston
Chicago
Cleveland
Detroit
Houston
Los Angeles
New York
Philadelphia
Sacramento
St. Louis
Washington DC
4
5
Survey Area and Year
Atlanta, 2003
Boston, 2003
Chicago, 2003
. Cleveland, 2003
Detroit, 2003
Houston, 2003
Los Angeles, 2003
New York, 2003 .
Philadelphia, 2003
Sacramento, 2003 '
St. Louis, 2003
Washington DC, 2003
'

Percentage
97
75
87
75
81
99
55
82
91
95
96
96


Table A-2.  Lognormal distributions used for
          residential air exchange rates
City
Houston

Air
Conditioner
in residence
(Yes/No)
Yes
No
Yes
Temperature
Range
(Celsius)
520
20-25
25-30
>30
<10
10-20
>20
520
Scale
-0.898
-0.760
-0.862
-0.695
-0.422
-0.469
-0.088
-0.529
Shape
0.748
0.662
0.814
.0.541
0.518
1.070
0.897
0,639
Geometric
Mean
0.407
0.467 '
0.422
0.499
0.656
0.625
0.916
0.589
Geometric
Standard
Deviation
2.113
1.938
2.258
1.717
1.679
2.916
2.451
1.894
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Los'Angeles
Boston, Chicago,
Cleveland, Detroit,
New York City,
Philadelphia'
Atlanta,
Washington D,C.
Sacramento
St. Louis
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
520
20-25
25-30
>30
510
10-20
20-25
>25
510
10-25
>25
510
10-20
>20
510
10-20
20-25
>25
510
10-20
20-25
>25
5 25
>25
510 '
10-20
20-25
>25
510
10-20
20-25
25-30
>30
510
-0.529
0.096
-0.207
-1.323
-0.611
-0.292
0.316
-0.012
-0.341
0.130
0.218
0.016
-0.235
0.474
-0.045
-0.660
-0.646
-0.937
-0.283
-0.359
0.313
0.065 .
-0.687
-0.186
-0.643
-0.408
0.052
-0.190 '
-0.153
-0.642
-0.405
-0.770
-0.466
-0.077
0.639
0.861
0.882
1.026
1.127
0.735
0.825
0.676
0.702
0.985
0.778 -
0.760
0.714
0.751
0.674
0.702
0.783
0.730
, 0.840
0.779
0.829
0.687
0.653
0.856
1.161
0.777
0.537
0.817
0.703
0.739
0.923
0.850
0.729
0.734
0.589
1.100
0.813
0.266
0.543
0.747
1.372
0.988
0.711
1.139
1.244
1.016
0.791
1.606
0.956
0.517
0.524
0.392
0.754
0.698
1.367
1.067
0.503
. . 0.830
0.526
0.665
1.054
- 0.827
0.858
0.526
0.667
0.463
0.627
0.926
1.894
2.365
2.415
2.790
3.087
2.085
2.283
1.967
2.018
2.677
2.177
2.138
2.042
2.119
1.962
2.017
2.189
2.076
2.317
2.180
2.292
1.989
1.921
2.353
3.192
2.174
1.711
2.265
2.020
2.094
2.517
2.339
2.073
2.084
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10-20
>20
-0.310
0.321
0.846
0.822
0.733
1.378 .
2.330
2.276
27
 2   AER Distributions for Other Indoor Environments

 3          To estimate AER distributions for non-residential, indoor environments (e.g., offices and
 4   schools), we obtained and analyzed two AER data sets: "Turk" (Turk et al, 1989); and "Persiiy"
 5   (Persiiy and Gorfain, 2004; Persiiy et al., 2005). The earlier 'Turk" data set (Turk et al., 1989)
 6   includes 40 AER measurements from offices (25 values), schools (7 values), libraries (3 values),
 7   and multi-purpose (5 values), each measured using an SFe tracer over two or four hours in
 8   different seasons of the year.  The more recent "Persiiy" data (Persiiy and Gorfain, 2004; Persiiy
 9   et al., 2005) were derived from the U.S. EPA Building Assessment Survey and Evaluation
10   (BASE) study, which was conducted to assess indoor air quality, including ventilation, in a large
11   number of randomly selected office buildings throughout the U. S. This data base consists of a
12   total of 390 AER measurements in 96 large, mechanically ventilated offices; each office was
13   measured up to four times over two days, Wednesday and Thursday, AM and PM. The office
14   spaces were relatively large, with at least 25 occupants, and preferably 50 to 60 occupants. AERs
15   were measured both by a volumetric method and by a CC>2 ratio method, and included their
16   uncertainty estimates. For these analyses, we used the recommended "Best Estimates" defined by
17   the values with the lower estimated uncertainty; in the vast majority of cases the best estimate
18   was from the volumetric method.
19          Due to the small sample size of the Turk data, the data were analyzed without
20   stratification by building type and/or season. For the Persiiy  data, the AER values for each office
21   space were averaged, rather using the'individual measurements, to account for the strong
22   dependence of the AER measurements for the same office space over a relatively short period.
23   The mean values are similar for the two studies, but the standard deviations are about twice as
24   high for the Persiiy data. The proposed AER distributions were derived from the more recent
25   Persiiy data only.
26      '   We fitted exponential, lognorrnal, normal, and Weibull distributions to the 96 office
     space average AER values, and the best fitting of these was the lognorrnal.  Table A-3
     gives the fitted parameters for this distribution, which is
29   used for AER distributions for the indoor, non-residential microenvironments.
           November 2005
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     Table A-3. Lognormal distributions used for all
                non-residential indoor air exchange rates for all cities
Scale
0.1038
Shape
0.1036
Geometric
Mean
1.1094
Geometric
Standard
Deviation
3.0150
Lower
Bound
0.07
Upper
Bound
13.8
 5   Proximity and Penetration Factors For Outdoors, In-vehicle, and Mass Transit
 6          For the outdoors near-road, public garage/parking lot, and in-vehicle proximity factors,
 7   and for the in-vehicle penetration factors, we use distributions developed from the Cincinnati
 8   Ozone Study (American Petroleum Institute, 1997, Appendix B; Johnson et al., 1995). This field
 9   study was conducted in the greater Cincinnati metropolitan area in August and September, 1994.
10   Vehicle tests were conducted according to an experimental design specifying the vehicle typej
11   road type, vehicle speed, and ventilation mode. Vehicle types were defined by the three study
12   vehicles: a minivan, a full-size car, and a compact car. Road types were interstate highways
13   (interstate), principal urban arterial roads (urban), and local roads (local). Nominal  vehicle
14   speeds (typically met over one minute intervals within 5 mph) were at 35 mph, 45 mph,  or 55
15   mph. Ventilation modes were as follows:
16       •  Vent Open: Air conditioner off. Ventilation fan at medium.  Driver's window half open.
17          Other windows closed.
18       •  Normal A/C: Air conditioner at normal. All windows closed.
19       *  Max A/C: Air conditioner at maximum. All windows closed.
20   Ozone concentrations were measured inside the vehicle, outside the vehicle, and at six fixed-site
21   monitors in the Cincinnati area.
22          The draft Exposure Analysis TSD documents the rationale for the selection of
23   distributions of penetration and proximity factors for outdoors and in-vehicle microenvironments
     used in this modeling analysis, which are listed in Table A4.
     25
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     Table A-4. Distributions of penetration and
                proximity factors for outdoors and in-vehicle microenvironments
Microenvironment
Outdoors near road;
outdoors, public
garage / parking lot

Other outdoors
microenvironments

In-vehicle





Parameter
Penetration
factor
Proximity
factor
Penetration
factor
Proximity
factor
Penetration
factor
Proximity
factor



Road
Type
All
'All
All
All
All

Local
Roads
Urban
Roads
Interstates
Distribution
Constant
Normal
Constant
Constant
Normal

Normal
Normal '

Normal
Mean
1.0
0.755
1.0
•T
1.0
0.300

0.755
0.754

0.364
Standard Lower
• Deviation Bound
-
0.203 0.422


0.232 0

0.203 0.422
0.243 ' 0.355

0.165 0.093
Upper
Bound

1.0


1

1
1

1
 5
 6
 7
 8
 9
10
11
12
Ozone Decay and Deposition Rates
      A distribution for combined Os decay and deposition rates was obtained from the analysis
of measurements from a study by Lee et al. (1999). This study measured decay rates in the
living rooms of 43 residences in Southern California.  Measurements of decay rates in a second
room were made in 24 of these residences. The 67 decay rates range from 0.95 to 8.05 hour .  A
lognormal distribution was fit to the measurements from this study, yielding a geometric mean of
2.5 and a geometric standard deviation of 1.5. This distribution is used for all indoor
microenvironments.
     November 2005
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 1    REFERENCES

 2    AHS, 2003. U.S. Bureau of the Census and U.S. Department of Housing and Urban Development. 2003 American
 3          Housing Survey (AHS): National Survey Data. Available at:
 4          http :/Avww.census. gov/fahes/www/hous inc/ahs/ahs .html. and http://www .huduser.org/tiatasets/ahs.html.

 5    American Petroleum Institute. (1997). Sensitivity testing ofpNEM/O3 exposure to changes in the model algorithms.
 6          Health and Environmental Sciences Department.

 7    Johnson, T., Pakrasi, A., Wisfaeth, A., Meiners, G., Ollison, W. (1995). Ozone exposures within motor vehicles -
 8          results of a field study in Cincinnati, Ohio. Proceedings 88* annual meeting and exposition of the Air &
 9          Waste Management Association, June 18-23,1995.  San Antonio, TX. Preprint paper 95-WA84A.02.

10    Persily, A. and J. Gorfain.(2004). Analysis of ventilation data from the U.S. Environmental Protection Agency
11          Building Assessment Survey and Evaluation (BASE) Study. National Institute of Standards and Technology,
12          NISTIR 7145, December 2004.

13    Persily, A., J. Gorfain, G. Brunner (2005). Ventilation design and performance in U.S. office buildings. ASHRAE
14          Journal. April 2005, 30-3 5.

15    Turk, B. H., D. T. Grimsrud, J. T. Brown, K. L. Geisling-Sobotka, J. Harrison, R. J. Prill (1989). Commercial
16          building ventilation rates and particle concentrations. ASHRAE, No. 3248.
      November 2005
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 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
   APPENDIX 4B. FREQUENCY DISTRIBUTIONS OF DAILY MAXIMUM 8-HOUR
                      AVERAGE OZONE CONCENTRATIONS
      The measured concentrations and the concentrations representing just meeting the current
8-hour standard, for 2004 only, are summarized in the graphs in this Appendix in terms of the
frequencies of daily maximum 8-hour average Os concentrations above various concentration
levels. Since these are summations of "exceedances" for all monitors in an urban area, having
more monitors will lead to higher counts in these figures. These graphs also show the percent
reduction in exceedances of levels from the 2004 base year to when the current 8-hour standard
is just met.
      The lines in these graphs with hollow triangles and squares indicate frequencies for the
2004 base and current standard respectively, and their values can be read off the left axis. The
lines with solid circles give the percent reduction from the base to current standard, and
correspond to the scale of the axis on the right side of the figures.
     November 2005
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1
2
3
4
5
6
                              Figure 4B-1
Atlanta CSA:  Frequencies of doily maximum 8-hour ozone above different levels
               10000
                 1000
                                                                    1005!
                                                                      0*
    0.00    0,02    0.04    0.06    0.08    0.10    0.12    0.14    0.16
                              03 level (ppm)
               Right axis:   •*• Percent reduction from  base
          Left axis:  ***Bosecase         •»• Current standards
                              Figure 4B- 2
Boston CSA:  Frequencies of daily maximum 8—hour ozone above different levels
100001	:»	1 ioox
                 10001
                    H
                    0.00    0.02    0.04   0.06    0.08   0.10    0.12   0.14
                                             03 level (ppm)
                               Right axis;  •*• Percent reduction from base
                          Left axis:  *** Base case          ""Current standards
                                                                0.16
     November 2005
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1
2
3
4
                               Figure 4B-3
 Chicago CSA: Frequencies of doily maximum 8-hour ozone above different levels
 100001	:	7*=*	\  100*
                 1000
                                                                                      05!
     0.00    0.02    0.04 .   0.06   0.08    0.10    0.12    0.14   0.16
                               03 level (ppm)
                Right axis:   **• Percent reduction from base
           Left axis:  *** Base case      " .  ***Current standards
                                Figure 4B-4
Cleveland CSA: Frequencies of doily maximum 8—hour ozone above different levels
               10000
                 1000
                  100
                                                                     100*
                    1
                    0:00    0.02    0.04   0.06    0.08   0.10
                                             03 level (ppm)
                               Right axis:  *** Percent reduction from base
                          Left axis:   •** Base case         """Current standards
     November 2005
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1
2
3
4
5
                               Figure 4B-5
 Detroit CSA: Frequencies of daily maximum 8-hour ozone above different levels
               10000
                 1000
                  100-
                                                                    10Qx
    0.00    0.02   0.04    0.06   0,08    0.10   0.12    0.14   0.16
                              03 level (ppm)
                Right axis:  *** Percent reduction from base
           Left axis:   *~*Basecase         ""Current standards


                               Figure 4B-6
Houston CSA:  Frequencies of daily maximum 8-hour ozone above different levels
               10000
                 1000
                  100
                                                                    100%
                    0.00    0.02    0.04    0.06    O.OB    0.10    0.12    0.14    0.16
                                             03 level (ppm)
                               Right axis:  *** Percent reduction from base
                          Left axis:   *** Base case         "*"Current standards
     November 2005
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2
3
4
                                              Figure 4B-7
              Los Angeles CSA:  Frequencies of doily maximum 8—hour ozone above different levels
               IQOOODi	^  •••••*-	1 1.QO.
                10000
                  1000
                   100
                     0.00    0.02   0.04    0.06   O.OB    0.10    0.12   0.14    0.16
                                              03 level (ppm)
                               Right axis:  *** Percent reduction from base
                          Left axis:   *** Base case          ""Current standards
                               Figure 4B-8
New York CSA:  Frequencies of daily maximum 8—hour ozone above different levels
               100001
                 1000
                  100
                                                                     100*
                    O.'OO   0.02    0.04   0.06    0.08   0.10    0.12   0.14    0.16
                                             03 level (ppm)
                               Right axis:  *** Percent reduction from base
                          Left axis:  •"•"• Base case         ""Current standards
     November 2005
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1
2
3
4
5
6
               Philadelphia
                10000
                 1000
                  100
                           Figure 4B-9
      CSA:  Frequencies of daily maximum 8-hour ozone above different levels
                                                                 100*
                    0.00   0.02    0,04    0.06    O.OB    0.10   0.12    0.14    0.16
                                              03 level (ppm)
                               Right axis:   *** Percent reduction from  base
                          Left axis:  **• Base case         "-"Current standards
                                                                                      07.
              Sacramento
                10000
                 1000
                  100
                          Figure 4B-10
      CSA:  Frequencies of daily maximum 8-hour ozone above different levels
                                                                 100*
0.00    0.02    0.04    0.06   0.08    0.10    0.12    0.14    0.16
                          03 level (ppm)
           Right axis:  •** Percent reduction from base
      Left axis:   *** Base case         •**Current standards
                         Figure 4B-10 1
     November 2005
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1
2
3
4
5
                               Figure 4B-11
 St. Louis CSA:  Frequencies of daily maximum 8-hour ozone above different levels
               10000
                 tooo
                    1
                    0,00    0.02    0,04
                                                  0.12    0.14
            .16
                0.06    0.08   0.10
                   03 level (ppm)
     Right axis:  •** Percent reduction from base
Left oxis:  ***Basecase         """"Current standards
                               Figure 4B-12
Washington CSA: Frequencies of daily maximum B-hour ozone above different
 10000f
                 1000
                  100
                    1
                    0.00    0.02    0.04    0.06    0.08    0,10    0.12    0.14    0.11
                                             03 level (ppm)
                               Right axis:  •*• Percent reduction from base -
                          Left axis:   •*• Base case          ^Current standards
     November 2005
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         APPENDIX 4C. EXPOSURES FOR EXERCISING CHILDREN
      This appendix presents graphs for each modeled city of counts of person-days of
daily maxima 8-hour average exposures above different levels, concomitant with
moderate exertion, for children ages 5 to 18. The lines with hollow triangles and squares
indicate counts for the 2004 base and current standard respectively, and their values can
be read off the left axis. The lines with solid circles give the percent reduction from the
base to current standard counts, and correspond to the axis on the right.
November 2005
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                               Figure 4C-1
        Atlanta CSA:  Children ages 5—18, Person—days with moderate
           exertion above daily maximum 8—hour exposure levels
                                                               100%
                                                                90?.
                                                                80%
                                                                70%
                                                                60*
                                                              ' 50%
                                                                40%
                                                                30%
                                                                20%
                                                                10%
                                                                 07.
                0.06   0.07   0.08   0.09    0.10    0.11    0.12
                              Exposure level (ppm)
                Right axis:  *** Percent reduction from base
           Left axis:  *•*"* Base case         ***Current standard
                              Figure 4C-2 1
        Boston CSA:  Children ages 5-18. Person-days with moderate
           exertion above daily maximum 8—hour exposure levels
                                                               100%
                                                                90%
                                                                80%
                                                                70%
                                                                60%
                                                                50%
                                                                40%
                                                                30%
                                                                20%
                                                                10%
                                                                 0%
                0.06   0.07   0.08   0.09    0.10    0.11    0.12
                              Exposure level (ppm)
                Right axis:  *** Percent reduction from base
           Left axis:  *"•-* Base case         ***Current standard
November 2005
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                               Figure 4C-3
       Chicago CSA:  Children ages 5—18. Person—days with moderate
            exertion above daily maximum 8—hour exposure levels
                                                               100%
                                                                90%
                                                                80%
                                                                70%
                                                                60%
                                                                50*
                                                                407.
                                                                30%
                                                                20%
                                                                10*
                0.06
                  0.11    0'.12
            0.07   0.08   0.09    0.10
                   Exposure level (p%pm)
    Right axis:   *** Percent reduction from base
Left axis:  ***Base case         ""Current standard
                               Figure 4C-4
       Cleveland CSA: Children ages 5—18. Person—days with moderate
            exertion above daily maximum 8—hour exposure levels
                                                               100%
                                                                90%
                                                                80%
                                                                70%
                                                                60%
                                                                50%
                                                                40%
                                                                30%
                                                                20%
                                                                10%
                                                                 0%
                0.06   0.07   0.08    0.09   0.10   0.11   0.12
                              Exposure level (ppm)
                Right axis:  *** Percent reduction from base
           Left axis:   *** Base case        *** Current standard
November 2005
4C-3
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                               Figure 4C-5
        Detroit CSA:  Children ages 5—18. Person—days with moderate
           exertion above daily maximum 8—hour exposure levels
                                                              1007.
                                                               90%
                                                               80%
                                                               70%
                                                               60%
                                                               50%
                                                               40%
                                                               30%
                                                               20%
                                                               10%
                0.06,   0.07   0.08   0.09   0.10-   0.11    0.12
                              Exposure level (ppm)
               Right axis:   *•* Percent reduction from base
           Left axis:  *** Base case        ***Current standard
                               Figure 4C-6
       Houston CSA: Children ages 5—18. Person—days with moderate
           exertion above daily maximum 8—hour exposure levels
                                                              100%
                                                               90%
                                                               80%
                                                               70%
                                                               60%
                                                               50%
10,000,000
 1,000,000
   100.000
   ' 10,000
     1.000
       100
        10
         1
                                                               40%
                                                               2.0%
                                                               10%
                                                                0%
                                                    0.11    0.12
         0.06   0.07   0:08   0.09   0.10
                       Exposure level (ppm)
        Right axis:  **• Percent reduction from base
    Left axis:  **•• Base case        **•Current standard
November 2005
                          4C-4
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        10,000,000
         1,000,000
                         Figure 4C-7
Los Angeles CSA: Children ages 5-.18. Person-days with moderate
      exertion above daily maximum 8—hour exposure levels
                                                         1007.
                                                          907.
                                                          807.
                                                          707.
                                                          60*
                                                          507.
                                                          40%
                                                          307.
                                                          207.
                                                          10%
                       	V	n	n	n	n   Q%
           0.06   0.07   0.08   0.09   0.10   0.11   0.12
                        Exposure  level (ppm)
          Right axis:  •-"Percent reduction from base
     Left axis:   *-*-*Base case         •**Current standard

                         Figure 4C-8
 New York CSA: Children ages 5—18. Person—days with moderate
      exertion above daily maximum 8—hour exposure levels
                                                         1007.
                                                          90%
                                                          807.
                                                          707.
                                                          60%
                                                          507.
                                                          40%
                                                          307.
                                                          207.
                                                          10%
                                                                 07.
                 0.06
                                              0.11   0.12
            0.07    0.08    0.09   0.10
                   Exposure level (ppm)
    Right axis:   *** Percent reduction from base
Left axis:  *** Base case         *** Current standard
November 2005
                            4C-5
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r
                                                  Figure 4C-9
                         Philadelphia CSA: Children ages 5-1S. Person-days with moderate
                              exertion above daily maximum 8—hour exposure levels
                                                                                  100%
                                                                                   90%
                                                                                   80*
                                                                                   70%
                                                                                   60%
                                                                                   50%
                                                                                   403
                                                                                   30%
                                                                                   2 Of.
                                   0.06   0.07   0.08    0.09    0.10   0.11    0.12
                                                 Exposure level (ppm)
                                   Right axis:  •"*•• Percent reduction from base
                              Left axis:   **-* Base case        ""**Current standard
                                                 Figure 4C-10
                        Sacramento CSA: Children ages 5—18. Person—days with moderate
                              exertion above daily maximum 8—hour exposure levels
                                                                                  100%
                                                                                   90%
                                                                                   80%
                                                                                   70%
                                                                                   60%
                                                                                   50%
                                                                                   40%
                                                                                   30%
                                                                                   20%
                                                                                    0%
                                   0.06   0.07
                   0.08   0.09   0.10
                   Exposure level (ppm)
    Right axis:   ~* Percent reduction from base
Left axis:  *"*"*Base case         ***Current standard
           0.12
                   November 2005
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                               Figure 4C-11
       St. Louis CSA:  Children ages 5—18. Person—days with moderate
            exertion above daily maximum 8—hour exposure levels
                                                               100%
                                                                90%
                                                                80%
                                                                70%
                                                                60%
                                                                50%
                                                                40%
                                                                30%
                                                                20%
                                                                10%
                                                                 0%
                0.06   0.07
                  0.11    0.12
                         0.08   0.09   0.10
                         Exposure level (ppm)
          Right axis:  ™~* Percent reduction from base
     Left axis:   *~"Base case        ""^ Current standard
                         Figure 4C-12
Washington CSA: Children ages 5—18. Person—days with moderate
     exertion above daily  maximum 8—hour exposure levels
                                                         100%
                                                          90%
                0.06   0.07   0.08    0.09   0.10   0.11   0.12
                              Exposure level (ppm)
                Right axis:  *** Percent reduction from base
           Left axis:   **~*Base case        ""Current standard
November 2005
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Appendix 4D. Table 4D-1. GEOS-CHEM Grids Used for 12 Urban Locations
City
Atlanta
Boston
Chicago
Cleveland
Detroit
Houston
Los Angeles
New York
Philadelphia
Sacramento
St Louis
Washington, DC
1 J
38 12
43 16
37 16
39 16
39 16
34 10
25 12
42 15
42 15
23 14
36 14
41 14
                     latitude  longitude
                          34
                          42
                          42
                          42
                          42
                          30
                          34
                          40
                          40
                          38
                          38
                          38
   -85
 -72.5
 -87.5
 -82.5
 -82.5
   -95
-117.5
   -75
   -75
-122.5
   -90
 -77.5
November 2005
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1   APPENDICES FOR CHAPTER 5

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Table 5A-1. Monitor-Specific O3 Air Quality Information: Atlanta, GA

AIRS Monitor ID

1305700011
1306700031
1307700021
1308500012
1308900021
1308930011
1309700041
1311300011
1312100551
1313500021
1315100021
1322300031
1324700011
Average:
Fourth

2002
0.089
0.100
0.099
0.088
0.095
0.090
0.098
0.088
0.100
0.089
0.099
0.099
0.099
0.095
Daily Maximum 8-Hour
Average (ppm)
2003 2004

0.084 0.073
0.077 0.083
0.077 0.068
0.080 0.084
0.091 0.088
0.085 0.080
0.077 0.084
0.091 0.089
0.088 0.092
0.082 0.085
0.083 0.073
0.078 0.087
0.083 0.082
Design Value*:
Average of the 3
Year-Specific
Values (ppm)

0.085
0.086
0.077
0.086
0.089
0.087
0.083
0.093
0.089
0.088
0.085
0.088

0.093
"The design value is the maximum of the monitor-specific averages of the annual
 fourth daily maximum 8-hour average over the 3 year period.
Table 5A-2. Monitor-Specific O3 Air Quality Information: Boston, MA

AIRS Monitor ID

2500900051
2500920061
2500940041
2501711021
2502130031
2502500411
2502500421
2502700151
Average:
Fourth

2002
0.088
0.100
0.094
0.096
0.107
0.102
0.074
0.091
0.094
Daily Maximum 8-Hour
Average (ppm)
2003 2004

0.079 0.081
0.080 0.077
0.073 0.070
0.088 0.078
0.078 0.079
0.074 0.064
0.080 0.074
0.079 0.075
Design Value*:
Average of the 3
Year -Specific
Values (ppm)

0.086
0.083
0.079
0.091
0.086
0.07
0.081

0.091
*The design value is the
 fourth daily maximum 8
maximum of the monitor-specific averages of the annual
i-hour average over the 3 year period.
November 2005
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Table 5A-3.  Monitor-Specific 03 Air Quality Information: Chicago, IL

AIRS Monitor ID

1703100011
1703100321
1703100422
1703100501
1703100641
1703100721
1703100761
1703110032
1703116011
1703140021
1703140071
1703142011
1703142012
1703170021
1703180031
1704360011
1708900051
1709710021
1709710071
1709730011
1711100011
1719710081
1719710111
1808900221
1808900241
1808900301
1808920081
1809100051
1809100101
1812700202
1812700241
1812700261
5505900021
5505900191
5505900221
Average:
Fourth

2002
0.094
0.096
0.103
0.084
0.085
0.085

0.092
0.081
0.084
0.093
0.087
0.067
0.091
0.074
0.084
0.082
0.090
0.100
0.087
0.090
0.086
0.087
0.094
0.086

. 0.101 .
0.107
0.100
0.097
0.101
0.100
0.110
0.116
0.096
0.092
Daily Maximum 8-Hour
Average (ppm)
2003
0.077
0.080

0.069
0.067
0.075

0.071
0.075
0.070
0.073
0.080

0.082

0.066
0.076
0.074
0.078

0.079
0.077
0.073
0.076
0.081

0.081
0.082
0.084
0.079
0.077
0.082
0.085
0.088
0.088
0.077
2004
\ 0.065
0.067


0.054
0.060
0.068
0.067
0.067
0.059
0.064
0.067
0.051
0.071

0.065
0.069
0.068
0.071

0.068
0.063
0.068
0.064

0.064
0.067
0.070


0.069
0.072

0.078

0.066
Design Value*:
Average of the 3
Year-Specific
Values (ppm)
0.078
0.081


0.068
0.073

0.076
0.074
0.071
0.076
0.078

0.081

0.071
0.075
0.077
0.083

0.079
0.075
0.076
0.078


0.083
0.086


0.082
0.084

0.094


0.094
 *The design value is the maximum of the monitor-specific averages of the annual
  fourth daily maximum 8-hour average over the 3 year period.
November 2005
5A-2
Draft - Do Not Quote or Cite

-------
Table 5A-4.  Monitor-Specific Os Air Quality Information: Cleveland, OH

AIRS Monitor ID

3900710011
3903500341
3903500641
3903550021
3905500041
3908500031
3908530021
3909300171
3910300031
3913310011
3915300201
Average:
Fourth

2002
0.103
0.090
0.090
0.098
0.115
- 0.104
0.088
0.099
0.091
0.097
0.103
0.098
Daily Maximum 8-Hour
Average (ppm)
2003 2004
0.099 0.081
0.076 0.057
0.079 0.063
0.089 0.077
0.097 0.075
0.092 0.079
0.080 0.076
0.085 0.074
0.086 0.077
0.091 0.081
0.089 0.077
0.088 0.074
Design Value*:
Average of the 3
Year-Specific
Values (ppm)
0.094
0.074
0.077
0.088
0.095
0.091
0.081
0.086
0.084
. 0.089
0.089

0.095
The design value is the
  fourth daily maximum 8
maximum of the monitor-specific averages of the annual
i-hour average over the 3 year period.
Table 5A-5.  Monitor-Specific O3 Air Quality Information: Detroit, Ml

AIRS Monitor ID

2604900211
2604920011
2609900091
2609910031
2612500012
2614700051
2616100081
2616300012
2616300161
2616300192
Average:
Fourth

2002
0.088
0.089
0.095
0.092
0.093
0.100
0.091
0.088
0.092
0.083
0.091
Daily Maximum 8-Hour
Average (ppm)
2003 2004
0.087 0.075
0.091 0.077
0.102 0.081
0.101 0.071
0.090 0.075
0.086 0.074
0.091 • 0.071
0.085 0.065
' 0.084 0.066
0.098 0.066
0.092 0.072
Design Value*:
Average of the 3
Year-Specific
Values (ppm)
0.083
0.085
0.092
0.088
0.086
0.086
0.084
' 0.079
0.08
" 0.082

0.092
*The design value is the
 fourth daily maximum 8
maximum of the monitor-specific averages of the annual
-hour average over the 3 year period.
November 2005
                         5A-3
Draft - Do Not Quote or Cite

-------
Table 5A-6.  Monitor-Specific O3 Air Quality Information: Houston, TX

AIRS Monitor ID

4803910032
4803910041
4803910161
4816700141
4816710022
4820100242
4820100263
4820100292
4820100461
4820100472
4820100512
4820100551
4820100621
4820100661
4820100701
4820100751
4820110151
4820110342
4820110353
4820110391
4820110411
4820110501
4833900781
. Average:
Fourth

2002
0,095
0.092

0.093
0.083
0.096
0.088
0.098
0.078
0.072
0.101
0.094
0.095
0.084
0.088
0.078

0.093
0.092
0.095
0.090
0.094
0.082
0.090
Daily Maximum
Average (ppm)
2003

0.097

0.092
0.082
0.095
0.098
0.096
0.093
0.082
0.103
0.107
0.094
0.081
0.100
0.096
0.108
0.102
0.105
0.113

0.092
0.094
0.097
8-Hour

2004

0.103
0.081
0.088

0.096
0.085
0.090
0.084
0.083
0.095
0.104
0.097
0.097
0.078
0.093
0.093
0.091
0.092
0.097

0.097
0.080
0.091
Design Value*:
Average of the 3
Year -Specific
Values (ppm)

0.097

0.091

0.095
0:09
0.094
0.085
0.079
0.099
0.101
0.095
0.087
0.088
0.089

0.095
0.096
0.101

0.094
0.085

0.101
 The design value is the
  fourth daily maximum 8
maximum of the monitor-specific averages of the annual
.-hour average over the 3 year period.
November 2005
                         5A-4
Draft - Do Not Quote or Cite

-------
Table 5A-7.  Monitor-Specific 03 Air Quality Information: Los Angeles, CA

AIRS Monitor ID

0603700021
0603700161
0603701131
0603710021
0603711031
0603712011
0603713011
0603716011
0603717011
0603720051
0603740021
0603750011
0603750051
0603760121
0603790331
0605900071
0605910031
0605920221
060595001 1
0606500121
0606520021
0606550011
0606560011
060658001 1
0606590011
0606590031
0607100011
0607100051
0607100121
0607100171
0607103061
'0607110042
0607112341
0607120021
0607140011
0607140031
0607190021
0607190041
0611100051
0611100071
0611100091
0611110041
0611120021
0611120031
0611130011
Average:
Fourth

2002
0.097
0.111
0.073
0.091
0.077
0.111
0.049
0.074
0.099
0.095
0.059
0.064

0.131
0.102
0.069
0.066
0.081
0.071
0.113
0.097
0.109
0.107
0.109
0.104

0.092
0.131
0.115
0.087
0.106
0.105
0.089
0.114
0.113
0.117
0.101
0.105
0.076
0.080
0.087
0.097
0.092
0.064
0.064
0.093
Dally Maximum
Averaqe (ppfn)
2003
0.104
0.123
0.083
0.096
0.082
0.119
0.057
0.082
0.109
0.101 '
0.063
0.070

0.137
0.103
0.080
0.079
0.095
0.080
0.127
0.100
0.105
0.116
0.120
0.112

0.088
0.130
0.103
0.084 .
0.104
0.114
0.087
0.132
0.110
0.137
0.111
0.123

0.087
0.093
0.093
0.093
0.074
0.069
0.099
8-Hour

2004
0.092
0.095
0.076
0.089
0.078
0.101
0.065
0.079
0.095
0.093
0.070

0.085
0.107 .
0.095
0.088
0.076.
0.085
0.075
0.112
0.094
0.099
0.095
0.111
0.100
0.060
0.082
0.122
0.097
0.087
0.085
0.102
0.082
0.111
0.099
0.119
0.102
0.112

0.086
0.086
0.092
0.092
0.069
0.065
0.091
Design Value*:
Average of the 3
Year-Specific
Values (ppm)
0.097
0.109
0.077
0.092
0.079
0.11
0.057
0.078
0.101
0.096
0.064


0.125
0.1
0.079
0.073
0.087
0.075
0.117
0.097
0.104
0.106
0.113
0.105

0.087
0.127
0.105
0.086
0.098
0.107
0.086
0.119
0.107
0.124
0.104
0.113

0.084
0.088
0.094
0.092
0.069
0.066

0.127
*The design value is the maximum of the monitor-specific averages of the annual
 fourth daily maximum 8-hour average over the 3 year period.
November 2005
5A-5
Draft - Do Not Quote or Cite

-------
Table 5A-8.  Monitor-Specific O3 Air Quality Information: New York, NY

AIRS Monitor ID

3600500831
3600501101
3602700071
3607150011
3607900051
3608100981
3608101241
3608500671
3610300021
3610300041
3610300092
3611110051
3611920041
Average:
Fourth

2002 .
0.096
0.089
0.111
0.082
0.102
0.082
0.089
0.099
0.108
0.090
0.103
0.084
0.102
0.095
Daily Maximum 8-Hour
Average (ppm)
2003 2004
0.079 0.074
0.082 0.069
0.081 0.076
0.087 0.078
0.082 0.082
0.072 0.064
0.086 0.075
0.086 0.083
0.094 0.081
0.082
0.102 0.079
0.082 0.076
0.091 0.078
0.085 0.076
Design Value*:
Average of the 3
Year-Specific
Values (ppm)
0.083
0.08
0.089
0.082
0.088
0.072
0.083
0.089
0.094

0.094
0.08 ' '
0.09

0.094
*The design value is the maximum of the monitor-specific averages of the annual
  fourth daily maximum 8-hour average over the 3 year period.
Table 5A-9.  Monitor-Specific O3 Air Quality Information: Philadelphia, PA

AIRS Monitor ID

4201700121
4202900501
4202901001
4204500021
4209100131
4210100041
4210100141
4210100241
4210101361
Average:
Fourth

2002
0.111
0.104
0.112
0.106
0.101
0.082
0.098
0.110
0.094
0.102
Daily Maximum 8-Hour
Average (ppm)
2003 2004
0.087 0.082
0.085
0.085 0.085
0.080 0.081
0.085 0.083
0.069 0.054
0.083 0.077
0.082 0.091
0.070 0.073
0.081 . 0.078
Design Value*:
Average of the 3
Year -Specific
Values (ppm)
0.093

0.094
0.089
0.089
0.068
0.086
0.094
0.079

0.094
 *The design value is the maximum of the monitor-specific averages of the annual
  fourth daily maximum 8-hour average over the 3 year period.
November 2005
5A-6
Draft - Do Not Quote or Cite

-------
Table 5A-10.  Monitor-Specific O3 Air Quality Information: Sacramento, CA

AIRS Monitor ID

0601700101
0601700111
0601700121
0601700201
0605700051
0605700071
0605710011
0606100021
0606100041
0606100061
0606100071
0606130011
0606700021
0606700061
0606700101
0606700111
0606700121
0606700131
0606750031
0611300041
0611310031
Average:
Fourth

2002
0.098
0.067
0.077
0.111
0.099
0.093
0.065
0.101
0.101
0.095-

0.097 -
0.095
0.105
0.083
0.069
0.104
0.079
0.097
0.076
0.088
0.090
Daily Maximum
Average (ppm)
2003
0.096
0.065
0.075
0.106.
0.098
0.090

0.094
0.089
0.085
0.068
*
0.086
0.097
0.076
0.087
0.098
0.075
0.097
0.077
0.082
0.086 '
8-Hour

2004
0.089

0.073
0.089
0.093
0.085

0.092
0.087
0.082


0.076
0.083
0.067
0.077
0.087
0.067
0.089
0.071
0.069
0.081
Design Value*:
Average of the 3
Year -Specific
Values (ppm)
0.094

0.075
0.102
0.096
0.089

0.095
0.092
0.087


0.085
0.095
0.075
0.077
0.096
0.073
0.094
0.074
0.079

0.102
*The design value is the maximum of the monitor-specific averages of the annual
 fourth daily maximum 8-hour average over the 3 year period.
November 2005
5A-7
Draft - Do Not Quote or Cite

-------
Table 5A-11. Monitor-Specific O3 Air Quality Information: St. Louis, MO

AIRS Monitor ID

1708310011
1711700021
1711900081
1711910091
1711920072
1711930071
1716300102
2909900121
2918310021
2918310041
2918900041 '
2918900061
2918930011
2918950011
2918970031
2951000071
2951000721
2951000861
Average:
Fourth

2002
0.100
0.085.
0.094
0.090
0.090
0.084
0.093
0.093
0.099
0.098
0.098
0.094
0.094
0.095
0.093
0.090 '
0.081
0.098
0.093
Daily Maximum
Average (ppm)
2003
0.083
0.077
0.089
0.088
0.082
0.083
0.079
0.082
0.091
0.090
0.088
0.086
0.082
0.088
0.088
0.084
0.071
0.090
0.085
8-Hour

2004
0.073
0.068
0.074
0.078
0.068
0.073
0.073
0.070
0.077
0.076
0.070
0.067
0.067
0.068
0.069

0.058
0.072
0.071
Design Value*:
Average of the 3
Year -Specific
Values (ppm)
0.085
0.076
0.085
0.085
0.08
0.08
0.081
0.081
0.089
0.088
0.085
0.082
0.081
0.083
0.083

0.07
0.086

0.089
The design value is the maximum of the monitor-specific averages of the annual
 fourth daily maximum 8-hour average over the 3 year period.
Table 5A-12. Monitor-Specific O3 Air Quality Information: Washington, D.C.
AIRS Monitor ID
1100100251
1100100411
1100100431
Average:
Fourth Daily Maximum 8-Hour
Average (ppm)
2002 2003 2004
0.097 0.079 0.080
0.102 0.082 0.070
0.106 0.081 0.081
0.102 0.081 0.077
Design Value*:
Average of the 3
Year-Specific
Values (ppm)
0.085
0.084
0.089

0.089
*The design value is the maximum of the monitor-specific averages of the annual
 fourth daily maximum 8-hour average over the 3 year period.
November 2005
5A-8
Draft - Do Not Quote or Cite

-------
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                       INL/EXT-05-Q00767
Atmospheric Mercury
Concentrations near
Salmon Falls Creek
Reservoir - Phase 1

Michael L. Abbott
October 2005
The INL is a U.S. Department of Energy National Laboratory
operated by Battelle Energy Alliance

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