DRAFT DO NOF QUOTE OR CITE THE MAGNITUDE AND MATURE PROBLEM STATES OF THE AIR TOXICS IN THE UNITED U.S. Environmental Protection Agency Office cf Air and Radiation Office of Policy, Planning and Evaluation September 1984 Elaine Haemi segger Alan Jones Bern Steigerwald Vivian Th oms on This document is a preliminary draft. It has not been formally released by the U.S. Environmental Protection Agency and snould not at this stage be construed to represent pee~-reviewed Ager.cy policy. It is currently undergoing external review for tecnni cal meri t. ------- September 14, 1984 MEMORANDUM SUBJECT: Goals and Context of the Attached Draft Report FROM: Elaine Haemisegger Alan Jones Bern Steigerwald Vivian Thomson TO: Readers of the Report Attached is a draft of an EPA staff report entitled, "The Magnitude and Nature of the Air Toxics Problem in the United States." The attached copy has been reviewed internally, but is currently undergoing external peer review, and thus represents work in progress. We feel that you should fully understand the context and goals of the study and that certain caveats be made explicit to ensure that the study and its conclusions are interpreted correctly. The analysis was undertaken to orient EPA to the problem of air toxics, to stimulate policy discussion, and to guide further studies. Despite the fact that quantitative estimates of risk are presented in this report, the study will not be used to support specific regulatory initiatives. Rather, its goal was to obtain quickly some estimate of the magnitude and nature of the air toxics problem nationally, and as such should be regarded as a "scoping" study only. Consideration of the limited scope of the study, as well as the caveats and assumptions that are discussed in the text of the report, is an important responsibility of those reading and using this report. Some of the important caveats to keep in mind are: - Every attempt was made to use the best available data. However, existing data on air toxics potencies, emissions, and ambient levels are extremely limited, in terms of adequacy and quality. - Most of the potency estimates used in the study are plausible upper-bound estimates: that is, the actual unit risks are not likely to be higher than those used in the study, but could be considerably lower. In many cases the potency estimates are preliminary. ------- - The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substantial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for this report, a conservative scenario (i.e., that all compounds examined are human carcinogens) has been assumed. - Risk estimates for many air pollutants could not be calculated due to data limitations. This also held true for many source types examined in the study. - Many assumptions and extrapolations are necessary to transform ambient or modeled levels of air pollutants into exposure estimates. Whether such assumptions introduce a high or low bias into the results is difficult to assess. However, it is clear that the use of such assumptions injects a considerable degree of uncertainty into the analyses. In summary, because of data limitations, the risk estimates presented in this report should be regarded as only rough approximations of total incidence and individual risks. Estimates presented for individual compounds are highly uncertain and should be used with extreme caution. As more data become available, the risk estimates will undoubtedly change. As such, the portrait of the air toxics problem depicted in this study should be regarded as a snapshot, the form and substance of which will certainly change as new data become available. A final point concerns the actions EPA is currently taking on some of the sources and pollutants discussed in this report. Some of those actions are as follows: - An Air Toxics Group has been established to: review the results of the study, assess source controllability, disseminate the results to a wide range of interest groups for discussion and input, and develop strategy options. - The Administrator has committed to reviewing 20 to 25 air pollutants over the next two years for potential listing and regulation as hazardous air pollutants. - Standard-setting activities under Section 112 of the Clean Air Act are underway for asbestos, arsenic, benzene, coke oven emissions, and radionuclides. - Grant and technical support to State and local agencies for air toxics activities has been increased. ------- - Task Forces on dioxin, wood smoke, and gasoline marketing have been established. - Research on air toxics monitoring, health effects (e.g., the effects of various nickel and chromium species), and emissions has been increased. Thus, while this report stops short of recommending options for dealing with the sources and pollutants discussed, it represents a first step in the development of a comprehensive air toxics strategy. Attachment ------- ACKNOWLEDGMENTS Many individuals and organizations within EPA participated in this study. The report is based primarily on a series of detailed analyses and reviews done specifically for the study, often in cooperation with private companies under contract to EPA. These are listed below. We thank the authors for their efforts and for contributing so much to this analysis. Joe Bufalini, Bruce Gay, Basil Dimitriades. "Production of Hazardous Pollutants through Atmospheric Transformations." June 1984. Elaine Haemisegger. "Hazardous Air Pollutants: An Exposure and Risk Assessment for 35 Counties." September 1984. (Contractor: Versar; American Management Systems, Inc.) Jim Hardin. "Issue Paper — National Air Toxics Problem: Radionuclides," August 1984 Bill Hunt, Bob Faoro, Tom Curran, Jena Muntz. "Estimated Cancer Incidence Rates for Selected Toxic Air Pollutants Using Ambient Air Pollution Data". July 1984. (Contractor: PEDCo). Tom Lahre. "Characterization of Available Nationwide Air Toxics Emissions Data." June 1984. (Contractor: Radian Corp.) Nancy Pate. "Review of the Clement Associates Report on Evidence for Cancer Associated with Air Pollution." June 1984. Bob Schell. "Estimation of the Public Health Risks Associated with Exposure to Ambient Concentration of 87 Substances." July 1984. (Contractor: Radian Corp.) Bob Schell. "Definition of the Air Toxics Problem at the State/Local Level." June 1984. (Contractor: Radian Corp.) Vivian Thomson. "Indoor Air Pollution: Ramifications for Assessing the Magnitude and Nature of the Air Toxics Problem in the United States." July 1984. ------- ACKNOWLEDGMENTS (Continued) Donn Viviani, Doreen Sterling, Robert Kayser. "Acceptable Risk Levels and Federal Regulations: A Comparison of National Emission Standards for Hazardous Air Pollutants (NESHAP) with Other Federal Standards Based on Quantitative Risk Asessment (QRA)." May 1984. Others wi»thin EPA provided assistance during the study. We especially wish to recognize the following: Carol Cox Alan Ehrlich Greg Glahn Sue Perli n ------- TABLE OF CONTENTS Page Executive Summary i I. Introduction 1 II. Risk Assessment Methods 6 A. Estimates of Potency or Unit Risk 6 1. Why Cancer? 6 2. Why Not Assess Other Health Effects? 6 3. Estimating Potency 8 B. Estimates of Exposure 10 1. Monitori ng Data 11 2. Emission Estimates and Dispersion 13 Modeli ng III. Magnitude of the Ambient Air Toxics Problem 16 A. Introduction 16 B. Summaries of Individual Analyses 18 1. Survey of State and Local Agencies, 18 Canada, and Europe 2. Evaluation of Cancer Associated with 21 Air Pollution Using Epidemiological Studi es 3. NESHAPS Study 27 4. 35 County Study 32 5. Ambient Air Quality Study 39 6. Other Pollutants, Sources and Pathways 46 C. Summary of the Magnitude of the Air Toxics 67 Problem D. Perspective and Context: Other Cancer Risks 71 ------- TABLE OF CONTENTS conti nued Page IV. Nature of the Air Toxics Problem 75 A. Pollutants 75 B. Sou rces 76 C. Geographic Variability 79 D. Indirect Control of Air Toxics 83 V. Adequacy of Data Bases 85 VI. Conclusions 90 Attachment A - Pollutants Examined, Upper-Bound Risk Values, Preliminary Approximations of Incidence and Maximum Lifetime Risk ------- LIST OF TABLES Number Page 1 NESHAPS Study: Preliminary Approximation 29 of Annual Incidence and Maximum Lifetime Risk 2 35 County Study: Preliminary Approximation 34 of Annual Incidence 3 Ambient Air Quality Study: Preliminary 42 Approximation of Annual Incidence 4 Ambient Air Quality Study: Preliminary 44 Approximation of Individual Lifetime Risks 5 Ambient Air Quality Study: Preliminary 45 Approximation of Additive Lifetime Risks 6 Estimates of Incidence and Individual Risk 49 Due to Radionuclides Emitted to Air Preliminary Estimates of Incidence and 61 Individual Risks Associated with Air Releases from One Treatment, Storage and Disposal Faci1ity Summary Table: Preliminary Approximation of 69 Annual Incidence Estimates per Million Popula- tion from the NESHAPS Study, the Ambient Air Quality Study and the 35 County Study Perspective and Context: Statistics on Cancer 72 Risks 10 Sources of Selected Compounds Examined in 77 This Study 11 Percent of Incidence Associated With Point and 80 Area Sources Based on 35-County Study 12 Comparison of Measured Air Quality for Selected 81 Cities and Pollutants; ngm/m^ 13 Comparison of Sources of Risk in Several Counties 82 Selected from 35-County Study ------- DRAFT Executive Summary DO NOT QUOTE OR CITE This report summarizes the results of a project which was designed to define the dimensions of the ambient air toxics problem in the United States. The analyses that make up this study examined four basic questions concerning the magnitude and nature of the air toxics problem: (1) What is the approximate magnitude of the air toxics problem, as represented by numerical estimates of cancer incidence associated with air pollution? (2) What is the nature of the air toxics problem in terms of major, pollutants and major sources, and what is their relative importance? (3) Does the air toxics problem vary geographically, and if so, in what ways? (4) Are current air toxics data bases adequate, and what are the significant data gaps? We limited the study to cancers that may be associated with direct inhalation, since other health effects and pathways could not be quantified. Cancer unit risk values were obtained from EPA's Carcinogen Assessment Group (CA6) and Clement Associates. Four major analyses formed the quantitative core of the study. The Ambient Air Quality Study used air toxics ambient data for five metals, 11 organic compounds, and benzo(a)pyrene (B(a)P) to estimate excess cancer incidence and individual lifetime risks. Ambient data were available for approximately 170 sites for the metals and for about 50 sites for BaP, whereas fewer data were available for volatile organic compounds. ------- -11~ DO NOT QUOTE OR CITE A second analysis reviewed epidemiological studies that evaluated the association between air pollution and lung cancer using health statistics. In this analysis, ambient and occupational B(a)P data were used as an indicator for pollutants associated with incomplete combustion (PIC). A dose-response coefficient relating lung cancer and B(a)P concentrations was generated from these studies. Cancer incidence associated with exposure to PIC was estimated by applying this dose-response coefficient to current ambient B(a)P concentrations and BaP emission estimates. The other two core analyses (the "NESHAPS Study" and the "35 County Study") used exposure models to estimate incidence and maximum individual risks. Exposure modeling combines emissions estimates, meteorological dispersion models, population distribution data, and i cancer potency (unit risk values) to estimate excess annual cancer incidence and maximum lifetime individual risks. The NESHAPS Study provides national estimates for about 40 compounds. The 35-County Study was limited to 22 compounds and 35 counties, but was designed to allow city-to-city comparisons and more detailed assessment of source contributions. Other attempts were made to supplement the information derived from the four quantitative studies. All 50 state air pollution agencies and 33 local agencies were contacted to determine whether they had any quantitative risk information on air toxics. Canada and the Commission of European Communities were also contacted. This poll revealed that virtually no other studies are available that quantify excess cancer incidence from air toxics. ------- -in. DRAFT DO NOT QUOTE OR CHI Four additional reports were prepared to assist in interpreting the results of the study. A comprehensive review summarized emission data for over 90 compounds by source type, geographic distribution, growth trends, and data quality. Other papers were prepared on atmospheric transformation of air pollutants; indoor/outdoor relation- ships for air toxics; and the risk estimates used by other program offices within EPA in regulating toxics. Quantitative risk assessments available from other EPA activities for asbestos, radionuclides, and gasoline marketing were incorporated into the report. Also, a short section is provided to allow the results of this study to be put into perspective with the estimated 440,000 annual cancer deaths from all causes in the U.S. and other available estimates of risk associated with diet, smoking, and all environmental pollution. Finally, the study examined several source categories with insufficient data for quantitative risk estimates at this time, such as hazardous and municipal waste disposal and Superfund sites, and summarized all available information on air releases. The goal of this study was to examine the magnitude and nature of the air toxics problem using existing data and standard EPA quantitative risk assessment techniques. Therefore, no attempt was made to examine the various controversies surrounding risk assessment techniques. Methods commonly used within EPA for risk assessment were used for this study. For example, we relied on upper-bound potency estimates generated by EPA's Carcinogen Assessment Group (CA6) and by Clement Associates; exposure modeling techniques used incorporate such traditional approaches as assuming 70 years of continuous exposure ------- DRAFT -iv- 00 NOT QUOTE OR CfTE to a given pollutant concentration. The study's objective was not to evaluate existing risk assessment tools, but rather to apply those tools in as comprehensive a fashion as possible. However, where appropriate, we have attempted to point out the possible effects of considering non-traditional approaches (e.g., considering the effect of indoor exposures). We readily acknowledge that risk analysis for carcinogens is uncertain, that all of the analyses were limited by data gaps, and that wide-ranging assumptions were necessary. As more data become available, these risk estimates will undoubtedly change. As such, the portrait of the air toxics problem depicted in this study should be regarded as a snapshot, the form and substance of which will certainly change as new data become available. In order to be most useful the studies have been presented in a very quantitative fashion. Careful interpretation is needed and we caution against misuse of the estimates contained in this report. The analysis was undertaken in order to orient EPA to the problem of air toxics, to stimulate policy discussion, and to guide further study. It is not intended to lead directly to decisions on whether a specific compound is a carcinogen or whether source control is needed. It is likely that further studies will show that some of the pollutants included in the current study are not carcinogens; also that many other compounds, sources and effects not now able to be evaluated for lack of information will be determined to be a problem. Consideration of caveats, disclaimers, and assumptions is an important responsibility of those using this report. ------- DRAFT DO NOT QUOTE OR CITE -v- Given the scope, omissions, methods, and assumptions discussed in this report, the Study Team believes that the following conclusions can be drawn from this study: (1) The four analyses that attempted to quantify risks du.e to 15 to 45 toxic air pollutants resulted in estimates of annual cancer incidence that ranged from 6 to 9 cases per million people annually* Those same analyses resulted in estimates of total national cancer incidence due to 15 to 45 toxic air pollutants that ranged from 1,600 to 2,000 per year. (2) Maximum lifetime individual risks of 10-4 ^ 1n iQ or greater in the vicinity of point sources were estimated for 25 pollutants. Maximum lifetime individual risks of 10~3 or greater were estimated for 12 pollutants. (3) Additive lifetime individual risks in urban areas due to simultaneous exposure to 10 to 15 pollutants ranged from 10~3 to 10-4. These risks, which were calculated from monitoring data, did not appear to be related to specific point sources, but rather represented a portion of the total risks associated with the complex mixtures typical of urban ambient air. (4) While there is considerable uncertainty associated with the estimates for some substances, the study as a whole indicated that the following pollutants may be important contributors to aggregate incidence from air toxics: metals, especially chromium, arsenic, and nickel; asbestos; products of incomplete combustion; formaldehyde; benzene; ethylene oxide; gasoline vapors; and chlorinated organic compounds, especially chloroform, carbon tetrachl ori de, perch! oroethyl ene, and t ri chl oroethyl ene. (5) Both point and area sources appear to contribute signifi- cantly to the air toxics problem. Large point sources are associated with many high individual risks; area sources appear to be responsible for the majority of aggregate incidence. (6) A wide variety of source types contributes to individual risk and aggregate incidence from air toxics. These include: mobile sources; combustion of wood, coal and oil; solvent usage; metallurgical industries; chemical production and manufacturing; gasoline marketing; and waste oil disposal. ------- -VI - DO NOT QUOTE OR CITE (7) Some low-production organic chemicals appear to contribute little to aggregate risk. For example, 21 organic chemicals were estimated to account for a total of less than 1.0 excess cancer cases per year nationwide. However, some organic chemical plants involved with these compounds appear to cause high individual risks for those living nearby. For example, the maximum lifetime individual risk for 4,4-methylene dianiline was estimated at 1.5xlO~3. (8) While the study indicated that non-traditional sources such as Publicly Owned Treatment Works (POTW's) and Treatment, Storage and Disposal Facilities (TSDF's) may not be dominant contributors to nationwide air toxics incidence, it appears that such sources may pose risks in some locations. For example, a municipal sewage treatment plant in a major metropolitan area was estimated to account for 18 percent of the area's total aggregate incidence, and individual lifetime risks for a single compound at one TSDF were estimated as high as 10-5. (9) Criteria pollutant control programs appear to have done more to reduce air toxics risks than have programs for specific toxic compounds. This seems reasonable considering the sources of air toxics, the multi-pollutant nature of the problem, and the relative intensity of these programs. (10) For those cities with sufficient data for analysis, large city-to-city and neighborhood-to-neighborhood variation in pollutant levels and sources was found. However, our current data base is inadequate to accu- rately characterize most local air toxics problems. (11) Even after many regulations under Section 112 of the Clean Air Act are in place, it appears that arsenic and benzene may still be significant contributors to aggregate risk. This seems to demonstrate that to be fully effective the base for air toxics programs needs to be broadened to include emissions from small area sources, such as combustion, road vehicles, and solvent usage. Factors which may have caused the risk estimates discussed above to understate total air toxics risks are as follows: (1) Risk estimates for many substances which have been found in the ambient air could not be calculated, due to data limitations. Urban ambient air is characterized by the ------- -vii- DRAFT DO NOT QUOTE OR CITE presence of dozens, perhaps hundreds, of separate substances. These include many organic compounds; fine particulate matter, including metals and polycylic aromatic hydrocarbons; and criteria pollutants. (2) Indoor concentrations of certain pollutants (e.g., radon, tobacco smoke, formaldehyde, and other volatile organic compounds) are commonly several times higher than outdoor concentrations. While risk assessment could not be performed for all these pollutants, the estimated cancer incidence associated with passive smoking (3,000 to 14,000 annually) and radon (1,000 to 20,000 annually) clearly show that indoor sources are a major contributor to air toxics risks. (3) Risks due to compounds formed by reactions in the atmos- phere could not be quantified in the exposure models, but there are indications that those risks may be significant. For example, formaldehyde is formed in the atmosphere by the breakdown of other organic compounds, and some compounds (e.g., toluene) may be converted into toxic substances through photochemical reactions. Factors which may have caused the risk estimates discussed above to be overstated are as follows: (1) EPA unit risk estimates generally are regarded as plausible, upper-bound estimates. That is, the unit risks are not likely to be higher, but could be consid- erably lower. (2) The degree to which outdoor-source related emissions of many pollutants (e.g., trace metals) penetrate inside is largely unknown. Should emissions from outdoor sources not penetrate completely indoors, then we will have over-stated risks, since we have assumed constant exposures to levels equalling those of outdoor air. ------- DRAFT I. INTRODUCTION DO NOT QUOTE QR Progress has been slow in making regulatory decisions on hazardous air pollutants under Section 112 of the Clean Air Act, and many observers, including States, Congress, environmentalists, and EPA management, have expressed concern about EPA's inaction. The most recent and formal criticism of EPA's implementation of Section 112 came from the General Accounting Office (6AO) in response to a request from Congressman John Dingell. On August 26, 1983, GAO released a report entitled, "Delays in EPA's Regulation of Hazardous Air Pollutants". The Administrator testified at hearings called by Chairman Dingell on November 7, 1983, responding to the GAO report and commenting on issues associated with Section 112. During internal discussions before the hearings, it became clear that EPA did not have a good understanding of the dimensions of the national air toxics problem, either in terms of size or causes. A cursory analysis suggested that a group of pollutants that were being considered for regulation under 112 might account for no more than an estimated few hundred cancer cases each year. This led to some fundamental questions concerning the magnitude and nature of risks caused by air toxics. o Do air toxics present a significant health problem, or does current concern stem from the fear caused by the specter of environmentally caused cancers? o If air toxics do pose a significant health problem, what sources and pollutants are responsible? o Is there an important part of the national air toxics problem that cannot be effectively addressed using Section 112? o Will a comprehensive program demand the active, coordinated participation of State and local air pollution agencies? ------- DRAFT DO NOT QUOTE OR CITE The Deputy Administrator decided that a broad scoping study of the air toxics problem was needed before management could begin to outline a comprehensive national program. An ad hoc study, called the "Six Month Study" because of its original intended duration, was started in November 1983. Many offices and individuals within EPA contributed to this effort, but the study was primarily a cooperative effort between the Office of Air and Radiation (OAR) and the Office of Policy, Planning and Evaluation (OPPE). This report summarizes the results of that study. In order to prepare the most useful report possible, decisions were made in the early days of the study to emphasize four general issues that would be most useful to policymakers as they attempt to define the scope and direction of a national air toxics program. 1. The magnitude of the air toxics problem We have attempted to characterize the size of the problem by presenting quantitative estimates of cancer risk. More precisely, we have presented estimates of the annual incidence of cancer that may be linked to air pollution, and estimates of lifetime individual risks. 2. The nature of the air toxics problem What pollutants and source categories contribute to the public health threat from air toxics? What is their relative significance? 3. Geographic variabi1ity EPA's strategy for regulating air toxics may be influenced by the city-specific nature of the problem. Some sources of air toxics may be relatively widespread and found in most areas of the nation. ------- .3- DRAFT DO NOT QUOTE OR CfTE Other sources may vary a great deal from city to city and controlling them may require considerable flexibility, both in terms of the pollutants and sources controlled, as well as the most effective regulatory approach. An urban area will probably have different priorities than a national program, and may still have significant problems after federal regulations are in place. 4. Adequacy of data bases This study is the most comprehensive attempt to date to assemble and analyze all available data on air toxics. Therefore, it is a useful vehicle for evaluating existing data bases, and identifying knowledge gaps. This summary should help programs set priorities and plan for future data gathering efforts, while providing policymakers with some insight into the relationship between the national problem and current EPA information collection and management efforts. The resources and time available required that the study be limited, in most cases, to gathering, organizing, and evaluating exi sti ng information. This, in turn, suggested that the results would be less than definitive, would include major data gaps and assumptions, and would require a great deal of judgment to interpret properly. The final report supports these expectations. Risk analysis for carcinogens is very uncertain, and assessing air toxics is complicated by the poor quality of available data. For several potentially significant issues, the lack of information prevents any analysis, and even in those areas with relatively good information, we had to make important assumptions. ------- -4- DRAFT °o Nor QUOTE OR CITE Consideration of caveats, disclaimers, and assumptions is an important responsibility of those using this report. Some of the major assumptions used in this risk analysis are presented in the following section. Specific limitations associated with individual analyses are presented in the summaries of each of those studies. Because of the long list of uncertainties associated with such a study, we chose a wide variety of analytical approaches in attempting to assess the national air toxics problem. A brief summary of each individual analysis follows. 1. Survey of State and Local Agencies, Canada and Europe We surveyed 50 State agencies and 33 local agencies, Canada, and several European nations to determine if they had completed quantitative assessments of air toxics exposures within their boundari es. 2. Epidemiological Evidence We evaluated existing reports that reviewed epidemiological evidence on lung cancer and its relationship to air pollution. 3. Ambient Air Quality Data Ambient air quality data were gathered, and then matched to population data to estimate cancer risks. 4. Emissions of Air Toxics Available information on air emissions of toxic substances was gathered, organized, and analyzed. 5. NESHAPS Study Finally, two other studies used exposure models to estimate total expected incidence, the relative importance of pollutants and sources, and city-to-city variability. Both of these studies use ------- 5 DRAFT DO NOT QUOTE OR CITE emission estimates, meteorological dispersion models, population distribution data, and cancer potency numbers to derive their risk estimates. The first of these is a national study that concen- trates on approximately 40 pollutants being considered for listing under Section 112 and that are candidates for National Emission Standards for Hazardous Air Pollutants (NESHAPS). 6. 35 County Study The second study based on emission estimates and dispersion modeling analyzes in more detail the risks caused by 22 pollutants in 35 counties. This study also attempts to assess sources that are not typically considered major sources of air pollution. The results of these disparate analyses are discussed separately, followed by a discussion of sources and pollutants not covered by the six studies, and then brought together in a summary section on the magnitude of the problem. ------- DRAFT -6- DO NOT QUOTE OR CITE II. RISK ASSESSMENT METHODS A. Estimates of Potency or Unit Risk 1. Why cancer? In our attempt to determine the magnitude of the air toxics problem and the relative significance of pollutants and sources, we relied solely on cancer risk estimates. There were several reasons for this deci si on. o Cancer is a significant cause of death in the U.S.: approximately 20% (440,000 per year) of all U.S. deaths are caused by cancer. o A link has been established between urban areas and higher lung cancer rates. o Several identified air pollutants are known to be human carcino- gens (e.g., benzene, arsenic, and vinyl chloride). o The public is concerned about cancer, and about the link between environmental pollution and cancer incidence. o The only accepted basis for extrapolation to low levels of exposure for estimating risk is with cancer. o Ambient air concentrations are likely to be lower than the thre- hold for most chronic and sub-chronic health effects, whereas there is a considerable degree of scientific support for using the non-threshold assumption in assessing carcinogens. 2. Why not assess other health effects? Except for the criteria pollutants, ambient air concentrations of most compounds usually appear to be too low to be linked easily to health effects other than cancer, with the possible exception of impacts on very sensitive individuals. Most acute health effects are caused by concentrations in the several parts per million range, while ambient concentrations of most compounds tend to be in the parts per billion range. ------- -7- DRAFT DO NOT QUOTE OR CITE Mutagenicity and teratogenicity are receiving more emphasis, however. For example, although ethylene dibromide and ethylene oxide are of concern primarily because of carcinogenicity, these compounds have be.e.n shown to be mutagenic in test systems, and 2,3,7,8-TCDD has been shown to be a developmental toxin in animals. Although examples like these exist, the data for most compounds are too limited to qualitatively determine whether the substances are potentially mutagenic or teratogenic. For those few substances with enough data to pass the qualitative weight of evidence test, there is rarely enough information to develop any reliable dose-response estimates. While it is generally accepted that there are thresholds for some teratogenic effects in test animals, data are seldom available that will allow the calculation of threshold levels. The uncertainty is compounded when animal data are used to predict human teratogenic effects. For teratogens, there tend to be multiple end points and the timing of exposure often is crucial; these may not be the same for animals and humans. In contrast, however, there is underlying biological support for a non-threshold mechanism for carcinogenesis in both animals and humans. Furthermore, it is generally accepted that if a chemical is carcinogenic in test animals, it is likely to be carcinogenic in humans. Since only animal data are available for most compounds, quantitative risk estimates can be established routinely only for cancer. ------- DRAFT DO NOT QUOTE OR CHI 3. Estimating Potency Assessing the risk of cancer caused by exposure to toxic substances in the environment is a complex, controversial, and uncertain business. The risk per unit dose estimates for most of the pollutants covered by this analysis were developed by the Carcinogen Assessment Group (CAG) in EPA's Office of Health and / Environmental Assessment (OHEA) in the Office of Research and Development. To calculate such estimates, OHEA makes several significant assumptions, each of which adds a measure of uncertainty to the numerical estimates. The major assumptions used by CAG in assessing carcinogenic potency* are described as follows: o Experimental data showing that a substance is carcinogenic in animals are used as evidence that the substance may be carcinogenic in humans as well. o In the absence of human data, the results of such animal bioassays are used to estimate the probability of carcinogenic effects in humans, and such extrapolations assume humans to be as sensitive as the most sensitive animal species tested. o CAG uses a nonthreshold, multistage model that is linear at low doses to extrapolate from high dose response data (either occupational studies or animal bioassays) to the low doses typically caused by exposure to ambient air. In other words, carcinogenic substances are assumed to cause some risk at any exposure level. These unit risk values represent plausible upper bounds, that is, they are unlikely to be higher but could be substantially lower. Quantitative estimates of carcinogenic potency (the unit risk value) are expressed as the excess chance of contracting cancer from a 70 year lifetime exposure to a concentration of 1 ug/rn-^ of a given substance. Generally the unit risk value represents cancer cases, not deaths. However, since the epidemiological studies that generated the potency number for PIC (products of imcomplete combustion) are based on lung cancer mortality, the PIC estimates used in this report imply lung cancer deaths. ------- DRAFT DO NOT QUOTE OR CUE -9- o CAG assumes that exposed individuals are represented by a reference man having a standard weight, breathing rate, etc. No reference is made to health, race, nutritional state, etc. Some have charged that some of the Agency's methods may lead to overestimates of risk. However, there are other factors that may tend to offset conservatism in the techniques. These include: o People are exposed to complex mixtures of chemicals. Data are not available to demonstrate or deny the existence of either synergistic or antagonistic health effects at low exposu res. o Virtually all animal and human data are based on exposure to adults. There may be enhanced risk associated with fetal, child, and/or young adult exposures to some agents. o There may be high susceptibility for some population groups because of metabolic differences or inherent differences in their response to effects of carcinogens. The Administration recently took a position on some of the more controversial assumptions above. On May 22, 1984, the White House Office of Science and Technology Policy (OSTP) released their final report, Review on the Mechanisms of Effect and Detection of Chemical Carci nogens. The report's statement of principles concludes that available information "does not allow one to define the existence or location of a threshold" for carcinogenicity. Furthermore, the principles state that "a model which incorporates low-dose linearity is preferred when data and information are limited as is the usual case and when much uncertainty exists regarding the mechanisms of carcinogenic action." ------- -ID- DRAFT DO HOT QUOTE OR CfTE In summary, this study is based on methods for assessing cancer potency now in use throughout EPA. No judgments were made regarding the appropriateness of these methods, nor did we attempt to use alternative techniques. We felt that a comprehensive analysis of risk assessment techniques was beyond the scope of this study, and that alternative methods would make risk comparison with other programs more difficult. B. Estimates of Exposure Risk assessment for cancer usually requires three basic kinds of information: an estimate of the potency of the compound or group of compounds being considered (the unit risk value), information on the sources and emissions of that substance, and the concentrations that different numbers of people breathe. Whereas the preceding discussion focused on the methods and uncertainties associated with estimating potency, this section discusses the methods, assumptions and uncertainties associated with estimates of exposure. For most of the analyses summarized in this report, two measures of risk were calculated. The first, lifetime individual risk, is a measure of the probability of an individual developing cancer as a result of exposure to an ambient concentration of an air pollutant or group of air pollutants.2 Often, the maximum lifetime individual risk is also presented, which usually applies to individuals living nearest the source. In an attempt to gauge the significance of additive risks, we also calculated multi-pollutant individual risks 2 A maximum individual lifetime risk estimate of 3.0x10-4, for example, near a point source implies that if 10,000 people breathe a given concentration for 70 years then at the upper bound three of the 10,000 will develop cancer as the result of the exposure to that pollutant from the source. ------- -ii- DRAFT , u DO NOT QUOTE OR CITE caused by several pollutants measured in the same area. These multi-pollutant risks were not associated with a specific point sou rce. Aggregate or population risk estimates, on the other hand, are estimates of the annual incidence of excess cancers for the entire affected population. These estimates are calculated by multiplying the estimated concentrations of the pollutant by the unit risk value and by the number of people exposed to different concentrations. This calculation yields an estimate of the total number of excess cancers that may occur over a 70 year period; the total must then be divided by 70 (because of the assumed duration of exposure) to estimate annual incidence. 1. Monitorlng Data Two major techniques were used to estimate ambient concentra- tions for this study, and each has its own set of uncertainties. The first was to use ambient air quality measurements. Intuitively, estimates based on ambient data appear more reliable. The estimates are based on direct measurements of ambient concentrations instead of a modeled estimate of the concentrations resulting from environ- mental releases. Monitoring avoids the problems of incomplete emission inventories, incomplete knowledge on current control status, a lack of knowledge concerning pollutants formed or destroyed in the atmosphere and the list of errors associated with dispersion modeli ng. However, there is significant potential for error in using monitoring data to estimate aggregate risk. The most important is the classic problem of extrapolating measurements at a single site to a much larger geographic area in order to estimate population exposure. To estimate concentrations in a city, we were forced to ------- DRAFT ~12~ DO NOT QUOTE OR CITE average measured values and assume that these values applied to the entire area. The number of monitoring sites in a metropolitan area ranges from one or two to a maximum of ten in Baltimore and Philadelphia. Because of this limited coverage and because monitors are often intentionally located away from major sources, using monitoring data probably is especially unsuitable for estimating maximum individual risk. Second, estimating annual incidence forced us to extrapolate the available data for a relatively small number of areas to the rest of the nation. For trace metals and organic particulates, the National Air Monitoring System and State and Local Air Monitoring Systems (NAMS/SLAMS) contain data for counties representing a total of 25 million to 75 million people. Data on volatile organics are available for areas with a total population of only 2 million to 25 mi 11i on people. Third, because cancer risk assessment assumes long term exposures, the most useful data are long term average concentrations, preferably annual averages. Very few studies have collected ambient samples for toxics continuously for an entire year. For purposes of this study, monitoring data for 20 days a year was labeled as being sufficient for calculating an annual average. This was available for most of the trace metals. For organics, annual averages were calculated if monitoring data were available for 10 separate days spread over at least two quarters. Finally, all air quality data are subject to errors in sampling and analytical methods. These problems are greater for air toxics than for criteria pollutants, but are generally considered less significant than the other potential sources of error. ------- -is- DRAFT DO HOT QUOTE OR CITE 2. Emission Estimates and Dispersion Modeling Several of the analyses presented in this report relied on emission estimates and dispersion modeling to estimate ambient concentrations. A major advantage of this method over ambient data is the ability to characterize the contribution of various sources. Also, emission modeling provides continuous geographical coverage and, therefore, is more comprehensive than monitoring at identifying "hot spots" that are of concern because of high individual risk. Finally, modeling generally allows a larger number of pollutants to be considered, and it avoids the problem of geographic extrapol a.ti on. Emission estimates and dispersion modeling were used in three analyses that are summarized in this report: the 35 County Study, the NESHAPS Study, and work completed by the Office of Radiation Programs on radionuclides. Conceptually, the models all operate the same way. Emission estimates for area and mobile sources are apportioned uniformly over the entire area being considered, while point sources are located at a specific site. Emission estimates for point sources are developed using available sources of information, which may vary widely in quality. The emission estimates are loaded into the computer dispersion model along with information on stack height and diameter, emission velocity and temperature. Meteorological data (wind speed, direction, and stability) from the nearest of over 300 National Climate Center sites is entered into the model along with population distribution information from 1980 census data. Running the models results in estimates of ambient concentrations at different distances from the source. The dispersion models were run for 50 km in the 35 County study, 20-50 km in the NESHAPS analysis depending on the ------- .14. DO NOT QUOTE OR CITE pollutant, and 80 km for the radionuclides analysis. The appropriate choice for the outer boundary when estimating pollutant dispersion is a matter of considerable debate. Some of the major issues surrounding the use of both monitoring and dispersion modeling techniques in estimating exposure are as • f o 11 ow s: o The dispersion models assume flat terrain and average meteorological conditions. Rough terrain in the area surrounding a source, such as a valley, would probably cause higher concentrations near point sources and lower concentrations further away from the source. o Although exposure estimates apply to a certain point in time, our risk assessments assume that the people that live in an area are exposed to the estimated ambient concentrations for 70 years. In other words, we assume that the plant operates for 70 years, that no one moves in or out of an area, and that no one moves around within the area. Few plants operate for 70 years, and most people change homes several times during their life; however, an individual may still be exposed to emissions of the same or different toxic compounds after moving from an area. o A related issue is the assumption that people are continually exposed to outdoor ambient concentrations. In fact, most Americans spend 80 to 90% of their time indoors. Thus, a significant part of total exposure to air toxics occurs indoors. Unfortunately, we were unable to quantify the risks due to indoor exposures to the substances examined in this study. However, there are strong indications that indoor levels of many volatile organic compounds are higher than outdoor levels, since there are many indoor sources of organic compounds. No indoor/outdoor comparisons were found for the metals examined in this study, but the limited data available for other trace metals show that indoor air levels are sometimes higher and sometimes lower than outdoor levels. o Dispersion modeling is often extended to only 20 km from the source, a technique which can lead to understatement of risk if extending dispersion increases significantly the number of people exposed. To see what difference a 50 km boundary would make, five organic substances were modeled to that distance, and the change increased annual cancer incidence by a factor of 1.35. ------- -15- DRAFT DO NOT QUOTE OR CITE Dispersion estimates are rarely based on site-specific meteorology. Often, data from hundreds of kilometers away must be used. In running the dispersion models, we do not consider increases in concentrations that could result from reentrainment of toxic particles from streets, rooftops, etc. With the exception of radionuclides, we also do not consider background concentra- tions and emissions from other sources not explicitly included in the analyses, including toxics formed in the atmosphere. Emission estimates are generated using data and assumptions that could be in error. For example, although the 35 County Study incorporates plant-specific emission estimates whenever possible, the pollutant releases for the remaining sources were developed by applying speciating factors against the VOC and TSP data in the National Emission Data System (NEDS). Unfortunately, some of the information in NEDS is of questionable consistency and quality for the purposes of quantitative risk assessment. For other analyses, estimates are based on plant capacity and emission factors. These studies assume that plants continuously operate at an assumed percentage of capacity and that no changes in emission rates occur. Malfunctions are not considered. ------- DO .: -"T -10- AMr' DQ mi QUOJ£ Qfl III. MAGNITUDE OF THE AMBIENT AIR TOXICS PROBLEM A. Introducti on One of the major goals of this study was to improve our under- standing of the size of the overall public health problem caused by air toxics, a task that has been colorfully characterized in the trade press as determining whether the air toxics problem is "an elephant or a mouse." Although the study is the most comprehensive effort to date to define the aggregate risk from air toxics, the results are not totally satisfying. First, the pollutant coverage is spotty. Constrained by available data on emissions and risk, the various analyses were able to include only 15-45 of the hundreds of potential carcinogens in the atmosphere. Second, from the standpoint of exposure and risk estimation, only the inhalation pathway and cancer are assessed. Ingestion of air pollutants, and skin cancer that could be caused by the effect of air pollution on the stratospheric ozone layer were not considered. Third, the range of error for individual estimates is«great, requiring judgment in order to interpret properly. Finally, no quantitative estimates are available for many potentially important source categories, e.g., Superfund sites, hazardous waste disposal and pollutants formed in the atmosphere. At the onset of the study, we identified several analytic techniques for assessing the nature and magnitude of the air toxics problem. Each methodology offered different advantages, as well as varying degrees of resolution and uncertainty. Rather than select one approach for the analysis of such a complex issue, we chose to complete several studies: ------- -17- DRAFT DO NOT QUOTE OR CUE o An assessment of the hazardous air pollutant problem based on state and local experience; o An evaluation of epidemiological evidence on cancer and its relationship to air pollution; o An estimate of national exposure and risk from about 40 pollutants being considered for listing under Section 112 of the Clean Air Act; o A more detailed estimate and analysis of exposure and risk in 35 counties for about 20 pollutants, including consideration of sources that were not considered sources of air emissions in the past, such as municipal sewage treatment plants (POTWs) and waste oil combustion; o An analysis of existing ambient air quality data for metals and volatile organic compounds; o A discussion of pollutants and sources either not covered by the analyses above, e.g., radionuclides, asbestos and gasoline marketing, or not easily quantified, e.g., dioxin and combustion of hazardous waste in boilers. In this chapter, we will first describe each of these studies in more detail and summarize their findings on the magnitude of the ambient air toxics problem. We have expressed the magnitude of the problem in three ways: annual national cancer incidence; annual incidence per million people; and lifetime individual risk. We then summarize and compare the results from each effort, and develop general conclusions. Again, we must caution against misuse of the results of this scoping study. The analysis was not undertaken to lead directly to decisions on carcinogenicity nor source regulation. Use of the results should be limited to: 1) identifying the potential signifi- cance of the risk caused by air toxics from a national and regional ------- -is- DRAFT DO NOT QUOTE OR CfTE perspective; 2) assisting the Agency in setting research and regulatory priorities; 3) identifing those pollutants and sources for which only scant data exist and should therefore be explored in more detail; and 4) assisting in developing long-term goals and gen.eral strategi e.s. f or air toxics. B. Summaries of Individual Analyses 1. Survey of State and Local Agencies, Canada, and Europe The responsibility of dealing with air toxics is not unique to EPA or this nation. Several State and local agencies have active air toxics programs, and have a great deal of experience in dealing with these problems. Also, other industrialized nations have the same public concern over environmental cancers as the United States. We reasoned that they may have the same need as EPA to define the risks from air toxics in order to justify programs and to set priorities. Therefore, a portion of the study involved communication with Canada, the European Community, all States, and 33 major local air agencies^,^,5 on their risk assessment activities. 3 Memorandum from B.J. Steigerwald to Alan Jones et al., "Air Toxics Program in Canada," EPA, April 16, T9~8TT~ 4 Memorandum from Delores Gregory, OIA, to B.J. Steigerwald, EPA, OAR, "E.G. Regulation of Hazardous Air Pollutants," May 3, 1984. 5 Radian Corporation, "Definition of the Air Toxics Problem at the State/Local Level," EPA Contract 68-02-3513, Work Assignment 45. June 1984. ------- -19- DRAFT DO NOT QUOTE OR CfT£ Of these, only California has attempted to quantify public health risks from air toxics. Officials in Canada believe that risk assessment will be increasingly important in their toxics programs, but they have not yet developed methods and do not apply risk assessment in any systematic way. They will evaluate in • detail the results of this study. Cables were sent to the Commission of the European Communities through EPA's Office of International Activities and discussions were held with individuals involved in toxics programs in Europe. There is much information available from the international community on the potential toxicity of various compounds, but nothing seems to be available on cancer incidence or on individual risks from exposure to ambient air. The California estimate was an isolated analysis published in 1982 to support proposed legislation on air toxics.6 It used air quality data for nine specific compounds to calculate excess lifetime cancer rates per million population in the Los Angeles basin. Potency for each compound was determined in a unique way using an air equivalent of EPA's Water Quality Criteria rather than the unit risk value used in EPA's risk assessment procedures. Therefore, the results are not directly comparable to our results obtained using air quality data for Los Angeles. For the nine compounds selected, the California analysis estimates about 1000 excess lifetime cancers per million people or about 14 annual cases per million. The study was used by the California Air Resources Board 6 Batchelder, J. et al.. Proposed Amendments to Chapter 1, Part III of Title 17, CaTTfornia Administrative Code, Regarding the Emission of Toxic Air Contaminants." California Air Resources Board; September 1982. ------- DRAFT ~2°~ 00 NOT QUOTE OR CITE for orientation purposes only and to show that the problem deserved additional attention. They do not recommend the study be given weight beyond its original purpose. Since most State and local agencies included in the poll expressed concern over air toxics but could not quantify their concern directly,, we explored other more subtle indicators of the problem. Counting air "episodes," "incidents," or "complaints" involving health scares produced no usable statistics. An evaluation of source permits indicated that, at least for States with fenceline ambient standards, air toxics programs could require substantial resources and often require controls beyond those needed for criteria pollutants. For example, about 1000 new source permits a year are issued in Michigan for emissions of toxic pollutants. New York reviews 36,000 operating permits every 1 to 5 years under their air toxics regulation; this number increased by 6000 emission points in the past 2 years. Illinois reviews 5000-6000 permits each year that involve emissions of air toxics. In a recent detailed study of 42 permits for source categories likely to emit toxics, Illinois found that 20 of the sources were required to control beyond that needed for criteria pollutants. In summary, essentially no other agency has attempted to quantitatively define risks from air toxics. However, general concern about the problem is universal, and an increasing number of States have begun to issue air toxics permits to large numbers of new and existing sources. These permits are generally based on diffusion modelling and compliance with fenceline ambient standards that are derived from occupational guidelines. ------- -21- DRAFT DO NOT QUOTE OR CITE 2. Evaluation of Cancer Associated with Air Pollution Using Epidemiological Studies Background The traditional way to demonstrate the effect of environmental pollution on public health has been to perform an epidemiological study. A variety of such studies has been attempted for air pollution. Our primary source of data on these was a report prepared by Clement Associates for EPA which described and critically evaluated the evidence for cancer associated with air pollution.7,8 The Clement report assembled 3 main types of evidence linking cancer incidence to air pollution: epidemiological studies, laboratory studies on mutagenicity of airborn materials, and ambient air monitoring data for pollutants known to be carcinogens. Data from the mutagenicity and monitoring studies confirmed other reports that extracts of airborne material from polluted air and emissions from motor vehicles and stationary sources are mutagenic or carcinogenic • in experimental bioassy systems. 7 Clement Associates, Inc., "Review and Evaluation of Evidence for Cancer Associated with Air Pollution." (EPA-450/5-83-006) Review Draft. November 9, 1983. 8 Pate, Nancy, "Review of the Document 'Review and Evaluation of the Evidence for Cancer Associated with Air Pollution1 and Assessment of this Approach for Better Defining the Extent and Magnitude of the Air Toxics Issue." June 1984. ------- DRAFT DO NOT QUOTE OR CUE -22- The report also reviewed epidemiological studies linking air pollution and lung cancer by using levels of benzo(a)pyrene (BaP), a known potent carcinogen, as an indicator of air pollution.9 Using selected of these studies, the Clement report presented calculations of the number of lung cancer deaths which could be associated with a given level of air pollution as characterized by BaP concentrations, By combining lung cancer mortality from the 1960's with estimated levels of BaP in the 1930's and 1940's. Clement estimated that roughly 10,000 cases of lung cancer per year (11%) during the 1960's were attributable to air pollution. Unfortunately, because of the long lag time between exposure and onset of cancer, these findings are not directly relevant to the hazard posed by current air pollution, particularly since BaP concentrations have generally declined by a factor of 10 since the 1960's.10 9 BaP is a ubiquitous pollutant generally found in emissions from incomplete combustion, especially of wood and coal in small combustion units and in motor vehicle exhaust (soot and smoke). BaP is one of the literally hundreds of organic particulates known as polynuclear organic compounds; many polynuclear organics are carcinogenic, many are not. 10 Pate, Nancy. 0_p_. cit. ------- DRAFT ~23~ 00 NOT QUOTE OR WT£ Despite this limitation in the direct use of the results of epidemiological studies, we felt we could not ignore the polynuclear organics represented by BaP in this analysis. Even though overall BaP emissions have decreased significantly since the 1930's and 1940's, BaP-related compounds are still present in the ambient air and may still represent an important part of the air toxics problem. For example, a recent study completed in New Jersey examined ambient BaP concentrations and mutagenicity of organics extracted from inhalable particulate matter samples. BaP levels increased by tenfold during the.winter relative to the summer, and mutagenicity tests found winter particulate matter samples to be 1-1/2 to 3 times as mutagenic as summer samples.H Thus, we decided to use the dose/response coefficient derived from data cited in the Clement report and to combine it with current air quality data and emissions of BaP to estimate cancer incidence associated with the large category of BaP-related pollutants which we will refer to in this study as Products of Incomplete Combustion (PIC). The Clement report presented 14 estimates obtained from 12 separate reports of the dose/response relationship between air pollution levels as indexed by BaP concentrations and lung cancer rates. Of these 14 estimates, 6 were derived from occupational epidemiological studies, while 8 were derived from general population studies that related cancer deaths in the period 1959-1975 to BaP levels from 1958-1969. 11 Lioy, Paul J., and Daisey, Joan M. "The New Jersey Project on Airborne Toxic Elements and Organic Substances (ATEOS): A Summary of 1981 Summer and 1982 Winter Studies", Journal of the Air Pollution Control Association, Volume 33, Number 7, July 1983. ------- DRAFT DO NOT QUOTE OR C/TE -24- Clement Associates adjusted the dose/response coefficients in these general population studies downward to account for the decline in ambient BaP levels during the lag periods between exposure and death from lung cancer. In accordance with recom- mendations by research groups within EPA, certain of the occupa- tional dose/response estimates presented in the Clement report were revised (for example, the Carcinogen Assessment Group's latest estimate f.or coke oven emissions was substituted for that appearing in the Clement report). The final potency estimates (as expressed by lung cancer deaths per year per ng/m^ BaP) for the occuptational studies varied from 0.46 to 0.88 x 10 ~ 5, whereas those for the general population studies varied from 0.3 to 1.4 x 10"5. When the potencies for each of the two categories of studies were averaged, estimates of 0.69 x 10~5 (general population) and 0.71 x 10~5 (occupational) were obtained. A value of 0.7 x 10~5 was selected and combined with estimates of population exposure to BaP; based on air quality data, an estimate of 821 incidences of lung cancer per year attributable to PIC was estimated, whereas 148 deaths per year were estimated using BaP emissions data and the more limited population studied in the 35-County Study. The reader should be alerted to several key limitations of using BaP levels as a surrogate for exposure to a complex mixture of compounds, as we have done in this analysis. A major weakness of using the potency estimates derived from the occupational studies is that the mix of PIC in the exposures studied (coke oven emissions, roofing tar fumes, and gas fumes) almost certainly ------- DRAFT -25~ DO NOT QUOTE OR CITE differs from that of the ambient air. A limitation of general population studies is that BaP in these studies is used as a surrogate for all air pollution, not just PIC, and BaP ambient levels in the 1930's and 1940's had to be estimated. In addition, the proportion of -carcinogenic activity attributable to BaP in PIC mixtures is known to vary between source categories and sometimes within a source category (e.g., different automobiles). The impact of this varying ratio of BaP to other compounds is further complicated since synergistic and antagonistic effects between BaP and other PIC compounds are known to occur, but at present are virtually unquantifiable. All of these factors indi- cate strongly that BaP is almost certainly not a stable index of the carcinogenicity of polluted air. In spite of the limitations of the BaP-surrogate method, it appeared that there was no better alternative for estimating risk due to PIC. Simply citing risk estimates for mixtures from specific sources of PIC was not an option, since quantitative risk estimates are available for only one mixture--coke oven emissions--which comprises only a small fraction of total estimated PIC emissions. Also, sufficient data on potency and emissions do not exist to characterize PIC risks on a compound by compound basis. It should be noted that there are precedents for using BaP as a surrogate in just this way. The National Academy of Sciences (NAS) recently used BaP as a proxy to estimate the cancer risk from polycyclic aromatic hydrocarbons (a chemically defined analogue of our more loosely defined "PIC"). In a 1983 report ------- DRAFT DO NOT QUOTE OR CfTE -26- entitled, "Polycycllc Aromatic Hydrocarbons: Evaluation of Sources and Effects," the NAS estimated cancer risks as follows: This appendix...assumes that benzo(a )pyrene (BaP) can be used as a proxy for PAH's and that human exposure to BaP in the ambient air at an average concentration of 1 ng/m^ over an entire lifetime has the effect of increasing by 0.02-0.06% the risk of dying prematurely (at or before the age of 70) because of lung cancer. Although the appropriateness of BaP as a surrogate for PAH's in general has been questioned, it has been so used extensively in the past, and much of the available information refers to it as an indicator for exposure to PAH's. (p. D-l) By way of comparison with the potency estimate used in our analysis (0.7 x 10-5), the NAS lifetime potency estimates translate into 0.3 to 0.9 x 1Q-5 lung cancer deaths per year per ng/m^ BaP. Parenthetically, we might add that the same NAS report presented estimates of cumulative lung-cancer incidence due to lifelong exposure to diesel exhaust from various types of vehicles. These estimates varied from a low of 20 per 100,000 to a high of 787 per 100,000 for two different makes of automobiles, compared to that of 43 per 100,000 for coke oven emissions. Thus, we acknowledge that there are real analytical problems associated with estimating risk due to PIC and that there is vari- ation in the BaP-surrogate potency estimates. However, since this report was intended to focus policy and planning activities and was not meant to serve as the basis for regulatory acton, we decided to include the incidence estimate for PIC as a preliminary estimate of the magnitude of the PIC problem. ------- -27- DRAFT DO NOT QUOTE OR 3. NESHAPS Study Background The NESHAPS study was one of two analyses that employed dispersion modeling to assess exposure and risk due to air toxics.12 EPA's Human Exposure Model (HEM) was employed to convert point source emission estimates into estimated ambient levels. The study was designed to examine in more detail the growing belief that sources covered in the past under NESHAPS, i.e., industrial producers and users of the chemicals of concern, may be responsible for only a small part of the air toxics problem. The risk estimates in this study are national in scope, and consider emissions obtained from traditional air pollution inventories. The sources covered include mobile and area sources, but the emphasis was on point sources. Consideration of some potentially important pollutants, such as radionuclides, gasoline vapors and products of incomplete combustion (PIC), and nontraditional sources, such as POTWs and hazardous waste disposal were not included in this analysis. The original intent of this effort was to estimate exposure and risk for 87 pollutants: the original 37 candidates for listing under Section 112 and 50 additional substances identified by EPA's Office of Air Quality Planning and Standards (OAQPS). OAQPS identified 12 Schell, R.M. "Estimation of the Public Health Risks Associated with Exposure to Ambient Concentrations of 87 Substances;" OAQPS, USEPA, July 1984. ------- DO NOT QUOTE OR CfTE -28- th is latter grouping of pollutants using the Hazardous Air Pollutant Prioritization System (HAPPS) developed by Argonne National Labora- tories. They also considered ambient air monitoring data for organics and production data. Unfortunately, after a great deal of effort to gather all available dose-response data on these pollutants, we were only able to quantitatively analyze 42 compounds (see Table 1). The qualitative judgment regarding the carcinogenicity of some of these compounds is still an open question, and they are included here for analytical purposes only- All of the unit risk values used in this report are presented in Attachment A. Emission estimates for 27 of the 42 compounds were developed using OAQPS staff analyses and other OAQPS contract documents. For the remaining 15 compounds, little information was available. Surrogate estimates of exposure were made for these using a "best-fit" approach with known compounds based on physical properties, uses, and production volumes. ------- NESHAPS STUDY: -29- TABLE 1 PRELIMINARY APPROXIMATION OF ANNUAL AND MAXIMUM LIFETIME RISK DRAFT DO NOT QUOTE OR CITE INCIDENCE Pollutants Havi ng Some Evidence of Carci nogeni city* Preliminary Approx- imation of Maximum Individual Lifetime Risk** Preliminary Approx- imation of Incidence** Aery 1 ami de Acryl oni tri le Al lyl chlori de Arseni c Benzene Benzyl chlori de Beryllium 1,3 Butadi ene Cadmi urn Carbon Tetrachl ori de Chloroform Ch romi urn"1" Coke Oven Emissions Di ethanol ami ne Dimethyl nit rosami ne Dioctyl phthalate Epi chl orohydri n Ethyl acrylate Ethyl ene Ethylene dibromide 7.4x10-5 3.8x10-3 1.3x10-6 6.5x10-3 8.0x10-3 3.0x10-5 1.0x10-4 9.7x10-6 7.5x10-4 5.8x10-4 3.0x10-3 1.6x10-1 2.0x10-2 2.0x10-7 5.4x10-5 9.8x10-6 1.9x10-6 4.7x10-5 4.9x10-4 1.6x10-4 0.01 0.42 <0.01 4.70 32.30 <0.01 1.20 0.01 16.30 14.00 0.27 330.0 8.60 <0.01 0.05 <0.01 <0.01 <0.01 <0.01 26.70 * The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substantial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purposes of this report, a conservative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. ** Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approximations of total incidence and maximum lifetime individual risk. Estimates of incidence for individual compounds are much less certain. These incidence and maximum risk estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. * Risk estimates assume that all species of chromium and nickel are carcinogenic, although only certain species have evidence of carcinogenicity. Current data do not allow differentiation among species. ------- -29a- TABLE 1 (cont.) DRAFT DO NOT QUOTE OR CITE NESHAPS STUDY: PRELIMINARY APPROXIMATION OF ANNUAL INCIDENCE AND MAXIMUM LIFETIME RISK Pollutants Having Some Evidence of Careinogenicity* Preliminary Approx- imation of Maximum Individual Lifetime Risk** Preliminary Approx- imation of Incidence** Ethylene dichloride Ethylene oxide Formal dehyde 4,4 Isopropyl i denedi phenol Mel ami ne Methyl Chloride Methylene chloride 4,4 Methylene dianiline Nickel t Ni trobenzene Nitrosomorphol i ne Pentachl orophenol Perchloroethy lene PCBs Propylene dichloride Propylene oxide Sty rene Terephthal i c aci d Titanium dioxide Tri chloroethyl ene Vinyl chloride Vi ny 1 i dene chl ori de 2.9x10-4 6.8x10-3 6.1x10-4 1.1x10-6 1.5x10-6 1.2x10-5 9.0x10-6 1.5x10-3 1.6x10-3 1.2x10-6 6.0x10-9 1.7x10-5 4.6x10-4 3.0x10-4 2.1x10-6 3.0x10-2 3.3x10-5 1.5x10-6 3.2x10-7 1.0x10-4 3.8x10-3 4.2x10-3 44.00 47.80 1.60 0.03 <0.01 <0.01 1.0 0.02 80.00 <0.01 <0.01 0.12 2.90 0.21 <0.01 0.97 <0.01 <0.01 0.01 9.70 11.70 0.04 Total 634.7 * The weight of evidence of carci nogeni ci ty for the compounds listed varies greatly, from very limited to very substantial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purposes of this report, a conservative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. ** Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approximations of total incidence and maximum lifetime individual risk. Estimates of incidence for individual compounds are much less certain. These incidence and maximum risk estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. Risk estimates assume that all species of chromium and nickel are carcinogenic, although only certain species have evidence of carcinogenicity among species. Current data do not allow differentiation ------- DRAFT DO NOT QUOTE OR CITE -30- Fi ndi ngs For the 42 compounds included in the NESHAPS analysis, a total nationwide annual cancer incidence of 635 was calculated (see Table 1). Roughly 93 percent of these can be attributed to eight compounds. These compounds, ranked in descending order, are as follows: chromium; nickel; ethylene oxide; ethylene dichloride; benzene; ethylene dibromide; cadmium; and carbon tetrach1oride. 13 Maximum individual risks 10~3 or greater were estimated for 12 compounds: acrylonitrile; arsenic; benzene; chloroform; chromium; coke oven emissions; ethylene oxide; 4-4 methylene dianiline; nickel; propylene oxide; vinylidene chloride; and vinyl chloride. In addition to the usual uncertainties, there are further complications with the risk estimates for several compounds, including chromium, nickel, carbon tetrachloride, and formaldehyde. These considerations demonstrate the need for caution in interpreting such studies. In the case of chromium, only the hexavalent form has been proven to be carcinogenic with a unit risk value of 1.2xlO~2 compared The individual percentage contributions of each compound are: chromium (52%); nickel (13%); ethylene oxide (8%); ethylene dichloride (7%); benzene (5%); ethylene dibromide (4%); cadmium (3%); and carbon tetrachloride (2%). ------- -31- DRAFT DO NOT QUOTE OR CITE to arsenic at 4.29x10-3. There is now insufficient evidence to determine that the trivalent form is also carcinogenic. The NESHAPS analysis, however, assumes that total chromium releases are carcinogenic and that trivalent chromium is as potent as hexavalent. There is no information now available on the ratio of trivalent to hexavalent for emissions or ambient concentrations, but some occupa- tional exposure studies suggest that the trivalent form may dominate. On the other hand, several important source categories are known to emit at least some hexavalent chromium and there is some evidence that changes in the valence state can occur in the atmosphere. The problem of speciation adds one more layer of uncertainty to the risk estimates for chromium. The situation for nickel is similar. Only two rare nickel subspecies (nickel subsulfide and nickel carbonyl) are considered carcinogenic; however, the unit risk factor for these forms is applied to total nickel emissions. Although research is underway, there is little information available at present on ambient concen- trations of the different nickel forms. Carbon tetrachloride is a very stable organic compound that has a half-life of about 35 years compared to a half-life of hours or days for most other common volatile organic compounds. As a result, carbon tetrachloride is accumulating in the atmosphere. Therefore, current emissions are associated with cancer risks now, and in the future, by increasing background concentrations. The NESHAPS analysis only covers risk from current emissions and known sources, and estimates incidence at 14 per year. If current background levels are considered, the incidence estimate increases to about 85 per year. Carbon tetrachloride also has the potential to deplete ------- DRAFT -32- DO HOT QUOTE OR C/TE stratospheric ozone and thereby indirectly increase the incidence of skin cancer. For example, it is estimated that by the year 2020 U.S. emissions of carbon tetrach1oride could be responsible for between 500 and 22,000 excess cases of skin cancer annually in the U.S., resulting in 3-220 excess deaths per year- Formaldehyde can be formed in large quantities in the atmosphere, and the risks posed by the resulting ambient concentrations are not able to be considered in exposure analyses based on emission estimates alone. Assessments based on ambient monitoring data should provide a more complete accounting of actual risk due to formaldehyde, because they cover concentrations resulting from both emissions and atmospheric formation. 3. 35 County Study Background In contrast to the national scope of the NESHAPS study, the 35 County Study was designed to address the air toxics problem from a more local perspective.^ Building on the work of EPA's Integrated Environmental Management Division (IEMD) in its geographic demonstra- tion projects in Philadelphia, Baltimore and Santa Clara Valley, this analysis explored the following: 0 the incidence of cancer resulting from exposure to several pollutants and sources in specific localities; 0 the pollutants and sources that are the most significant contributors to the problem; and 0 the geographic variability of pollutants, sources, and exposures. Versar; American Management Systems, Inc. "Hazardous Air Pollutants: An Exposure and Risk Assessment for 35 Counties." September 1984. ------- DRAFT _33_ D° NOT QUOTE OR CfTE The analysis focused on traditional sources, i.e., large point sources such as power plant and industrial facilities, and area sources, such as motor vehicles, space heating, gasoline marketing, and solvent usage. However, it also included "nontradi- tional" sources, such as woodstoves, waste oil combustion, and sewage treatment plants. Data limitations did not permit emission estimates or any extensive exposure modeling for TSDFs (hazardous waste treatment, storage and disposal facilities), Superfund sites, hazardous waste in boilers, municipal waste incinerators, municipal landfills, and sewage sludge incinerators. The Agency has initiated various studies to explore emissions and risks for most of these sources in more detail. Information on these efforts, as well as any preliminary findings, is provided in the Other Sources, Pollutants and Pathways section at the end of this chapter. The analysis characterized exposure and risk associated with 22 compounds (see Table 2). Most of these compounds were screened using one or more of the following criteria: 0 Sufficient evidence of carcinogenicity; 0 Significant release rates; and 0 Readily available emissions information. ------- -34- TABLE 2 D"1. .. <~T i\*r I 00 NOT QUOTE OR CITE 35 COUNTY STUDY: PRELIMINARY APPROXIMATION OF ANNUAL INCIDENCE Pollutants Having Some Evidence of Carcinogenicity * Preliminary Approximation Inci dence** (20% of U.S. Population) of PIC*** Benzene Ch romi urn"!" Formaldehyde Vinyl chloride Trichloroethy1ene Gasoline Vapors Perch!oroethylene Acrylonitri1e Coke oven emissions Ethylene dichloride Arsenic Cadmium Benzo(a)pyrene Ethylene dibromide 148.0 18.5 13.4 10.0 8.2 6.8 6.8 6.7 4.2 2.4 1.5 1.1 1.1 1.1 1.0 ** The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substantial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purposes of this report, a conser- vative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approximations of total incidence. Estimates for individual compounds are much less certain. These incidence estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. *** "Products of Incomplete Combustion" (PIC) refers to a large number compounds, probably consisting primarily of polynuclear organics. of PIC unit risk value was derived from dose-response data which use B(a)P levels as a surrogate for PIC or total air pollution. There are many limitations of using the B(a)P surrogate method to estimate PIC risks: all PIC estimates presented in this report must be regarded as highly uncertain. Refer to pp. 21-26 for a more detailed explanation of how the PIC unit risk value was derived. Risk estimates assume that all species of chromium and nickel are carcinogenic, although only certain species have evidence of carcino- genicity. Current data do not allow differentiation among species. ------- -34a- TABLE 2 (Cont. ) DRAFT DO NOT QUOTE OR CITE 35 COUNTY STUDY: PRELIMINARY APPROXIMATION OF ANNUAL INCIDENCE Pollutants Having Some Evidence of Carcinogenicity* Preliminary Approximation of Inci dence** (20% of U.S. Population) NickelT Carbon tetrachloride Chioroform Styrene B e ry 11 i u m 1,3-Butadi ene Pentachlorophenol Total 0.7 0.2 0.1 0.02 0.01 0.01 < 0.01 231.84 ** *** The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substantial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purposes of this report, a conser- vative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approximations of total incidence. Estimates for individual compounds are much less certain. These incidence estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. "Products of Incomplete Combustion" (PIC) refers to a large number of compounds, probably consisting primarily of polynuclear organics. The PIC unit risk value was derived from dose-response data which use B(a)P levels as a surrogate for PIC or total air pollution. There are many limitations of using the B(a)P surrogate method to estimate PIC risks: all PIC estimates presented in this report must be regarded as highly uncertain. Refer to pp. 21-26 for a more detailed explanation of how the PIC unit risk value was derived. Risk estimates assume that all species of chromium and nickel are carcinogenic, although only certain species have evidence of carcino- genicity- Current data do not allow differentiation among species. ------- DRAFT DO N07 QUOTJE Qfi -35- Emissions estimates were developed using several techniques. Whenever possible, the analysis relied on plant-specific data and EPA documents on emissions from specific source categories. Where this information was unavailable, surrogate loadings were developed • using the information in the National Emissions Data System (NEDS), and apportioning factors that speciate the VOC and PM data into individual toxic constituents. The NEDS data vary a great deal in quality, and some of it is very poor. However, an extensive effort was made to screen the NEDS information for the 35 counties to correct for any obvious inaccuracies in release rates, source locations and stack specifications. For the "non-traditional" sources (POTWs, waste oil combustion, woodsmoke, and gasoline marketing), we developed special algorithms. To calculate volatile releases for eight compounds (ethylene dichloride, vinyl chloride, perchloroethylene, trichloroethylene, benzene, chloroform, carbon tetrachloride and aery 1onitrile) from sewage treatment plants, we modeled thirteen prototype sewage treat- ment plants (POTWs) using information provided by EPA's Industrial Facilities Discharge (IFD) file, the NEEDS Survey, and a study conducted by the effluent guidelines program to determine the fate of priority pollutants in 50 POTWS.15,16 Tne sewage treatment 15 Fate of Priority Pollutants in Publicly Owned Treatment Works, Vol. I. (EPA 440/1-82-303). September 1982. 16 For further explanation on the methodology for estimating POTW volatilization, see: Versar; American Management Systems, Inc. "Hazardous Air Pollutants: An Exposure and Risk Assessment for 35 Counties." Appendix D. September 1984. ------- DRAFT ~36- DO NOT QUOTE OR C/TE plants in each of the 35 counties were assigned to one of the model plants based on the following factors: the percent of inflow to the POTW attributable to industrial dischargers; the types of industries that discharge to the POTW; and the level of treatment at .the POTW. The .modeled sewage treatment plant emissions were treated as point sources in the exposure assessment. Toxic emissions from waste oil combustion were characterized using data from Office of Solid Waste (OSW) documents on: the typical contaminant concentrations found in used oil; the estimated amount of waste oil burned in each State; the destruction efficien- cies for metals and organic compounds burned in industrial and residential, institutional and commercial (RIC) boilers; and the percentage of total waste oil burned in each type of boiler.1? The study of waste oil focused on the following hazardous air pollutants: chromium; nickel; cadmium; beryllium; arsenic; benzene; benzo(a )pyrene; perchloroethylene; and trichloroethylene. Waste oil emissions were modeled as area sources. Air toxics releases from woodsmoke were estimated for two sources--fireplaces and wood stoves.18 Using available information, we developed factors for six compounds (benzo(a )pyrene, formalde- For further explanation on the methodology for estimating toxics emissions from waste oil combustion, see: Versar; American Management Systems, Inc. "Hazardous Air Pollutants: An Exposure and Risk Assessment for 35 Counties." Appendix C. September 1984. For further explanation on the methodology for estimating woodsmoke emissions, see: Versar; American Management Systems, Inc. "Hazardous Air Pollutants: An Exposure and Risk Assessment for 35 Counties." Appendix B. September 1984. ------- -37- DRAFT 00 NOT QUOTf QR CITE hyde. beryllium, nickel, cadmium, and arsenic) that relate pollutant emissions to the quantity of wood burned in each county. Data on wood consumption in each county were obtained from NEDS. The break- down on the amount- of wood burned in wood stoves vs. fireplaces in each area was provided by an industry association. Wood smoke was modeled as an area source. Finally, air toxics emissions from gasoline marketing were calculated using the VOC data in NEDS and apportioning factors developed from varied sources.19 The pollutants considered are: gasoline vapors; benzene; ethylene dibromide; and ethylene dichloride. On the choice of geographic sites, we decided to concentrate on counties, as data are rarely disaggregated below this level, and chose 35 counties to explore in detail. The counties selected fall into one of three categories: 0 Densely populated, highly industrialized; 0 Densely populated, low industrial activity; or • 0 Low population density, highly industrialized. These counties also contain a wide range of industrial bases and geographic locations. Although only about one percent of the counties in the U.S., the 35 counties account for roughly 20% of 19 Op. cit. ------- DRAFT -38~ DO NOT QUOTE OR CITE U.S. population (1980 Census Data), 20% of total national VOC emissions, and 10% of total PM emissions. As with the NESHAPS analysis and other Agency studies on exposure, the 35 County Study employs dispersion modeling to calculate dose and- exposure. EPA's Office of Toxic Substances' fate and transport model, GAMS, was used in this effort. To facilitate running the model more quickly and efficiently, we used an approach that only allowed us to calculate annual aggregate incidence for the 35 counties. Fi ndi ngs Multiplying the results from the exposure modeling by the appropriate unit risk values resulted in the incidence estimates presented in Table 2. The estimated aggregate incidence of cancer for the 22 pollutants and 35 counties is 231 per year. As shown, eight substances account for roughly 95% of the total risk. These pollutants, ranked in descending order, are as follows: PIC (products of incomplete combustion); benzene; chromium; formaldehyde; vinyl chloride; trichloroethylene; gasoline vapors; and perchloroethylene. PIC alone contributes almost 64% to total incidence. Many of the basic problems discussed in the NESHAPS analyses are applicable to the 35 County Study. For example, it was not possible to speciate emission estimates for chromium and nickel in our analyses. Also, the 35 County Study only considers emissions of carbon tetrachloride from a limited number of sources. Background concentrations due to the long half-life of carbon tet were not modeled, although they may significantly contribute to cancer risks. ------- DRAFT 00 NOT QUOTE OR CITE -39- 5. Ambient Air Quality Study Background As part of the overall study, we used ambient air quality data to estimate cancer incidence and individual risks.20 Two basic groupings of compounds were used in this analysis: those for which fairly extensive data were available (five metals and B(a)P); and those for which less extensive data could be found (nine organic compounds). The metals and B(a)P data were drawn from the National Air Data Bank's Storage and Retrieval of Aerometric Data (SAROAD) system, whereas the data for organic compounds came from a variety of sources. For the most part, the data on organics were obtained from studies which used different sampling and analytical methods and a variety of sampling periods. Every attempt was made to gather all available data on air toxics. For example, for organic compounds the data base incorporated air toxics data compiled from a variety of sources by Dr- Hanwant Singh of SRI International, and from more recent monitoring studies 20 Hunt, Bill et al., "Estimated Cancer Incidence Rates from Selected Toxic Air Pollutants Using Ambient Air Data." OAQPS, OAR, EPA. July 1984. ------- DRAFT DO NOT QUOTE OR CUE performed in the cities of Baltimore, Los Angeles, Houston, Philadelphia, and in northern New Jersey. As far as we know, this effort represents the most comprehensive attempt yet to compile nationwide air data for toxic substances and to perform risk assessments based on those data. • It is appealing to use ambient air quality data—as opposed to modeled estimates—to estimate risks because these data represent the actual ambient concentrations to which people are exposed. However, the reader is reminded of three cautions which were presented in the previous section on Estimates of Exposure. First, we must assume that data collected at a limited number of sites can be extrapolated to represent city-wide and county-wide levels, and that these data in turn can be extrapolated to the national level. Second, we must often use data that were collected over a short time period, e.g., 24 hours, and assume that in the aggregate they are representative of concentrations for much longer periods, e.g., annual averages. Third, we assume that people are continuously exposed to outdoor ambient levels. National estimates of cancer incidence were calculated for metals (see Table 3) by estimating county averages based on 1979 to 1982 data for the approximately 170 counties that had data, using these averages to extrapolate to those counties that lacked data, and then applying unit risk values. A national incidence number for PIC was estimated by dividing the country into eleven regions and using urban/rural B(a)P concentrations in combination with urban/rural population figures for each region. ------- DRAFT 00 NOT QUOTE OR CITE -41- Estimating incidence for the volatile organic compounds was somewhat more difficult, given that ambient data on these compounds are scarce and often derived from short-term studies. In order to provide at least minimal seasonal balance when computing annual averages, we established a data completeness criterion^! for organic compounds in urban areas which greatly reduced the amount of data that could be used. Only data from studies performed in Baltimore, Philadelphia, Los Angeles, Houston, and northern New Jersey met the criterion. For these cities, an average level was calculated for each organic compound, and these averages were then combined with population figures to calculate incidence. Next, these estimates were extrapolated to the national level by using urban population data. Non-urban risks were calculated by using non-urban pollutant levels and population data, and these were added to urban risks to obtain national estimates. As Table 3 shows, seven compounds are associated with greater than 50 cancers per year. These seven pollutants are as follows: arsenic, PIC, benzene, carbon tetrachloride, chloroform, chromium, and formaldehyde. The national incidence estimate based on ambient data for the compounds shown in Table 3 is approximately 1870 per year. The estimated incidence per million population for those pollutants is about 8.1 per year. 21 More than 2 sites per county, and at least 10 samples over 2 quarters in a single calender year. ------- -42- TABLE 3 DRAFT DO NOT QUOTE OR CITE AMBIENT AIR QUALITY STUDY: PRELIMINARY APPROXIMATION OF ANNUAL INCIDENCE Pollutants Having Some Evidence of Carci nogeni city* Preiimi nary Approximation of Incidence** Incidence per Million Population** Arseni c Berrzo(a)py rene PIC*** Benzene B e ry 1 1 i u m Cadmi urn Carbon tet rachl oride Chi orof orm 60.0 5.4 820.9 248.6 0.1 14.6 84.7 106.7 0.26 0.023 3.57 1.08 0.0004 0.06 0.37 0.46 ** The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substantial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purpose of this report, a conser- vative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approximations of total incidence. Estimates for individual compounds are much less certain. These incidence estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. *** "Products of Incomplete Combustion" (PIC) refers to a large number of compounds, probably consisting primarily of polynuclear organics. The PIC unit risk value was derived from dose-response data which use B(a)P levels as a surrogate for PIC or total air polluton. There are many limitations of using the B(a)P surrogate method to estimate PIC risks: all PIC estimates presented in this report must be regarded as highly uncertain. Refer to pp. 21-26 for a more detailed explanation of how the PIC unit risk value was derived. ------- -42a- TABLE 3 (Cont.) DRAFT DO NOT QUOTE OR CITE AMBIENT AIR QUALITY STUDY: PRELIMINARY APPROXIMATION OF ANNUAL INCIDENCE Pollutants Havi ng Some Evidence of Carcinogenicity* Prelimi nary Approximation of Inci dence** Incidence per Mi llion Population** Ch romi urn"1" Formal dehyde Methyl chloride Methyl chloroform Methylene chloride Nickel1" Perchloroethyl ene Tri chl oroethylene Vi nyl i dene chl ori de Total 242.0 191.3 0.9 0.1 7.4 15.0 25.4 25.4 20.4 1868.9 1.05 0.83 0.004 0.0004 0.03 0.07 0.11 0.11 0.09 8.12 * The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substantial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purpose of this report, a conser- vative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. ** Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approximations of total incidence. Estimates for individual compounds are much less certain. These incidence estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. *** "Products of Incomplete Combustion" (PIC) refers to a large number of compounds, probably consisting primarily of polynuclear organics. The PIC unit risk value was derived from dose-response data which use B(a)P levels as a surrogate for PIC or total air polluton. There are many limitations of using the B(a)P surrogate method to estimate PIC risks: all PIC estimates presented in this report must be regarded as highly uncertain. Refer to pp. 21-26 for a more detailed explanation of how the PIC unit risk value was derived. t Risk estimates assume that all species of chromium and nickel are car- cinogenic, although only certain species have evidence of carcinogeni- city. Current data do not allow differentiation among species. ------- DRAFT ~43- DO NOT QUOTE Qfi Individual lifetime risks were also estimated for metals, PIC, and organics (Table 4). Individual risks ranged up to 10~3 for some of the trace metals and PIC, whereas individual risks for the organics tended to be in the range of 10-* anc| lower. It should be noted that the sites where these data were collected are generally not located near points of expected maximum concentrations. Therefore, the individual risk estimates for single pollutants based on air quality data tended to be lower than those based on exposure modeling of emissions from point sources. However, in order to provide better understanding of risks in urban areas, individual risks were estimated not only on an individual pollutant basis, but also for many pollutants measured at the same site. The results of this analysis are presented in Table 5 for several urban areas that have attempted a more compre- hensive definition of their problem through air quality monitoring. These multi-pollutant individual risks represent the summed individual risks at each site using monitoring data that were available for 10 to 15 organics, metals, and PIC. Table 5 shows that these multi- pollutant individual risks range around lxlO~3 for all of the areas with sufficient data for analyses. Lifetime individual risks for single pollutants at these sites varied from 10~3 to 10~9j pollutants causing risks in the 10~3 to 10"* range included chromium, PIC, carbon tetrachloride, benzene, and chloroform. To our knowledge, none of the monitoring sites were near major point sources of the relevant compounds, although all sites were centrally located in major urban areas. It is important to note that the uncertainties associated with extrapolating data collected at a few monitoring sites to an entire urban area do not apply to these estimates of multi-pollutant ------- -44- TABLE 4 DRAFT DO NOT QUOTE OR CITE AMBIENT AIR QUALITY STUDY: PRELIMINARY APPROXIMATION OF INDIVIDUAL LIFETIME RISKS Pollutants Having Some Evidence of Carci nogeni city* Preli mi nary Approximation of Maximum Lifetime Individual Risk** Arseni c B(a)P PIC*** Benzene Beryl 1 ium Cadmi urn Carbon tetrachloride Ch loroform 3.99xlO-3 2.47xlO-5 3.75xlO-3 1.54xlO-4 2.40x10-7 1.47x10-3 1.54x10-4 7.70xlO-5 ** The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substantial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purpose of this report, a conser- vative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approximations of maximum lifetime individual risk. Estimates for individual compounds are very uncertain, These risk estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. *** "Products of Incomplete Combustion" (PIC) refers to a large number of compounds, probably consisting primarily of polynuclear organics. The PIC unit risk value was derived from dose-response data which use B(a)P levels as a surrogate for PIC or total air polluton. There are many limitations of using the B(a)P surrogate method to estimate PIC risks: all PIC estimates presented in this report must be regarded as highly uncertain. Refer to pp. 21-26 for a more detailed explanation of how the PIC unit risk value was derived. ------- -44a- TABLE 4 (Cont. ) DRAFT DO NOT QUOTE OR CITE AMBIENT AIR QUALITY STUDY: PRELIMINARY APPROXIMATION OF INDIVIDUAL LIFETIME RISKS Pollutants Having Some Evidence of Carci nogenici ty* Preliminary Approximation of Maximum Li fetime Individual Risk** Chromi urn"1" Fo rma1dehyde Methyl chloride Methyl chloroform Methylene chloride Nickel"!" Perchloroethylene Tri chloroethylene Vi ny1i dene chlori de 1.44x10-3 • 4.91x10-5 4.60x10-7 2.25x10-8 8.28x10-7 2.84x10-5 1.88x10-5 2.59xlO-5 6.72x10-6 * The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substantial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purpose of this report, a conser- vative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. ** Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approximations of maximum lifetime individual risk. Estimates for individual compounds are very uncertain. These risk estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. *** "Products of Incomplete Combustion" (PIC) refers to a large number of compounds, probably consisting primarily of polynuclear organics. The PIC unit risk value was derived from dose-response data which use B(a)P levels as a surrogate for PIC or total air polluton. There are many limitations of using the B(a)P surrogate method to estimate PIC all PIC estimates presented in this report must be regarded as uncertain. Refer to pp the PIC unit risk value . 21-26 for a was derived. more detailed explanation risks: hi ghly of how Risk estimates assume that all species of chromium and nickel are car- cinogenic, although only certain species have evidence of carcinogeni- city. Current data do not allow differentiation among species. ------- -45- DO NOT QUOTE OR CITE TABLE 5 AMBIENT AIR QUALITY STUDY: PRELIMINARY APPROXIMATION OF ADDITIVE LIFETIME RISKS* Urban Area A Monitoring Site 1 2.6xlO~3 Monitoring Site 2 2.6xlQ-3 Urban Area B Monitoring Site 1 0.7xlO~3 Monitoring Site 2 0.7xlQ-3 Urban Area C Monitoring Site 1 l Monitoring Site 2 1 .2xlQ-3 Urban Area D Monitoring Site 1 0.9xlQ-3 Monitoring Site 2 l.OxlO-3 * These estimates are based on a sum of estimated lifetime individual risks for PIC (products of incomplete combustion), 2 to 3 metals and 6 to 10 organic compounds for each monitoring site. Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approximations of individual risk. Estimates for individual compounds are much less certain. These incidence estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. ------- -46- DO NOT QUOTE OR CITE individual risk. All that is involved is summing individual risks from a pollutant mixture at a given urban location. Thus, with the assumption that risks are additive, we can say that, even in neighbor- hoods not located near major point sources, urban dwellers may experience individual risks of 10~3 to 10~4 due to mul ti -pol lutant air exposures. 6. Other Pollutants, Sources and Pathways One of the principal findings of this study of air toxics is that there are important gaps in our knowledge of this problem. This study estimates cancer risks caused by 15-45 substances, when there may be many more potential carcinogens in the ambient air. The International Association for Research on Cancer (IARC), the National Toxicology Program, and EPA's Carcinogen Assessment Group have each identified over 100 compounds as carcinogenic. Many of these compounds are probably not air pollutants, but it is clear that this study does not quantitatively address a large number of pollutants that exist in significant quantities in the ambient air. This study attempted also to address all known or suspected sources of air toxics, as well as known pollutants. Unfortunately, we were unable to quantify the risks caused by several source categories, including several nontraditi onal sources. In addition, each of the individual analyses missed some sources or pollutants. However, some of the sources and pollutants not included in the major analyses have been subjects of quantitative analysis by others. The following section summarizes available information on the pollutants and sources that (1) were not covered by the individual analyses; or (2) could not be quantitatively assessed because of data limitations. ------- -47~ DRAFT DO NOT QUOTE QR CITE POLLUTANTS Dioxin Only isolated estimates are provided for individual risks from emissions of dioxin and these are limited to municipal incinerators. The exposure pattern for dioxin appears to be complex and available data are inconsistent; however, this is true for many compounds that we have included in the study. Dioxin is unique because exposure and risk are being studied in great detail by EPA's Dioxin Task Force. The study team believed that there was little value at this time in attempting an estimate of the aggregate risk from air exposure for a pollutant that is currently being analyzed elsewhere in such detai 1. Asbestos Asbestos is now receiving a great deal of attention as a contaminant of indoor air from past use of asbestos-containing building materials. Asbestos is also commonly found in the ambient air, although at much lower levels than indoors, and selected sources are already covered by federal emission standards under Section 112 of the Clean Air Act. Sampling and analysis for asbestos in the atmosphere presents significant problems and concentrations vary by several orders of magnitude. The available data suggest an average of three nanograms/m3 and 30 fibers per nanogram.22 Coupling this 22 "Guidance for Controlling Friable Asbestos-Containing Materials in Buildings." EPA Office of Pesticides and Toxic Substances, EPA 560/5-83-002, March 1983. ------- DRAFT DO NOT QUOTE OR CITE -48- with an average risk factor for lung cancer and mesothelioma,23 gives a national estimate of over 100 excess cancers per year, or about 0.5 per million population per year. This estimate covers outdoor exposures only. Radionuclides EPA's Office of Radiation Programs (ORP) is currently proceeding to regulate radionuclides as a hazardous pollutant based on the widespread human exposure to these compounds in the ambient air, and the numerous studies that document the incidence of cancer resulting from exposure to ionizing radiation in many species of animals and human populations. ORP has recently summarized their exposure and risk assessment for radionuclides.24 As shown in Table 6, the total national estimated incidence for radionuclides is 17.5 per year; maximum lifetime individual risks range from 4 x 10~2 to 5 x 10~7. The major sources of radionuclides include nuclear power plants, national defense weapons facilities, industrial plants, coal-fired boilers and natural sources. The incidence calculation does not consider exposure to indoor concentrations of radon. 23 Schneiderman, Nisbet, and Brett: "Assessment of Risks Posed by Exposure to Low Levels of Asbestos in the General Environment", Berichte. Bundes-Gesundheits-AMT, pp. 3-1 to 3-28, April 1981. 24 Hardin, J. "Issue Paper. National Air Toxics Problem: Radio- nuclides." EPA, Office of Radiation Programs, August 1984. ------- DRAFT -49- DO NOT QUOTE OR CITE TABLE 6 ESTIMATES OF INCIDENCE AND INDIVIDUAL RISK DUE TO RADIONUCLIDES EMITTED TO AIR* Source An Dept. of Energy Faci lities Nuclear Regulatory Maximum Individual nual Cancer Incidence Lifetime Risk 0.08 0.01 2 x 10-4 2 x 10-5 Commission (NRC) Li censed Facilities Federal Facilities 0.01 5 x 1Q-? Uranium Fuel Cycle 5 1 x 10~4 Faci1ities Uranium Mill Tailings 7 4 x 10~2 Piles Uranium Mines 2.2 N/A Phosphorus Plants 0.05 1 x 10~3 Coal-Fired Boilers 3 4 x 10~5 Sources of Natural Radio- 0.1 2 x 10"3 nucli des to Ai r TOTAL 17.45 * Because of uncertainties in underlying data, the values presented in this table should be regarded as estimates of incidence and maximum lifetime risk. This table was provided by EPA's Office of Radiation Programs. Please refer to footnote 24 for a more detailed explanation of the methodology. ------- DRAFT -50- °° NOT QUOTE OR CITE Recent studies have indicated that indoor air concentrations of various pollutants can greatly exceed ambient conditions. As a result, risk assessments based on ambient levels may be an understatement of the actual situation. In the case of radionuclides, recent estimates place the annual incidence of cancer due to indoor radon exposure at between 1,000 and 20,000. A more detailed discussion of the ramifications of indoor air on the hazardous air pollutant problem is provided in the section of this report on Perspective and Context. Other Pollutants It is apparent that urban ambient air is characterized by the presence of hundreds of organic compounds; fine particulate matter, including metals and organic particulates; and significant concentra- tions of the other criteria pollutants, including sulfur and nitrogen oxides, and carbon monoxide. There are relatively few data available on how all of these substances may interact once they enter the human body. An example of the complexity of urban air is shown in Figure I, a gas chromatogram from lEMD's monitoring program in Baltimore. It represents the concentrations and number of gaseous organics in the ambient air as detected by gas chromatography/mass spectroscopy. Each peak represents a separate organic compound. The peaks corre- sponding to some compounds are labeled. Tentatively identified compounds added up to the following totals: ------- RIC 63/12/84 14:56:68 DATA: CALI: 1518 ttl 1518 #2 SCAMS 1 TO 1400 100.0-1 SAMPLE: SITEft2 P«27 UME466A 36.9L TAGttS482A COHDS.: FSCC 30H DB-5 0 FOR 6 TO 120 GIB RANGE: G 1,1400 LABEL: H 0, 4.0 QUAH: A 8* 1.8 J 0 BASE: U 29, 3 229 O >-i I- U. RIC 565248, n> 1236 o O 400 5:00 7:30 8@0 10:00 1000 12:30 1200 15:00 1460 SCAM 17:30 TIME ------- DRAFT DO NOT QUOTE OR CITE -52- Alkanes 39.1 ug/m3 Aromatics 34.8 ug/m3 Halogenated compounds 9.8 ug/m3 Oxygenated compounds 7.5 ug/m3 Alkenes 3.4 ug/m3 SOURCES Atmospheric Transformation Most population exposure models begin with estimates of emis- sions and they inherently cannot handle toxic compounds that may be formed or rapidly destroyed in the atmosphere. The exposure models used in the NESHAPS and 35 County studies assume that all exposures occur within several hours of emission (within 20 to 50 km of the source) and no corrections are made for transformation of pollutants in the atmosphere. As part of the study, EPA's Office of Research and Development was asked to review the possibility that chemical reactions in the atmosphere could form toxic compounds or increase the potency of emitted pollutants.25 Ozone is the prime example of this phenomenon for criteria pollutants. Although work in this area has not been extensive, the study identified several potentially significant examples of atmospheric transformation. 25 Bufalini, Gay and Dimitriades. "Production of Hazardous Pollutants Through Atmospheric Transformation." ESRL, ORD, USEPA, June 1984. ------- DRAFT -53- DO NOT QUOTE OR CITE Formaldehyde and acrolein are formed readily in a variety of photochemical reactions involving emissions from many types of natural and man-made hydrocarbon emissions. For formaldehyde, an important contributor to total risk in this study, atmospheric formation may produce several times the amount directly emitted from all sources. This may explain some of the major differences between the risks estimates obtained by using exposure models vs. measured data. Experimental evidence is also available that photooxidation of compounds with little evidence of carcinogenicity, such as toluene and propylene, produce substances with significant mutagenicity. The compounds responsible have not been fully identified. In other experiments, phosgene has been produced photochemically from chlorinated hydrocarbons such as solvents. The studies suggest that a hundred times more phosgene may be formed in the atmosphere than is emitted directly. As a final example, studies of the mutagenic activity of polycyclic organic particulates show large increases in activity when the material is subjected to mixtures of ozone and nitrogen oxides. Organic particulates are a ubiquitous group of pollutants generally associated with incomplete combustion (mobile sources, small units burning wood, coal, and oil). They are represented by PIC in this report and may be a major contributor to risks from air toxics in many communities. Gasoline Marketing Gasoline marketing includes a series of emission points ranging from major bulk terminals to filling of individual vehicles at self- service stations. These sources are receiving special attention within EPA because of the significance of their emissions, the potential ------- DRAFT -54- DO NOT QUOfE OR CITE economic impact of control on thousands of service stations, the alternative of onboard controls, litigation on benzene under Section 112, and the importance of gasoline marketing for ozone attainment strategies. EPA's Gasoline Marketing Task Force has developed detailed estimates of the risk from these facilities that cover benzene, i ethylene dibromide, ethylene dichloride, and gasoline vapors. The Task Force estimated an aggregate incidence of 43 excess cancers per year from all gasoline marketing sources, and this estimate was used in portions of this study. Woodstoves As indicated in the Ambient Air Quality and 35 County studies, products of incomplete combustion may be a significant hazardous air pollutant problem. At present, there is great interest n woodstoves based on recent studies that suggest that residential wood combustion contributes about 40% of total national emissions of polycyclic organic matter (POM). POM compounds found in wood smoke include BaP and polycyclic organic ketones. In addition, one EPA study suggests that the emissions rate of mutagenic and carcino- genic substances from woodstoves is at least several orders of magnitude greater than from other combustion sources used to heat homes. Findings from the 35 County Study also support this concern, i.e., roughly 80% of the annual estimated cancer incidence for BaP from heating in the 35 counties is attributable to wood combustion. There are currently no effects data on the human health risks attributable specifically to wood smoke. As a result, the 35 County ------- DRAFT DO NOT QUOTE OR CITE -55- Study assessed the potential human health hazard posed by wood combustion considering the health effects associated with only a few individual compounds (BaP, formaldehyde, nickel, cadmium, beryllium, and arsenic). The estimated annual cancer incidence in the 35 counties resulting from exposure to these compounds is 32, including the use of BaP exposure as a surrogate for PIC. EPA recognizes the need to explore woodstoves in more detail and has established a committee that soon will recommend research and regulatory initiatives to the Agency. These recom- mendations will include: a comprehensive research program on health effects, emission testing procedures, and control techniques; establishment of a variety of technical assistance programs on wood smoke; and consideration of a new source performance standard for woodstoves. The Integrated Cancer Assessment Project (IACP), which is scheduled to begin this fall, also plans to assess the contribu- tion of woodstove emissions to the total organics, POM, and mutagenic activity in the airsheds to be studied. Sewage Treatment Plants Sewage Treatment Plants have become a source of interest for air releases based primarily on work undertaken by EPA's Integrated Environmental Management Division (IEMD) in some of their geographic demonstration projects. Preliminary findings suggest that many POTWs located in urban areas with industrial indirect dischargers may emit volatile organic compounds in excess of 100 kkg/year. Using a POTW algorithm developed for the 35 County Study, we estimated an annual ------- DRAFT DO NOT QUOTE OR CITE -56- cancer incidence in the 35 counties of 2.3 for the nine pollutants that were able to be considered. Given the paucity of data on air releases from sewage treat- ment plants, there is a need to explore this topic in more detail. The IEMD will continue to monitor and model POTWs as part of its activities in future work on geographic sites; EPA's Pretreatment Task Force may also explore potential air emissions from sewage treatment plants. Hazardous Waste Combustion in Boilers Although insufficient data were available to quantify the problem of disposal of hazardous waste in boilers, the Office of Solid Waste (OSW) has attempted to assess the risk resulting from the burning of hazardous waste using a model boiler approach. OSW has also just completed the Survey of Handlers and Burners of Used or Waste Oil and Waste-Derived Fuel Material (Track 2) which should provide useful information for future studies on risk. The OSW model boiler approach considers three boiler sizes and • estimates exposure and risk for three metropolitan areas: New York; Cleveland; and Los Angeles. These cities were chosen because they represent a wide variety of exposure characteristics for densely populated, highly industrialized areas. As information on quantity, distribution and toxic content of the hazardous material burned was limited at the time OSW initiated this analysis, this study tends to depict a worst-case scenario. The study findings suggest that: 0 Risks to the most exposed individuals (MEI) are much greater than to the average exposed individual (AEI). ------- DRAFT DO NOT QUOTE OR CITE -57- Lifetime individual risks for the MEI in these three regions range from 5xlO~6 to 1.4x10-5, depending on the boiler type.26 Risks to the AEI in these three regions ranged from 1.2x10-7 to 6x10"', depending on the boiler type. 0 Estimated annual cancer incidence in these three regions range from .01 to .2, depending on the boiler type. 0 The risk associated with metals is potentially much higher than that for organics. Using metal concentrations found in virgin fuel, the analysis shows that metals contribute roughly 52% to the total estimated incidence. The burning of hazardous material with metal concentrations higher than these could increase the problem. OSW has just received the survey results and although the analysis has just begun, some preliminary findings on the burning of waste-derived fuel material (WDFM)27 are as follows: 0 924 million gallons of WDFM are burned each year; and 0 About 200 million gallons of this material are estimated to be hazardous, as defined by the Resource Conservation and Recovery Act (RCRA); and 0 Chemical manufacturing, pulp and paper, lumber, primary metals, and petroleum refining industries burn about 90% of total WDFM. 26 "Draft Preliminary Risk Assessment for Burning Hazardous Waste in Boilers." Office of Solid Waste, EPA. February 16, 1984, p.2. 27 "Status of the Data Collection Effort for the U.S. EPA: Survey of Handlers and Burners of Used or Waste Oil and Waste- Derived Fuel Material: Track II." December 1983, pp. 3-4. It should be noted that WDFM is a broader category than hazardous waste. For the purposes of the survey, WDFM was defined as "any material that is a constituent of a fuel, or is destined to be burned as a fuel, that is not a conventional fuel material." Examples of conventional fuel are: distillate fuel oil; residual fuel oil; natural gas; coal; liquified petroleum gas; and refuse- derived fuels. ------- -58- DRAFT DO NOT QUOTE OR CITE OSW is initiating analyses to identify boiler operating practices; characterize the specific wastes being burned; and determine the quantity and geographic distribution of these hazardous wastes. This information will be used to complete an exposure and risk assessment that will support the Regulatory Impact Analysis for the regulation of burning hazardous waste and used oil fuels. The tentative schedule for completing this analysis is the end of FY 85. Waste Oil Combustion The Office of Solid Waste (OSW) estimates that 500 to 550 million gallons of used oil are recycled as fuels each year-28 Most of these fuels are burned in boilers, but may also be burned in kilns, space heaters, and diesel engines. Because of contamina- tion during use and because of mixing, used oils typically contain elevated levels of toxic metals, such as arsenic and chromium, and organics, such as BaP and PCBs. Burning used oils may result in elevated ambient concentrations of some of these contaminants, particularly when the combustion sources are clustered.^9 The potential emissions of metals--lead, arsenic, cadmium, and chromium-- appear to be the most significant. The 35 County Study also found these substances to be important. We estimated a total annual 28 U.S.EPA, "Composition and Management of Used Oil Generated in the U.S." December 1983. 29 U.S.EPA, "A Risk Assessment of Waste Oil Burning in Boilers and Space Heaters." Draft, January 1984. ------- DRAFT DO NOT QUOTE OR CITE -59- cancer incidence of 6.7 from waste oil combustion in the 35 counties. Chromium accounted for most of the incidence (90%), followed by arsenic (9.5%) and cadmium (0.5%). OSW is currently developing emission standards for waste oil combustion and will evaluate these risks more closely, for inhalation and other exposure pathways. Hazardous Waste. Faci Titles Over the past several years, there has been an increasing concern that treatment, storage and disposal facilities (TSDFs) may be an important source of air emissions. There have been many efforts to quantify releases of volatile organic compounds from TSDFs. In general, these analyses have either focused on individual facilities, using ambient monitoring to estimate atmospheric pollutant concentrations, or on national estimates, employing emission models to assess air releases. In addition, Westat, Inc. recently completed an extensive survey of TSDFs for the Office of Solid Waste (OSW) that provides a great deal of background information on the quantity, constituency and distribution of hazardous waste generated and managed by TSDFs throughout the country. The recently completed survey estimates that a total of 71.3xl09 gallons (264xl06 metric tons) of waste is managed by hazardous waste facilities and that over 50% of this quantity is treated, stored and/or disposed of in impoundments and landfills. ------- .60- . DO NOT QUOTE OR CITE In addition, the survey indicates that over 70% of the total hazardous waste is generated by the chemicals industry. If we make the assumption that a substantial amount of the chemical industry's waste consists of volatile organic compounds, there is a clear potential for significant volatile releases from TSDFs. Although the survey information yields some interesting findings on the types and quantity of hazardous waste managed at TSDFs, it is nonetheless one step removed from actual emission estimates. There have been several recent attempts to estimate releases from TSDFs at the national level using emission modeling. Unfortunately, these studies have come under severe criticism. It is apparent that estimating volatilization from TSDFs is still in its infancy and these models generally require further refinement and validation. The monitoring data on ambient concentrations around specific TSDFs is probably more persuasive in making the case that TSDFs are potentially significant sources of air toxics. We used air toxics concentration data from a study of one TSDF, the BKK land- fill in California,30 to explore the potential hazard from the volatilization of organic compounds. This was the only data set found that attempted to capture actual ambient concentrations to which individuals living around the TSDF would most likely be exposed. The results are presented in Table 7. It is important 30 "Ambient Air Monitoring and Health Risk Assessment for Suspect Human Carcinogens around the BKK Landfill in West Covina." California Department of Health Services, California Air Resources Board and South Coast Air Quality Management District. 1983. ------- DRAFT DO NOT QUOTE OR CITE -61- TABLE 7 PRELIMINARY ESTIMATES OF INCIDENCE AND INDIVIDUAL RISKS ASSOCIATED WITH AIR RELEASES FROM ONE TREATMENT, STORAGE AND DISPOSAL FACILITY Pollutants Havi ng Some Evidence of Concentration**(ug/m3) Carcinogeni city* Max M i n Preliminary Approximati on of Individual Lifetime Risk*** Max Min Benzene Chloroform Vinyl Chloride Perch loro- ethy lene Trichl oro- ethy lene Et hy 1 ene di chlori de Total Additive 3.8 1.0 12.1 6.8 5.4 6.3 Li fetime Ri sk 0.0 0.0 0.0 0.0 2.1 0.8 2.6x10-5 l.OxlO-6 3.2x10-5 1.2x10-5 2.2x10-5 4.4x10-5 1.4x10-4 0.0 0.0 0.0 0.0 8.6x10- 5.6x10- 1.4x10-5 6 6 * The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substantial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purposes of this report, a conser- vative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. ** Concentration data source: California Department of Health Services, California Air Resources Board and South Coast Air Quality Management District. "Ambient Air Monitoring and Health Risk Assessment for suspect Human Carcinogens around the BKK Landfill in West Covina." 1983. *** Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approximations of lifetime individual risk. These estimates are drawn from measurements made at one TSDF, and should not be considered representative of usual TSDF emissions, but rather illustrative of potential TSDF emissions. ------- DRAFT DO NOT QUOTE OR CITE -62- that these numerical estimates be interpreted as an isolated example, providing only a rough indicator of risk. The numbers exhibited in this table suggest that risks around this landfill are similar to those near major point sources. The lifetime individual risks for the highest observed values range from 10~5 to 10~6; tne maximum additive lifetime individual risk for the six compounds is 1.4 x 10*4. Superfund Sites As with hazardous waste facilities, there is evidence suggesting that uncontrolled or abandoned hazardous waste facilities, i.e., Superfund sites, may be significant sources of air toxic releases. Information provided by the Hazard Ranking System (MRS) [40 CFR Part 300: Appendix AJ, is one indication of this potential. For an abandoned hazardous waste site to be listed as a Superfund site and placed on the National Priorities List (NPL), the site must receive a specified score using the HRS. In the HRS, air releases must be significantly above background concentrations and "observed" in order to receive a score. In contrast, only a "potential" for release to surface or ground water is required in the HRS. The requirement for an observed release for air resulted from a lack of any better method for considering the air route; no good, consistent correlation was found between physical/chemical properities of wastes and their potential for air migration. To date, the HRS has placed 109 sites on the NPL due to high air scores. Of these, 43 were listed for particulate, heavy metal or radium releases. The ------- DRAFT -63- DO NOT QUOTE OR CITE remaining 67 sites are those with volatile organic compounds. These 109 facilities represent a total of 16% of all currently listed NPL sites. Municipal waste disposal: incinerators and landfills Few attempts have been made to assess the risks that may be attributable to air toxics emissions from municipal incinerators and municipal landfills. Our search for risk assessments on municipal waste treatment led to only one study designed specifically for the purposes of assessing risks. In this study, dioxin emissions from several municipal incinerators were measured, and maximum individual risks estimated at levels varying from 10-5 to 10-6.31 The investigators concluded that the levels of dioxin from the six incinerators monitored did not present a public health hazard for the residents living in the immediate vicinity. In another EPA-sponsored analysis, very preliminary estimates were made of emissions of several metals and organic compounds from municipal incinerators. These estimates indicated that maximum individual risks from poorly-run facilities may in certain cases exceed those measured in the dioxin risk assessment described above; well-run facilities appear to pose risks approximately 10 to 100 times less than those of poorly-run facilities.32 These latter estimates could be performed only by using a variety of assumptions, 31 TCDD Emissions from Municipal Waste Combustors. Memorandum from Michael Cook to Regional Dioxin Coordinators. U.S. EPA, Office of Solid Waste and Emergency Response. Dec. 16, 1983. 32 David Sussman, U.S. EPA Office of Solid Waste. Pers. comm. June 1984. ------- DRAFT -64- DO N07 QUOTE OR CITE since no systematic program has been undertaken to monitor stack emissions from municipal incinerators for the purposes of risk analysis. No broad-based studies characterizing risks due to air toxics emissions from municipal landfills were identified. However, there is speculation that emissions may in some cases be high due to decomposing plastics, discarded solvents, and mobilization of volatile organics to the atmosphere by methane gas. Two ad hoc studies performed at municipal landfills on Long Island and in the Los Angeles area provide preliminary confirmation of such speculation. At the Long Island landfill, vinyl chloride was detected in the landfill gases at 90 ppm; at the Los Angeles landfill, landfill gas concentrations of vinyl chloride reached 20 to 30 ppm, and ambient levels near the landfill exceeded those found away from the land- fill. 33»34 in addition, stack emissions of vinyl chloride from a gas collection facility at this same Los Angeles landfill exceeded the vinyl chloride NESHAP emission limit (10 ppm) established for other source categories; Since their initial detection, these emissions have been abated. The Los Angeles air pollution control authorities are currently conducting a monitoring program near selected Los Angeles landfills to evaluate the need for air emissions controls. Drinking Water Treatment Facilities The Office of Drinking Water and the Office of Policy Analysis are conducting a study of air emissions from aeration facilities at drinking water treatment plants. Aeration is used to remove volatile organics from surface water before it is pumped to 33 Marcus Kantz, EPA Region 3. Personal communication. May 1984. 34 Edward Camarena, South Coast Air Quality Management District, Personal Communication. June 1984. ------- DRAFT DO NOT QUOTE OR CITE -65- residential communities for use. A second issue regarding these facilities concerns potential air emissions of chloroform from chlorination of drinking water supplies. In lEMD's monitoring program in Philadelphia, the highest ambient concentrations of chloroform were measured at the monitoring site on the grounds of the drinking water treatment plant. These findings are still preliminary and must be examined in greater detail. Sewage Sludge Incineration EPA's Office of Water Regulations and Standards and the Office of Policy Analysis are examining the issue of air emissions from sewage sludge incineration. The Water Office is specifically interested in whether the New Source Performance Standard (NSPS) for sewage sludge incinerators promulgated under the Clean Air Act is adequate. The NSPS regulates emissions of particulate matter, but does not consider the potential health effects of the toxic constituents of those emissions. PATHWAYS Ingesti on This study considers inhalation effects only. The quantitative risks due to human ingestion of air pollutants are not covered, although several such pathways are possible and anecdotal examples are available. In Tacoma, Washington, researchers discovered that children living near the ASARCO copper smelter have elevated levels of arsenic in their urine; one possible exposure route is via ingestion of contaminated soil. Fish in Lake Superior contain ------- DRAFT DO NOT QUOTE OR CITE -66- toxaphene that was deposited in the lake after being carried by the wind from areas where toxaphene was used as a pesticide. In Maryland, some analyses suggest that as much as 30% of some metals loadings to the Baltimore Harbor may be due to air deposition, either direct deposition or urban runoff. Half of the 1000+ chemicals inventoried in the Great Lakes appear to result at least in part from air deposition. Stratospheric Ozone Depletion and Skin Cancer The analysis did not consider the possible health effects caused by a reduction in the stratospheric ozone layer. Carbon tetrachloride, and other chlorinated organics with long atmospheric lifetimes, have the potential to affect the ozone layer, and could indirectly increase the incidence of skin cancer. For example, it is estimated that by the year 2020 U.S. emissions of carbon tetra- chloride could be responsible for between 500 and 22,000 excess cases of skin cancer annually in the U.S., resulting in 3-220 excess deaths per year- ------- DRAFT DO NOT QUOTE OR CITE C. Summary of the Magnitude of the Air Toxics Problem Estimated risks from air toxics have been presented for each major analytical study: the NESHAP Study, the 35 County Study, and the Ambient Air Quality Study. The results differ among the three studies because of differences in technical approaches, pollutants and sources covered, and emissions estimates, making interpretation and integration of the disparate results difficult. The most useful statistic for summarizing the results of all three studies seems to be annual incidence per million population. Table 8 summarizes this statistic for the 17 pollutants/pollutant groups for which sizeable risks were estimated in any of the three analyses. It should be noted that these national estimates were derived differently in each of the studies: those from ambient air data weighted urban and rural population and concentrations to arrive at a national average; the national aggregate values calculated for the NESHAPS Study and for asbestos, radionuclides, and gasoline marketing were spread over the total national population of 230 million; and the population living in the 35 counties was used to calculate incidence per million for the 35 County Study. The estimated annual incidence per million people for the pollutants included in this report were 7.1 for the NESHAPS analysis, 8.9 for the Ambient Air Quality Study, and 5.5 based on the 35 County Study. These totals are surprisingly close. However, this closeness is somewhat coincidental and disguises large inconsistencies in the pollutant-by-pollutant estimates. For instance, chromium accounts for only 0.29 cases per million in the 35 County study and 1.43 in the Ambient Air Data Analysis. Volatile organic compounds contribute a total of 3.1 per million based on the ambient measurements and only ------- DRAFT -68' DO NOT QUOTE OR CITE 0.8 for the NESHAPS data. A major contributor to these estimates is the pollutant category we have labeled products of incomplete combustion (PIC). It is unique among the pollutants examined and deserves special mention. PIC is used in this study to represent a large number of air pollutants associated with lung cancer in epidemiological studies of people exposed in the 1940's and 1950's. We assumed that * these exposures were dominated by products of incomplete combustion. The unit risk factor was derived by using B(a)P as a surrogate for PIC, and is based on these epidemiological studies. This method of quantifying risk is unusual and the fact that major risks are calculated for PIC makes the calculation controversial. The alternative is to exclude PIC and to ignore the implications of the epidemiological studies and the contribution of these compounds, some of which are proven carcinogens. More detail on the deviation of the unit risk value for PIC is provided on pages 21 to 26. Although incidence per million population is an important statistic, aggregate national totals also provide perspective and allow comparison with other cancer statistics. The annual inci- dence estimates derived from the incidence rate for the major analyses (Table 8) are: NESHAPS - 1,633 (national estimate) Ambient Air - 2,047 (national estimate) 35 County - 231 (for 35 counties only) Individual lifetime risk is another way of expressing risk and was included in most of our studies. Individual lifetime risk estimates describe the risk to a specific individual at a specific location (usually the worst-case site), whereas aggregate incidence applies to an entire population. Partially because of methodology, maximum individual risks almost always occur within 0.1 and 0.3 km from ------- -69- TABLE 8 DRAFT DO NOT QUOTE OR CITE SUMMARY TABLE: PRELIMINARY APPROXIMATION OF ANNUAL INCIDENCE ESTIMATES PER MILLION POPULATION FROM THE NESHAPS STUDY, THE AMBIENT AIR QUALITY STUDY AND THE 35 COUNTY STUDY** Po 1 lutants Ha vi ng Some Evidence of Carcinogeni city* NESHAPS Ambient Ai r Data 35 County Study Six Month Study Risk Estimates Formaldehyde 0.01 Benzene 0.14 Ch romi urn"1" 1.43 Cadmi urn 0.07 Nickel1" 0.35 Arsenic 0.02 Trichloro- ethylene 0.04 Perch 1oro- ethylene 0.01 Ethylene di- chloride 0.19 Ethylene oxide 0.21 Carbon tetra- chloride 0.06 0, 1, 1. 0. 0, 83 08 05 06 07 0.26 0.1 1 0.11 N/A N/A 0.37 0.21 0.39 0.29 0.02 0.02 0.02 0.15 0.14 0.03 N/A 0.004 * The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substantial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purposes of this report, a conser- vative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. ** Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approximations of incidence. Estimates for individual compounds are much less certain. These incidence esti- mates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority- setting and to provide policy guidance. Risk estimates assume that all species of chromium and nickel are carcinogenic, although only certain species have evidence of carcino- genicity. Current data do not allow differentiation among species. ------- -69a- TABLE 8 (Cont.) DM!-! 00 NOT QUOTE OR CITE SUMMARY TABLE: PRELIMINARY APPROXIMATION OF ANNUAL INCIDENCE ESTIMATES PER MILLION POPULATION FROM THE NESHAPS STUDY, THE AMBIENT AIR QUALITY STUDY AND THE 35 COUNTY STUDY** Pol lutants Ha vi n Some E vi dence of Carcinogeni city* Ethylene di- bromi de Chi orof orm Gasoline vapors All other Risk Estimates f Radi onucl i des Asbestos PIC*** Gasol i ne Market TOTAL 9 AMBIENT AIR NESHAPS DATA 0.12 < 0.01 N/A 0.10 rom Other EPA Efforts 0.08 0.50 3.57 ing 0.20 7.1 N/A 0.46 N/A 0.14 0.08 0.50 3.57 0.20 8.9 35 COUNTY STUDY 0.02 0.002 0.15 0.34 0.08 0.50 3.10 5.5 * The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substantial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purposes of this report, a conser- vative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. ** Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approximations of incidence. Estimates for individual compounds are much less certain. These incidence esti- mates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority- setting and to provide policy guidance. *** "Products of Incomplete Combustion" (PIC) refers to a large number of compounds, probably consisting primarily of polynuclear organics. The PIC unit risk value was derived from dose-response data which use B(a)P levels as a surrogate for PIC or total air pollution. There are many limitations of using the B(a)P surrogate method to estimate PIC risks: all PIC estimates presented in this report must be regarded as highly uncertain. Refer to pp. 21-26 for a more detailed explanation of how the PIC unit risk value was derived. ------- DRAFT •7°- DO NOT QUOTE OR CITE the fenceline of major sources. The values are very susceptible to errors in modeling assumptions, population location, and emission estimates, and it is difficult to interpret the results of national studies. In our analysis, maximum risks near point sources frequently reached one in a thousand (10~3) or greater and were routinely greater than 10~4. For example, in the NESHAPS study, 12 pollutants presented a risk of lxlO~3 or greater in at least one location, and 25 pollutants (nearly half of those studied in the NESHAPS analysis) presented risks greater than 1x10"^. The ambient air data were used to calculate an aggregate individual risk for multi-pollutant exposures. Since these aggregate individual risks were based on measured data for a specific sampling site, they were subject to less uncertainty than most of the risk estimates in this report and may be used as an important indicator of the general magnitude of the urban air toxics problem. However, the amount of data available fall short of that needed for a comprehensive analysis of any of the urban areas and the results should not be used for city-to-city comparison. Since reasonably complete monitoring data were needed to estimate these aggregate risks, only a few urban areas with the best data bases could be included. Generally, these were large cities with medium to heavy industrialization. The additive risks ranged from 0.7x10-3 to 2.6x10-3 based on measurements of two to three metals, BaP as an indicator for PIC's, and six to ten volatile organics monitored at the same or very proximate locations (Table 5). These locations generally were in center city and were not associated with specific point sources. It is not possible to estimate the number of people exposed to such multi-pollutant risks. However, it is interesting to compare them to the estimates of annual incidence per million ------- DRAFT -71- DO NOT QUOTE OR CITE reported earlier. A lifetime risk of 2.6x10-3 equates to 2,600 excess cancer cases per million population for a 70-year period, or 37 per million per year; a lifetime risk of 0.7x10-3 equates to about 10 per million per year. These estimates are compatible with the average incidence numbers presented in Table 8. D. Perspective and Context: Other Cancer Risks One way to evaluate the importance of the air toxics risks presented above is to compare them to those linked to other factors. For example, Doll and Peto estimate that about 65% (286,000) of annual cancer deaths appear to be related to smoking (30%) or diet (35%), and that about 2% of total cancer deaths (8800) are associated with environmental pollution.35 The magnitude of the air toxics problem presented in this study is given for PIC in terms of cancer deaths, and as cancer cases for other pollutants. Therefore, they should be compared both to statistics regarding total cancer cases and cancer deaths. Table 9 presents estimates of 1983 cancer mortality and morbidity made by the American Cancer Society-36 This table shows that about 850,000 cancer cases and 440,000 cancer deaths were projected for 1983. The ACS reports also that 135,000 lung cancer cases and 117,000 lung cancer deaths are projected for 1983. If indoor air exposures are considered, this analysis may not accurately estimate the potential number of cancers associated with air toxics exposures. Historically, indoor, non-occupational air quality has been virtually ignored by EPA and other Federal 35 Doll, Richard, and Richard Peto. "The Causes of Cancer: Quantitative Estimates of Avoidable Risks of Cancer in the United States Today." Journal of the National Cancer Institute. June, 1981 36 American Cancer Society, 1982. Cancer facts and figures, 1983. ------- -72- TABLE 9 PERSPECTIVE AND CONTEXT: STATISTICS ON CANCER RISKS* MAFT DO NOT QUOTE OR CITE TOTAL ESTIMATED CANCER CASES (1983)* 850,000 (3700/mi 1 lion) TOTAL ESTIMATED CANCER DEATHS (1983)* 440,000 (1900/million) Diet** Smoki ng** Environmental pollution** 154,000 (670/million) 132,000 (570/mi1 lion) 8,800 (38/million) CANCER CASES ASSOCIATED WITH INDOOR AIR EXPOSURES *** Radon 1,000 to 20,000 Passive smoking 3,000 to 14,000 Formaldehyde (conventional homes) 160 (4 to 91/mil. ) (13 to 61/mil. ) (0.7/million) Other organics (PCE, TCE, benzene) No risk estimates available; however, indoor levels exceed outdoor levels by several times. ** Source: American Cancer Society, 1982. Cancer Facts and Figures, 1983. These estimates are presented for illustrative purposes only, since many consider that such attribution of cancer cases to a particular exposure oversimplifies the multi-causal nature of cancer. The estimates were derived by combining the estimated percent of cancer deaths attributed to diet, smoking, and pollu' tion presented in Doll and Peto (see reference 35) with the American Cancer Society estimates of total 1983 cancer deaths (reference 36). *** Source: see reference 37. ------- DRAFT -73- DO NO! QUOTE OR CITE agencies despite the fact that the average American spends about 80% to 90% of his or her time indoors. Recent data show that indoor radon exposures may cause from 1,000 to 20,000 lung cancer cases annually, and EPA estimates show that 3,000 to 14,000 cancer cases may be caused by passive smoking.37 in addition, indoor levels of formaldehyde routinely exceed outdoor levels by an order of magnitude, while indoor levels of other organics such as benzene, trichloroethylene, and tetrachloroethy1ene may exceed outdoor levels by 2 to 5 times for the median-exposed individual and up to 50 times for the most-exposed individual.38 Combined with the large amount of time that Americans spend indoors, these data indicate that our estimates of the magnitude of the air toxics probl em--based only on outdoor ambient levels—may underestimate the extent of the toxics inhalation problem as far as certain organic compounds are concerned, since these compounds can be be emitted indoors. It is also possible that our analysis has somewhat overstated risks due to the metals examined in the study- No indoor/outdoor data could be found for the specific metals examined in this study; however, there are limited data indicating that other trace metals (e.g., vanadium, manganese) show indoor/outdoor ratios somewhat less than 1.0.37 37 Thomson, Vivian. "Indoor Air Pollution: Ramifications for Assessing the Magnitude and Nature of the Air Toxics Problem in the United States." U.S. EPA, Office of Policy Analysis. July 1984. 38 Wallace, Lance et a 1. "Total Exposure Assessment Methodology (TEAM) Study: FT rst Season - Northern New Jersey." Interim Report. U.S. EPA, Office of Research and Development. ------- DRAFT .74. D0 NOT QUOTE OR CITE Few data are available characterizing the cancer risks due to ambient environmental exposures other than air pollution. As part of this study, EPA's Chemical Coordination Staff (CCS) attempted to compare regulatory risk levels across several of EPA's program offices. CCS concluded that such comparisons are difficult to make, since EPA has in fact made few regulatory decisions for car- cinogens based on quantitative risk assessment. However, a few examples of risk-assessment based decisions were found. For instance, the EPA recently banned most uses of the pesticide ethylene dibromide after estimating that EDB exposures might cause as many as 13,000 cancer cases per year. EPA has also banned most uses of chlordane/ heptachlor, based on estimates of 500 cancer cases caused annually, and the asbestos school inspection program was started after risks were estimated at approximately 60 cancer cases annually.39 As previously discussed, the maximum individual risks estimated in this study ranged widely, from 1Q-1 to less than 10~6. Risks of 10~3 ancj greater were commonly estimated for major point sources, and the combined lifetime individual risks based on ambient data were • in the 10"3 range. CCS's analysis shows that, on average, EPA has taken regulatory action based on maximum individual risks in the 10~3 t0 iQ-4 range, although there may be differences among program offi ces: Although the data is somewhat limited, OAR (the Office of Air and Radiation) generally appears to use a marginally higher level of individual risk (both before and after regulation) than other offices. However, when viewed from an aggregate risk perspective, risks to the total population are not much different from those of other offices." 39 Viviani, Donn et a!. " Acceptable Risk Levels and Federal Regula- tions: A CompaTTson of National Emission Standards for Hazardous Air Pollutants (NESHAP) with Other Federal Standards Based on Quantitative Risk Assessment." U.S.EPA, OPTS. May 1984. ------- -75- DO NOT QUOTE OR CITE IV. NATURE OF THE AIR TOXICS PROBLEM Whereas previous sections of this report focused on the magnitude of the national air toxics problem, the following section will discuss the causes of air toxics exposures and risks. Four questions will be addressed, using the results of the studies and analyses previously discussed: - Pol lutants What pollutants appear to cause most of the air toxics problem as we understand it now? - Sources What sources appear to be major contributors to air toxics risks? ic variability Do air toxics problems vary geographically? - Indirect control Can we estimate the degree to which indirect control of air toxics is effected through the criteria pollutant programs? A. Pollutants Table 8 summarizes the annual incidence per million population estimated by the NESHAP Study, the Ambient Air Quality Data analysis, and the 35-County Study for the pollutants/pollutant groups showing the highest risks. Table 8 shows that approximately 17 pollutants/ pollutant groups account for most of the risks: PIC, chromium, nickel, benzene, arsenic, cadmium, carbon tetrachl ori de, chloroform, ethylene dibromide, ethylene dichloride, ethylene oxide, formaldehyde, gasoline vapors, perch loroethyl ene, tri chl oroethyl ene, asbestos, and ------- DRAFT -76- DO NOT QUOTE OR CITE radionuclides. Thus, it appears that the pollutants responsible for most of the cancer cases associated with air toxics consist of a mixture of metals, volatile organic compounds, and products of incomplete combustion. Many of these same pollutants (for example, chromium, benzene, and arsenic) also show maximum individual risks in the 10-1 to 10-3 range. An interesting feature of the analysis is the relatively low aggregate risk estimated for many of the synthetic organic chemicals: national incidence totalled less than 1.0 cancer cases per year for 21 such compounds. This fact is noteworthy since it has been speculated that such "exotic" chemicals may be major sources of air toxics risks. The reader should bear in mind, however, that the low incidence estimates are based on exposure modeling, and have not been verified by ambient data. In addition, maximum individual risks associated with some of these chemicals ranged up to 10~3. B. Sources An examination of emissions associated with the pollutants listed above shows, not surprisingly, a diverse and complex group of sources. Table 10 gives a source breakdown for several of the more important pollutants examined in the study. For example, chromium is emitted from major point sources such as steel and refractory manufacturing, as well as from fuel combustion. Formaldehyde is emitted from mobile sources, chemical plants, fuel combustion, indoor sources (such as particleboard), and is formed photochemically in the atmosphere. Carbon tetrachloride is set apart from the rest of the major risk pollutants in that it has an unusually long half-life estimated to exceed 35 years. Thus, although the short-term risks from direct emissions of carbon tetrach1oride may be low (as indicated by the ------- -77- TABLE 10 DRAFT DO NOT QUOTE OR CITE SOURCES OF SELECTED COMPOUNDS EXAMINED IN THIS STUDY Pollutant Sources Arsenic Benzene Ch1oroform Ch romi urn Ethylene Oxide Formaldehyde Nickel Perchloroethylene PIC Combustion sources such as waste oil burning, utility boilers (coal-fired), wood smoke, smelters, glass manufacturing Road vehicles, gasoline marketing, petroleum refining Solvent usage, water treatment Waste oil burning, steel manufacturing, refractory manufacturing, metals manufacturing, combustion sources Chemical industry, sterilant Road vehicles, formaldehyde manufacturing, petroleum refining, oil and gas combustion Combustion sources Solvent usage, dry cleaning facilities BaP sources include use of wood and coal in small combustion units, coke operations, internal combustion engines Trichloroethy lene Solvent usage ------- 78 DO NOT QUOTE OR ClfE NESHAP and 35-County Study), ambient levels will continue to increase: half of 1984 emissions will still be in the atmosphere in 2019. The complexity and diversity of air toxics sources are under- scored by the following observations concerning emissions of the most significant pollutants listed in Table 8.40 - SOCMI sources are responsible for greater than 20% of total emissions for only 3 of the major pollutants. - Mobile sources account for greater than 20% of emissions for only 3 of the major pollutants. - Solvent usage is responsible for greater than 20% of emissions for only 3 major pollutants. - Fuel combustion in stationary sources accounts for greater than 20% of emissions for only 4 of the major pollutants. Another orientation to which source types appear to be important contributors to the air toxics problem can be had by using the individual risk or incidence estimates from the NESHAP and the 35 County Studies. For pollutants that were evaluated directly, area and point sources each accounted for about half of the aggregate incidence (45 percent for area sources, 55 percent for point sources for the NESHAP study; 53 percent area, 47 percent point in the 35 County Study). When PIC is included (using BaP as a surrogate) area sources become more dominant, accounting for 85 percent of the incidence in the 35 County Study and 75 percent of total incidence estimated based on the NEHSAP study. This result is consistent with the fact that PIC is estimated to account for a large portion of aggregate Lahre, Tom. "Characterization of Available Nationwide Air Toxics Emissions Data." June 13, 1984. ------- DRAFT -79- D0 NOT QUOTE OR CITE incidence and that nearly all BaP emissions appear to come from area sources (principally motor vehicles, and combustion of wood, coal and oil in small heating units). The contribution of the most significant source types based on cancer incidence as determined by the 35 County Study are shown in Table 11. The second measure of risk used in this study is maximum individual risk. The NESHAP study indicates that the highest individual risk is generally associated with large point sources. C. Geographic Variability A final method of characterizing the nature of the air toxics problem is to examine geographic variability in ambient air quality and in air toxics risks. Mean ambient concentrations for selected metals and organic compounds are shown for several cities in Table 12. These data may be for different years and are not for matched sites; therefore, detailed comparison is not warranted. However, they do indicate that ambient levels of air toxics can vary widely from city to city, with ratios commonly ranging from 5/1 to 10/1. The 35 County Study also allowed us to examine the ways in which risks vary from one county to the next. The results are shown in Table 13 (PIC was excluded from this data set because the uncertainty in the emission estimates for BaP make detailed city-specific compari- sons especially unreliable). For example, the percent of risk from point sources varies from 52 percent in in County 4 to 25 percent in County 2. Similarly, petroleum refining accounts for 22% of total risk in County 2, but Q% in Counties 3 and 4. There are, however, source categories (road vehicles and waste oil burning) that account for approximately the same percent of risks across counties, primarily ------- -80- TABLE 11 DRAFT DO NOT QUOTE OR CITE PERCENT OF INCIDENCE ASSOCIATED WITH POINT AND AREA SOURCES BASED ON THE 35 COUNTY STUDY* Point Sources Chemicals Production Metals Manufacturing Petroleum Ref i ni ng Rubber Production Utilities POTWs All Other % Total Inci dence (w/o PIC) 1 1 8 5 5 4 3 11 % Total Inci dence (w/PIC) 4 3 2 2 1 1 4 TOTAL POINT 47 15 Area Sources Road Vehicles Solvent Usage Gasol i ne Marketi ng Waste Oi 1 Burni ng Heati ng Wood smoke (stoves/fireplaces) All other TOTAL AREA 23 1 1 9 9 0.5 1.5 53 60 4 3 3 12 3 85 * Because of the uncertainties in the incidence estimates used to derive these estimates, they should be regarded as rough indicators only. These computations have been performed to provide a rough idea of the nature of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. ------- DRAFT -81- D0 N°r QUOTE OR CITE TABLE 12 COMPARISON OF MEASURED AIR QUALITY FOR SELECTED CITIES AND POLLUTANTS; ngm/m3 City Pollutant ABC Arsenic* 7.4 3.7 3.2 Benzo(a)pyrene 1.7 0.5 0.2 Chromium* 93.5 9.3 25.3 Nickel* 18.6 3.0 24.8 Benzene** 11.0 Carbon tetra- chloride** 4.2 Chloroform** 9.9 Methyl chloro- form** 17.1 Trichloro- ethylene** 1.4 D E F G 33.5 7.0 6.0 0.3 0.2 0.4 13.4 17.0 60.0 8.6 18.0 23.0 14.8 15.7 9.5 0.3 2.4 2.6 0.4 1.5 7.9 6.3 2.2 25.1 2.0 0.4 2.8 * Concentrations expressed in nanograms/m3. ** Concentrations expressed in micrograms/m3. ------- TABLE 13 COMPARISON OF SOURCES OF RISK IN SEVERAL COUNTIES SELECTED FROM 35 COUNTY STUDY * ** All 35 County 1 County 2 County 3 County 4 County 5 Counties Combined Percent of risk from area sources, point sources, and POTW's Area Point POTW's 61 38 1 66 25 9 Percent of risk from given source categpries 48 50 2 41 52 7 67 32 1 51 46 3 Road vehicles 31 Petroleum refining 13 Chemical production 5 Solvent usage 8 Waste oil burning 8 26 1 3 18 11 23 22 21 5 9 14 0 24 10 12 31 0 2 17 10 23 5 10 10 8 00 Percent of risk from given pollutants Formaldehyde Chromium Benzene Vinyl chloride Perchloroethylene 18 9 30 2 10 7 14 24 0 10 29 8 24 2 3 5 10 20 25 6 30 12 25 0 11 12 17 23 11 8 * For pollutants evaluated directly; excludes PIC. ** Because of the uncertainties in the incidence estimates used to derive these estimates, they should be regarded as rough indicators only. These computations have been performed to provide a rough idea of the nature of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. o o o ------- DRAFT -83- DO NOT QUOTE OR CITE because these risks are strongly linked to population. Thus, two main types of sources appear to emerge from the analysis: sources accounting for approximately equal portions of risk from one area to the next, and those sources peculiar to a particular area. While the data bases used in these analyses are at present inadequate'to accurately define most areas' air toxics problems, the data do support the intuitive prediction that reducing air toxics risks will necessitate dealing with certain types of problems at the local level. If we consider air toxics emissions data, we also find regional variation. For example, of the 86 compounds covered in the emissions study^l, a large concentration of organic substances were found to be produced in an area stretching from Corpus Christi, Texas to New Orleans, Louisiana. Eighteen organic compounds are produced entirely in Texas and Louisiana and almost 50% of the remaining 88 organic compounds examined in the emissions study are manufactured in those two states. As noted earlier in the report, emissions of many of the synthetic organics are associated with only very low annual i nci dence. D. Indirect Control of Air Toxics Toxic compounds are emitted into the atmosphere from many sources that are regulated for criteria pollutants. Metals and * polynuclear compounds usually are emitted as particulate matter and most of the volatile organic compounds are ozone precursors. As such, they are regulated under SIP's, NSPS, and Title II on motor Lahre, Tom. Op. cit. ------- DRAFT -84- DO HOT QUOTE OR CITE vehicles. Also, reduction in emissions for some of the compounds-- especially solvents--are accomplished for economic reasons to recover lost product or energy. We attempted to evaluate available analyses on the effects of such indirect control of toxic air compounds.42 TWO studies were found. One focused on nine potential air toxics, including benzene, chloroform, and chromium, and evaluated the impact of existing regulations on major point sources. Control of metals from point sources was generally high, ranging from 80 to 98%. Much more variation and less control was apparent for organics, with the percentage control ranging from 30 to 90%. A second study was less quantitative but provided estimates for 37 compounds and included area sources and motor vehicles. Air quality trends, rather than control regulations, were evaluated to estimate the indirect control of toxic particulates. Generally, reductions of 30 to 70% have been observed since the 1950's. In addition, SIP's and NSPS are credited with reducing emissions of 15 chemicals from the chemical industry by 10 to 80% and 8 solvents by 30% nationwide. Motor vehicle controls remove up to 90% of several potentially toxic compounds from exhaust gases. It is apparent, even from these cursory analyses, that indirect control can be very significant for toxic compounds. At this time, it appears that control under criteria pollutant provisions of the Clean Air Act far exceeds the impact of Section 112 regulations. Since sources are already controlled by criteria pollutant programs, the remaining risks will probably be more difficult to control. 42 Lahre, Tom. Op. cit. ------- -85- DO NOT QUOTE OR CITE V. ADEQUACY OF DATA BASES There are two principal informational problems in the quantitative assessment of air toxics risks. The first involves basic health factors such as evidence of carcinogenicity, potency, the presence or absence of thresholds, and synergism. These are well-known knowledge gaps basic to cancer, and strategic discussions on air toxics will not influence their resolution. No attempt was made in this study to use new assumptions or procedures; we relied on techniques and methods in use across EPA. In the short term, the more relevant problem to understanding the air toxics issue is the lack of data on emissions and air quality that makes difficult solid problem definition for many situations and impedes policy discussions on risk assessment. The problem is widely recognized and universally frustrating. In the poll of State/local agencies, ten were interviewed in depth on their air toxics problems. All perceived a need for better emissions data. The contractor who conducted the interviews concluded that • "The agencies do not seem to have adequate data that would enable them to perform risk assessments for the toxic pollutants emitted."43 With the exception of radonuclides, the study consistently found major weaknesses in the data base for air toxics, both in the 43 Radian Corp. "Definition of the Air Toxics Problem at the State/Local Level." EPA Contract No. 68-02-3513; Work Assignment 45, June 1984. ------- DRAFT -86- DO NOT QUOTE OR CITE coverage and in the quality of information available. If more than one source of data existed, inconsistencies were the norm. Most of the air quality data could not be used for population exposure and were clearly not obtained for risk assessment purposes. Many potentially large source categories could not even be included in the study due to a lack of data. These sources included incineration, hazardous waste disposal, atmospheric formation, and Superfund sites. Today, air quality data are generally collected to determine trends for criteria pollutants; very few data are available for developing population exposure estimates for toxics. Despite significant efforts to assemble monitoring data for all sources, this analysis could only cover about eighteen pollutants. ! 0 More air quality data were found for metals than for B(a)P or volatile organics. However, while 170 counties with a total population of about 60 million had monitoring data, only 30 counties had data for more than one site and essentially no measurements were optimal for exposure assessment. 0 Data for BaP were found for about 50 counties. However, most of the measurements were taken 3-5 years ago and only one county had data for more than one site. ° For volatile organic compounds, OAQPS evaluated over 250 references with thousands of entries for over 40 pollutants. However, even with the most relaxed criteria for data completeness, only five cities had data that allowed estimates of annual averages for more than one site, and two of those five had data only because of the monitoring programs conducted as part of lEMD's multimedia studies in Baltimore and Philadelphia. EPA does not routinely measure ambient levels of potentially toxic VOCs, and only a few states, e.g., California, routinely gather such data. Of the available reports examined for this analysis, most involve spot measurements for 24 hours or less as part of a narrow study. Only 45 areas in the nation had one valid calendar quarter worth of data for any toxic VOCs (total of five days of data in the quarter) and only 12 areas had two valid quarters of five days each. ------- DRAFT -87- DO NOT QUOTE OR CITE Emission inventories for toxic compounds also have major problems. About 250 references were evaluated in this Study. Based on this analysis, the most significant concerns were:^4 0 inconsistent coverage of sources; 0 highly variable emission estimates; 0 poorly defined source categories; 0 obvious anomalies and gaps; 0 form of metals not shown (speciation ); 0 poor coverage of dispersive end uses, e.g., solvents; and 0 changing data base with time. In an effort to quantify the quality of the information available, emissions data for each of the 93 pollutants reported were given a "Confidence Score" by the reviewers. This is commonly used in evaluating emission inventories and is a subjective rating of the adequacy of the data for a specific pollutant. The results are summarized below. 0 5 pollutants scored "A" (consistent among information sources; recent detailed study); 0 22 scored "B" (reasonable agreement among several information sources); 0 59 scored "C" (sketchy data or significant variability in the estimates); 0 7 scored "D" (virtually no information found). The detailed report on emissions also discusses some examples of inconsistencies found in the data. For example, five references Lahre, T. "Characterization of Available Nationwide Air Toxics Emissions Data." EPA Contract No. 68-02-3513, Task No. 46, June 1984. ------- DRAFT -88- DO NOT QUOTE OR CITE were found for chloroform with emissions ranging from 3999 kkg/year to 11,800 kkg/year (kkg = 1,000 kilograms). For chloroform, the subcategory of solvent use accounted for percentages of total emissions ranging from 6.2% to 92% in the various studies and production emissions varied from 1.7% to 11.7%. Water chlorination • was mentioned as a source of chloroform emissions in only one study. Not only are emissions data scarce and often inconsistent, but systems and institutions are not in place to collect, store, or retrieve data that may become available. There is an almost complete lack of standardization, definition, and data systems. If data are collected, they are collected for a single, short-term purpose. For monitoring programs, there are no standard methods or guidance available on network design, siting of monitors, and averaging times. The Aerometric Information Retrieval System (AIRS) is being developed by EPA, but until it becomes available in 1987, there is no central repository for air toxics monitoring data. A comparison with criteria pollutants helps explain why the data base for toxics is relatively inadequate. There are eight pollutants tracked or regulated under SIPs, while toxic compounds of interest number from 50-100. About $30 million per year of EPA grants to state and local agencies are used for data gathering on criteria pollutants, while only about $1 million is used for air toxics. In addition, ambient concentrations of toxics are almost always 100 times less than criteria pollutants. Metals, such as chromium and cadmium, are rarely seen at 0.01 ug/m3, whereas TSP is measured in tens of ug/m3. The TSP primary annual ambient standard is set at 75 ug/m3. Regulation of criteria pollutants is ------- DRAFT ~89~ DO NOT QUOTE OR CITE based simply on attainment of a uniform ambient level everywhere- However, toxics regulation often is driven by risk analysis which requires population exposure estimates and, therefore, a more comprehensive data base. Institutional support has been developed for criteria pollutants over a period of two decades. This infra- structure includes data systems (SAROAD, NEDS), regulations requiring monitoring networks, and comprehensive emission inventories (SIPs), standard methods of sampling and analysis, and formal quality assurance programs. None of these are yet available for air toxics. ------- °0 NOT QUOTE OR CITE VI. CONCLUSIONS Given that this analysis was a scoping effort undertaken for purposes of orientation and not to directly support regulation, and considering the omissions and uncertainties discussed in this report, the Study Team believes that the following conclusions can be drawn from this study: (1) The four analyses that attempted to quantify risks due to 15 to 45 toxic air pollutants resulted in estimates of annual cancer incidence that ranged from 6 to 9 cases per million people annually. Those same analyses resulted in estimates of total national cancer incidence due to 15 to 45 toxic air pollutants that ranged from 1,600 to 2,000 per year. (2) Maximum lifetime individual risks of 10"^ or greater in the vicinity of point sources were estimated for 25 pollutants. Maximum lifetime individual risks of 10-3 or greater were estimated for 12 pollutants. (3) Additive lifetime individual risks in urban areas due to simultaneous exposure to 10 to 15 pollutants ranged from 10-3 to 10-4. These risks, which were calculated from monitoring data, did not appear to be related to specific point sources, but rather represented a portion of the total risks associated with the complex mixtures typical of urban ambient air. • (4) While there is considerable uncertainty associated with the estimates for some substances, the study as a whole indicated that the following pollutants are important contributors to aggregate incidence from air toxics: metals, especially chromium, arsenic, cadmium, and nickel; asbestos products of incomplete combustion; formaldehyde; benzene; ethylene oxide; gasoline vapors; and chlorinated organic compounds, especially chloroform, carbon tetra- chloride, perchloroethylene, and trichloroethylene. (5) Both point and area sources appear to contribute signifi- cantly to the air toxics problem. Large point sources are associated with many high individual risks; area sources appear to be responsible for the majority of aggregate incidence. ------- DRAFT -91- °° NOT QUOTE OR CITE (6) A wide variety of source types contribute to individual risk and aggregate incidence from air toxics. These include: mobile sources; combustion of wood, coal and oil; solvent usage; metallurgical industries; chemical production and manufacturing; gasoline marketing; and waste oil disposal. (7) Some low-production organic chemicals appear to contribute little to aggregate risk. For example, 21 synthetic organic chemicals were estimated to account in total for less than 1.0 excess cancer cases per year nationwide. However, some organic chemical plants involved with these compounds appear to cause high individual risks for those living nearby. For example, the maximum lifetime individual risk for 4,4-methylene dianiline was estimated at 1.5xlO~3. (8) While the study indicated that non-traditional sources such as Publicly Owned Treatment Works (POTW's) and Treatment, Storage and Disposal Facilities (TSDF's) may not be dominant contributors to nationwide air toxics incidence, it appears that such sources may pose risks in some locations. For example, a municipal sewage treatment plant in a major metropolitan area was estimated to account for 18 percent of the area's total aggregate incidence, and individual lifetime risks for a single compound at one TSDF were estimated as high as 10~5. (9) Criteria pollutant control programs appear to have done more to reduce air toxics risks than have programs for specific toxic compounds. This seems reasonable, considering the sources of air toxics, the multi-pollutant nature of the problem and the relative intensity of these programs . (10) For those cities with sufficient data for analysis, there appear to be significant differences across cities and neighborhoods in risk levels, and the pollutants and sources that cause risk. However, our current data base is inadequate to accurately characterize most local air toxics problems. (11) Even after many regulations under Section 112 of the Clean Air Act are in place, it appears that arsenic and benzene will still be significant contributors to aggregate risk. This seems to demonstrate that to be fully effective an air toxics program needs to broaden its base, including emissions from small area sources, such as combustion, road vehicles, and solvent usage. ------- 92 DRAFT DO NOT QUOTE OR CITE Factors which may have caused the risk estimates discussed above to understate total air toxics risks are as follows: (1) Risk estimates for many substances which have been found in the ambient air could not be calculated, due to data limitations. Urban ambient air is characterized by the presence of dozens, perhaps hundreds, of separate substances. These include many organic compounds; fine particulate matter, including metals and polycylic aromatic hydrocarbons; and criteria pollutants. (2) Indoor concentrations of certain pollutants (e.g., radon, tobacco smoke, formaldeyde, and other volatile organic compounds) are commonly several times higher than outdoor concentrations. While risk assessment could not be performed for all these pollutants, the estimated cancer incidence associated with passive smoking (3,000 to 14,000 annually) and radon (1,000 to 20,000 annually) clearly show that indoor sources are a major contributor to air toxics risks. (3) Risks due to compounds formed by chemical reactions in the atmosphere could not be quantified in the exposure models, but there are indications that those risks may be significant. For example, formaldehyde is formed in the atmosphere by the breakdown of other organic compounds, and some compounds (e.g., toluene) may be converted into toxic substances through photochemical reactions. Factors which may have caused the risk estimates discussed above to be overstated are as follows: (1) EPA potency estimates generally are regarded as plausible, upper-bound estimates. That is, the unit risks are not likely to be higher, but could be considerably lower. (2) The degree to which outdoor-source related emissions of many pollutants (e.g., trace metals) penetrate inside is largely unknown. Should emissions from outdoor sources not penetrate completely indoors, then we will have over-stated risks, since we have assumed constant exposures to levels equalling those of outdoor air. ------- DRAFT DO NOT QUOTE OR CUT ATTACHMENT A SUMMARY TABLE POLLUTANTS EXAMINED, UPPER-BOUND RISK VALUES, PRELIMINARY APPROXIMATIONS OF INCIDENCE AND MAXIMUM LIFETIME RISK ------- POLLUTANTS EXAMINED, UPPER-BOUND RISK VALUES, PRELIMINARY APPROXIMATIONS OF INCIDENCE AND MAXIMUM LIFETIME RISK Pollutants Having Some Evidence of Carcinogenicity* Ac ryl amide Acrylonitrile Allyl Chloride Arsenic Asbestos Benzene Benzo-a-Pyrene Benzyl Chloride Beryllium 1,3 Butadiene Cadmium I/ Unit Risk Value 1.7x10-5 6.8x10-5 5.5x10-8 4.3x10-3 I/ 6.9x10-6 3.3x10-3 1.2x10-5 4.0xlO-4 4.6x10-7 2.3x10-3 Source CLEM CAG CAG CAG CLEM CAG CAG CLEM CAG CLEM CAG Preliminary Approximation of Annual Incidence** NESHAPS 0.01 0.42 <0.01 4.7 32.3 <0.01 1.2 0.01 16.3 35 2/ County 4.2 1.1 18.5 1.1 0.01 0.01 1.1 Air Quality 60 248.6 5.4 0.1 14.6 Other Preliminary Approxima- tion of Incidence Per 106 Population** 35 County 0.02 0.5 0.39 0.02 <0.001 <0.001 0.02 Air Quality 0.26 0.5 1.08 0.02 <0.001 0.06 NESHAPS <0.01 .002 <0.01 .02 0.5 0.14 <0.01 0.01 <0.01 .07 Preliminary Approx- imation of Maximum Lifetime Individual Risk** (xlQ4) NESHAPS 0.74 38 0.01 65 80 0.3 1.0 0.1 7.5 Air Quality 40 1.5 0.25 0.002 14.7 o o o X o * The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substan- tial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purposes of this report, a conservative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. ** Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approxima- tions of total incidence and maximum lifetime individual risk. Estimates for individual compounds are very uncertain. These incidence and maximum risk estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. ------- -2- POLLUTANTS EXAMINED, UPPER-BOUND RISK VALUES, PRELIMINARY APPROXIMATIONS OF INCIDENCE AND MAXIMUM LIFETIME RISK Pollutants Having Some Evidence of Carcinogenicity* Carbon Tetrachloride Chloroform Chromium''" Coke Oven Emissions Diethanolamine Dimethyl nitrosami ne Dioctyl Phthalate Epichlorohydrin Ethyl Acrylate Unit Risk" Value 1.5x10-5 1.0x10-5 1.2x10-2 6.2x10-4 1.1x10-7 5.4x10-3 1.3x10-7 2.2x10-7 5.0x10-7 Source CAG CAG CAG CAG CLEM CAG CLEM CAG CLEM Preliminary Approximation of Annual Incidence** NESHAPS 14 0.27 330.0 • 8.6 <0.01 0.05 <0.01 <0.01 <0.01 35 2/ County 0.2 0.1 13.4 2.4 Air Quality 84.7 106.7 242 Other Preliminary Approxima- tion of Incidence Per 106 Population** 3S County 0.004 0.003 0.29 0.05 Air Quality 0.37 0.46 1.05 NESHAPS .06 <0.01 .11 .04 <0.01 <0.01 <0.01 <0.01 <0.01 Preliminary Approx- imation of Maximum Lifetime Individual Risk** (xlO^) NESHAPS 5.8 30 1600 200 <0.01 0.54 0.1 0.02 0.47 Air Quality 1.54 0.77 14.4 o o o zo O * The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substan- tial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purposes of this report, a conservative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. ** Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approxima- tions of total incidence and maximum lifetime individual risk. Estimates for individual compounds are very uncertain. These incidence and maximum risk estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. t Risk estimates assume that all species of chromium and nickel are carcinogenic, although only certain species have evidence of carcinogenicity. Current data do not allow differentiation among species. ------- —3— POLLUTANTS EXAMINED, UPPER-BOUND RISK VALUES, PRELIMINARY APPROXIMATIONS OF INCIDENCE AND MAXIMUM LIFETIME RISK Pollutants Having Some Evidence of Carcinogenicity* Ethylene Ethylene Di bromide Ethylene Di chloride Ethylene Oxide Formaldehyde Gasoline Vapors Gasoline Marketing 4,4 150 Propylidene Di phenol Mel ami ne Methyl Chloride I/ Unit Risk Value 2.7x10-6 5.1x10-4 7.0x10-6 3.6x10-4 6.1x10-6 7.5x10-7 7.5x10-7 1.4x10-6 4.1x10-7 1.4x10-7 Source CLEM CAG CAG CAG CAG CAG CAG CLEM CLEM CLEM Preliminary Approximation of Annual Incidence** NESHAPS <0.01 26.7 44 47.8 1.6 0.03 <0.01 <0.01 35 Z/ County 1.0 1.5 10.0 6.8 Air Quality 191.3 0.9 Other 43 Preliminary Approxima- tion of Incidence Per 106 Population** 35 County 0.02 0.04 0.21 0.15 Air Quality 0.83 <0.01 NESHAPS <0.01 0.12 0.19 0.21 0.01 <0.01 <0.01 <0.01 Preliminary Approx- imation of Maximum Lifetime Individual Risk** (xlO4) NESHAPS 4.9 1.6 2.9 68 6.1 <0.01 <0.01 0.12 Air Quality 0.73 0.49 a o z c c: — i m O 3O 0 m <0.01 * The weight of evidence of Carcinogenicity for the compounds listed varies greatly, from very limited to very substan- tial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purposes of this report, a conservative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. ** Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approxima- tions of total incidence and maximum lifetime individual risk. Estimates for individual compounds are very uncertain. These incidence and maximum risk estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. ------- -4- POLLUTANTS EXAMINED, UPPER-BOUND RISK VALUES, PRELIMINARY APPROXIMATIONS OF INCIDENCE AND MAXIMUM LIFETIME RISK. Pollutants Having Some Evidence of Carcinogenicity* Methyl Chloroform Methylene Chloride 4,4 Methylene Di aniline Nickel* Nitrobenzene Nitrosomorpholine Pentachlorphenol Perchloroethylene Products Incomplete Comb PCBs I/ Unit Risk Value 2.6x10-9 1.8x10-7 2.1x10-5 3.3x10-4 1.2x10-7 2.5x10-5 3.9x10-7 1.7x10-6 5x10-1 1.2x10-3 Source CAG CA6 CLEM CAG CLEM CLEM CLEM CAG £/ CLEM Preliminary Approximation of Annual Incidence** NESHAPS 1.0 0.02 80 <0.01 <0.01 0.12 2.9 0.21 35 2/ County 0.7 <0.01 6.7 148 Air Quality 0.1 7.4 15.0 25.4 820.9 Other Preliminary Approxima- tion of Incidence Per 106 Population** 35 County ' 0.02 0.14 3.1 Air Quality <0.01 0.03 0.07 0.11 3.57 NESHAPS .004 <0.01 .35 <0.01 <0.01 .001 .01 3.57 .001 Preliminary Approx- imation of Maximum Lifetime Individual Risk** (xlO4) NESHAPS 0.1 15.0 16 <0.01 <0.01 0.17 4.6 3.0 Air Quality <0.01 <0.01 0.28 c ( < < c ( 0.19 ' c 37.5 c r * The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substan- tial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purposes of this report, a conservative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. ** Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approxima- tions of total incidence and maximum lifetime individual risk. Estimates for individual compounds are very uncertain. These incidence and maximum risk estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. t Risk estimates assume that all species of chromium and nickel are carcinogenic, although only certain species have evidence of carcinogenicity. Current data do not allow differentiation among species. ------- -5- POLLUTANTS EXAMINED, UPPER-BOUND RISK VALUES,.PRELIMINARY APPROXIMATIONS OF INCIDENCE AND MAXIMUM LIFETIME RISK Pollutants Having Some Evidence of Carcinogenicity* Propylene Di chloride Propylene Oxide Radionuclides Styrene Terephthalic Acid Titanium Dioxide Trichloroethylene Vinyl Chloride Vinylidene Chloride I/ Unit Risk Value 7.2x10-7 1.2x10-4 varies 2.9x10-7 1.8x10-8 5.6x10-7 4.1xlO-6 2.6xlO-6 4.2x10-5 Source CLEM CLEM 5/ CLEM CLEM CLEM CAG CAG CAG Preliminary Approximation of Annual Incidence** NESHAPS <0.01 0.97 <0.01 <0.01 0.01 9.7 11.7 0.04 35 Z/ County 0.02 6.8 8.2 Air Quality 25.4 20.4 Other 17.5 Preliminary Approxima- tion of Incidence Per 106 Population** 35 County <0.01 0.15 0.2 Air Quality 0.11 0.09 NESHAPS <0.01 .004 <0.01 <0.01 <0.01 .04 .05 <0.01 Preliminary Approx- imation of Maximum Lifetime Individual Risk** (xlO4) Air NESHAPS Quality 0.02 300 0.33 <0.01 <0.01 1.0 38 42 0.07 S o .0 0.26 3 o •so o 0.07 m * The weight of evidence of carcinogenicity for the compounds listed varies greatly, from very limited to very substan- tial. Further, the extent of evaluation and health review performed varies considerably among compounds. However, for the purposes of this report, a conservative scenario (i.e., that all compounds examined could be human carcinogens) has been assumed. ** Because of the uncertainties in the data used to make these estimates, they should be regarded as rough approxima- tions of total incidence and maximum lifetime individual risk. Estimates for individual compounds are very uncertain. These incidence and maximum risk estimates have been performed to provide a rough idea of the possible total magnitude of the air toxics problem, and will be used only for priority-setting and to provide policy guidance. ------- FOOTNOTES - ATTACHMENT A, SUMMARY TABLE "Pollutants Examined, Upper-Bound Risk Values, Preliminary Approximations of Incidence and Maximum Lifetime Risk" _!_/ The unit risk value is the estimated probability of contracting cancer as the result of a constant exposure over 70 years to an ambient concentration of one microgram per cubic meter (ug/m^). "CAG" denotes risk values obtained from EPA's Carcinogen Assessment Group; "CLEM" denotes risk values obtained from Clement Associates. 2_l The population of the counties covered in the 35 County Study (about 47.3 million) represents approximately 20% of the national population. _3_/ The unit risk value used for asbestos was that a lifetime risk of 10-6 for lung cancer would result from an exposure to 10 fibers/cc and that a lifetime risk of 10-6 for mesothelioma would result from an exposure to 5 fibers/cc; 30 fibers per nanogram were assumed. £/ "Products of Incomplete Combustion" (PIC) refers to a large number of compounds, probably consisting primarily of polynuclear organics. The PIC unit risk value was derived from dose-response data which use Benzo(a)Py rene (BaP) levels as a surrogate for PIC or total air pollution. There are many limitations of using the B(a)P surrogate method to estimate PIC risks: all PIC estimates presented in this report must be regarded as highly uncertain. Refer to pp. 21-26 for a more detailed explana- tion of how the PIC unit risk value was derived. 5y Estimates of cancer and genetic risks are based on those found in the 1980 National o Academy of Science Report, "Effects on Population of Exposures to Low Levels of z Ionizing Radiation" (BEIR - 3 reports). 3 o SO ------- |