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                                                     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.

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                             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.

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     -  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.

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     -  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

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                       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.

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                 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

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                          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

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                        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

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                          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

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                       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.

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     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.

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     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

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                                -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.

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                               -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.

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                               -VI -
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     (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

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                               -vii-
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          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.

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     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?

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     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.

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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.

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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

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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.

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                        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.

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     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.

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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.

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                               -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."

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        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.

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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

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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.

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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

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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.

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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.

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             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:

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  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

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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.

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     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.

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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.

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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.

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                                -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.

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     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.

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                                -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

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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

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                                -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.

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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.

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                               -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.

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   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.

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                               -29a-

                          TABLE 1 (cont.)
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   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

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                               -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%).

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                               -31-                            DRAFT
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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

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                               -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.

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                                _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.

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                                      -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.

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                                     -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.

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                                                            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.

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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.

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                                -37-
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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.

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                                -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.

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                               -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.

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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.

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                               -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.

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                                     -42-

                                  TABLE 3
                                                                    DRAFT
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           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.

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                                     -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.

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     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

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                                     -44-


                                   TABLE  4
                                                                   DRAFT
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           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.

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                                     -44a-

                               TABLE  4  (Cont. )
                                       DRAFT
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           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.

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                              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.

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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.

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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.

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                                -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.

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                              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.

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     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:

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            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

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                                -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.

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     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

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 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

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                                -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

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                                -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).

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                               -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.

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     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.

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                                 -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.

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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.

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                                   -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.

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                               -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

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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.

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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.

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                               -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

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                               -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-

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 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

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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

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                                      -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.

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                                     -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.

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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

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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.

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                               -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.

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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.

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     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.

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                               -75-
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                 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

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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

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                                 -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

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                                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.

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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

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                                 -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.

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                                        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.

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                                                         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

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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.

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                               -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.

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                     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.

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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.

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     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.

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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

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                                                               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.

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                          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.

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                           -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.

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                                92                            DRAFT
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     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.

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                                                          DRAFT
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                       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.

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                                                           -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.

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                                                           —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.

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                                                           -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

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