DRAFT




    EPA's  Emission Standards  for

Low-Arsenic  Primary Copper Smelters
           NAS Case Study
           Ralph  A.  Luken
           April  27,  1987

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                              CONTENTS


Chapter 1	Introduction


Chapter 2	Environmental  Regulation fo the Copper
                      Smelting Industry


Chapter 3	Assessment of Risks from the Copper Smelting
                      Industry

                Unit Risk Estimate
                Public Exposure
                Individual  and Aggregate Risks


Chapter 4	Risk Management:  Assessing Control Options
                      and Setting Final Industry Standards

                Converter Fugitive Emission Controls
                Matte and Slag Tapping Fugitive Emission Controls


Chapter 5	Exploration of Issues

                Risk Assessment Issues
                Risk Management Issues
  r-

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              -              Chapter 1
                            INTRODUCTION

    Section 112 of the Clean Air Act requires EPA to establish
emission standards for hazardous air pollutants  that protect public
health with an "ample margin of safety."  In interpreting the
language for the purposes  of regulatory development, EPA does not
believe that the word "safety"  implies a total  absence of risk.
Many activities involve some risks,  but are  not  considered "unsafe."
In EPA's veiw, standards  under  section 112 should protect the public
against significant health risks.

    In setting a section  112 standard, EPA first defines what a
"significant risk" would  be for the  pollutant in question.  It then
identifies sources of pollution that are likely  to pose significant
risks, determines the current and  planned levels of control  at
those sources, and assesses the health risks associated with those
levels.  Finally, EPA selects a level  of control  that, In Its
judgment, reduces the health risks to the greatest extent that can
reasonably be expected, after considering the uncertainties  in the
risk analysis, the residual risks  remaining  after the application
of the pollution control  technology, the costs  of further control,
and the societal and other environmental impacts of the regulation.
This entire process is referred to as risk management.

    Policy analysts and decision makers have long struggled  with
how to best apply economic methods and assumptions when analyzing

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                                -2-

and control!ing "risk.   On one hand, the limitations of economic
assumptions and 'ana-lysis have been widely discussed and have, in
fact, somewhat restrained their application to such areas as risk
management.  On the other hand, the necessity of recognizing the
risk choices  associated with, and the tradeoffs of,' regulatory
options argues for some role for economics in analysis and decision
making.

    Debate over the use of economic principles and methods in risk
management eventually  focuses on the underlying assumptions (usually
implicit)  that relate  to rational behavior, ethics, public choice,
and time preference.  At this level, the issues concern notions
about equity, social values, philosophical presuppositions, and the
social contract between government and its citizenry.

    This case study demonstrates how EPA used risk assessment and
risk management in setting standards for inorganic arsenic emissions
Chapter 2  provides some background on the regulatory history of the
copper smelting industry, while chapters 3 and 4 describe the risk
assessment and risk management information that served as a basis
for the regulation.  The final  chapter illustrates some of the
conceptual and methodological issues associated with the economic
analysis of risks.  It shows how using different methods and
assumptions would have greatly changed the information available
for determining the final standard.  More important, it asks whether
redesigning EPA's risk assessment and risk management techniques
would better  reflect actual  risks and protect the public against
those risks.

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                             Chapter 2
      ENVIRONMENTAL-REGULATION OF  THE COPPER  SMELTING INDUSTRY

    The primary copper smelting industry uses pyrometallurgical
processes to extract copper from sulfide copper ores containing
arsenic as an impurity.   At the 15 primary copper smelters  operating
in the U.S. in 1983, the average arsenic content of copper  ore
ranged from 0.0004 to 4.0 percent.  The average arsenic  content  of
the ore was well  below 0.5 percent at the majority of smelters,  and
only the ASARCO-Tacoma smelter processed ore  with more than 1  per-
centarsenic.

    On June 5, 1980, EPA published a Federal  Register notice listing
inorganic arsenic as a hazardous air pollutant under section 112 of
the Clean Air Act (44 FR 37886).  On July 11, 1983, EPA  proposed
standards (48 FR 33112,  July 20, 1983) for inorganic arsenic emis-
sions from the 14 low-arsenic primary copper  smelters as  well  as
high-arsenic copper smelters and glass manufacturing plants.  The
proposed standard for low-arsenic  primary copper smelters regulated
secondary inorganic arsenic emissions from converter operations
and from matte and slag  tapping furnances.  The proposed  standards
for converter operations applied to smelters  with an annual  average
inorganic arsenic feed rate of 6.5 kilograms  per hour (kg/h) or
greater.  And the proposed standards for matte and slag  tapping
furnaces applied to smelters with  an annual  average combined inorganic
arsenic process rate of  40 kg/h or greater.   The latter  standards
were less restrictive than the former because secondary  emissions
from converters are typically 1 to 25 times  greater than  the combined
emissions from both matte and slag tapping operations.

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                                -4-

    The proposed standards affected 6 of the existing 14 low-arsenic
primary copper smelters.   The estimated capital  and annualized costs
required to meet the standards were approximately $35.3 million
and $9.5 million, respectively.

    Because of public comments, EPA conducted additional analyses
to ensure that the final  rule was based on the most complete and
accurate information available.  These additional analyses included
revising the emission estimates, dispersion modeling, and risk
assessment, and conducting additional cost and economic impact
analyses.  The scope of these analyses resulted in considerable
changes in the risk assessment and risk management information
that was incorporated in  the final  rulemaking of August 4, 1986
(51 FR 27956).

    As a result, the final  standard affects only one of the 14
smelters and does not apply to matte and slag tapping operations.
It applies only to smelters with annual arsenic feed rates to
converters greater than 75 kg/h .  Because the only high-arsenic
copper smelter affected by the earlier proposal  (one owned and
operated by ASARCO in Tacoma, Washington) ceased operation in 1985,
EPA withheld further action on the proposed standard for high-
arsenic primary copper smelters.  EPA also confirmed its decision
not to regulate six other sources emitting inorganic arsenic.

    The estimated capital and annualized costs required to meet the
final  standard are approximately $1.8 million and $380,000,
respectively .

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                             Chapter 3
    ASSESSMENT Of C-ANCER RISKS FROM THE COPPER SMELTING INDUSTRY

    The quantitative estimates of public cancer risks presented in
this chapter are based on (1)  EPA's linear non-threshold model,
which is a dose-response model that numerically relates the degree
of exposure to airborne inorganic arsenic to the risk of getting
lung cancer, and (2) EPA's Human Exposure Model, which expresses
numerically the degree of public exposure to ambient air concentra-
tions of inorganic arsenic from the 14 copper smelters.  This
chapter describes these models and the assumptions used to assess
cancer risks and presents EPA's quantitative estimates of individual
and aggregate risks.

UNIT RISK ESTIMATE
    The numerical constant that defines the relationship between
exposure to a pollutant (dose) and the potential health effects, or
risk (response), resulting from that exposure is called the unit
risk factor.

    For an air pollutant, the  unit risk factor is the excess cancer
risk associated with an individual's lifetime of exposure (70 years)
to an average concentration of 1 microgram per cubic meter (lx/{g/m3)
of the pollutant in the air.  For inorganic arsenic, the unit risk
estimate is based on EPA's analysis of five data sets of the latest
smelter worker epidemological  data collected by four researchers at
two smelters (Table 3.1).  To  establish a single point estimate,
EPA obtained the geometric mean for data sets within distinct

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                                     -6-
                                   Table 3.1

                   COMBINED UNIT RISK ESTIMATES FOR ABSOLUTE-
                               RISK LINEAR MODELS
Exposure Source
Study
Geometric
Mean Unit
Unit Risk Risk
i
Final Estimated
Unit Risk
Anaconda smelter
ASARCO smelter
Brown & Chu
Lee Feldstein
Higgins et al

Enterline &
    Marsh
                            1.25 x 10-3
                            2.80 x 10-3
                            4.90 x 10-3
                                     6.81 x 10-3
                                     7.60 x 10-3
                                                     2.56 x 10-3
                                            7.19 x 10-3
                                                                      4.29 x 10-3
Source:  U.S. EPA (1986)
         and Arsenic Plants
                 "Inorganic Arsenic Emissions from Primary Copper Smelters
and Arsenic Plants - Background Information for Promulgated Standards,"
Appendix C - Inorganic Arsenic Risk Assessments for Primary Copper Smelters,
EPA-450/3-83-010^!.

                b

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                                -7-

exposed populations, and took the final  estimate to be the geometric
mean of those value's.  Based on this analysis, EPA used a 0.00429
per ug/m^ unit risk estimate in assessing the health impact of
inorganic arsenic.

PUBLIC EXPOSURE
    EPA applied the Human Exposure Model  (HEM) to the 14 smelters.
This general model can produce quantitative expressions of public
exposure to ambient air concentrations.   In addition, it carried out
more site-specific dispersion modeling at El  Paso, Texas, and Douglas,
Arizona.

    Table 3.2 lists, on a piant-by-plant  basis, the total number of
people included in the exposure analysis.  "Any risk" is the number
of people exposed to some degree to emissions from the specified
source, as calculated by HEM.  "Maximum  lifetime risk" is the
number of people exposed to the maximum  individual risk, assuming
70 years of exposure.

INDIVIDUAL AND AGGREGATE RISKS
    Unlike the unit risk factor, which concerns an individual's
lifetime exposure to an average concentration of a pollutant,
individual risk reflects an individual's  probability of getting
cancer if continuously exposed to the  estimated maximum concentration.
Aggregate risk is expressed as the total  probable incidences of
cancer among all  of the people included  in  the analysis, after 70
years of exposure.  For statistical convenience, it is often divided
by 70 and expressed as probable cancer incidences per year.

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                               -8-
                            Table 3.2

                    NUMBER OF PEOPLE EXPOSED
Plant
ASARCO-E1 Paso
ASARCO-Hayden
Kennecott-Hayden
Kennecott-Hurl ey
Kennecott-McGill
Kennecott-Garf iel d
Phelps Dodge-Morenci
Phelps Dodge-
Dougl as
Phelps Dodge-Ajo
Phelps Dodge-Hidalgo
Copper Range-White
Pine
Magma-San Manuel
Inspiration-Miami
Tennessee Copper-
Copperhil 1

Any Risk*
493,000
46,800
46,800
26,300
7,350
810,000
25,500
31,100
6,600
2;560
16,900
211,000
35,700
164,000
Total
Number of
People Exposed
Maximum Life-
time Risk**
1
1
1
1
1
2
2
2
6
909
1
1
1
1
Distance
(km) from
Source
•
1.0
0.3
0.3
0.3
0.3
5.0
2.0
0.2

2.4

0.2
0.4
0.5
 * A 50-kilometer radius was used for the analysis.
** People exposed within distance specified in next  column.

Source:  U.S.  EPA (1986), "Inorganic Arsenic Emissions from  Primary
         Copper Smelters and Arsenic Plants - Background Information
         for Promulgated Standards," Appendix C - Inorganic  Arsenic
         Risk  Assessments for Primary Copper Smelters, EPA-450/3-83-
         010^.

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                                -9-

    Table 3.3 summarizes the maximum individual  lifetime risk and
the annual  incidence for baseline and promulgated control  scenarios.
The baseline level  of risks results from the level  of emissions
after applying in-place controls or controls required to be in
place to comply with current state or federal  regulations, but
before applying controls required by the final  arsenic standard.
The converter control scenario level  of risk represents the remaining
risks after implementing the final arsenic standard.

    The final  standard would reduce secondary  inorganic arsenic
emissions from the  one smelter by about 1 to 4  megagrams per year.
As a result of this emission reduction, EPA estimated that the lung
cancers due to inorganic arsenic for people currently living within
50 kilometers of the affected smelter would be  reduced from 0.18-
0.38 to 0.16-0.29 incidences per year.   The final standard would
reduce the  estimated lifetime risk from exposure to airborne arsenic
from a range of 60-100 in 10,000 to a range of  50-80  in 10,000.

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                                             -10-,
                                          TABLE 3.3
                          RISK ESTIMATES FOR PRIMARY COPPER SMELTERS

Maximum lifetime risk
ASARCO - El Paso:!/
(1) 	
(2) 	
(3) 	
ASARCO - Hayden 	
Kennecott - Garfleld (Utah) 	
Kennecott - Hayden 	
4-i-I nsplratlon - Miami 	
Phelps Oodge - Oouglas(l) 	
mi/
Kennecott - Mcdll 	
*Phelps Do dqe - Hidalgo 	
*Phelps Oodge - Morencl 	
*Phel ps Dodge - Alo 	
*Kennecott - Hurley 	
*Tennessee Chemical - Copperhill...
*Copper Range - White Pine 	 	

Maximum L
Baseline x
10-4
10
5
10
13
0.6
3
1 .9
12
0.8
4
0.05
0.8

I .?
0.6
1 .6
1 .1

.ifetime Ri
Converter
Control x
8
5
9
12
0.6
0.5
1.0
2
0.7
0.6
0.03
0.2
1.7
0.5
0.1
0.4
0.15

sk
Reduction
x 10~4
2
1
1
1
o
2.5
0.9
10
0.1
3.4
0.02
0.6
0.3
0.7
0.5
1 .2
0.95

Annual ]
Basel ine
0.38
0.20
0.18
0.06
0.14
0.016
0.0069
0.022
0.025
0.006
0.0001
0.0028
0.0045
0.0008
0.003
0.0026
0.0004

ncidence, c
Converter
Control I/
0.29 4/
0.18 '/
0.16 ^/
0.05
0.14
0.0054
0.0034
0.0081
0.013
0.0015
0.0001
0.0009
0.0038
0.0003
0.0006
0.0017
0.0002

ases per year
Reduction
0.09
0.02
0.02
0.01
0
0.0106
0.0035 '
0.00139
0.012
0.0045
0
0.0019
0.0007
0.0005
0.0027
0.0000
0.0002

  Controlof converter fugitive emissions
percent collection efficiency.
                                   ny a system consisting of a secondary nood witn
' El  Paso figures represent secondary arsenic emissions based:  (1)  on an emission factor for
uncontrolled converter fugitive emission of 15% of the arsenic contained in the primary converter
process gases, and (2) on a 3.75% emission factor.  These figures  are estimated by EPA to repre-
sent the upper and lower bounds of uncontrolled converter fugitive emissions at ASARCO-E1 Paso.
3 Risk estimates calculated using site-specific analyses ( ISCLT/Val 1 ey model)  and 3.75% emission
factor.
4 Risk estimates calculated assuming no additional control  by the  building evacuation system
(BES)  of emissions escaping the converter secondary hoods.   Some control of these emissions by
the BES may occur although the amount of control  can not be determined.  To the exten.t that
emissions escaping the converter secondary hoods are controlled by the BES, these risk estimates
are overstated.
5 Risk estimates calculated using si te-s;peci f ic analyses ( ISCLT/Val 1 ey model).
*De minimi's risk.
NOTE
SOURCE
Tne baselIne level  of risks results from the level  of emission after applying in-place
controls or controls required to be in place to comply with  current  state  or federal
regulations, but before applying controls required  by the arsenic standard.   The
converter control  level  of risk  represents  the remaining  risk  after  implementing the
arsenic standard.

  U.S. EPA (1986),  "Inorganic Arsenic  Emissions from Primary Copper  Smelters and Arsenic
  Plants - Background Information for  Promulgated "Standards,"   Appendix  C  -  Inorganic
  Arsenic  Rsk Assessments  for Primary  Copper Smelters, EPA-450/3-83-010f.

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                             Chapter 4
                          RISK MANAGEMENT:
   ASSESSING CONTROL OPTIONS AND SETTING FINAL INDUSTRY STANDARDS

    After determining the cancer risks from arsenic emissions, EPA
examined the two available options for control 1 ing ," or managing,
the risks:  converter controls and matte and slag tapping controls.
This examination considered the estimated emission and risk reduction
from applying the options, the remaining public  exposure to and
risk from inorganic arsenic after control,  and the costs and economic
impacts of a standard based on those control  options.

CONVERTER FUGITIVE EMISSION CONTROLS
    The standard would require installing secondary hoods on
converters that have an annual average arsenic feed rate of 75
kilograms per hour or greater.  The potential  emission reductions
from, and the estimated annualized costs of, the converter secondary
controls at each of the existing smelters appear in Table 4.1.  The
estimated cost-effectiveness ($/Mg) ranges  from  about  $100,000 to
$8,000,000 per Mg at the 14 smelters.

    Applying controls for converter secondary emissions would reduce
the range of estimated maximum risks to  between  1.2 x  10~3 and 3.0
x 10~6 from a range of 1.3 x 10~3 to 5.0 x  10~6  (see Table 3.3).
It would also reduce the estimated annual  incidence of lung cancer
from 0.38-0.0001 to 0.29-0.0001.

    Using these risk and cost estimates, EPA concluded that for
eight copper smelters (identified with an asterisk (*) in Table

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                                                       -12-

                                                     Table 4.1

                        ENVIRONMENTAL AND COST IMPACTS ASSOCIATED WITH SECONDARY INORGANIC
                             ARSENIC EMISSION CONTROL SYSTEMS FOR CONVERTER OPERATIONS
Smel ter
ASARCO - El Paso:!/
(1) 	
(2) 	
ASARCO - Hayden 	 	
Kennecott - McGi 11 	
Kennecott - Hayden 	
Phelps Dodge - Douglas 	
Inspiration - Miami 	
Phel ps Dodge - Morenci 	
Kennecott - Utah (Garfield) 	
Phelps Dodge - Hidalgo 	
Tennessee Chemical - Copperhill . . .
Magma - San Manual 	
Phelps Dodge - Ajo 	
Kennecott - Hurley 	
Copper Range - White Pine 	
t m 	 — . 	 r-
Arsenic
Content
of Feed
(percent)
0.5
0.5
0.42
0.033
0.015
0.03
0.033
0.006
0.144
0.003
0.0004
0.006
0.015
0.0005
0.008

Arsenic
Feed Rate to
Converters
(kilograms
per hour)
98.9
98.9
63.4
9.3
7.2
4.2
5.7
1.9
14.7
0.4
0.7
0.6
0.8
0.8
0.5

Potential
Secondary
Arsenic
Emissions
(megagrams
per year)
98.3
24.6
10.2
10.1
6.5
4.1
1.9
1.9
1.5
0.2
0.65
0.55
0.52
0.46
0.30

Baseline
Secondary
Arsenic
Emissions
(megagrams
per year)
13.3
3.4
5.4
10.1
6.5
4.1
1.9
1.9
1.5
0.2
0.65
0.55
0.52
0.46
0.30

Predicted
Secondary
Arsenic
Emission
Reduction?./
(megagrams
per year)
3.7
1.0
4.4
9.2
5.9
3.7
1.7
1.7
1.4
0.18
0.58
0.50
0.47
0.42
0.27

Annualized
Control
Costs
($1,000)
379
379
798
2,201
2 140
2,943
2,943
3,432
2,028
1 745
1,278
3 979
1,562
2,296
1,278

Cost per
Unit
Emission
Reduction
(dollar
per
(megagram)
102,430
379 000
181,365
239,240
362 710
795,405
1,731 000
2,019,000
1,449,000
9,694 000
2,203,000
7,958 000
3,323,000
5,467 000
4,733 000

fugitive emissions of 10% of the arsenic contained in the primary converter process gases and (2)  on a 3.75%
emission factor.  These figures are estimated by EPA to represent the upper and lower bounds of uncontrolled
converter fugitive emissions at ASARCO-E1 Paso.
2 Emission reduction estimates calculated, assuming no additional control  by the building evacuation system (BES)
of emissions escaping the converter secondary hoods.  Some control of these emissions by the BES may occur,
although the amount of control cannot be determined.  To the extent that emissions escaping the converter
secondary hoods are controlled by the BES, these emission reductions are understated.

Source:  U.S. EPA (1986), "Inorganic Arsenic Emissions from Primary Copper Smelters and Arsenic Plants -
         Background Information for Promulgated Standards," Appendix C - Inorganic Arsenic Risk Assessments
         for Primary Copper Smelters, EPA-450/3-83-010b.

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                                -13-

3.3), the baseline risk was insignificant,  and that regulation
was not warrante'd. • For five of the six remaining smelters that
the proposed standard would have affected,  EPA concluded that the
costs were disproportionate to the risk reductions that could be
obtained.  Furthermore, the economic analysis showed that for two
of these five smelters, the control costs were likely to result in
the smelters' remaining permanently closed  (Kennecott - Hayden and
Kennecott - McGil1).

    For the last remaining facility, ASARCO-E1 Paso, the analysis
indicated that risk  could be reduced at a reasonable cost.  An
additional factor  considered in the assessment was that secondary
hoods will be installed on all  converters at ASARCO-E1  Paso to
comply with requirements in the Texas SIP for attainment of the
national  ambient air  quality standard for lead.  Since  the costs
of the controls are  reasonable and the control can be implemented
now, EPA decided that these controls should be applied  only at
ASARCO-E1 Paso.  Consequently,  EPA revised  the cutoff to cover
only facilities where the converter arsenic feed rate is 75 kg/h
or greater.  Based on available information, this cutoff would
require applying converter secondary controls only at the ASARCO-E1
Paso smelter.

MATTE AND SLAG TAPPING FUGITIVE EMISSION CONTROLS
    The standard would have required capturing and controlling
matte and slag process secondary emissions  from smelting furnaces

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                                -14-

with arsenic process rates greater than 40 kg/h.  However, all
three smelters above this cutoff have already installed localized
hoods over matte and slag tapping operations, and two have also
installed devices to control  emissions of participate matter.

    The potential emission reductions and the costs to control  the
collected emissions at the smelters that are not currently controlling
them are summarized in Table  4.2..  The cost-effectiveness of these
controls ranges from $330,000 to $7,300,000 per Mg for the 14
primary copper smelters.

    The risk reductions achievable through applying these controls
are insignificant because of  the current low emission rates (less
than 1-2 Mg per year).  In addition, controls on matte and slag
tapping operations are required by the Tripartite Agreement for
ASARCO-E1  Paso, so that no additional emission reduction would  be
achieved by an inorganic arsenic standard.  Controls on matte and
slag tapping operations at the remaining facilities would impose
costs that are greatly disproportionate to the risk reduction
achieved.   Therefore,  the proposed control requirement for matte
and slag tapping operations was not included in the final standard.

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                                                     -15-
                                                  Table 4.2

                       REVISED ENVIRONMENTAL AND COST IMPACTS ASSOCIATED WITH SECONDARY
               INORGANIC ARSENIC EMISSION CONTROL SYSTEMS FOR MATTE AND SLAG TAPPING OPERATIONS
Smelter
ASARCO - Hayden 	
ASARCO - El Paso 	
Kennecott - Utah (Garfield) 	
Kennecott - Hayden 	
Inspiration - Miami 	
Phelps Dodge - Douglas 	
Kennecott - McGill 	
Phel ps Dodge - Morenci 	 	
Phelps Dodge - Hidalgo 	
Phelps Dodge - Ajo 	
Kennecott - Hurl ey 	
Tennessee Chemical - Copperhill ...
Magma - San Manuel 	
Copper Range - White Pine 	

Arsenic
Process
Rate
(kilograms
per hour)
98.2
102.1
40.4
9.4
19.8
10.4
5.6
5.0
0.8
1.8
1.6
1.1
1.0
0.6

Potential
Secondary
Arsenic
Emissions
(milligrams
per year)
8.5
6.7
2.0
0.9
0.8
0.6
0.3
0.3
0.05
0.1
0.1
0.09
0.08
0.06

Baseline
Secondary
Arsenic
Emissions
(megagrams
per year)
1.1
0.8
2.0
0.9
0.8
0.4
0.3
0.3
0.05
0.1
0.1
0.09
0.08
0.06

Predicted
Secondary
Arsenic
Emission
Reductions
(megagrams
per year)
0
0
1.7
0.78
0.69
0.32
0.26
0.26
0.04
0.09
0.09
0.08
0.07
0.05

Annual ized
Control
Costs
(1,000)
0
0
1,914
257
261
514
257
514
257
257
265
257
514
257

Cost per Unit
Emission
Reduction
(dollars
per megagram)


1,126,000
329 490
378 260
1,606 000
988,460
1,977,000
6,425,000
2,856,000
2,944 000
3,213,000
7,343 000
5,140 000

Source:  U.S. EPA (1986), "Inorganic Arsenic Emissions from Primary Copper Smelters and Arsenic Plants •
         Background Information for Promulgated Standards," Appendix C - Inorganic Arsenic Arsenic Risk
         Assessments for Primary Copper Smelters, EPA-450/3-83-010jf.

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                             Chapter 5
                       EXPLORATION OF ISSUES

    The risk assessment and risk management information used in this
case study raises several  issues about the methods EPA generally
uses to set standards.   This chapter highlights some of these issues.

RISK ASSESSMENT ISSUES
    Various methods and assumptions used in the case study's risk
assessment may have significantly overestimated or underestimated
the health risks from inorganic arsenic emissions.

Exposure for Entire Lifetime
    Some of the basic assumptions implicit in the exposure methodology
are:  (1) that all  exposure occurs at people's residences, (2)  that
people stay at the  same location for 70 years, (3) that the ambient
air concentrations  and  the emissions that cause these concentrations
persist for 70 years, arid  (4) that the concent rat 1 ons are the same
inside and outside  the  residences.  In sum, they assume that indivi-
duals are exposed to inorganic arsenic emissions for their entire
1ifetime.
    Several commentors  questioned these simplifying assumptions,
particularly the assumption of 70-year resident immobility.  If
EPA used a more reasonable assumption -- say, a 10-year residency
in the area -- then the maximum lifetime individual risk would
decrease by approximately  one order of magnitude.  However, this
10-year assumption  would not change the annual cancer incidence,
because this calculation is independent of population mobility.

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                                -17-

Early Lifetime Exposure
    Although the"estimates derived from the various epidemological
studies are quite  consistent, there are a number of uncertainties
associated with them.  The estimates were made from occupational
studies that involved exposures only after employment age was
reached.  In estimating risks from environmental exposures through-
out life, EPA assumed in the linear non-threshold model  that  the
increase in the age-specific mortality rates of lung cancer was a
function only of emulative exposures, irrespective of how the
exposure was accumulated.  Although this assumption adequately
describes all of the data, it may be in error when applied to
exposures that begin very early in life.  Similarly, the linear
models possibly are inaccurate at low exposures, even though  they
reasonably describe the experimental data.

    Given greater  access to the data from these studies, other
uGSe measures, as  well  as iiiuuel S Other than the linear nun-thresholu
model, could be studied.  Such analyses would indicate whether
other approaches are more appropriate than the ones applied here.

Use of Census Data
    The official EPA risk assessment (Table 3.3) underestimated the
maximum lifetime risk and annual  cancer incidence at the El Paso
and Douglas Smelters because it did not include the Mexican popula-
tion living in border towns and illegally on plant property.

    In the case of the  El Paso smelter, the population in neighboring
Juarez is approximately the same as in El Paso.  The maximum  lifetime

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                                -18-

rlsk there is similar,  10~3,  and the annual  cancer incidence
ranges from .40 to .70,  which is double the  incidence among the
U.S. population.  These  estimates do not include the Mexicans
living illegally in the  U.S.  because they are not counted by the
U.S. Census.

    In the case of the  Douglas smelter, the  population in neighboring
Agua Prieta is about double  the population  in Douglas.  The maximum
individual risk is similar,  10~3, and the annual cancer incidence
is  .04, which is double  the  incidence among  the U.S. population.

    If this information  were  incorporated in risk management decisions,
it would, as  described  later  in this chapter, lower the cost per life
saved and increase the  economic efficiency  of the regulation, parti-
cularly at El  Paso.

Assumption of No Latency Period
    EPA's risk assessment assumes that there is no latency period
between exposure and incidence.  Although there is no definitive
information on exactly  what  the latency period is for airborne
arsenic,  it is greater  that  zero.  Enterline and Marsh (1982)
suggest that  it may be  in the range of 10 to 19 years because
their standardized mortality  ratios appear  to become significant
about 10 - 19 years after the exposed workers have left the plant.
     If this  information were incorporated  in risk managemnt
decisions, it would, as  described later in  this chapter,  decrease
the economic  efficiency  of the regulation,  particularly at El Paso.
Paso.

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                                -19-

Exclusion of Oth'er Health Effects
    The unit risk e-stimate used in this case study applies only to
lung cancer.  Other health effects are possible.  These include
skin cancer, hyperkeratosis,  peripheral neuropathy, growth retarda-
tion and brain dysfunction among children, and increase in adverse
birth outcomes.   No numerical  expressions of risks relevant to
these health effects are included in this study.
     If more quantitative information about the health risks were
available and could be assigned monetary values, it would increase
the economic efficiency of the regulation at all plants.

RISK MANAGEMENT  ISSUES
    For each control  option,  EPA's risk management process considers
the magnitude of the risks, the degree to which risks can be reduced
by available control  measures, uncertainties in the risk  estimates,
the environmental  and economic impacts, and the affordability of
the centre!  measures.  In this case, the decision resulted from
consideration of the economic  impacts associated with the application
of controls, compared with the degree of risk reductions  achievable
at the three smelters.  However, the risk management paradigm, as
espoused by  EPA, offers several other ways to think about the
necessity of imposing controls.  These include consideration of
cost-effectiveness per incidence avoided, economic efficiency,
equity, and  legislative consistency.

Cost-Effectiveness
    To determine whether the  standard is cost-effective in terms of
cases avoided, EPA must establish a reasonable value for  a statistical

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                                -20-

life saved.  The EPA Guidelines for Regulatory Impact Analyses
suggest that this v-alue should fall in the range of $400,000 to
$7,000,000, with a point estimate of $2,000,000.  This value is
supported,  in part,  by a recent survey  of 130 decisions made by
the U.S. government  to regulate carcinogens (Travis', 1987).  It
found that  the average implicit value of a statistical life saved
was approximately $2,000,000.

    If $2,000,000 is a reasonable value to consider in the decision
to control  arsenic,  then the  figures in Table 5.1 suggest that the
standard is not cost-effective.  They show that the cost per case
avoided exceeds $2 million  at  all  plants.   The cost per .case avoided
at the one  plant regulated  -  El Paso lies  between $4.2 million
                                    A
and $18.9 million, depending  upon assumptions about emission rates
and exposure.

    If the  $4,200,000 value at ASARCO - El Paso is thought to be a
reasonable  value to  initiate  action, a case could still be made not
to control  fugitive  emissions  from the converter at the plant.  An
alternative risk assessment scenario at ASARCO - El Paso, described
in Table 3.3, shows  a smaller  reduction in cancer incidence (0.02)
and consequently a higher value per case avoided ($18.9 million).
These figures exceed the highest value in  the Guide!ines and the
average value implied by past  U.S. government regulatory decisions.
The scenario assumes that only 3.75 percent, rather than 15 percent,
of arsenic  emissions escape the primary vent hood.  The higher
emission factor of 15 percent  reflects actual emissions before El
Paso upgraded its primary vent hood.  The  lower emission factor of

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                                                 -21-
                 ANNUAL COST PER
             Table 5.1
CASE AVOIDED AND NET PRESENT
 (millions of 1982 dollars)
VALUE (NPV)  OF CONTROLS
Plant
ASARCO-E1 Paso (1)
(2)
( 3)_ly
Asarco-Hayden
Kennecott-Garfield
Kennecott-Hayden
Inspiration-Miami
Phelps Dodge-Douglas (1)
( 2)2/
Kennecott-McGill
Phelps Dodge-Hidalgo
Phelps Dodge-Morenci
Phelps Dodge-Ajo
Kennecott-Hurley
Tennessee Copper-
Copperhil 1
Magma-San Manuel
Copper Range-White
Pi ne
Annual
reduced
cases
0.09
0.02
0.02
0.01
0
0.0106
0.0035
0.0159
0.012
0.0045
0
0.0019
0.0007
0.0005
0.0027

0.0009

0.0002
Annual
cost/case
(10%, 0 yrs)
4.2
18.9
19.0
79.8

201.9
840.9
185.1
;?45.2
488.1
	
1306.3
2231.4
4592.0
473.3

4421.1

6390.0
NPV
( ben-cost)
(4%,0 yrs)
-1.6
-3.5
-3.5
-8.4
-22.3
-24.0
-36.5
-36.2
-36.3
-25.5
-21.6
-38.9
-19.1
-28.4
-15.9

-49.8

-16.0
NPV
( ben-cost)
( 10%, 0 yrs)
-1.7
-2.9
-2.9
-6.6
-17.3
-18.0
-25.0
-24.8
-24.9
-18.7
-14.9
-29.2
-13.3
-19.5
-10.8

-33.9

-10.9
NPV
( ben-cost)
(4%, 15 yrs)
-2.7
-3.7
-3.7
-8.5 '
-22.3
-24.2
-36.6
-36.4
-36.4
-25.6
-21.6
-38.9
-19.1
-28.4
-15.9

-49.8

-16.0
NPV
(ben-cost)
( 10%, 15 yrs)
' -2.9
• -3.1
-3.1
-6.8
-17.3
-18.2
-25.0
-25.0
-25.0
-18.7
-14.9
-29.2
-13.3
-19.5
-10.9

-33.9

-10.9
1 Risk Estimates calculated using site-specific analyses (ISCLT/Val1ey model)  and 3.75 percent
emission factor.
2 Risk estimates calculated using site-specific analyses (ISCLT/Val1ey model).-

Source: U.S. EPA (1986), "Inorganic Arsenic Emissions from  Primary Copper Smelters and Arsenic
        Plants - Background Information  for Promulgated Standards,"  Appendix  C -  Inorganic  Arsenic
        Risk Assessments for Primary Copper Smelters, EPA-450/3-83-010b.

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                                -22-

3.75 percent reflects measured values at other sites (Hayden and
Takoma) where the equipment is similar to the upgraded vent hood
at El Paso, rather than actual  measured values at El Paso after
installing the new equipment.   The new emission factor is certainly
lower than 15 percent, which means that the cost pe'r incidence
avoided is higher than the lower bound of $4.2 million.

    A counter to the above argument about the unreasonableness of
the cost per case avoided is that it fails to include the benefits
to the Mexican population.  Including the Mexican population and a
high emission rate reduces the annual incidence by 0.265, rather
than the .09 reduction achieved with controls on fugitive emissions.
Consequently, the cost per case avoided is $1.4 million,  rather
than $4.2 million.  Including  the Mexican population and  a 1ow
emission rate reduces the annual  incidence by 0.12,  rather than
the .02 reduction achieved with controls on fugitive emissions.
Consequently, the cost per case avoided is $3.2 million,  rather
than $18.9 million.  These revised estimates suggest that the cost
per case avoided is consistent with EPA Guide!ines and other U.S.
government decisions.  However, including the Mexican population
in the estimates for the Douglas smelter only brings the  cost per
case avoided near to the high  end of the range in the EPA GUI' del i nes

Economic Efficiency
    EPA can determine whether  a standard is economically  efficient
by comparing the net present value of the standard's benefits and
costs (Table 5.1).  With a 10  percent discount rate  and  no latency
period, no control option has  a positive net present value, assuming

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                                -23-

$2.0 million per statistical  life saved.  Changing the discount to
4 percent does not "significantly change the results.  The net
present value of all  controls is negative.   Thus,  regulation at
all  plants would be rejected  on the grounds of economic efficiency.

    Using a 15-year latency period changes  only the economic
efficiency evaluation at the  El Paso smelter.   The magnitude of the
change in the negative net present value is greater for this plant
because of the greater proportionate reduction in  the values for
cancer cases avoided.  The assumption of a  15-year latency does
not  markedly alter the negative economic efficiency evaluation at
the  other 13 plants,  because  fewer cases are avoided, and the
control costs overwhelm the benefits in the net present value
calculations.

    Assuming $7.0 million per statistical  life saved only partly
alters the negative economic  efficiency valuation  at the El  Paso
smelter.   Using the highest reduction in annual incidence -- 0.09
cases --  makes the net present value positive  for  both discount
rates with no latency period, and for the  4 percent discount rate
with a 15Aear latency period.  In all other circumstances at El
Paso (.09 incidence/10%/15 years and .02 incidence/any combination
of rates  and years) and at all  other smelters, the net present
value would remain negative,  even for a relatively high value per
statistical life saved.

    Although the EPA  General  Counsel ruled  that EPA could not
look beyond the requirements  of section 112 in setting this  standard,

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                                -24-

this conference could examine whether  the  standard would be  economi-
cally efficient if the total  benefits  of emission  reductions were
compared against the costs.   At El  Paso, controls  for fugitive
arsenic from converters would achieve  a 6.6 megagram reduction in
lead (Pb) and a 30 megagram  reduction  in particulate matter  {PM).
Controls at Douglas would reduce PM by 780 megagrams.

     An immediate issue is how to.compare  and  aggregate  these  health
and welfare benefits.  In the case  of  PM,  there are reductions in
mortality, morbidity, and welfare damage (Table 5.2).  EPA's
Guide!ines encourage monetizing these  benefits and then  adding them
together to obtain a dollar  per ton number.

     Incorporating the PM benefits  into an economic analysis alters
the efficiency evaluation at  the Douglas plant if  one assumes
benefits at $3,800 per ton (Table 5.3).  The PM benefit/ton  number
typically ranges from $300/ton to $10,000/ton, depending on  the PM
sources and exposure patterns for receptors near the sources.   Using
these values makes the benefits equal  to the costs, in contrast to
the negative net present value of $25  million  - $36 million  where
no PM benefits are considered, or a negative $16 million -  $25
million for the scenario with $2,400/ton PM benefits.

     Incorporating the PM benefits  into an economic analysis of
controls at the El Paso plant does  not alter the negative efficiency
calculation for any value within the range of  $300/ton - $10,000/ton.
However, incorporating the Pb benefits yields  a positive net present
value of $14 million - $26 million, rather than a  negative  net present
value of $1.6 million - $3.1  million.

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                                -25-
                             Table 5.2

       LEAD AND PARTICULATE MATTER HEALTH AND WELFARE EFFECTS
Pollutant / Effect
  Number Reduced         . Benefits
 Effects per Ton     (Dollars) per Ton
Emission Reduction3 Emission Reduction
Lead
Chelation
Hypertension
Myocardial Infarction
Strokes
Mortal i ty

4
47
0
0
0

.5
.0
.1
.0
.1



4
3
3

case
case
case
case

s
s
s
s
deaths

$
$
$
$
$

1
1



6
0
8
1
260

.5
.5
.8
.4
.0

X
X
X
X
X

103
103
103
103
103
          Total  for Lead
                      $ 297.2 x 103
Particulate Matter

     Mortality
     Morbi dity
        Lost  Work-Days
        Reduced Activity-
             Days
        Medical Expendi-
             tures

     Soiling  and Material
        Damages
  4.3 x 10-5 deaths

   8.8 person-days

  27.9 person-days
          Total  for Particulate Matter
$
$
$
$
$
$
0.
0.
1.
0.
0.
2.
1
7
1
3
2
4
x
x
X
X
X
X
103
103
103
103
103
103
  Effects based on county-weighted average for estimates of
  reduced number of effects  per ton of reduced pollution emissions
  Range fo~r particulate matter total  benefit value varies between
  $0 and $300,000/ton for individual  counties in the U.S.  The
  variation by county for the benefits of reducing lead emissions
  was not calculated.
Source:  Costs and Benefits of Reducing Lead in Gasoline: Final
        Regulatory Impact Analysis.U.S.  EPA,Office of Policy
        Analysis, February 1985;   Benefits and Net Benefits
        Analysis for Alternative  National  Ambient Air Qualfty
        Standards for Particulate Matter,  U.S. EPA, Office  of
        Air Quality Planning and  Standards, March 1983.

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                                                -26-

                                            Table  5.3                         	

        NET  PRESENT DISCOUNT VALUES FOR BENEFIT-COST STREAMS OF PARTICULATE MATTER (PM),
                            LEAD, AND ARSENIC EMISSION REDUCTIONS
Pr
Reduced
Pollution
Plant / Pollutant Emissions
ASARCO-E1 Paso
Lead 6.6 tons
PM 29.5 tons
Arsenic!5
Scenario 1 3.7 tons
Scenario 2 1.0 tons
Total
Scenario 1
Scenario 2
Phelps Dodge-Douglas
PM 776 tons
Arsenicc
Scenario 1 3.7 tons
Scenario 2 3.7 tons
Totald
Scenario 1
Scenario 2
Scenario A
Scenario B
•esent Value Benefits3
(Millions $)
Discount Rates:
4%

$36.7
1.0
2.4
0.5
$ 40.1
$ 38.2

$ 25.3
0.4
0.3
$ 25.7
$ 25.6
10%

$16.7
0.6
1.5
0.3
$ 18.8
$ 17.6

$ 15.9
0.3
0.2
$ 16.2
$ 16.1








Net Present Value
(Millions $)
Discount Rates:
4%



$ 26.0
$ 24.1


$ -10.8
$ -10.9
$ > 0.0
10%



$ 15.6
$ 14.4


$ -8.9
$ -9.0
$ >0.0
  Assumes  no  latency  period  for  assessing  health  and  welfare effects for  PM , lead and arsenic
  ASARCO-E1  Paso  Scenario  1  assumes  that  15%  of  the arsenic emissions escape the primary
  vent hood  and  Scenario  2 assumes  that 3.75% of  the  arsenic emissions escape.
  Phelps Dodge Scenario  1  risks  8ire  based  upon standard exposure analysis.  Scenario 2 risks
  are based  upon  site-specific analysis ( ISCLT/Val ley model).
  The expected benefit  per ton vailue  for  reductions in PM  is $2,400/ton.
  present  value  greater  than zero with a  discount rate of  4% (scenario A)
  ton value  must  be  at  least $3,400/ton.   The benefit per  ton value given
  rate (Scenario  B)  must  be  at loast $3,800/ton.
To achieve a net
 the PM benefit per
a 10% discount
Source:  Tables 5.1  and  5.2

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                                -27-

Equity
    EPA may also"consider whether a standard meets an equity objec-
tive, rather than an economic efficiency objective.  For example,
the conference  might think that controls should apply in all circum-
stances where maximum lifetime risk equals or exceeds 1 in 1,000.
This risk level  existed at three smelters - El  Paso, Hayden, and
Douglas.  However, the final  EPA standard required application of
controls at only one facility (El Paso).

Legislative Consistency
    An overriding risk management issue is whether the final decision
was consistent  with the requirements of the Clear Air Act.  As
required by section 122(b)(l)B of the Act, standards must be set
"at the levels  which in [the  Administrator's] judgment provides an
ample margin of safety to protect the public health" from inorganic
arsenic emissions.

    EPA interprets section 112, as applied to non-threshold pollu-
tants, as a judgment about the degree of control  that can be considered
amply protective.  Two choices are available:  either to set the
standards at zero to eliminate the attributable health risks, or to
permit some residual risk.  In the absence of a specific directive on
this choice in  section 112, and in recognition  of the drastic
economic consequences that could follow from a  requirement to
eliminate all  risk from hazardous pollutant emissions, EPA believes
that it is not  the intent of  section 112 to eliminate all risks.
Standards that  permit some level  of residual  risk can be considered

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                                -28-

to provide an ample margin of safety to protect public
health.  Therefore," EPA set the emission standards for inorganic
arsenic at a level that may present some human health risk.

    The National  Resource Defense Council  ( NRDC) is. chal 1 engi ng
EPA's interpretation of section 112.  It thinks that basing standards
on the Best Available Technology places too  much emphasis  on non-
health issues, such as technologyi economics, and affordability.
Further, NRDC holds that protecting public health, rather  than the
costs and the availability of technology,  should be the primary
consideration in  developing section 112 standards.

    EPA's General  Counsel  ruled that EPA could not take the PM and
Pb benefits into  account in choosing the final standard.   If it
had the legal  authority, it might have required emission  controls
at the smelter at  Douglas as well as at El  Paso.

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                             References


Travis,  C.C.,  S.A.  Richter,  E.A.C.  Crouch,  R.  Wilson,  and E.  Klema
  (1987).   "Cancer  Risk Management  By Federal  Agencies."   Environ-
  mental  Science and Technology,  forthcoming.


U.S. EPA (1986). "Inorganic  Arsenic Emissions  from Primary Copper
  Smelters  and Arsenic  Plants -  Background  Information for Promul-
  gated  Standards."   EPA-450/3-83-010b.


U.S. EPA (1986).  National  Emission Standards  for Hazardous Air
  Pollutants;  Standards for  Inorganic Arsenic."  Federal  Register
  51 (149) :   27957-28042.


U.S. EPA (1985). "Costs and  Benefits of Reducing Lead  in  Gasoline".
  Final  Regulatory  Impact  Analysis.  EPA-230-05-85-006.
                                                      p

U.S. EPA (1984).  "Health  Assessment Document  for Inorganic Arsenic,"
  EPA-600/8-83-021f.


U.S. EPA (1983). "Benefits  and Net  Benefits Analysis for  Alternative
  National  Ambient  Air  Quality Standards  for Particulate  Matter."
  Final  Regulatory  Impact  Analysis.

U.S. EPA (1983).  "Guidelines for Performing Regulatory  Impact
  Analysis."   EPA-Z30-1-84-003.


U.S. EPA (1983).  "National  Emission Standards for Hazardous  Air
  Pollutants;  Proposed  Standards  for Inorganic Arsenic."   Federal
  Register  48  (140):  33112-33180.


U.S. EPA (1980).  "National  Emission Standards for Hazardous  Air
  Pollutants:   Addition of  Inorganic Arsenic to List of  Hazardous
  Pollutants."  Federal  Register  45 (110):   37886-37888.

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