Rnal Report of the
Philadelphia integrated Environmental
                  Management Project


                        Executive Summary
                               EPA
                      Regulatory Integration: Division
                         Office of Policy Analysis
               Office of Policy, Planning, and Evaluation
                 U.S. Environmental Protection-Agency
                              December 1986

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                        EXECUTIVE SUMMARY

                     Philadelphia Integrated
                Environmental Management Project
INTRODUCTION

     The Philadelphia Integrated Environmental Management Project
(IEMP) was an innovative study designed to analyze and address
the problems posed by toxic chemicals in the Philadelphia area.
This project became a prototype for a series of lEMPs that the
U.S. Environmental Protection Agency (EPA)  has conducted over the
last four years.   The Project's goals were, therefore, both to
provide insights  on particular environmental issues and to
develop new general methods.  Our objectives were:

       •  To develop a methodological approach to evaluating and
          comparing the risks to human health caused by exposure
          to toxic pollutants in the environment, as measured by
          cancer  and, to a lesser degree,  other chronic health
          effects

       •  To use  this evaluation to help local officials in the
          process of setting priorities for more detailed analy-
          sis and, where appropriate, regulatory controls

       •  To involve local government agencies in the development
          and review of the analysis

     The concept  of integrated environmental management developed
out of EPA's recognition that there are drawbacks to the tradi-
tional approach that EPA and the states have used to develop
environmental regulations.  That approach  has focused on indi-
vidual industries, pollutants, and media.   While very useful, it
has nevertheless  limited our ability to determine where among the
various media our resources are best employed to get the most
health protection.  It does not ensure that pollution controls
are not merely shifting risk from one medium to another.  In
addition, we have often used national standards that do not ade-
quately address all site-specific situations.

     In contrast, the IEMP approach provides a multimedia analy-
sis of issues and accounts for transfers of toxics across media—
in land, air, surface water, and ground water.  It is founded
principally on the concepts of risk assessment and risk manage-
ment.  Risk assessment requires a systematic evaluation of the
potential for adverse effects to human health from exposure to

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pollution.  Risk management is a process for evaluating pollution
controls in terms of their projected cost and the level of risk
reduction they afford.  Finally, we use the IEMP approach to
focus on the issues of one community at a time, so we can develop
environmental management strategies tailored to each area's
unique problems and characteristics.


Risk Assessment

     The IEMP uses risk assessment techniques to evaluate and
compare the potential problems from toxic pollutants in the air,
land, and water.  In Philadelohia, we focused specifically on
assessing the risks in air, surface water, and drinking water.
At times this work was qualitative in nature.  However, in other
situations, we were able to provide quantitative estimates of the
probability that an individual would contract cancer and of the
expected cancer incidence in the entire population.  Our tech-
niques for estimating health effects are in accordance with stan-
dard EPA practices, as described in the proposed EPA risk assess-
ment guidelines.  Despite these standards, our analysis has some
significant uncertainties, which we elaborate below.  The goals
of our risk assessment in Phase I of the Philadelphia IEMP were
(1) to determine which toxics issues were suitable for a more
detailed examination of risks and control options in Phase II and
(2) to identify study topics for which we would initiate ambient
monitoring programs to better assess exposure levels and, in some
cases, potential risks.


Risk Management

     Risk management is the process by which policymakers balance
programs to reduce human health risks against the available
resources to support those programs.  In its simplest form, it
requires an examination of how large the risks are, how much the
risks can be reduced by various regulatory controls, and the
costs of these controls.  However, it often entails a lot more.
It can involve consideration of the strength of evidence we have
that a health problem could exist or whether effective regulatory
controls can be enforced.  Risk management is a process that
requires an assessment of all pertinent information before deci-
sions are made to control pollution.  Sometimes the appropriate
decision may be to conduct further analysis of the problem.  In
Phase II of this study, we dedicated a significant amount of
effort to providing the data and analysis that serve risk manage-
ment needs.   This is especially true of areas where we carried
out further problem definition through ambient monitoring or
performed cost-effectiveness analyses to allow local policymakers
to examine risk reductions and costs of controls for general
policy evaluation.

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Choice of Location

     Philadelphia was chosen as the site of this pioneering study
because it provided a good setting for the examination of multi-
media issues.  The City offered the benefits of several rela-
tively good toxics databases and local officials who we believed
provided a strong technical resource for project implementation.
Philadelphia was not chosen because it had significant environ-
mental problems.  Local officials had already demonstrated exem-
plary leadership in some areas.  EPA and local officials wanted
to explore ways to identify, assess, and manage human health
risks in an area where significant progress had been made in
understanding and controlling toxics issues.


Conclusions

     In the following sections we discuss the methodological and
substantive conclusions from the Philadelphia TEMP.   First, we
review our activities in Phase I, largely devoted to screening
pollution issues, and report our findings.  Second,  we present
findings from our Phase II risk assessment and control-options
analysis.  We also discuss the limitations in conducting risks
assessments of toxics.  Third, we summarize our methodological
findings from the ambient monitoring programs and the substantive
insights gained from these activities.  Finally, we close with
observations on our application of the IEMP methodology in
Philadelphia.
SUMMARY OF PHASE I OF THE PHILADELPHIA
IEMP PROCESS AND FINDINGS

     Phase I consisted of three major activities:

       •  Establishing two intergovernmental committees.   The
          first was the Steering Committee, which included pri-
          marily senior appointed officials from all participat-
          ing jurisdictions and EPA.   The other group,  the Tech-
          nical Committee, consisted  of technical staff from the
          environmental agencies.  The Steering Committee
          directed the study.   The Technical Committee  reviewed
          and guided the technical and scientific activities.

       •  Gathering and reviewing data.  We collected data to
          assess the potential effects of human exposure  to toxic
          chemicals.  In some  instances,  data directly  useful for
          measuring exposure were already available, e.g., data

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          on the quality of finished drinking water.   In other
          cases, especially in the case of air,  we estimated the
          expected concentration of a compound in the environment
          using data on pollutant sources and the manufacturing
          processes, which were used to run fate and  transport
          models.  After gathering available data, we organized
          it to facilitate easy review by those on our project
          committees who had considerable knowledge about the
          quality of the data.  We relied heavily on  their expert
          judgment.

       •  Developing a screening process for identifying critical
          toxics issues for detailed assessment in Phase II.
          Once we had collected,organized, and reviewed the
          preliminary data, we narrowed the project's geographic
          and analytical scope.  We set project priorities on the
          basis of the primary criteria:  quantitative and quali-
          tative measures of risk.  Then we applied secondary
          criteria.  These criteria included EPA, state, and
          local program objectives, the analytical feasibility of
          examining the issues, and our ability to control
          environmental impacts.

     After applying the screening criteria, which narrowed down
our original list of 170 pollutants associated with over
376 ooint and area sources, we arrived at a subset of 17 sources
of nine toxic chemicals released to the ambient air and surface
water and contained in drinking water.  These sources and chemi-
cals constituted our Phase II study topics, which, along with our
analytical activities and objectives, are set out in  Table 1.

     We emphasize that not all study topics had the same objec-
tives.  We also note that we could not analyze each issue with
the same degree of technical rigor.  Finally, the Phase I results
warrant two concluding remarks:

       •  We successfully identified a manageable set of multi-
          media topics that could be usefully examined with
          available EPA resources and analytical methods and that
          would address issues of interest to the community.  Our
          Phase II efforts would focus on toxic chemicals in air
          from point and area sources, toxics in finished drink-
          ing water, and intermedia transfers of toxics from the
          City's major POTW.

       •  We had to exclude some important environmental issues
          early in Phase I of the Philadelphia IEMP,  for several
          reasons.  First, limited resources required that we set
          priorities among possible topics.  Second,  limited data

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          Study Topics
                                              Taole 1

                                         PHILADELPHIA IEMP

                         OVERVIEW OF PHASE II  STUDY TOPICS AND ACTIVITIES



                                     Analytical Activities
          Objectives
                                       Riak And Control-Option* Analysis
   -Identified through screening of
    available data

   -Addressed 7 of the 11 initial
    screening issue papers

    - Benzene emissions
    - Area sources of solvents
    - Refinery, pipeline, and
      terminal emissions
    - Baxter drinking water
    - Queen Lane/Belmont drinking
      vtater
    - Multimedia discharges of
      1,2-OCE and 1,2-OCP
    - Haloforms (chloroform)
                                —Monitor ambient air

                                —Monitor ambient water

                                —Validate emission estimates

                                —Recalculate exposures and risks
                                  using air dispersion models

                                —Identify feasible controls

                                —Calculate control costs and
                                  removal efficiencies

                                —Develop model to evaluate and
                                  rank cost-effective control
                                  option strategies

                                —Provide results in useful format
                                  for review by decision makers
—Determine baseline exposures

—Identify which sources, pollu-
  tants, and exposure pathways
  contribute most significantly to
  estimated human health risk

—Develop cost-effective strategies
  for reducing risks to human
  health:

  - Aggregate excess cancer
    incidence
  - Risks to the Most Exposed
    Individual

—Examine noncarcinogenic risks

—Identify limitations of analysis
                                                Monitoring
1.  Benzene Emissions  (specifically
    from gasoline marketing)

    —Identified by Philadelphia as
      a topic of interest
2.  formaldehyde Ralessaa to the
    Aabient Air

    —Identified by Philadelphia as
      a topic of interest
3.  Coabustion of Used Oil

    —Identified by all study
      participants aa a topic of
      interest
                                 -Short-term benzene ambient air    —Determine significance of
                                  monitoring at selected intersec-    observed concentrations
                                  tions with and without service
                                  stations                            - Philadelphia air guidelines
                                                                      - Cancer risk
                                —Ambient air monitoring            —Determine significance of
                                                                      observed concentrations

                                                                      - Philadelphia air guidelines
                                                                      - Cancer risk
                                 -Sampling at points of distribu-   —Compare observed used oil concen-
                                  tion and use                        trations with EPA fuel specifica-
                                                                      tions
                                 -Analysis of samples for metals
                                  and organics
4.  Air Emissions froa Landfills
    (focusing specifically on New
    Jersey landfills)

    —Identified by New Jersey and    —Short-term monitoring at a select —Identify compounds and observed
      EPA as a topic of interest        number of sanitary and hazardous    concentrations
                                        waste landfills in New Jersey
    —Satisfied EPA interest in test-   (but within geographic boundary   —Determine significance of
                                        of project)
ing the applicability of a
mobile monitoring system for
use in future geographic
studies
  measured concentrations

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          restricted the extent of our analysis.  Third, certain
          research and analytical methods now in practice were
          not available at the time of the study.  Changes in any
          of these factors probably would have altered our selec-
          tion of issues.  We wish to emphasize that the absence
          of an issue from our list of study topics does not mean
          that the issue is insignificant.
PHASE II FINDINGS

     In the following sections we present the findings of the
analytical efforts to characterize risks to human health and
examine the cost-effectiveness of control options to reduce these
potential hazards.  We also discuss our conclusions from the
ambient monitoring programs.  Tn each area, we summarize both
methodological and quantitative results.  Since the Philadelphia
IEMP was a pilot study, we believe that both types of findings
are important for consideration.


Baseline Risk and Control-Options
Analysis for Policy Development

     Methodology

     We were successful in designing an analytical approach that
could be used by decision makers to identify which environmental
issues present the most significant risks,  roughly quantify the
magnitude of these risks, and evaluate the cost-effectiveness of
various control strategies to reduce the risks that we could
quantify.  We were successful for several reasons:

       •  We were able to enlist the critical participation of
          the members of our project committees,  most notably the
          representatives of the Philadelphia Water Department
          and Air Management Services (AMS).

       •  The AMS emissions inventory allowed us  to select a
          limited number of pollutants and sources that contrib-
          uted most significantly to ambient "air  releases of the
          toxic pollutants included in our analysis.  Without
          this inventory, it would have been extremely difficult
          to narrow the scope of the project.

       •  We employed existing EPA analytical methods used in
          Agency research and rulemaking activities to generate
          much of the data and our analytic results.  We tailored
          their application to our site-specific  needs.

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     Limitations and Uncertainties

     The success of providing an analytical approach to evaluate
the risks to human health and the cost-effectiveness of alter-
native control options to reduce these risks must be appreciated
in the context of the uncertainties associated with this work.
We discuss below the limitations in the project scope, exposure
data, toxicological data, and estimates of the cost of controls.

     Limitations in Scope.  The Philadelphia IEMP was not an
epidemiological study.  We did not collect data on diseases that
occurred in local populations or attempt to trace their causes,
environmental or otherwise.  Instead, we combined local data and
engineering estimates of environmental exposure to toxic chem-
icals with toxicological data to estimate the risks to human
health.

     The Philadelphia IEMP only attempted to estimate the health
risks from exposure to toxic chemicals in the ambient environ-
ment.  For example, we did not estimate risks resulting from
occupational and indoor air exposures.  We also did not include
exposures through the food chain.  The omission of these routes
of exposure in our study does not imply that they are unimpor-
tant.  It is quite possible that risks from any of these exposure
pathways could exceed risks from the exposures we considered.   We
decided not to assess these exposure routes because of resource
constraints and because these areas were generally outside of
EPA's traditional regulatory purview and area of expertise.

     We chose not to analyze the exposure and risks from conven-
tional pollutants in air and water (such as ozone and sulfur
oxides in air, and oxygen-depleting substances and oil and grease
in water) because we believed that we could make a more signifi-
cant contribution by concentrating on toxic chemicals, which are
neither as well understood nor as well regulated.  Future proj-
ects, however, may want to consider these pollutants.

     Limitations in Exposure Data.  Another important limitation
to our analysis is that we did not examine exposures associated
with all sources and pollutants.  While we tried to identify and
assess the cancer risks from the most significant sources and
pollutants,  some of those for which we were unable to estimate
exposure, such as combustion of used oil, may also pose health
risks.

     Even where exposure data were available, those data varied
significantly in quality.  As a result, the exposure estimates
vary in their reliability.  Those based on extensive monitoring,

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such as for trihalomethanes in drinking water and selected chlor-
inated solvents in air, are the best exposure estimates we have.
The exposure data from short-term ambient air monitoring for
benzene from service stations and formaldehyde are much more
uncertain.

     Exposure estimates derived from modeling also vary in their
reliability.  Estimates of exposure to toxic organic chemicals in
air derived from dispersion models are dependent primarily on the
quality of the emissions data and a few other factors, such as
meteorological data.  In general, the uncertainties introduced by
the exposure data are probably much smaller than those associated
with the dose-response information used to estimate human health
risks.

     Limitations in Toxicological Data.  Estimates of health
effects are designed to be conservative in several ways.  When
evaluating potential health hazards from a chemical, EPA scien-
tists assume that health effects observed in laboratory animals
are a reasonable indicator of potential effects in humans.  In
converting the animal data to estimate predicted human responses,
and in extrapolating from high doses to low doses, we use models
that yield a plausible, upper-bound estimate of potency rather
than a "best guess" estimate.

     Many substances of potential concern have never been evalu-
ated scientifically, or have not been evaluated in sufficient
detail to allow estimation of effects on humans.  For example,
lead (present in air, water, and dust) is thought to pose a
health risk to children at ambient levels; however, at the time
we conducted this project, we had no way of estimating individual
risks or numbers of possible cases.

     The addition of new toxicological data and revised scienti-
fic interpretations of previous animal studies often leads to
revised potency values.  This makes risk assessment of various
chemicals subject to changes in scientific understanding.  Since
the time we completed our Phase II analysis, several unit risk
factors used have been revised by EPA's Carcinogen Assessment
Group (GAG).  However, these revisions do not appear to change
our findings dramatically.

     We relied on CAG unit risk factors for all chemicals except
1,2-dichloropropane.  We developed the inhalation and ingestion
unit risk factors for 1,2-dichloropropane using the (potency)
qi* value found in EPA's Drinking Water Criteria Document on
1,2-dichloropropane (March 2, 1984).  The Drinking Water Criteria
Document is nearing completion of external review and, as a
result, the unit risk factor for 1,2-dichloropropane could
change.

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     Despite these uncertainties, our risk estimates are useful
policy analysis results for comparing issues with one another;
setting priorities among environmental issues and concerns that
we examined; and roughly assessing the potential magnitude of the
overall risks from particular pollutants, sources, and pathways.

     Limitations In Estimates of the Cost of Controls.  For a
variety of reasons, we were unable to obtain complete site-
specific control cost information for all plants in our control-
options analysis.  We were able to gather, with the assistance of
AMS, detailed information about the manufacturing process and
variations in production levels for many plants.  Many of the
estimates are based on best engineering judgments, using standard
cost estimation techniques employed in EPA regulatory activities.


Risk Assessment and Control-
Options Analysis Results

     Within the limitations described earlier, we are able to
draw the following conclusions about the nine pollutants and 17
sources we investigated.^-  The reader should be careful not to
construe any risk estimates presented below as predictions of
actual cancer risk in Philadelphia.  Actual risks may be signifi-
cantly lower; in fact, they could be zero.  The unit risk factors
used in this analysis are based on conservative assumptions that
generally produce upper-bound estimates.  Because of limitations
in data and methods in several areas of the analysis, such as
exposure calculations and pollutant selection, risk estimates
were calculated as aids to policy development.  The proper func-
tion of the estimates is to help local officials select and eval-
uate issues, set priorities, and develop control strategies for
the topics examined.

     1.   Our upper-bound estimate of aggregate excess cancer
          incidence for the general population of about 1.7 mil-
          lion in Philadelphia was close to three cases per
          year.2  Drinking water accounted for over four-fifths
          of the estimated excess cancer risks we found in our
          analysis.  Table 2 shows the upper-bound excess cancer
          risks by source category and exposure pathway.  The
^•Unless otherwise noted, all conclusions on risk and control
 strategies are based on the results from our original  (1984)
 analysis using the environmental and health data available at
 that time.
2it is important to consider the opening caveat in the  beginning
 of this section as each, risk number is read.

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                                              Table 2

                                        PHILADELPHIA IEMP

                        PHASE II RESULTS INTENDED FOR POLICY DEVELOPMENT1

                UPPER-BOUND ESTIMATES OF EXCESS ANNUAL CANCER INCIDENCE BY SOURCE

                                         CURRENT CONTROL

                                         (1984 analysis)2
     Sources
Air (point)
  Pharmaceutical Manufacturer
  Chemical Manufacturer
  Garment Manufacturer
  Plastic Cabinet Manufacturer
  Industrial Dry Cleaner
  Refinery B
  Refinery A
  Northeast MPCP3

    Subtotal

Air (area)
  Degreasing
  Dry Cleaning
  Other Industrial Usage
  Gasoline Marketing (excluding self-service)
  Sewer Volatilization (NEMPCP)
  Delaware River (receiving NEWPCP effluent)

    Subtotal

Drinking Water
  Baxter DWTP
  Belmont DWTP
  Queen Lane DWTP

    Subtotal

    Total4
Estimated Excess
 Annual Cancer
   Incidence5
  (cases/year)
    .006
    .007
    .001
    .000
    .000
    .066
    .007
    .090

           .177
    .049
    .064
    .003
    .053
    .021
    .024

           .214
   1.221
    .447
    .770
  Percentage
 Breakdown of
the Total 2.8
    Caaea
     .28
     .28
     .08
     .08
     .08
    2.38
     .28
    3.28

           6.38
    1.78
    2.38
     .18
    1.98
     .78
     .88
   43.18
   15.88
   27.28
                               7.68
          2.438
                              86.28
   2.8
  100.08 (Note:
1008 is equal
    to 2.8
  cases/year)
WPCP - Water Pollution Control Plant.
DWTP = Drinking Water Treatment Plant.

Note:  Numbers have three decimal places not aa an indication of precision,  but to
       identify source contribution to the risks.
     UNIT RISK FACTORS USED IN THIS ANALYSIS ARE BASED ON CONSERVATIVE  ASSUMPTIONS THAT  GENERALLY
 PRODUCE UPPER-BOUND ESTIMATES.  BECAUSE OF LIMITATIONS IN DATA AND METHODS IN SEVERAL AREAS OF
 THE ANALYSIS, SUCH AS EXPOSURE CALCULATIONS AND POLLUTANT SELECTION,  RISK ESTIMATES WERE  CALCU-
 LATED AS AIDS TO POLICY DEVELOPMINT, NOT AS PREDICTIONS OF ACTUAL CANCER RISKS IN PHILADELPHIA.
 ACTUAL RISKS MAY BE SIGNIFICANTLY LOWER; IN FACT,  THEY COULD BE ZERO.   THE PROPER FUNCTION OF  THE
 ESTIMATES IS TO HELP LOCAL OFFICIALS SELECT AND EVALUATE ISSUES,  SET  PRIORITIES,  AND DEVELOP
 CONTROL STRATEGIES FOR THE TOPICS EXAMINED.
2The risk estimates presented in this table were calculated using  unit  risk  factors from  1984.
'Recent reductions in discharges to the NEWPCP may  result in lower risk numbers than presented  in
 this table.
^Columns may not sum due to rounding.
5IEc, Inc., Coat-Effectiveness Analysis of Strategies to Reduce Human  Health Risk  in Philadelphia.
 U.S. EPA. May 1985.

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                              11
         compound responsible for most of the estimated upper -
         bound excess cancer incidence in drinking water was
         chloroform, a trihalomethane.  Chloroform's presence in
         finished drinking water is a byproduct of the process
         for disinfecting the water.  Chloroform concentrations
         in the Philadelphia drinking water are less than half
         of EPA's primary interim drinking water standard.

         For the nine pollutants and 17 sources we investigated,
         we estimated an upper-bound incidence of nearly three
         cases per year of cancer in a city that had about 4,500
         die of cancer in 1984.3,4  This point helps place our
         analysis in context.  Additional perspective on our
         findings could be gained by examining estimated cancer
         risks from environmental exposures developed independ-
         ently of this study.  For example, recently available
         data suggest that it is quite possible that the risks
         from indoor air exposures may be significantly higher
         than those from ambient air exposures and those of the
         other risks we examined in this study.

         Less than one-fifth of the estimated three cases
         (upper-bound) per year were attributable to exposures
         in air and are divided about evenly between point and
         area air sources.3  Table 2 shows the different air
         source categories we analyzed and the estimated cancer
         incidence associated with exposures to ambient air
         releases from^sach.  The traditional point sources
         (i.e., smokestack industries) were accountable for a
         modest percentage (nearly 3 percent) of the risks we
         could quantify.

         Roughly one-third of the 0.4 estimated annual cancer
         cases (upper-bound) from exposure to air toxics risks
         is attributable to intermedia transfers (from water to
         air) resulting from industrial wastewater discharges to
         the Northeast Water Pollution Control Plant (NEWPCP).3
         Roughly two-thirds of the estimated upper-bound excess
         cancer risks from these intermedia transfers occur at
         the sewage treatment plant itself.  The remaining one-
         third is split fairly evenly between volatilization
         from the major sewer line into the NEWPCP and volatil-
         ization from the discharge to the Delaware River.
   is important to consider the opening caveat in the beginning
of this section as each risk number is read.
We should note that on average the annual number of cancer cases
could be nearly twice the number of annual deaths from cancer
(based on 1983 American Cancer Society national data).

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                              12
         Recent reductions in discharges to the NEWPCP and
         operational changes may result in lower risk numbers
         than presented in the report.

         We found that the cumulative upper-bound cancer risks
         from multiple chemical exposures are greater than
         single-chemical risks by a factor of 10 and, in some
         cases, by a factor of 100.  EPA's regulatory actions
         often focus on individual pollutants, such as the list-
         ing and control decisions for hazardous air pollutants
         under Section 112 of the Clean Air Act, and do not
         account for the cumulative risks that may occur from
         exposure to multiple chemicals.

         We found no concentrations of toxic chemicals that
         warrant increased concern about noncarcinogenic
         effects.  However, independent monitoring information
         (e.g., AMS's breathing zone study) indicated that ben-
         zene concentrations could pose some concern.  A better
         determination of the significance of these concentra-
         tions will depend on where the "no-effect" thresholds
         for benzene, which are currently under internal EPA
         review, are finally set.

         People could experience upper-bound individual lifetime
         risks of cancer of around 1 in 10,000 from their drink-
         ing water and in some cases of air exposure.5  However,
         upper-bound risks to the maximum exposed individuals in
         air generally are above 1 in 100,000.  Table 3 shows
         the upper-bound risks to the maximum exposed individual
         (MED from air and drinking water.

         Decision makers wanting to achieve different levels of
         risk reduction will need to employ different control
         strategies.  For example, to reduce risks by less than
         20 percent, the most cost-effective control strategies
         focus solely on lowering ambient air releases of
         toxics.  However, to achieve significantly greater
         reductions in risk, some previously recommended air
         controls may be replaced by controls at the drinking
         water treatment plants.  Controls at the drinking water
         treatment plants can achieve large, discrete reductions
         in risk, as opposed to the smaller, incremental reduc-
         tions, achievable through air emission controls at
         different sources.
It is important to consider the opening caveat in the beginning
of this section as each risk number is read.

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                                   Table 3

                               PHILADELPHIA IEMP

                   PHASE II RESULTS INTENDED FOR POLICY DEVELOPMENT1

                UPPER-BOUND ESTIMATES OF CUMULATIVE LIFETIME CANCER RISKS
                           TO THE MOST EXPOSED INDIVIDUAL

                                (1984 analysis)2


                                                           Cumulative Lifetime
                   Cumulative Lifetime     Cumulative Lifetime       Total Cancer Risk
                      Cancer Risk           Cancer Risk       (Upper-Bound) Inhalation
ME I Location        (Upper-Bound) Inhalation (Upper-Bound) Inqestion      and Inpestion

Northeast WCP3           5.6 x 10~5            1.0 x 10"*             1.6 x 1CT4
Refinery 8               1.4 x 10"5            1.0 x 10~4             1.1 x 10~4
Chemical Mfr.             2.2 x UP*            1.0 x 10'4             3.2 x 10'4
Plastic Cabinet Mfr.       6.5 x 10~6            1.0 x HT4             1.1 x 10~4
Pharmaceutical Mfr.        4.5 x 10"5            1.0 x HT4             1.4 x 10"4
Garment Manufacturer       1.2 x 10'5            1.0 x 10"4             1.1 x 10'4
Refinery A               3.0 x HT5            1.0 x 10"4             1.3 x 10"4
Industrial Dry Cleaner      2.2 x UP5            1.0 x 10'4             1.2 x ID'4
    UNIT RISK FACTORS USED IN THIS ANALYSIS ARE BASED ON CONSERVATIVE ASSUMPTIONS THAT GENERALLY
 PRODUCE UPPER-BOUND ESTIMATES.  BECAUSE OF LIMITATIONS IN DATA AND METHODS IN SEVERAL AREAS OF
 THE ANALYSIS, SUCH AS EXPOSURE CALCULATIONS AND POLLUTANT SELECTION, RISK ESTIMATES WERE
 CALCULATED AS AIDS TO POLICY DEVELOPMENT, NOT AS PREDICTIONS OF ACTUAL CANCER RISKS IN PHILA-
 DELPHIA.  ACTUAL RISKS MAY BE SIGNIFICANTLY LOWER;  IN FACT, THEY COULD BE ZERO.  THE PROPER
 FUNCTION OF THE ESTIMATES IS TO HELP LOCAL OFFICIALS SELECT AND EVALUATE ISSUES, SET PRIORI-
 TIES,  AND DEVELOP CONTROL STRATEGIES FOR THE TOPICS EXAMINED.
2The risk estimates presented in this table were calculated using unit risk factors from 1984.
'Recent reductions in discharges to the NEWPCP may result in lower risk numbers then presented in
 this table.

Source: lEc, Inc., Cost Effectiveness Analysis of Strategies to Reduce Human Health Risk in
       Philadelphia. U.S. EPA, May 1985.
  9.    Philadelphia  would  have to  implement  controls  at  the
        drinking  water  treatment plants  to  reduce most of  the
        estimated upper-bound  excess  cancer  incidence  for  the
        sources and pollutants  considered in  our analysis.    It
        is  important  to  recognize,  however,  that the upper-
        bound  estimated  individual  risk  associated  with inges-
        tion of Philadelphia drinking water  is  smaller than the
        current nationally  accepted risk for  drinking  water,
        based  on  the  concentrations established by  EPA's  pri-
        mary interim  drinking  water standards.

  10.   The City  would need to  make significant expenditures
        for controls  at  its treatment plants  to reduce most of
        the estimated risks from drinking water.   This situa-
        tion presents local decision  makers  with a  difficult

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                    o
                                Figure 1
                       Philadelphia IEMP
Phase II Results Intended for Policy Development1
       Cost vs. Reduction in Cancer Incidence
                       Air and Drinking Water
                  Percentage Reduction in  Cancer Cases
                   30      40      50      60       70
      Total
   Annual Cost
(millions of dollars)
                                                                                     Percentage
                                                                                    of Maximum
                                                                                    Control Cost
                -10
                                                 1            1.5             2
                                           Number of Cases Reduced per Year
                                                                  2.5
2.8
  1 The unit risk factors used in this analysis are based on conservative assumptions that generally produce upper-bound estimates. Because of limitations in data
   and methods in several areas of the analysis, such as exposure calculations and pollutant selection, risk estimates were calculated as aids to policy development,
   not as predictions of actual cancer risks in Philadelphia. Actual risks may be significantly lower; In fact, they could be zero. The proper function of the estimates
   is to help local officials select and evaluate issues, set priorities, and develop control strategies for the topics examined.

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                          15
     risk management decision, involving the examination of
     the amount of risk reduced, the control costs, and
     other factors.  Reductions in the upper-bound estimated
     cancer risks from drinking water can be achieved by
     reducing chloroform levels through the use of granular
     activated carbon (GAC) filters.  These controls reduce
     the chloroform that forms in drinking water following
     disinfection.

     In our cost-effectiveness analysis, we incrementally
     added GAC controls to each drinking water treatment
     plant to achieve increasing levels of risk reduction.
     The results of our analysis suggest that implementing
     GAC at the Belmont drinking water plant only could
     reduce approximately one-fifth of the estimated drink-
     ing water risks.  Implementing GAC at all three drink-
     ing water plants could reduce nearly all the estimated
     cancer risk.  The annual costs of these controls would
     range from roughly $11 million to $58 million.  The
     average cost per cancer case avoided ranges from around
     $24 million to $26 million, depending on the drinking
     water treatment plant controlled.  The value of the
     reduction depends on what other risk reduction oppor-
     tunities are possible for these same expenditures and
     the value of other social services that could use these
     resources.

11.  For the range of control options we examined, we did
     not see any dramatic increase in the cost per case
     avoided as we pursued additional control strategies to
     raduce further increments of risk.  Figure 1 illus-
     trates our results.  Typically one would not expect
     such a linear relationship; rather, one would expect
     that, as costs increase, a larger fraction of the
     potential risk could be reduced for a significantly
     smaller portion of the cost.  We attribute this result
     to two factors affecting the dominant sources of risk
     (i.e., the drinking water treatment plants).  First,
     the available inexpensive controls, such as switching
     from chlorine to chloramines as the residual disinfec-
     tant, have already been implemented.  Second, as noted
     above, the increase in risk reduction would be achieved
     by applying the same control technology (i.e., GAC
     filters) to additional drinking water treatment plants.
     In practice, the City would most likely implement
     controls at all three drinking water treatment plants
     to further remove contaminants in the City's drinking
     water supply.

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                               16
     12.  Some controls to reduce air risks would save money.
          These controls included product and solvent recovery.
          These controls would reduce the estimated cancer risks
          from inhalation exposures by close to a tenth of the
          air risks we quantified and save over one hundred
          thousand dollars annually.

     13.  From a different vantage point, decision makers who are
          concerned about the risks to the MEI could realize a
          risk reduction of roughly an order of magnitude by
          implementing controls costing about $23 million
          annually.  Again, the value of that purchase depends on
          the community's priorities and the importance of pro-
          viding everyone with protection above the current
          level.

     14.  Our evaluation of the risks and costs of control was
          initially completed in 1984.  Our 1986 revision of the
          risk estimates, using more current environmental and
          health data, indicates that there would be little, if
          any, change in the conclusions discussed above.  The
          major changes noted in our analysis were in the cancer
          unit risk factors and reductions in the discharges from
          the chemical manufacturer to the NEWPCP occurring after
          completion of our monitoring programs in Philadelphia.
          The reduction in the industrial indirect discharges
          have undoubtedly led to lower volatilization rates from
          sewer lines, the sewage treatment plant, and the
          Delaware River.

     Readers of these conclusions should recognize that local
officials will be considering other information outside our anal-
ysis in using this study's findings.  They will evaluate the
control-options analyses we performed in a broader context of
other health, safety, and social services that they provide their
citizens.  We provide our findings to local policymakers to
assist them in their continuing efforts to set priorities among
environmental issues.
Monitoring Activities

     Our completion of various ambient monitoring programs leads
us to the following conclusions about our approach and about  the
substantive environmental issues we addressed in Philadelphia.

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                                17
     Insights for Future IEMP Studies

       •  Our ability to quantify differences between monitoring
          and modeling  results highlighted  the advantages  of
          using both techniques together to improve exposures
          assessments substantially.  Modeling, which relates
          source releases to ambient pollutant levels,  is  limited
          by the available information on sources and pollutant
          loads.  Monitoring, on the other hand, provides  infor-
          mation about  pollutants and sources for which one may
          know very little, but is not necessarily well-suited to
          pinpoint the  sources of toxic releases.  The  two in
          combination complement the strengths of each  and reduce
          the inherent  weaknesses of. both when used indepen-
          dently.

       •  Difficult technical and scientific problems in deter-
          mining ambient toxic pollutant concentrations can con-
          strain attempts to quickly fill in missing data.  In
          addition, one may be forced to use new and unproven
          monitoring techniques to gather the needed information.
          For example,  our experience in Phase II showed that the
          ROSE system is not well-suited for measuring  ambient
          air releases  from landfills.  In another example, the
          monitoring technique used by AMS to measure formalde-
          hyde levels in the ambient air has not yet been  proven
          to be reliable for quantifying formaldehyde concentra-
          tions at low  levels representative of ambient condi-
          tions.  Finally, in the two years since our use  of
          Tenax for ambient air monitoring, its use, effective-
          ness, and reliability have been called into question by
          scientists inside as well as outside EPA.  EPA is cur-
          rently exploring alternatives to Tenax.


Monitoring Results

     We gained important insights on environmental exposures from
our examination of benzene, formaldehyde, used oil, and landfill
air emissions.  The most important findings are stated  below.


     Benzene in the Ambient Air

       •  Average benzene concentrations at the Philadelphia
          intersections that we examined ranged from 5.4 micro-
          grams per cubic meter (ug/m^) to 22.3 ug/m^.  However,
          we were unable to distinguish between the influence of
          traffic versus gasoline marketing on ambient

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                                18
          concentrations.  From benzene concentrations at busy
          traffic intersections, we calculated rough
          approximations of average individual cancer risks
          (upper-bound, lifetime) that were  in a range comparable
          to drinking water and air risks we studied in more
          depth.

       •  A breathing zone study showed benzene concentrations
          during 14 refueling episodes that  ranged  from a low of
          1.5 ug/m^ to a high of more than 88,714 ug/m^.  Because
          of the small numbers of sampling events,  these values
          are only a limited indication of average  benzene con-
          centrations from refueling.


     Formaldehyde in the Ambient Air

     At the four sites monitored, average ambient formaldehyde
concentrations ranged 2.8 ug/m^ to 3.6 ug/m^.  These concentra-
tions are significantly lower than those measured in several
major cities nationwide.

       •  The average ambient formaldehyde concentrations are
          below the AMS ambient air quality  guideline for formal-
          dehyde.  However, when we considered the  individual
          sampling events at each site, we found a  few days on
          which the ambient concentrations exceeded the guide-
          line .

       •  Our 1984 rough approximations of average  upper-bound
          lifetime individual cancer risks at each  of the four
          monitoring locations showed risks  roughly comparable to
          most of the air risks examined above in the control-
          options work.  If we employ recent changes (1986) in
          the unit-risk factor for formaldehyde, we find the risk
          to be in a range that is roughly twice to 30 times
          that high.  Therefore, we now see  that formaldehyde may
          be a more significant health concern than many of the
          pollutants we looked at in our control-options work.


     Combustion of Used Oil

     A short-term sampling program (45 samples collected and
analyzed) was conducted in coordination with Philadelphia, the
State of Pennsylvania, and the State of New  Jersey.  Because of
the limited data, we have not estimated exposure and risk.  How-
ever, the data suggest that contaminated fuel oil contains lead
at levels that warrant further investigation.  For  all samples,

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                               19
the lead concentrations exceeded the recently promulgated EPA
standards for burning used oil.  However, the lead concentrations
in used oil will fall dramatically as the lead in gasoline is
phased out.


     Air Emissions from Landfills

     As noted above, the EPA field monitoring using the ROSE
system experienced serious equipment problems and resulted in
poor results.  Better data were collected by New Jersey using
different monitoring equipment.  While the New Jersey data are
too limited to assess exposure or risk: adequately, the results do
indicate that a fairly large number of toxic pollutants can be
emitted from landfills and that concentrations of volatile
organic compounds (VOCs) around landfills can be above urban
background levels.
OBSERVATIONS FOR THE FUTURE

     The Philadelphia IEMP has shown us that exercises to set
priorities across numerous environmental issues can be managed  to
provide useful information to local decision makers.  The project
has also revealed important practical limitations  in our ability
to apply the IEMP methodology.  Three of the most  important  les-
sons we learned are discussed below.

       •  It is essential to define the objectives and scope of
          the project in its early stages.  In Philadelphia  we
          learned that, because of methodological  and resource
          constraints, we cannot analyze every environmental
          issue.  It is therefore important to identify at the
          beginning of an IEMP the areas of greatest concern to
          the project participants and to set priorities among
          this subset of issues for analysis.  This allows the
          limited resources available to be used well on a man-
          ageable set of topics, rather than superficially on
          every potential issue in a community.

       •  The data and analytical methods available are very
          significant influences on the topics we  analyze and how
          we analyze them.  Major advances in methods for assess-
          ing noncarcinogenic risks and ecological damage could
          greatly increase the ability of lEMPs to aid local
          decision makers in priority setting.  Some environ-
          mental concerns may be given a low priority because we
          either know little about them or do not  currently  have

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                     20
the capability to analyze these issues.  Users of this
analysis should not misconstrue our results as state-
ments about priorities based on a comprehensive
assessment.

When we have reasonable knowledge about an issue, we
can conduct monitoring or perform analyses that may
shed new light on a subject.  Or, when data is the only
concern, we can collect some data even with our limited
resources if it appears that the increased base of
knowledge will improve local decision making.  For the
lEMPs, methodological problems can be much more
intractable, especially on very complex topics.

Two new methods, beyond the scope of any particular
IEMP, would greatly enhance our assessments:   (1) an
ability to quantify the noncarcinogenic risks  for com-
pounds present in the environment at concentrations
above the threshold, in ways analogous to carcinogenic
risk assessment, and (2) an ability to assess  ecosystem
effects.  Estimates of noncancer effects would allow
comparisons between cancer and noncancer problems and
provide insightful information for those responsible
for public health protection policies.  We then could
treat noncancer health concerns more equally with can-
cer concerns, which often seem more important  because
they can be quantified.  Methods for quantitatively
measuring risks to ecosystems currently do not exist in
any very sophisticated form.  It is, therefore, diffi-
cult to assess very rigorously the cost-effectiveness
of control options that reduce ecological risks or to
clarify for local decision makers the implications of
environmental issues that span cancer, noncancer, and
ecological concerns.

Finally, we found it essential to have representatives
from state and local public health and environmental
agencies participate in the project.  Local participa-
tion in this IEMP greatly enhanced the quality of the
analysis performed.  It also increased the amount of
available data, facilitated the communication  of com-
plex issues (such as risk assessment), and built credi-
bility into the project.  Also, since we cannot practi-
cally analyze all environmental issues, local  involve-
ment ensures that our limited resources are used for
priority setting and issue evaluation in the areas most
critical to the host community.  We believe direct
local involvement in this and future projects  is vital
to achieving sound results, essential to gaining local

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                     21
acceptance of the project findings, and critical for
using the IEMP approach to aid better environmental
policymaking in specific geographical locations.

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