AN  ASSESSMENT OF LUNG CANCER
                          FROM  THE 1984 TIRE  FIRE  IN
                              EVERETT,  WASHINGTON
    On September 24, 1984 a fire broke out in a scrap tire dump east of Everett which
contained more than a million tires. The tires burned for more than two months.  The
Puget Sound Air Pollution Control Agency requested that EPA perform a risk analysis
using data gleaned from selected ambient particulate matter samples from stations in
Everett and North Seattle operated by that agency.  These samples were analyzed for
selected products of incomplete combustion (including benzo(a)pyrene). These data
coupled with emission parameter estimates were then used to estimate risk to  the exposed
population. This document presents the results of the risk analysis.
                                   October,  1986

                       U.S.  Environmental Protection Agency
                                     Region  10
                                 1200 Sixth  Avenue
                             Seattle, Washington  98101

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                 U.S. ENVIRONMENTAL PROTECTION AGENCY
                                 REGION' 10
                               :200 £.:/T>- ^VLVJE'
                           SEATTLE. '.VASHINGTON 5cn.'<  '
  p«o^                                      GCT   8 1906

RF"IY
 TI N OF
            .,.<.
            "/»>
Mr. Arthur Dammkoehler
Air Pollution Control  Officer
Puget Sound Air Pollution Control  Agency
P.O. Box 9863
Seattle, WA  98109

Dear Mr. Dammkoehler:

    As you requested in your letter of November  20,  1985, we have  evaluated
the long term health risk from the Everett tire  fire.   We have confined our
health assessment to estimating the increased  cancer risk from inhalation
exposure to airborne particulates  emitted during the fire.  The  specific
contaminants evaluated were benzo(a)pyrene (B(a)P) and  a class of  compounds
called Products of Incomplete Combustion (PIC).   Attached is a report
summarizing the results of that assessment.

    Using EPA risk assessment methods, the analysis  indicated that those
individuals (4 of them) calculated to have the highest  exposure  to the tire
fire emissions may have an increased lung cancer risk from 2 in  one million to
2 in ten thousand.  Since exposure for other residents  living in the vicinity
of the fire was less,  their estimated lung cancer risks are also less
(substantially less for most).

    Because of the methodologies used these estimates represent  a  likely upper
bound of lung cancer risk - the actual risk is somewhere between zero and
these numbers.  It should also be  stressed that  there are many uncertainties
and assumptions involved in deriving these lung  cancer  estimates.   These are
summarized in the report.

    The U.S. EPA has not defined a cancer risk level which is considered to be
significant.  However, excess cancer risk levels above  1 in a million to 1  in
100,000 (10~6 to TO'5) generally give some cause for concern and suggest
that exposures should  be reduced.   To put these  numbers in perspective,
however, a lung cancer risk of 10~6 to 10~5 is equivalent to smoking about
5 to 50 cigarettes in  a lifetime.

    We appreciate the  support your staff provided in performing  this
assessment.  Should you have any questions about the results or  methodologies,
please contact Dana Davoli  at 442-1757.

                                      Sincerely,
                                      Gary O'Neal, Director
                                      Air and Toxics Division
Attachment

cc:  Dave Peterson,  Snohomish  Health  District

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     On September 2£, 198^, a tire ^ire began burrvng e:  trie  old  City of
Everett Landfill  in Everett, Kashi ngtors.  During t-ie first  few weeks of the
fire large quantities of smoke were released.  This fire  continued  to
smolder for about two months emitting smoke at gradually  decreasing levels.
The City of Everett, which is west of the fire, was at times  heavily
impacted by the plume.  Smoke was also dispersed to the east  and  to the
south toward Seattle.

     Limited air  monitoring for organic vapors was done around the  tire fire
by the U.S. Environmental Protection Agency's (U.S. EPA)  Technical
Assistance Team on September 28, 1984.  ("Tire Fire Investigation,  TAT
Activities Report", U.S. EPA, Region 10, October,  1984).  The results from
this one day of monitoring showed that high levels of some  compounds (e.g.,
benzene) were present in or very near the fire but dropped  off rapidly in
concentration within a half mile.  At the request  of the  Snohomish  Health
District, the Centers for Disease Control (CDC) reviewed  these data.  CDC
concluded that "concentrations of some chemicals in the immediate vicinity
of the fire were  high enough to pose a potential immediate  health threat to
individuals within 200 feet of the fire."  Personnel  at the scene of the
fire (e.g., firemen) were of most concern.   Persons living  beyond the
immediate area of the fire may have received transient exposure,  according
to CDC, resulting in a "temporary increased risk of acute short term health
effects" (e.g., respiratory impairment; eye, throat and respiratory
irritation).  CDC also stated that "we do not anticipate  any  significant
increased risk of long term health effects  nor can we conclude that
chemicals in the  smoke reached the public in sufficiently high concentration
to significantly  affect health."

     The Puget Sound Air Pollution Control  Agency  (PSAPCA)  has monitors
located in Seattle and Everett to measure levels of particulates  in the
air.  A sample collected from the Everett monitor  on September 28,  1984
(about 1.2 miles  from the fire) was analyzed for selected particulate
organics by a lab at the University of Washington  in January,1985.   The
results showed levels of polycyclic aromatic hydrocarbons (PAHs)  that were
above background.  Several  members of this  class of compounds are known or
suspected of causing cancer.  At the request of PSAPCA, the U.S.  EPA's
Region 10 laboratory analyzed 24 additional  samples collected by  PSAPCA at
the Everett station and at two stations in  Seattle (approximately 20 and 25
miles south of the tire fire) during the first few months after the tire
fire began.  These results  also showed elevated levels  of PAHs in Everett
and at" both Seattle locations during the fire which lasted  about  2  months.
Because of these  results PSAPCA requested that.EPA quantitatively "assess
the long-term health risk from the tire fire emissions."

     In response  to PSAPCA's request, EPA has estimated the lung  cancer risk
that may result from.emissions of benzo(a)pyrene 
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(1)       Although increased levels  of participates  were detected  on
     PSAPCA's samplers more than a mile from  the  tire  fire,  the  limited
     sampling data collected by EPA  for gaseous organics suggest  that levels
     of these gaseous compounds dropped off quickly  within a  short distance
     of the fire.   CDC concluded from these data  that  these  gaseous organics
     did not reach the public in sufficiently high concentrations  to  cause a
     long term health risk.

(2)       Although other particulate organics were detected  on PSAPCA's
     samples, toxicity and potency (unit risk numbers) data  are  available
     only for B(a)P and the generic  class  of  incomplete combustion products,
     PICs.  (see below).

(3)       Data from' the literature are available  to  make rough estimates of
     the amounts of B(a)P emitted from the fire.  These data  were  used in a
     computer dispersion model  to estimate ambient air exposure  for
     residents in  the Everett-Seattle area.   These modeled ambient air
     results could also be compared  to those  levels  measured  by  PSAPCA.

     The scientific data now available make it extremely difficult, 'if not
impossible, to identify a level  of exposure to cancer-causing agents  that is
safe.  Therefore,  EPA and other federal  agencies  have taken  the  position
that cancer may occur at any level of exposure no matter how  low.   EPA has
also assumed that  the risk of cancer increases as.exposure increases  and
that this relationship is linear (e.g.,  when  exposure doubles so  does
risk).   Thus, although a "safe" exposure can't be defined, estimates  can be
made of the risk of getting cancer if exposure to a  cancer-^causing substance
is known.  To estimate the risk from the tire fire,  EPA has  combined  two
different types of data:  data  on the B(a)P exposure for the  populations
living  within about 30 miles of the  fire and  data on the cancer  potency of
B(a)P and PIC.

     As a first step in calculating  exposure  levels, emission levels  of
B(a)P from the fire were estimated from data  on the  number of tires consumed
during  the fire and from literature  data on the amounts of B(-a)P  released
per pound of burning tire.  A mathematical (dispersion) model used these
emission data as well as data on weather and  geographic conditions to
estimate the concentrations of  B(a)P at about 250. points around  the fire
Within  a 30 mile radius.  This  information was then  combined  with Bureau of
Census  population  figures to provide an estimate  of  the number of people
exposed to a given level-of B(a)P (see the Attachment for a  more  detailed"
explanation of this methodology).

     The other type of data needed to estimate the public lung cancer risk
from the fire is that on the potency of B(a)P-this potency is expressed as a
unit risk number.   The unit risk number is defined as the lifetime cancer
risk that would occur in a population which is exposed throughout their
lifetime (70 years) to one microgram per cubic meter of B(a)P in  the  air
they breathe.  The unit risk number  for B(a)P, which was derived  using
experimental data  on animals, is about 3 X 10~3 per  ug/tn3 (micrograms of
B(a)P per cubic meter of air).

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                                     -3-                       .  •

     The unit risk number for B(a)P and  the  estimated  B(a)P exposure for
people living around the fire site  were  multiplied to  give tne estimated
lung cancer risk if exposure to the fire  had occurred  for  70 years (over an
entire lifetime).   This risk number was  then divided by 420, "the number of
two month periods  in 70 years,  to adjust  it  for  the fact that exposure
occurred only for  the tire fire duration  (i.e.,  about  2 months).  For the
persons with the highest exposure to B(a)P emitted by  the  tire fire, their
increased lifetime cancer risk  is approximately  2 X 10~5.   That is, their
estimated risk of  getting cancer as a result of  the fire is 2 in 1 million
(see Table 3 in the Attachment).  This risk  decreases  significantly as
distance from the  fire increases.

     This level of risk could be compared to the average expectation of
dying of all types of cancer which  is about  1  in 5 and the lifetime risk of
dying from lung cancer for cigarette smokers (pack a day)  which is about one
In 10.  Another way of stating  this is that  a  risk of  2 X  10~6 Is
equivalent to smoking about 10  cigarettes over a lifetime.

     Another way of estimating  risk from  exposure to B(a)P utilizes a
different unit risk number, that for Products  of Incomplete Combustion or
PIC.  During combustion of organic  material  many compounds in addition to
C02 and water can  be released because the combustion is not 100X efficient
and because of impurities in the materials being burned.  These may include
the original organic material or other more  or less complex compounds formed
during combustion.  As previously mentioned, this complex  mixture of
compounds is loosely defined as PIC and  includes PAH (polynuclear aromatic
hydrocarbons) and  possibly other organic  compounds.

       A unit risk number for PIC has been derived using B(a)P as a
surrogate.  As an  example, workers  exposed to  products of  incomplete
combustion (e.g.,  roofers, gas  workers)  have higher lung cancer rates than
non-exposed workers.  Although  PICs are  a complex mixture  of compounds, most
of the worker exposure data are expressed in B(a)P concentrations since
B(a)P is a suspected carcinogen and is fairly  easy to  measure.  Therefore,
in these studies,  B(a)P serves  as a surrogate  or indicator of the PICs, and
cancer risk is expressed in excess  cancers per unit measure (e.g., ug/m^)
of B(a)P.  Results from many studies such as these (occupational and
non-occupational)  were combined to  estimate  the PIC unit risk number.  The
B(a)P exposure levels estimated to  be produced as a result of the tire fire
can be used with the PIC unit risk  number (4 X 10-1 per ug/m3) to
estimate lung cancer risk resulting from  exposure to PICs  emitted by the
tire fire.  This results in an  estimated  lifetime cancer risk for thos-e -
persons with the highest exposure of 2 X  10~4  or about 2 in 10,000.  This
is significantly higher than the estimate using  the B(a)P  unit risk number,
2 in one million.

     It should be  kept in mind  that the  risk estimates given here for both
B(a)P and PICs are for those few people with the highest exposure to
emissions from the tire fire.   According  to  the  model  used by EPA, only 4
persons are living in this area of  highest exposure (0.26  ug/m3 of
B(a)P).  Exposures for other people living around the  fire were less as can
be' seen in Figures 1 and 2 (i.sopleth maps) of  the Attachment.  In the area

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west of the fire and  within  about  0.6  miles,  trie  model  we  used  predicts a
population of roughly 1200 residents.   Their  estimated  exposure ranges from
about 0.023 ug/m3 B(a)P to 0.26  ug/m3  B(a)P.   People  living  in
Snohomish, Monroe,  and Lynnwood  were exposed  to B(a)P  levels  between 0.0002
ug/m3 and 0.002  ug/m3.   Therefore  their risk,  is substantially less than
that of the highest exposure group.

     It must also be  stressed that there  are  many assumptions and
uncertainties involved in  this type of risk estimate.   For example,  for
carcinogens, EPA assumes that a  linear relationship exists between exposure
and cancer risk  (e.g.,  a person  who inhales one microgram  of  B(a)P per cubic
meter of air is  one-tenth  as likely to get cancer as a  person who inhales 10
micrograms per cubic  meter).   A  mathematical  model based upon this
assumption is used  to estimate the unit risk  number; the model  relies upon
laboratory data  in  animals (B(a)P) or  studies  of  workers or  community
exposures (PIC).  Because  this model is conservative,  the  risk  numbers
generated represent upper  bounds of risk  rather than an actual  expected
                                   risk  in terms of excess  cancers  is
                                   value calculated here  (2  in one  million
                                    Other assumptions  and uncertainties are
level of risk.   The  actual  level  of
somewhere between zero and  the  risk
for B(a)P and 2 in 10,000 for  PIC).
discussed below:
(1)  Model ing  - In  Attachment  A,  Table  2,  a  comparison  is  made  between the
     ambient levels of  B(a)P predicted  from  the dispersion model  and those
     measured  (observed)  by PSAPCA.   The discrepancies  between  these two
     numbers are likely a result  of  several  factors  in.cluding:

     0 Emission estimates of B(a)P from the  fire were based upon  emission
     rates  obtained from  the literature not  measured data  from  the. fire

     0 The  dispersion model that  estimates the ambient  levels of  B(a)P at
     various points is  limited in dealing  with complex  geographic and
     meteorological  conditions as well  as  non-constant  emissions  of
     pollutants as  was  the case with  the tire fire

     0 The  number of ambient air  samples analyzed by EPA were too few in
     number to consider them a very  good representation of an average
     concentration  over the two-month period of the fire.   Additionally,
     these  samples  were analyzed  more than 10 months after collection;
     volatilization and decomposition of substances on  the filter may have
     occurred.

(2)  Exposure

     8 Much of the  information available on  carcinogens,  including
     development of potency numbers  such as  the unit risk  numbers, are from
     laboratory or  occupational studies where exposure  occurred over a long
     time  period.   The  use of  such numbers for a two month exposure to B(a)P
     as occurred with the tire fire  may not  be appropriate.

     0 Exposure to  B(a)P  and PICs from  inhalation of contaminated dust or
     from  ingestion of  contaminated  soils  and dusts by  children has not been
     considered.

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     c  Tnere is  a ever, more unce-tai nty with trie °IC unit  risk  nurcaer  tnan
     w;.tn orner  unit risk numbers,  in part oecause of tne  way  it  was oe'ivec
     anci because 6(a)P is used as a surrogate.   For example,  the  PIC ur.it
     risk numoer is  derived from studies of workers and communities.  Tne
     rynes of chemicals present in  tnese situation: may be very different
     frotr. tnose  emitted from the tire fire.

Cone It's ion

     This assessment of the long term health effects from  the  tire  fire
emissions was limited to estimating lifetime lung cancer risk  for the
reasons already  discussed.   Using conservative  assumptions,  this  increased
lifetime cancer  risk may approach 2 in one million for B(a)P  and  2  in  10,000
for PIC for a limited number of people (about 4) with the  highest exposure
to emissions from the tire  fire.  It  should be  kept in mind  that  there are
many assumptions and uncertainties  involved in  this type of  risk  assessment
(e.g.,  assuming  that a linear relationship between exposure  and cancer risk
exists, estimating B(a)P emissions  using literature values,  using "lifetime"
unit risk numbers to estimate risk  from a two month exposure  to the tire
fire emissions).  It should also be stressed that these risk  estimates
represent upper  bounds of lung cancer risk rather than an  actual  expected
level  of risk;  that  is, the true risk is expected to be somewhere between
zero and the risk values calculated.

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                       ModeJinc Analysis to Assess T-j sk
                       fror, Everett Tire Fire LT.I scions


      The purpose of this attachment is to briefly document  a modeling
 analysis of the air emissions from the Everett tire fire and the development
 of risk estimates.   The modeling approach employed the Industrial  Source
 Complex (ISC)  Model to estimate concentrations, which were  then input  to
 the Human Exposure  Model (HEM) to estimate risk.

      Emissions estimates for benzo-a-pyrene [B(a)P] employed in the  risk
 assessment analysis were developed based on the following information:

           -  807,000 tires burned in. 60 days
           -  20 pounds per tire
           -  18 grams of B(a)P emitted per ton of tires burned *

 This yielded an average B(a)P emission rate during the fire of 0.02802 grams
 per second.  The fire was simulated in the ISC model as a volume source
 with horizontal dimensions of 100 meters by 100 meters,  and a vertical
 height of 20 meters.  This accounts for initial dilution of the emissions
 caused by the  spreading out of the fire as it progressed.   It also accounts
 for the minimal rise of the plume during most of  the two-ronth period. The
 source was located  at a latitude of 47° 57' 56" north,  and  a longitude of
 122° 11' 30" west.

      Meteorological data was supplied by the Puget Sound Air Pollution
 Control Agency (PSAPCA).  The data consisted of joint frequency distributions
 of wind speed, wind direction, and stability class for the  two-month period
 from September 24 to November 23,  1984.  Two distributions  were developed
 using the wind data from PSAPCA's monitoring stations at the Medical-Dental
 Building on Colby Avenue in Everett,  and at North 98th Street and  Stone Way
 in North Seattle.   Stability classes were developed from concurrent  cloud
 cover and ceiling height observations at Seattle-Taccrre Airport.   After
 preliminary model runs were ccrpleted, it became  evident that the  Everett
 wind data yielded higher modeled concentrations than the North Seattle
 d£±a-^_Purthermore,_owing to the close proximity  of the Everett station to
"fcheifire location,  the Everett wind data are judged to be more representative
 of the conditions which affected the fire than the North Seattle data. .
 Thus, all subsequent modeling analyses utilized the Everett meteorological
 data set.

      Other meteorological data input to the ISC model are documented in
 Table 1.  The  values are listed as.a function of  stability  class.  The
 temperatures and mixing heights are based on historical  ciimatological data
 for the Seattle area.  The vertical potential temperature gradients  and the
 vertical wind profile exponents are normal default'values.
    "Atmospheric Emissions from Open Burning;"  Pdcharcl Gerstle  and  Eouglasl::-.
       Kermitz,  Journal of the Air Pollution Control  Association,  'Wolume 7, •-- -
       Number 5, May 1967, page 324.

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     Concentrations were estirsterl using the rural  none of trie Jone-term
version of the ISC model (EPA-450/4-79-030).  ISC is e standard gaussian
model intended for use in flat or gently rolling terrain.   Deviations in
plume trajectories resulting from v.inc flows which are altered by ccnplex
terrain are not simulated by ISC.  Elevated stable plume irrpact on high
terrain is also not modeled by ISC.  liowever,  because cf the minimal plume
rise during most of the fire,  stable plume impact should not be a significant
factor in this analysis.  ISC does not,  as all gaussian models do not,
simulate very low wind speed conditions  well.   Light and variable winds
were reported about 4% of the time during the fire.  In spite of these
limitations, the ISC model is judged to be adequate for this analysis.

     Receptors in the modeling analysis were set in a polar grid with the
fire at the center of the grid.  Sixteen grid radials were spaced at azimuths
of 22.5° around a 360° circle.  Concentric rings of receptors were located
at ranges from the fire in kilometers of 0.5,  1.0,  1.5,  2,  3, 4,  5, 7, 9,
12, 15, 20, 25, 30, 40, and 50.  This grid layout .yields 256 receptors.

     ISC was used to calculate average concentrations of B(a)P at all receptor
locations.  The results are displayed in Figures 1 and 2.   Figure 1 contains
the predicted spatial distribution of B(a)P within a few kilometers of the
fire location, while the predicted concentrations over the entire receptor
grid are shown in Figure 2.  These figures show how concentration decreases
significantly with increasing distance from the fire.  For example, the
highest concentration estimate (0.26 micrograms per cubic meter)  was one-
half kilometer to the northwest of the fire, near the 1-5 freeway.  Further
into Everett near the intersection of Hewitt and Broadway,  the average
concentration was only about one-fifth of the maximum.  And, near Oak Harbor
on Whidbey Island, the average concentration estimate dropped by about a factor
of 30C from the maximum.  The concentration drops even more rapidly in other
directions from the fire.

     Measured ambient concentration data collected by PSAPCA at their
Everett and. North Seattle monitoring stations were obtained.  The measured
values were averaged over the duration of the fire for comparison with the_
model estimates.  The model estimated concentrations were interpolated from—	
the grid receptors to the monitoring locations so that a rough comparison- -. .-.-.   •_
of predicted and observed concentrations could be made.   The results of    '  •""-" •
this comparison are listed in Table 2.   •..--•

     There are several factors which suggest that this comparison is crude
at best, and may in part explain some of the discrepancies between the
predicted and observed concentrations.  While the emissions estimates are
based on the best information available, they must be considered very
approximate.  The plume from the Everett tire fire was not sampled, so that
emission factors had to be obtained frcrr-. the literature.  ISC assumes" that	
the fire emissions are constant,  while in reality the fire emissions were
obviously not constant "with' time.  No background concentration was "subtracted '.'.
from the measurements, so that the measured values include contributions
from sources other than the tire fire. •• No. measurements' of sriierit: cdncentrsticns..
were available for November.  The numbers of 24-hour averaged samples"for'"";     "
B(a)F at the Everett and North Seattle monitors are really too small to

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consider them a very good representation of an average concentration over
the two-month period of the fire.  Finally, the limited ability of the ISC
model to handle complex terrain and low wind speeds is also a  factor in the
comparison.

     It is not possible to draw any firm conclusions from the  comparison.
Statistical significance of the differences (or similarities)  between the
measurements and the model estimates can not be established.   From this
limited evaluation it appears that the modeled concentration estimates are
probably good enough for order-of-magnitude risk estimates.

     The output concentration estimates from the ISC model were input to
the HEM developed by Systems Applications, Inc. under contract to EPA.  A
draft user's manual for HEM (October 1985) was obtained from the Pollutant
Assessment Branch at the EPA Office of Air Cuality Planning and Standards.
HEM uses the ISC concentration estimates and the population data from the
1980 census to estimate exposures.  Risk estimates were developed with HEM
using two different unit risk factors:  the B(a)P unit risk factor of
0.0033 per microgram per cubic meter, and the unit risk factor for products
of incomplete combustion (PIC) of 0.42 per microgram per cubic meter.  The
HEM assumes a lifetime (70-year) exposure.  Therefore, the risk estimates
were adjusted for the shorter two-month exposure resulting from the fire.
This amounted to dividing the lifetime values by 420, the number of two—month
periods in 70 years.

     The results from the HEM are listed in Table 3.  The maximum individual
risk estimates due to emissions from the fire are for people who live very
close to the fire location.  These analyses extended to a radial distance
of 50 kilometers frcm the fire.  The total number of people within this
area is approximately 1.23 million.  The minimum risk is the lowest risk
value to which the entire population was exposed.

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                 Meteorciocicoi Leta  Input to  the  IS:: r-v
Stability
Class
A
D
C
D
E
p
Temp.
(dec II)
286
285
284
282
280
279
Mixing
Height
(meters)
950
850
750
750
10000
10000
Foter.tiaJ
Temp. C-rec: -
(dec, K / m)
0.0
C.O
0.0
0.0
0.020
0.025
Wind Profile
Exponent
0.10
0.15
0.20
0.25
0.30
0.30
                                  Table  2

         Comoarisbn of Estimated and Measured B(a)P Concentrations
Monitoring Station
Everett
Forth Seattle
ISC Estimate
(rucrograms
0.0484
0.000276
Average Measured
Concentration
per cubic meter)
0.0142
0.0032
Number of
24-Hour
Samples
8
2
                                  Table  3

       Risk Estimates for B(a)P Emissions from the Everett Tire Fire
                   Calculated bv the Human Exposure I-'ocel
Unit Risk Factor Employed
  C.0033
[for B(a)P]
  0.42
[for PIC]
Maximum Risk to an Individual
  as a "Result of Exposure
 2.1 x ID"6
2.4 x 10-4
Number of People at
  M? -v •» Tirtrn ^\T^ S"^"
Minimum Risk Level
 3.5 x 10-10
4.4 x 10-8

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Figure 1- - 7his..jr.ap shows the  spatial  distribution  of  predicted concentrations -•
vithin a few kilometers of the fire location  at~ ®~   The" concentrations*  '". T"7"T '.  ..~°
are in units of micrograms of  B(a)P per  cubic meter of air averaged over
the two—month period of the  fire.

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 Figure 2.  This map  shows the spatial distribution  of predicted concentrations
-over^the -entire modeling  grid,' within 50 -kllonie-l'-ers— of the fire. -location. -atir ®
    ^                        n
The^conceTitraTions are in units of" mi cr-ogf ani s o 'f -B ( a )?"" ^p'e f~ cubl^. m'e't erJ ^f^SL"."
air averaged  over  the two— month period  of  the fire.

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