26453-3
          An Industry Approach for the Regulation of
                       Toxic Pollutants
                         Prepared for

                  Toxics Integration Project
             U.S. Environmental Protection Agency
                         Prepared by

                Putnam, Hayes & Bartlett,  Inc.
                       SO Church Street
                     Cambridge, MA  02138
                        IS August 1981

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                                                         26453
TABLE OF CONTENTS
Chapter 1
EXECUTIVE SUMMARY
   Introduction ...................
   Sununary of Approach ................   *
   Summary of Results ..... ...........   °
   Overview of This Report ..............  10
Chapter 2                                                .
DESCRIPTION OF APPROACH	1J-

    Introduction  	  ^
    Characteristics  of  the  Problem	J-*
    Production and Pollution  Analysis.	  13
    Exposure Analysis	^
    Health  Effect Analysis  	  •  	  "
    Integration of Production,  Pollution,
    Exposure and  Health Analyses  	  28
    Cumulative Economic Impacts	32
 Chapter 3
 FORM,  INTERPRETATION AND USE OF RESULTS
    Introduction
    Cost-Effectiveness Analysis.  .  .  .
    Cumulative Economic Impact Analysis
    Major Limitations of the Approach
    Sensitivity Analysis

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TABLE OF CONTENTS
Chapter 4
INDUSTRY APPLICATIONS 	  50

   Introduction 	  50
   Chlorinated Organic Solvents Industry	51
   Copper Smelting Industry 	  89
APPENDICES  (Separate Volume)
Appendix A
MATHEMATICAL  PROGRAMMING  FORMULATION   	  A-l

    Introduction	•  •  •  •  A-l
    Objective  Function  	  A-4
    Material Balance  Constraints	A-7
    Factor Input  Constraints	-	A-7
    Capacity Constraints	A-8
    Operating  Constraints.  .  	  A-a .
    Pollution  Control Constraints	  A-10
    Health Effect Constraints	A-12
    Model Operation	A-14
    Model Results	A-14
 Appendix  8
 EXPOSURE  ASSESSMENT 	   B-l

    Air Pollution Modeling  	   B-l
    Analysis  of Human Exposure Through
    Drinking  Water and Fish Consumption	B-7
    Ground Water Contamination From
    Hazardous Waste	B-12
 Appendix C
 PROCEDURES FOR ESTIMATING HEALTH RISK	-   C-l

    Toxics Integration Program Scoring of
    Selected Pollutants for Relative Risk
    Prepared by Clement Associates,Inc.	   C-3

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TABLE OF CONTENTS
Appendix D
ALTERNATIVE WEIGHTING SYSTEMS
FOR EIGHT HEALTH EFFECTS	D-l

   Methods for Assigning Weights
   to Health Effects in Integrated
   Risk-Reduction Models'
   Prepared by Milton C. Weinstein	D-2

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ACKNOWLEDGEMENTS
     In carrying out this effort, Putnam, Hayes & Bartlett,
Inc. (PHB) received  guidance  and assistance  from many En-
vironmental Protection Agency  (EPA)  staff.   Overall super-
vision of the effort was  provided by  EPA's Project Officers:
Bob Fuhrman,  Fred Talcott and Jim Titus.  Toxics Integration
Project members who contributed included Dan Beardsley, Kathy
McMillan, Mike  Gruber,  Jim  Falco,  Mike  Alford  and  Walt
Kovalick.  In  addition to these  individuals, a  number of
EPA staff  members made  major  contributions  of  time,  data
and ideas to the  effort.  These  people include:
     Bob April
     Arnie Edelman

     Paul Farenthold

     Dave Graham
     Francine Jacoff
     Arnie Kuzmak
     Fred Leutner

     Alec McBride

     Bob McGaughy
     Dave Patrick

     George Provenzano
     Roy Rathbun

     Mike Slimak

     Pat Williams
Office of Water Enforcement
Office of Pesticides and Toxic
  Substances
Office of Water Regulations and
  Standards
Office of Research and Development
Office of Solid Waste
Office of Drinking Water
Office of Water Regulations and
  Standards
Office of Water Regulations and
  Standards
Office of Research and Development
Office of Air Quality Planning and
  Standards
Office of Research and Development
Office of Air, Noise and Radiation
  Enforcement
Office of Water Regulations and
  Standards
Office of Water Regulations and
  Standards

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     Putnam, Hayes & Bartlett,  Inc.'s  work on this project
was carried out under the overall direction of Mike Huguenin,
with project  management provided  by  John Butler,  Sharon
Chown and  Robert  Golden.   PHB   staff  contributing  to  the
effort included Kerry  Diehl,  Chuck  Elliott,  Bill Jackson,
Kate Mulroney, MaryAnn  Pocock,  Ken  Pott,  Maureen Ratigan,
and Howard Seidler.  Report production and general support
were provided  in  admirable  fashion  by   Kath  Fitzgerald,
Mary Ann Buescher, Carol Newman, and Barby Prothro.

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EXECUTIVE SUMMARY	 CHAPTER 1
INTRODUCTION

     In January  1981  the  U.S.  Environmental - Protection
Agency (EPA) embarked on  a  set of activities to develop an
overall Agency  strategy  for  toxic  pollutant  control.   As
cited in EPA's work  plan  for this effort, these activities
include:

     1.   Design of operational  mechanisms  to  coordinate
          regulation, data  gathering,  analysis  of  toxic
          substances, and analysis of nonregulatory control
          approaches.

     2.   Design and testing of prototype geographic, chem-
          ical-by-cheraical, and industry-wide approaches to
          toxic pollutant problems.

     3.   Identification of legislative changes  needed  to
          effectively integrate toxics control.

     4.   Organizational changes needed  to  implement  the
          Agency's integrated  toxics strategy.

     5.   Resource allocation  recommendations for FY 82 and
          FY 83.

Putnam, Hayes  and  Bartlett, Inc.  (PHB) was  engaged by EPA
to develop  and  test  a prototype  industry-wide  approach to
toxic pollutant control in  support of Task 2 above.

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      EPA's  intent  in developing an  industry  approach  is to
 develop  methods  that allow  identification  of  the  most  cost-
 effective options   to  minimize  tvealth  and   environmental
 risks associated  with industrial discharges.   The  specific
 objectives  of  the  approach  are to

      "characterize the  nature  and magnitude of the pollution
      problems  specific  to industry,  identify available  in-
      formation on  exposure  and risk  from the  pollutants,
      assess the  combined environmental and economic impacts
      of  various  levels  of  regulation, and attempt  to draw
      conclusions on  the need for  priority-setting  among
      environmental media and pollutants."

      It  is  important to  note the emphasis on developing pri-
 orities  for regulation.  What  is  desired  is  a  tool  to
 assist EPA   in deciding  upon  basic  regulatory  approaches
 for a given industry, using  consistent estimates of pollu-
 tion levels,  costs  and  the  relative  risks  posed by such
 pollution.   Detailed technical or economic analysis  of  the
 type required  to  support specific  regulations  is  not  the
 intended output  of the industry approach.

'  "    In  order to develop the  industry  approach, PHB designed
 a general methodology  and  applied  this methodology  to  the
 chlorinated organic solvents and the  copper smelting  indus-
 tries.  The intent  of  this  work was to  develop  and test
 the methodology and to gain initial  insights  into the  indus-
 tries considered.

      Each of  these  industries has  several  characteristics
 which led  to  its  inclusion  in the  study.   In the  case of
 chlorinated organic solvents,  the industry is the source of
 large amounts  of  toxic pollutants,   is  relatively  complex,
 and is well known to many EPA  staff.   In  the case of  copper
 smelting, the  industry  is the source of a different type of
 toxic pollutant (metals versus organic chemicals), presents
 different types of  exposure  problems,  and  is  of  interest
 to EPA due  to the upcoming  amendments to  the Clean Air Act
 and general financial pressure on the industry.

      The remainder of this  chapter provides a summary  of the
 industry approach and summarizes  the results of the chlorin-
 ated organic solvent and copper smelting  case studies.  Fi-
 nally, the   organization of  the remainder  of  this report is
 outlined.
                             -2-

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SUMMARY OF APPROACH

     The analysis of  industrial  discharges  of toxic pollu-
tants and the associated human  exposure  and health effects
can be  separated  into  four  elements as  diagrammed below.
                          Figure 1

                     PROBLEM COMPONENTS
Production


Pollution


Exposure


Health Effects
Production activities in any industrial sector create prod-
ucts for  sale,  employment opportunities,  and  profits;  and
determine the underlying  economic  strength and value added
by that sector  tb the overall  economy.   As a by-product of
these activities, however,  the sector will generate pollu-
tion.  Pollution  may consist  of  a  large  variety  of  sub-
stances that  are  released into the  air,  surface  water and
ground water.   The  discharge  of pollutants  will  result in
exposure of human populations.   Such exposure may generate
adverse health effects  depending  on  both  the  degree  of
toxicity of the pollutant and  the extent of human exposure.

     In analyzing the overall  problem, one  first must under-
stand the basic economics and production characteristics of
the industry  of  interest.   Next,  one  must  estimate  the
physical quantity and composition  of pollutants  that  are
generated by  the  industry,  and understand how the  flow of
pollutants can  be  reduced.   Pollutant  reduction  can occur
by installation of  pollution  control equipment,  changes in
raw materials  or manufacturing  processes,  curtailment of
production, and  other control  strategies.  Each  of  these
possible control approaches will impose costs on the indus-
try and will  result in  reduction in the release of pollut-
ants.  Considered  together,  this   information allows  the
analyst to  estimate the  feasibility  and  cost  of  limiting
the physical discharges of specific  pollutants  from specific
sources in production facilities.
                            -3-

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     In order  to  determine  the  extent  to which  specific
pollutants should be  limited,  one  must  consider  both the
costs of  control  and  the ultimate' damage  that  occurs as "a
result of such pollution.   If  human  health effects are the
damage of concern,  the  analyst must understand the various
exposure pathways through which pollutants  move and estimate
the actual dosage received by human populations.  Next, the
analyst must estimate  how changes in  dosage  levels  due to
industrial pollution  control  will   reduce health  effects
given the  level   of  background  pollution, the  attributes
of the  population  exposed  and  other  factors.   Finally,
the analyst  must  prioritize reduction of  different  health
effects in  some   way.    Considered  together,   all of  this
information allows  estimation  of the  human health effects
resulting from the  alternative  levels  of pollution from an
industry.

     Many of the  analyses described above  have been carried
out individually  before.  The great strength of the current
effort is that all analyses  are  carried  out simultaneously,
using consistent  assumptions  and  conditions.   This   inte-
grated approach ensures  that: •

     •    All pollutants  that  are important contributors of
          health  damage are  considered,

     •    All  feasible  control options are explored and as-
          sessed,

     •    Intermedia tradeoffs (especially due  to  control
          equipment) are  made after explicit consideration,
          and

    - •    The relative  importance of reduction  in different
          health  effects  is  evaluated.

     In order  to develop the  approach outlined above, PHB
has designed  a methodology  which utilizes to the maximum
extent possible  existing EPA  data  and  understanding.   In
the production and  pollution areas, EPA has  a good under-
standing  of  the  major manufacturing processes  in most  in-
dustries  and  the  pollution  quantities   emitted   by   these
processes.   The  exact  composition of  the pollutants, how-
ever, is  often uncertain.  Further,  SPA usually has devel-
oped cost and  removal  efficiency   estimates   for one   or
more methods of  pollution control  for  each specific source
of pollution.
                            -4-

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     In the exposure  area,  EPA has developed  a  variety of
analytic methods that can be used to predict the concentra-
tion of various pollutants around a discharge point.  These
models are best developed for air pollution, are less devel-
oped for water  pollution and are only  in very preliminary
stages for ground water pollution.

     Finally, EPA and others outside the Agency have examined
many pollutants and their associated health effects to under-
stand the  relationship  between  dosage of a given pollutant
and incidence of  a specific health  effect.   Although  this
work is  incomplete,  at  PHB's  request  Clement Associates,
Inc. developed  a  method to evaluate  the  relative  risk of
incidence  of different health effects from exposure to  dif-
ferent pollutants.

    ' The current  state  of  both  theoretical  knowledge and
available  data  concerning  several of  these  analytic  steps
is  insufficient to allow precise estimation  of  the  costs
and health benefits of alternative toxic control regulations;.
Thus,  the approach presented in this report is not sufficient
to  support specific regulations.   However, the approach 12
useful  to   evaluate  pollution  abatement strategies.   In
addition,  the .approach.  identifies  the  most  important  gaps
in  basic  understanding-and  data availability.             ;

     Although  the  limitations  in  the  approach are  largely
determined by  the  availability and quality of data  for any
industry-being  examined, one general limitation will  apply
for all industries considered.  Current toxicological  know-
ledge  prevents  estimation of  absolute  incidence of health
effects other  than  cancer.   This  fact  in  turn  prevents
development of  an  industry  approach  which predicts  absolute
levels of health  effects which could then be  used  to  calcu-
late  the  "benefit" of  toxic  pollutant  control.  Thus, the
approach outlined   herein  is  not a  true cost-benefit ap-
proach,  but instead indicates  the most  cost-effective  means
to  achieve alternate levels of relative health  risk  reduc-
tion.

      Finally,  the   current  effort focused  on human  health
effects and has not considered other environmental  effects.
The decision  to  focus  on  health effects was made due  to
time  and  resource  limitations and  is   not  meant  to  imply
 that  other effects of industrial  pollution are unimportant.
                             -5-

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The  analysis carried out for the chlorinated organic solvent
and  copper smelting  industries  included discharge  estimates
for  conventional  as  well  as  toxic  pollutants.    Further
consideration of  environmental  effects  could  be  added  to
these  analyses.                                    *
 SUMMARY OF  RESULTS

     The  overall  results  of  PHB's work  indicate that  the
 industry  approach  provides useful  results for  formulation
 of  industry-wide  approaches  to  toxic  pollutant control.
 In  addition,  the method  highlights  areas of  particularly
 severe uncertainty due to data limitations and therefore as-
 sists the planning of  future research  efforts.  The  sec-
 tions below review the  initial  insights developed  for the
 chlorinated solvents  and  copper  smelting  industries  and
 then summarize  the general results  of PHB's work. Detailed
 results for the industry  case  studies are provided  in the
"briefing  packages  included under separate cover.

     It is  important  to  restate  that  one   cannot reasonably
 generalize  about  the  value of specific existing regulations
 based on  the work  to  date, except in  terms of human  health.
 Even then,  such generalizations  may  be  unwarranted  and
 should be avoided. SPA   has   not  yet  thoroughly reviewed
 either the  data or the methodology used  in  these studies.
 Thus, all results  summarized below  and   in  the briefing
 packages  are preliminary and   are not an   appropriate basis
 for current policy decisions.
 Results  for Chlorinated Organics Industry

      The  chlorinated organic solvents industry is a segment
 of  the organic  chemicals industry.   Although  the  solvent
 segment  is  an  important part of  the larger  industry,  the
 results  for this segment cannot  be generalized to the over-
 all industry.    However,  the  chlorinated  solvent  segment
 itself has  been  of  major  interest  to  EPA  over  the  past
 several  years.

      The  results of PHB's study  indicate that major percen-
 tage reductions in  health risk can be achieved at relatively
 modest cost in  this industry. However,  it appears that the
 absolute  levels of  health risk due to uncontrolled industry
 operations  are   minor and  thus  additional  risk  reduction
                             -6-

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would be extremely  expensive  on a per unit  basis and thus
unwarranted.  If further reduction in health risk is deemed
desirable-,--additional control on a mix of air emission, -haz--
ardous waste, and then water effluent sources would be most
cost-effective.

     Regulatory decision  makers are  often  concerned  with
individual risk  levels  as well  as  aggregate  risk levels.
Maximum individual risk levels for one health  effect  (cancer)
have been estimated for one large chlorinated solvent plant
(accounting for  about  10.2 percent  of industry production)
in a  densely  populated  area.*   At  uncontrolled  pollution
levels, approximately  100 people around  this  plant  would
have an annual  individual  cancer risk in  the range of 10"4
to 10~5.**   If  such  levels   of individual  risk  are  of
concern, additional•work  should be done  to  estimate  indi-
vidual risk levels  for the entire industry.

     Current controls  in  place  in the  chlorinated organic
solvents industry  do  not appear  to  be  a  cost-effective
means to protect human health.   These controls  have  been
aimed primarily  at  reduction  of conventional water pollut-
ants such  as  BOD.   The benefits  of  conventional pollutant
reduction may   justify  the  expenditures  made   for  these
controls, but  equal -expenditures  on  a  different set  of
control options  could  have  provided  a  percentage health
risk reduction  of   over  80 percent.   The  implied  tradeoff
between conventional  and  toxic  pollutant   control should
receive further attention.

     In carrying out this analysis,  PHB found that air emis-
sions from  water  pollution  control  equipment  and  from
surface waters  are  a major  source  of  toxic air pollution
and health risk.  This occurs  because many of the  pollutants
generated by  the chlorinated  solvents segment  are highly
volatile.  In  some  cases,  the  addition  of  certain  water
pollution control equipment may actually  increase  slightly
the health risk  generated  by  these  plants.   However, there
*  Only cancer risks were  estimated  as GAG unit risk factors
   for cancer  are  the  only  generally  accepted  incidence
   measure.

** Approximately  4500  people would  have  an  annual  cancer
   risk in the range of 10~5 to 10~6.
                            -7-

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appear to  be  methods   (steam  stripping,  for  example)  to
alleviate this  problem  and  provide  cost-effective  risk
reduction.  Until  further  analysis  of this " issue" is per-
formed, it may be  advisable  to  exercise caution in mandat-
ing further  control of  water  effluent  in  the chlorinated
solvents industry.

     The overall organic chemicals  industry and the  chlor-
inated solvents  segment appear  to   be in  relatively good
financial health.   The modest cost of  health  risk  reduction
creates very little  financial  strain  on  the  industry.  In
addition, small  increases   in  product  prices  would   allow
almost full  recovery of costs  and  leave industry profits
near their baseline  level.
Results for Copper Smelting Industry

     The copper smelting  industry  is  a  large  source of  both
conventional and  toxic air  pollutants.  Large  amounts of
sulfur dioxide  (S02)  and  particulates are emitted, as  well
as toxic raetals such  as arsenic  and lead.  Current controls
at many of the smelters are not adequate to meet  air quality
standards.  Control  levels required  to bring the smelters
into compliance are  costly and may be  difficult to achieve
given the  industry's  current  financial  condition.

     At the time of publication  of this report,  work on the
copper smelting case study was not finished.*   However,  pre-
liminary results  indicate that  a  significant reduction in
health risk can  be achieved at relatively low cost by  con-
trolling fugitive  emissions  of  S02  and particulates.   In
general, current  controls  in place  in  the  industry  have
focused on stack  emissions  and  are  not  a  cost-effective
means of reducing  human health risk.

     In most  cases,  the additional- controls  currer.tly  man-
dated for  smelters focus  on  stack emissions.   Thus, these
mandated controls  are not a cost-effective means for reduc-
ing human  health risk.  However,  the  environmental benefits
(for example,  visibility  improvement,  reduced crop damage)
derived from  both the  mandated  and  in-place controls  may
justify the cost of  these controls.
 *   The  case  study  will  be  completed  by  late  August.
                             -8-

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     There are a  few smelters  which are  located  far from
population centers.  For these smelters, stack controls of-
fer more cost-effective protection  to human- health than, do—
fugitive controls.   However,  additional analysis  would  be
required to determine whether the absolute level of health
risk in these cases  warrants  either  stack  or fugitive con-
trols.
Overall Conclusions and Priorities
for Additional Work

     The industry  approach has proven  useful  in the chlo-
rinated organic  solvent and  copper  smelter applications.
In both  industries valuable insights have  been gained for
a number of important issues, including:

     •    The most cost-effective means  to   achieve  reduc-
          tion in  health   risk  from  industrial pollution,

     •    The effectiveness of current  controls  in   achiev-
          ing such risk reduction,

     •    The relative merit of a variety of additional con-
          trol strategies,

     •    The implications of  different health  effect  pri-
          orities,

     •    Current  and potential tradeoffs between  toxic and
          conventional pollution control,

     •    The cross media  impacts of  different  control  ac-
          tions , and

     •    The overall financial and economic impact  of  al-
          ternative control  strategies  on  each  industry.

The  cost  and  time required  to  develop the  approach and
achieve  these insights have been reasonable  given  the scope
and  importance of  the problem.

     The analyses  of both industries  has  been limited  by
several key data problems.   In order  to further improve the
industry approach,  additional  research should proceed  in
several areas:

     •    Research on health  effect  incidence  for  a  variety
          of pollutants should be accelerated.
                             -9-

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     •    Environmental effects should be added to the  In-
          dus try._..approach .

     •    Ground water models should be further developed.

     •    Existing water quality models should be combined
          with population data and automated  to ease access.

     •    Cross-media effects, especially due to  volatili-
          zation of pollutants from water control equipment,
          should be thoroughly analyzed.


OVERVIEW OF THIS REPORT

     The remaining  chapters  of   this  report  describe  the
industry approach and  case  studies in more detail, and are
organized as follows:

     Chapter 2  describes the approach  to  industry-wide as-
                sessment in detail;

     Chapter 3  reviews  the type  of results  derived  using
                the approach, explains their  interpretation,
                and discusses  the  limitations  of  the  ap-
                proach and methods of sensitivity  analysis;

     Chapter 4  summarizes  the results  from  applying  the
                method to  the chlorinated  organic solvent
                and copper  smelter cases;

     The appendices  are  provided  under separate cover and
include the  following  topics:

     Appendix A describes the  formulation  of   the problem
                using  mathematical programming  techniques;

     Appendix B provides more  detail  on the  methods used  to
                predict  human  exposure;

     Appendix C provides more  detail  about the  methods  used
                to predict  relative risk of  health effects;

     Appendix D provides more  detail  on the  methods   devel-
                oped to prioritize different health effects.

The  detailed  results  for the industry  case  studies are in-
cluded  in  two  briefing  packages provided  under separate
cover.

                             -10-

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DESCRIPTION OF APPROACH                           CHAPTER 2
INTRODUCTION

     In order  to develop  a  useful  industry  approach  to
toxic pollutant  control,  three types  of . problems  must  be
overcome.  First/ there is t'remendous diversity both within
and across  industries  and  their  associated  pollution,  ex-
posure and  health  problems.   Second,  the  industrial proc-
esses, exposure  pathways  and  health  effects  of  interest
are highly complex phenomena.  Finally, there is considerable
uncertainty in the existing knowledge concerning many aspects
of these phenomena.   Each of these problems must be addressed
in order to develop an industry approachr

     This chapter explains  how the  problems of diversity,
complexity and uncertainty were addressed in  this analysis.
The industry approach is then described  in detail.  Further
information about the approach is provided in the appendices.
The material  in  this   chapter  is  organized  as  follows:

     •    Characteristics of the Problem,

     •    Production and Pollution Analysis,

     •    Exposure Analysis,

     •    Health Effect Analysis,

     •    Integration of Production, Pollution, Exposure and
          Health Analyses,  and

     •    Estimation of Cumulative Economic  Impacts.

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CHARACTERISTICS OF THE PROBLEM

DiversTty"

     Industrial facilities and  associated  toxic  pollutant
problems are extremely diverse.  Facilities themselves range
from relatively simple operations with straightforward pol-
lutant generation (copper smelters, for example) to complex
plants comprised  of  many interconnecting  production proc-
esses with a large variety of pollutants (chemical plants).
In addition  to  the diversity  of  production  equipment  and
characteristic pollutants, facilities are  situated  in many
different areas and thus the exposure routes and populations
exposed to  toxic  pollutants   vary widely.   The  approach
developed must be able to accoraodate all of this diversity.

     The industry  approach  developed  is  therefore  very
flexible.  It can  be  used to  analyze highly complex indus-
tries by relying  on  generalized  plant  configurations  and
industry average  data  or  very  simple  industries  using
plant-specific data.   In  the  chlorinated  solvents  case
study, three  generalized  plant configurations and industry
average data  were used.  In  contrast, each  actual  copper
smelter was  analyzed  using  as  much  plant-specific  data as
possible.*
Complexity

     All of  the  phenomena underlying  toxic  pollution from
industrial facilities are  complex  as  well as diverse.  The
mechanisms through  which  industrial  processes  create and
emit pollutants  are relatively  straightforward.   However,
the means  by which pollutants  are transported through the
air, through  bodies of  water and  through the  ground are
quite complicated   and  difficult  to  analyze  accurately.
Further, the mechanisms  by which specific pollutants cause
undesirable  health  effects are  both complicated and poorly
*  It  was possible  to analyze  each copper  smelter since
   there are only  13  plants  owned by 5 firms, with at most
   4 production  processes,  and  significant  information on
   costs and  emissions was  available on  a  plant-specific
   basis.  The  chlorinated  solvents  industry is comprised
   of 31 plants owned  by 8 firms; the production facilities
   include as many as  11 production processes.
                            -12-

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understood.  All of these complexities  raust be included in
the approach  at  a level  of  detail  sufficient  to  yield
useful results while keeping the analysis feasibl-e.-

     As described  in  greater detail below,  PHB  used EPA's
models of the dispersion of pollutants through air, surface
water and ground water.   For health effects, Clement Asso-
ciates, Inc. developed measures of  the relative toxicity of
each pollutant  for different health effects.   In both the
exposure and health analyses, the complexity of the problem
was reduced  to  manageable  levels  by  utilizing   reasonable
approximations of  these complex phenomena.
Uncertainty

     The state of  current  knowledge about industrial toxic
pollutant problems is incomplete, and there is considerable
uncertainty associated with  all  the data required to carry
out the  analysis.   The  uncertainty in  the  available data
increases substantially  as one  moves  from  the production
and pollution  aspects of  the  problem to  the  exposure and
health aspects.  Thus,  the  industry approach  must utilize
available data while  at the same time evaluating the uncer-
tainty in the results.

     In order  to  assess  the reliability  of  the results, a
sensitivity analysis  was  carried  out.    This  sensitivity
analysis was designed to determine the  factors most critical
to the results and to establish the likely range of results.
Also, in  the  case  study  of  chlorinated  solvents,  it was
necessary to  perform  sensitivity  analysis  to assess  the
effect of generalization on  the  results.
PRODUCTION AND POLLUTION ANALYSIS

     This section  reviews  the  first  two  major elements
of the  industry  approach  — the  production and pollution
analysis.  The  following  pages   describe   the   conceptual
framework and provide  an  example.   Finally, the  sources of
data for this analysis are reviewed.

     The analysis of production and pollution is  based on  a
detailed simulation of  the  operations of  facilities  in  the
industry of  interest.   Each  facility is analyzed as a com-
bination of  production  processes  which  are  connected  by
                            -13-

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material and cost flows.   In addition, each process  is char-
acterized by the pollutants which it generates  and by the
control"options which may be—undertaken.- -Pollution- control
options available to the overall facility, such as  combined
water treatment plants or  secure  landfills,  are considered
as well.  The overall  intent  is to understand all  possible
modes of plant  operation and  associated  pollution genera-
tion and profitability  in sufficient depth  to predict the
behavior of  plant   operators  when  faced  with regulations
and other changes in conditions.

     The approach  to  production and  pollution analysis is
based on the following concepts.

     *    Process;  A process  is a combination  of  capital
          equipment which is characterized by  its input and
          output of economic resources.  Economic resources
          include feedstocks,  labor,  energy,  product,  and
          so forth.   A process can be  diagrammed   as shown
          in Figure 2-1.

     •    Manufacturing  Costs:  Manufacturing  costs are the
          costs of  the economic resources directly  consumed
          at each  process to  produce a  product.   For the
          purpose of   this  study  we  distinguish  between
          variable  costs, which  increase  as  the  level of
          production  increases  and are therefore attribut-
          able  to   units of   production,  and   fixed costs
          which are incurred independent of  production  lev-
          els and  which  are  not  attributable  to  units of
          production  except by  allocation.   The  fixed costs
          can be  avoided, however,   by  shutting  down the
          process*

     Facilities  in  any industry are comprised of one or  more
processes.  Since each process  is  characterized  by  specific
material and cost relationships,  the  economics  of any plant
can be  built  up from a knowledge of  which processes are in
use and  the capacities  of these  processes.   This  informa-
tion, along with data  on the unit  cost of required  economic
inputs  (labor, energy and so  forth) and  the volume and price
of products sold from  a  given  facility allow calculation of
revenues and manufacturing costs  for  the  plant.
                            -14-

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                         Figure 2-1

                  A- MANUFACTURING PROCESS
     Material Inputs-

     Energy Inputs—

     Labor Inputs	
Process
                  _^_ Major
                    Products
                  -w By-Products
                                                .Pollutants
                            Recoverable Wastes  and  Energy
     Each process  is  also   characterized by  generation of
pollutants in a ratio that is fixed with production.  Thus,
analysis of how the plant will  operate  based  on  manufac-
turing  economics  also   determines the  level  of pollution
generated by  the  plant.  In  addition,   possible pollution
reduction steps based on use  of alternative processes, raw
materials changes, produ«ct  mix  changes  and the addition of
pollution control equipment can be examined.

     The control equipment available to  reduce pollution at
a plant may serve  a process, several processes or the entire
plant.  However/  all  options are  characterized by  a cost
and a removal efficiency for  individual pollutants.  Know-
ledge of these characteristics allows the analyst to calcu-
late the least  costly  way  of achieving  various  levels  of
pollution reduction.

     A simple example will  illustrate the concepts described
above.  Exhibit 2-1 presents  a diagram  of a copper smelter
analyzed during this  effort.  As seen in  this diagram, there
are three key processes:   reverberatory furnace, converter
and anode furnace.   The inputs and  the resulting products
and pollutants  are shown  for each process.   For  example,
2316 tons of copper concentrate/ 258 tons of flux,  268 tons
of air,   1506  tons of recycled  slag,  labor and  energy are
combined to produce 2055 tons of copper matte, 1695 tons of
slag and  596  tons  of  pollutants  from  the  reverberatory
furnace.
                            -15-

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                                              Exhibit  2-1

                                     COPPER SMELTER PROCESS FLOW
                                            (Tons per  Day)
O\
I
                      FUGITIVES FLUCQAS
                       (24.5)    (571.7)
FUOIIIVES FLUE UAS
 (2-U)    QlW.l)
          COtlCEmnATES
                       (I09S.4)
              Source:  U.S.  Bureau of Mines.

-------
     Once the  pollutant  flows  are  defined,   the  options
available for controlling each pollutant can be determined.
Exhibit 2-2 illustrates the current pollution-controls-orr-a-
typical smelter.   As  can  be  seen  in  this  exhibit,  the
current controls  consist  of an  electrostatic precipitator
on the reverberatory furnace and  converter,  and a scrubber
and acid plant for the converter gases.

     To control the sulfur dioxide from the converter, most
sraelters remove the particulates from the gas with an elec-
trostatic precipitator, scrub the gas,  and then convert the
scrubber fluid to sulfuric acid in an acid plant.  The acid
is then sold,  neutralized  or used in the  plant's  mining
operations.  Fugitives, which  are  not  currently controlled
at most smelters,  can be controlled by hoods and ventilation
systems which  collect  the  emissions  and emit  them  into  a
stack or into  one of the process  control  systems.   In ad-
dition, some smelters  currently  control pollution  by cur-
tailing operations when air quality is poor.

     To summarize, the  production and pollution analysis pro-
ceeds by developing  a  process flow  for actual  or typical
plants in the  industry of interest.  Data are gathered des-
cribing the material flows, costs, and pollutants generated
at each process and the; pollution control, options available
both at the process and plant levels.  In addition, estimates
are made of the likely demand and price  levels  for products
and the unit costs of the required economic inputs.  All of
this information  is  analyzed  to  determine pollution levels
and the  associated costs and  plant cash  flow for  a  wide
range of plant operating  conditions.  Thus,  a schedule of
pollution levels  and associated  costs  to the  plant  can be
developed.

     In general,  this analysis is carried out  for a partic-
ular year  of  interest  and  is based on annual  costs  and
pollution levels. , This requires  that  capital expenditures
be converted to an annualized  capital  charge.  The annual-
ization is  carried out to equate  the  present value  of the
annualized costs after-tax to the present value of all cash
flows over time resulting from the capital expenditure, in-
cluding the  initial  expenditure  and all tax consequences.
This annualization method assures  that the  single  period
analysis will  result  in the same  control  strategies  as  a
multiyear cash flow analysis.
                            -17-

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                               Exhibit 2-2

            TYPICAL COPPER SMELTER CURRENT POLLUTION CONTROLS^
                                                   Acid Plant
                                                    Tail Gas
            Flue Gas
                             Scrubber
    Electrostatic
    Precipitator
       Electrostatic
       Precipitator
Fugitives
            Flue Gas
  Fugitives
    Reverberatory
       Furnace
Matte
               Flue Gas
         Converter
                                 Acid
                                 Plant
Blister
                                          Copper
                        Sulfuric
                       *• Acid
 Anode
Furnace
Anodes
      Slag
       to
      Dump
       Source: PHB Analysis.
                                   -18-

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     Exhibit 2-3 outlines  the  sources of data  used in the
production and pollution analysis  for the  chlorinated sol-
vents and copper smelting  studies.  Extensive  work was nec-
essary to convert  the  available  data on   pollution  and
pollution control costs into a consistent format useful for
this  analysis.  The  accuracy of*these  data is  discussed
in Chapter 3.
EXPOSURE ANALYSIS

Exposure Routes

     Once the possible levels of pollution from a plant and
the associated costs are analyzed, the next challenge is to
appropriately estimate population exposure.  In this effort
population exposure has been estimated for a number of dif-
ferent routes of exposure.

     Exhibit 2-4 diagrams  typical exposure  routes encoun-
tered in  the  analysis  of  chlorinated  solvent  plants  and
will be used to illustrate  the exposure analysis undertaken
in this  study.   These  plants   discharge  air  pollutants,
water pollutants and hazardous wastes.  These waste streams
often pass through pollution control equipment before release
to the environment.

     In applying pollution control equipment, some pollution
is transferred from  one  medium  to another.  Application of
water  pollution   control   generates  wastewater  treatment
sludges and fugitive air emissions.  Hazardous waste incin-
eration, which  is  in  common  use at  these  plants  due to
profitable chlorine  recovery,  generates air  pollution and
residual waste which must be landfilled.

     Human exposure  to  air pollution  is  associated  with
emissions from  process  stacks,  storage  tanks,  hazardous
waste incinerators and  fugitive  sources.   As the hazardous
waste incinerators  at  these  plants  are  throught  to have
99.999 percent destruction  efficiencies, air emissions from
these sources  are  negligible.   Air quality models are used
to estimate ambient  concentrations and population exposure
for the remaining  sources.

     Exposure  to  water pollutants  is  assessed  in several
ways.  As Exhibit 2-4 indicates, pollutants may be discharged
into surface  waters  or  may be  removed  and end  up  in the
                            -19-

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                        Exhibit 2-3

                      SOURCES-OP DATA
Major Element

Production Analysis

     Manufacturing Costs
     and Process Flows

     •  Chlorinated Solvents
     •  Copper Smelters
                              Data Sources
   EPA-OWRS
   Stanford  Research Institute
   Chem  Systems,  Inc.
   Data  Resources,  Inc.

   Bureau  of Mines
   PEDCo Environmental,   Inc.
Pollution  Analysis

      Pollution  and  Pollution
      Control  Costs

      •   Chlorinated Solvents

         1.  Air


         2.  Water


         3.  Hazardous Waste


      •   Copper Smelters

         1.  Air
         2.  Water

         3.  Solid Waste
•  EPA-OAQPS
•  Hydroscience, Inc.

•  EPA-OWRS
•  Catalytic, Inc.

•  Chem Systems, Inc.
•  SCS Engineers, Inc,
•  EPA-OAQPS
•  PEDCo  Environmental,  Inc.
•  Pacific Environmental
     Services,  Inc.

•  None

•  PEDCo Environmental,  Inc.
                             -20-

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                       Exhibit  2-4

                 TYPICAL '-EXPOSURE" ROUTES
              FROM  CHLORINATED SOLVENT  PLANTS
                           Air
                         Emissions
   Air
Emissions
Air
Treatment
4
Po
   Air
Pollution
 Fugitive  Air
   Emissions
            Hazardous
               Was
     Water
      Pollution
                                       Water Pollution
                                          Treatment
         Lagoon and
          Landfill
                                   Sludge
        Leaching  to
        Ground Water
   Drinking
    Water
   Intakes
Consumption of
 Contaminated
     Fish
         Source: PHB Analysis,
                            -21-

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sludge or in  the  air.   For chlorinated solvent plants, the
amount of pollution  that  is  found in  the  sludge  is  very
small in comparison to the amount discharged into the water
or into the  air.   Many of the  water  pollutants are highly
volatile and  are  transferred into  the  air as  a  result of
water treatment processes  or  volatilization  from  surfa'ce
waters.  These  emissions  are   added  to  the   fugitive  air
emissions from the plant, and population exposure is calcu-
lated using air pollution models.

     Exposure to  the pollutants  which  are not volatile and
remain in the water is assessed in two  ways.   First, pol-
lutant concentrations  and population exposure  are estimated
for each  drinking water  supply  downstream of  the plant.
Second, accumulation in  the  food  chain  can also  result in
additional population  exposure.   Consumption  of  contamin-
ated fish is  the  only  food examined in this analysis since
adequate data are not  available for other foods.  Water pol-
lution is not analyzed in  the  copper  smelter  study because
most smelters have zero discharge.  Smelters located  in the
desert often  recycle all water  for economic reasons.

     The disposal of  hazardous  waste  in  sanitary landfills
and lagoons  can  result  in  contaminaion of  ground water.
Exposure will result from drinking water supplies  drawn  from
contaminated  wells.  This  exposure route  is  examined in  a
rudimentary  manner because  little  is  known about  movement
of contaminants in ground  water.

     In  the  chlorinated solvent  analysis PHB examined all
major  routes  of exposure.   However,  in the copper smelter
case study  two  exposure routes have not  been  examined.  An
adequate model  for  predicting   the movement  of  metals in
ground water is not available and consequently this  exposure
route was  not  analyzed.   Local  health  officials  believe
ingestion of dust which contains  trace  quantities  of  heavy
metals is a  principal  source of exposure to children.   This
source of  exposure was also not examined due to a lack of
readily  available data.
                             -22-

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Exposure Analysis Methods

     As described  -above-,  the  -principal-- exposure --routes
examined are:

     •    Air exposure,

     •    Contamination of  surface  water  and  subsequent
          drinking water exposure,

     •    Exposure through fish consumption, and

     •    Ground water exposure.

Ambient concentrations  and  population  exposure   for  each
route are estimated by employing several  mathematical models
which are  briefly discussed  below  and  are  described more
fully in Appendix  B.   EPA models  were used whenever avail-
able.  Monitoring  data were  used to provide  estimates  of
background concentrations in air  and water.
     Air Exposure

     For the  chlorinated  solvents  industry,   SPA's  Human
Exposure Model  (HEM)  was used to  calculate  annual average
concentrations  and  the population exposed  to  various con-
centration levels.   For copper  smelters,  EPA's  Industrial
Source Complex  Model   (ISCM)  was  used  to  derive   annual
average ambient  air  concentrations.   The  output of this
model was  then  transferred  to  the  HEM to  calculate   the
population exposed  to  various concentration levels.

     The HEM  was developed  specifically to  model organic
chemical plants and  is  designed  to determine the  population
exposed to  various  levels   of  pollutants.   The  ISCM   was
used for the  copper  smelter study  since  the HEM was   not
designed to model sources  with  tall stacks  such as those
found at  smelters.    The ISCM  is used  to  assess  the   air
quality impact  of emissions from  a  wide variety of  indus-
trial sources.
     Surface Drinking Water Exposure

     Exposure from  surface  drinking water  has  been deter-
mined by  identifying  all drinking water intakes downstream
of each plant together  with  the  number of people served by
                            -23-

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these intakes.  Incremental  chemical  concentrations at the
drinking water intakes have  been evaluated  using  a mathe-
matical model  which- reflects  both  the  characteristics _o.f
the waterway (such as flow and velocity)  and the volatili-
zation rates  of  individual  chemical  pollutants.  Further,
it was assumed that the concentration in the drinking water
was equal to the  concentration at the  drinking water intake,
and hence no  additional  volatilization or  chemical trans-
formation  would  occur  as  the  drinking  water  undergoes
chlorine disinfection and transportation to consumers.
                                    •

     Exposure Through Fish Consumption

     Exposure from contaminated  fish has been determined by
estimating the amount of fish caught for human  consumption
downstream of each plant.  The average daily intake of fish
has been  assumed to  be  6.5  grams  per  person,  consistent
with the  assumptions used  in  the  Water  Quality  Criteria
Documents.  The  source  of  information  on quantities  of
fish caught  for  human consumption  in various geographical
areas  is  the  Department of  Commerce  publication  entitled
Fishery Statistics of the United States,  1976.


     Ground Water Exposure

     The mathematical  model which  calculates  the level of
ground water  contamination  resulting from landfill of haz-
ardous waste  is based  on; a method devised  by EPA.*  The
ground water model takes into account migration and  degrada-
tion of  the pollutant.   Exposure is estimated by accounting
for the  number  of  people  who  drink  ground water  in the
vicinity of  each plant.   This  model  is the most  uncertain
of the  exposure  models  used in  this  study.  Research is
currently being  done by  EPA to  gain a  better understanding
of the movement of contaminants through ground water.   Appen-
dix B  provides a more detailed  description  of the  formulas
used  in  the  model  and  discusses  the  limitations  of  this
approach.
    Falco  et al.,  "A  Screening Procedure  for  Assessing  the
    Transport  and Degradation of  Solid  Waste Constituents in
    Subsurface and Surface Water,"  to  be published  in Pro-
    ceedings of the Society of Environmental Toxicology  and
    Chemistrv.
                             -24-

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HEALTH EFFECT ANALYSIS

Health Effect Incidence

   .  Once the  number of people  exposed to  various levels
of pollution  is  estimated,  the  next  step  is  to determine
the health  effects  that would  result  from  that exposure.
Ideally, one  would  like  to  know the  portion  of the people
exposed to  a  given  level of  pollution who  would experience
certain health effects.  For  example,  one would  like to know
that 2 percent  of  the  people  breathing concentrations  of
sulfur dioxide in excess of 300 ug/m^  would develop respira-
tory problems.  Unfortunately, the available information on
the health  effects  at low dose  levels  does  not permit the
derivation of  such  an  incidence measure.   To  compare the
effects of  different  exposure  levels,  this   effort  has
developed a scoring system which measures the relative risk
of certain  health effects from certain  pollutants.*

     The pollutants of  concern have  been evaluated for the
following eight health effects:

     •    Carcinogenicity,

     •    Teratogenicity,

     •    Reproductive Toxicity,

     •    Mutagenicity,

     •    Hepatotoxicity,

     •    Renal Toxicity,

     •    Neurobehavioral Toxicity, and

     •    Toxic effects on other organ  systems  such as
          respiratory  effects.

The relative  risk measures  (scores)  for each pollutant are
based on the  use  of mathematical models for low dose extra-
polation.   Clement  Associates have  assumed a  linear dose
*  Clement  Associates,  Inc. developed  the  risk scores  for
   this study.   Their  approach  is described in Appendix C.
                            -25-

-------
response relationship.*  Thus, one  of  the following curves
was derived  for  each health  effect  and each  pollutant.
                         Figure 2-2

      RELATIVE PROBABILITY OF HEALTH EFFECT INCIDENCE
Proba- 1
bility
Proba- 1
bility
                           Dose
                           Dose
          Wo Threshold
          Threshold
     The scoring  system developed  uses  very  crude  models
to estimate -incidence.   The  use of these linear models has
not gained acceptance for effects other than cancer.  Thus,
in absence of a better understanding of dose-response rela-
tionships it  cannot  be claimed that the scores are an ab-
solute measure of risk.

     The relative  risk measures do allow  tradeoffs  to be
made across  pollutants  and  across health effects.   For
example, the same score  for renal toxicity  for both arsenic
and lead  implies  that  a person is equally likely  to  get
the effect  front  either  substance.   The  same  score  for
arsenic on  renal  toxicity  and  neurobehavioral  toxicity
implies that a  person is equally  likely  to develop either
health effect.  However,  in neither case  can  the  absolute
number of cases  of renal toxicity  or  neurobehavioral  tox-
icity be determined.

     Where data are not available to score a specific health
effect and a particular pollutant,  a score  of zero has  been
assigned.  This practice  gives  higher  weight to pollutants
which have been subject  to toxicological studies.  In other
cases, a  score  of  zero was  assigned  because  either  data
indicated zero risk or the quality  of the data was too  poor
to estimate risks with any confidence.
*  A  dose-response  relationship  quantifies  the  increased
   risk of  contracting  an  effect  as  a  function  of  the
   dose of the pollutant received.
                            -26-

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     It is important to recognize that  the uncertainty asso-
ciated with Clement's dose-response estimates is quite large.
The approach used  for  estimating  cancer risks is generally
accepted,  however, the estimates may  be high  or  low  by an
order of  magnitude..  The risk  estimates for  other healtjh
effects may well  be  less  certain  than those  for  cancer.
Health Effect Prioritization

     Once population  exposure and  relative  risk measures
have been calculated, the relative incidence levels of each
health effect  can  be  determined.    As   the  eight  health
effects may have different consequences and. imply different
control strategies, decision  makers  need  to make tradeoffs
among them. . Since  there  is  no unique and  objective means
of prioritizing the health effects, several sets of weights
have been developed  to  assist decision makers  explore the
consequences of  specific  tradeoffs.   This  section reviews
the development of alternative weights.*

     The following  methodology  was  employed  to  develop
several sets of  weights.   First, the  eight" health effects
of concern  were  classified   into  broad   health categories
for which  data  are  collected by  the National  Center for
Health Statistics.  Second, data were collected on the con-
sequences of each of these health categories.** Alternative
sets of weights  were then developed  based  on data for the
following consequences:

     •    Loss of life expectancy per case,

     •    Direct cost of treatment per case,

     •    Lost compensation per case,
*  The derivation  of these weights  is  described in detail
   in Appendix  D and  is  based  on  work performed  by Dr.
   Milton Weinstein of the Harvard School of Public Health.

** Much of the data on treatment  costs and lost compensation
   are found  in  B.  S. Cooper and D.  P.  Rice, "The Economic
   Cost of  Illness  Revisited,"  Social Security Bulletin 39
   (1976):  21-36.
                            -27-

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          Quality of life lost per case, and

          Loss  of  quality-adjusted  life  expectancy  per
          case.*
Exhibit 2-5  indicates  the  ordering of  the  broad  disease
categories along  the  five  consequences  described  above.
Exhibit 2-6  lists  the three  sets of  weights used  in the
analysis.   The weights  in Exhibit 2-6 are  derived  by map-
ping the  weights  in  Exhibit  2-5  into the  eight specific
health effects of  concern.    The  number  in  parenthesis  in
the first  column  in Exhibit  2-6  corresponds to the appro-
priate disease category  from  which the weight  is derived.
For example,   neurological   disorder  corresponds   to the
broad category of  diseases  of  the nervous  system.   Thus,
the quality  of  life lost weight for neurological disorders
corresonds to the quality of  life lost weight for diseases
of the  nervous  system.  The  weights  in  both exhibits have
been normalized to  sum to one.  EPA selected  the quality of
life weights  for  use as  baseline weights in  this analysis.
Chapter 4  discusses the  results  of the analysis using each
set of weights.

     The discussion above briefly describes  the  procedures
used to estimate  relative risk of health effects given_the
human exposure  estimates developed  earlier.  In addition,
a method  of  prioritizing  health  effects  through assigned
weights has been outlined. When combined with the  procedures
described  earlier,  this  information allows  the  analyst to
evaluate alternative pollution reduction strategies  in terms
of cost and  associated  reduction  in  relative health  risk.


INTEGRATION  OF PRODUCTION,  POLLUTION,
EXPOSURE AND HEALTH ANALYSES

     The sections   above have   described  the   four   major
elements of  the  industry approach:  production,  pollution,
exposure and health analyses.   Although  these elements have
been described separately, the great strength of the approach
is that  all  are   considered  together.    As described  in
*  These  weights,  while very subjective, are  an  attempt  to
   capture not  only the years of  life  lost but  the  number
   of  years  spent  in  the diseased  state.
                             -28-

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VO
I
                                               Exhibit 2-5



                                PRELIMINARY INDEX OF DISEASE CONSEQUENCES





                                Years of   Treatment  Economic  Quality-of-Life   Quality-Adjusted
Basic
1.
2.
3.
4.
5.
6.
7.
Disease Categories Life
Neoplasms .
Congenital Anomalies
Diseases of Nervous
System
Diseases of
Genitourinary System
Diseases of Digestive . .
System
Diseases of Respiratory
System
Complications of
Pregnancy & Childbirth
1.
Lost
50
34
07
03
04
03
0
00
Costs
.24
.07
• .32
.18
.09
.06
.04
1.00
. Costs*
.37
.15
.25
.09
.07
.06
.01
1.00
Lost
.13
.28
.21
.08
.12
.16
.01
1.00
Life Expectancy
.39
.32
.11
.04
.06
.07
0
1.00
*    This category includes treatment costs and lost compensation due to morbidity and mortality.


     Source: Plin Analysis.

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                                             Exhibit  2-6

                            ALTERNATIVE WEIGHTS  FOR  EIGHT  HEALTH  EFFECTS


                                              Average  of Years
                                              of Life  Lost and      Quality-of-Life
     Health Effect*

     Cancer (1)

     Mutagenicity  (2)

     Teratogenicity  (2)

»     Neurological  Disorder  (3)
LA>
o
1     Reproductive  Toxicity  ((2)  t  (7)) i  2

     Kidney Disease  (4)

     Hepatotoxicity  (5)

     Other (6)
Economic Costs
.3i
.17
.17
.13
.09
.05
.04
.03
1.00
Lost
.09
.20
.20
.15
.10
.06
.09
.12
1.00
Equal
.125
.125
.125
.125
.125
.125
.125
.125
1.00
        Numbers  in parentheses correspond  to disease categories  in Exhibit  2-5,


        Source:  PHD Analysis.

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Chapter 1,  this  allows  consistent  assumptions  to  be used
throughput the  analysis  and  insures  that  all  relevant
issues ~are""included.

     In order to  carry out the approach,  the  analyst must
first study the  industry of  interest  to  ascertain typical
production configurations/ regions of operation, and  likely
toxic pollutant problems.  The analyst then decides whether
to work with  actual  or typical plants  and exposure routes.
This decision is  based  on  time and  resource  constraints,
data availability and other factors.  Specific plants to be
analyzed are then configured.

     Once plants  are configured,  the  analyst  carries  out
the production and pollution elements.  This requires  devel-
opment of the material flows,  manufacturing costs, pollutant
levels and  pollution control  options.   Using  these  data,
the analyst determines all of  the .possible levels of  pollu-
tion and  the  associated  costs to the  plant.   In so  doing,
it is  assumed that  plant  operators will  seek to maximize
the net present  value of  the  cash  flow  generated  by the
plant.  Thus, for any mandated ilevel of pollution reduction
the plant will  select that combination  of control options
which meets  the  pollution  requirement  while  having  the
least possible effect on cash  flow.  Again, control options
can include  installation of  control  equipment,  changes in
raw  materials or  product mix,  and  partial  or  complete
process shutdowns.

     The  next step in the approach  is to determine  the human
exposure  that will  result from these pollution  levels.  As
described in  this chapter/  a  variety of mathematical  models
are used  to convert pollutant quantities  to concentrations
in the  media and region of  interest.   These  estimates of
concentration are  combined with population  data to  deter-
mine the  number of  people  exposed  to different  concentra-
tions.  When  generalized plants and  regions  are used, the
exposure  analysis is based  on typical  values for input  data
such as  source  characteristics,   meteorology,   population
density and so  forth.

     Finally, the  likely  health  effects  arising from the
predicted exposure  levels  are developed,  and health effects
are combined  into overall  metric using  the health weighting
schemes described.   These health effects  can  be traced to
the specific  level  of  pollution and  associated costs  incur-
red.  Thus, reduction in health risk can be related directly
back to  the costs   incurred  for pollution  control  by the
industrial  plant.

                            -31-

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     When the industry approach  is  applied to particularly
complex industries, mathematical programming can be used to
automate the required calculations.	By using math program-
ming, all of  the material,  cash,  and pollutant  flows can
be traced.   The model  simulates  the operating  decisions
made to  maximize  the  value  of  the plant's  cash  flows.
Constraints on  the  quantities  of pollutants  emitted  or on
the relative health risk levels arising from the pollutants
emitted can  be  applied.   The  model  will then  choose the
most cost-effective combination of pollution control options
to meet these constraints.

     The advantage  of  a mathematical program,  in addition
to automating the calculations, is that is ensures that the
analysis simultaneously  accounts  for costs  and  risks.  It
also forces  the  analyst  to  consider   pollution  control
options, such as process shutdowns and raw material substi-
tution, which are often not considered.

     The chlorinated  organic  solvents  industry  is  suffi-
ciently complex that PHB developed  a  math  programming formu-
lation to assist the case  study of this industry. ; Appendix
A includes a description of math programming and  the; detailed
equations that  were used  in the  chlorinated organics  case
study.   It  was  not necessary  to develop  a math program to
analyze  the  copper smelting  industry.
CUMULATIVE ECONOMIC  IMPACTS

     The  industry  approach considers  the  cost of  environ-
mental control  options at the  plant level.   In  evaluating
environmental policies,  analysts must  also consider  other
measures  of  impact  such  as  changes  in  employment,  price
levels and firm and  industry  profitability.  Likely employ-
ment changes will  be apparent  if partial or  complete  plant
shutdowns are  selected  as a  control  option  or  if  overall
plant cash  flow is  insufficient to allow  continued opera-
tions.  Estimation of profitability  and  price impacts  re-
quire further analysis.


Profitability

     The  plant   focus  of  the  industry  approach  requires
that cash flow  be  the primary cost metric  since  management
will try  to maximize the cash flow  which  results  from  plant
                             -32-

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operations.  Thus, management  will select those activities
and control options  which maximize the  cash  flow from the
plant while meeting  -whatever--regulatory  and  economic . con-_
straints are in force.*

     In order to estimate profitability,  an income statement
must be derived from the  cash  -flows.   Individual plant in-
come statements can  then  be  aggregated to firm or industry
statements.  The  cash flow  estimates  can be  converted to
an income statement  in the following manner.

     •    Delete annualized pollution  control capital costs
          from the  cash  flows  to arrive  at  the  plant's
          gross margin.

     *    Subtract the depreciation  charges  and  interest
          charges resulting  from  the  invested  capital in
          production  and  pollution control  equipment  from
          the plant's  cash  flow.  This  step  requires  that
          an estimate  be  made  of the age and  book value of
          invested capital  (including  working capital) re-
          quired  by  the  plant  and  the  capital structure
          which supports  this  investment.

     •    Subtract  the plant's share of  corporate  selling,
          general and  administrative  expenses-  and  other
          corporate  overhead expenses,

     •     Estimate  taxes  based on  the  typical or actual cor-
          porate  tax situation experienced in  the industry.
 *   Average  annual cash flow is used in the first four steps
    of  the  approach.   This  cash  flow  equals  revenues  less
    operating  costs, annualized  pollution  control  capital
    costs, and pollution  control  operating  and  maintenance
    costs.   The pollution control capital  costs  are  annual-
    ized  in  a  manner which  equates  the present value  of the
    annualized costs after-tax  to  the  present value  of the
    capital  costs  less  subsequent tax  effects  (depreciation
    tax shield and investment tax credit).  This annualization
    assures  that the single period  analysis will  result  in
    the same  control  strategies  as a multiyear  cash  flow
    analysis.
                             -33-

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The resulting income  statement  provides  an estimate of the
plant's after-tax profit.  The use of this income statement
is further discussed  in Chapter 3.
Price

     All of  the  analysis  described  thus  far  has  assumed
constant prices for  the  products  of the plant under consi-
deration.  However,  as  producers  incur  costs  to  reduce
pollution they are likely to increase prices to some extent
in order  to  recover  some of  these costs.  The  extent to
which such price  increases benefit  the producer  is deter-
mined by  the  price  elasticity   for  each  product.   Price
elasticity measures  the  likely reduction in demand brought
about by increases in price.

     Actual price elasticity figures  are difficult to esti-
mate and are  available  for  few  industrial products.   When
estimates are  available, the.approach  can be  carried out
through several iterations to allow price levels to stabilize
based on  the  selection  • of  control  options  and  resulting
costs.*  When  no  estimates are  available,  constant prices
are assumed  in order to be  conservative in overestimating
rather than underestimating cost  impact.

     In considering  economic  impacts  in  the absence  of
price elasticity data, it is useful  to calculate the maximum
price increase  that  might  be  needed.   The price increase
required to  maintain  profitability  can  be  calculated by
deriving the  additional  revenue needed  to  arrive  at the
same level of  profit.    The  additional  revenue needed will
be t
                     AREV *   A prof it
                                (l-Tax)

Where:     AREV » increase  in revenue  required
         AProfit = decline  in  profits experienced
             Tax - corporate income tax rate

In  addition,  if  price elasticity information  is  available,
the decline  in demand  which  results  from  any given  price
increase can be calculated.
    Changes  in product prices may in turn change the selection
    of  control options,  thus making several iterations neces-
    sary.

                             -34-

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FORM, INTERPRETATION AND USE OF RESULTS	CHAPTER 3


INTRODUCTION

     The industry approach described in Chapters  1 and 2 can
be used in  several ways  for  economic  and policy analysis.
The approach can be modified as needed  in specific applica-
tions, and  thus  may  produce  different  kinds of  results.
There are two uses of general interest:

     •    Cost-effectiveness analysis,  and

    ' •    Analysis of cumulative economic impacts.

     Cost-effectiveness analysis consists- of  the simultan-
eous consideration ofenvironmental  damage  (limited in the
work to date  to  human health  risk)  and  cost.   One of the
major outputs of the industry approach is a "cost-effective-
ness curve" for an actual or typical industry plant.  Cumu-
lative economic impact analysis is  based on  the consider-
ation of all environmental regulations  and control options,
and the resulting  impact on industry profitability, employ-
ment, and other economic variables.

     The purpose  of  this chapter  is  to explain  the use of
the industry  approach  in performing  each  of  these  types
of analysis,  review  the major  limitations  of the approach
and discuss methods of sensitivity analysis.  The remainder
of the  chapter  is  organized   in  the  following sections:

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     •    Cost-Effectiveness Analysis,

     •    Cumulative Economic Impact Analysis,

     •    Major Limitations of the Approach, and

     •    Sensitivity Analysis.


COST-EFFECTIVENESS ANALYSIS

     Cost-effectiveness analysis  considers  the  cost  and
effectiveness of  an  alternative  in  meeting  a  specified
goal.  Alternatives  that  are  most cost-effective will pro-
duce the greatest progress toward the goal per unit of cost
incurred.  In  carrying  out such  analysis,  it is important
to understand  the definitions  of  cost  and  effectiveness
being employed.


Definition of Cost and Effectiveness

     In the industry approach,  PHB  has defined the  cost of
an environmental  control  option  to  equal  the  sum  of:

     •    The net decrease in a plant's gross  margin  (re-
          venue less manufacturing  costs) caused by imple-
          mentation of the option, and

     •    The net increase  annualized capital  charges in-
          curred due  to   capital  expenditures required  by
          the option.

Gross margin  reduction  includes  additional  operating and
maintenance charges  for   control  equipment,  and the  cost
impact of  changes  in production  operations,  raw materials
and other  alterations  in  manufacturing  which  occur  to
reduce pollution.  Annualized  capital charges are computed
to equal the annual  equivalent  of the cash flows resulting
from a capital  expenditure  including the original expendi-
ture, tax consequences and  the  required return to debt and
equity financing.

     PHB has defined the  effectiveness  of a given environ-
mental control option, for present purposes, to be the per-
centage reduction  in  health   risk.    Percentage  reduction
can be considered  for  each  of the eight  health  effects  or
for a  "total"  health effect which reflects a  weighting of
                            -36-

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the eight.    Again,   it  is  important  to  note  that  health
risk reduction  is  a  relative   reduction  as  compared  to
the uncontrolled  case.   Absolute incidence  levels  are not
estimated due  to the  limitations  of  currently  available
toxicological data.
The Cost-Effectiveness Curve

     Exhibit 3-1 presents a typical cost-effectiveness curve
that results from  the industry  approach.   The  curve shows
the cost of  achieving, through  a  combination of pollution
control options, a  given  level  of health  risk reduction.
Note that  cost  increases  relatively  slowly up  until  the
80 percent risk  reduction  point and increases dramatically
thereafter.  This  is a  typical  result  which reflects  the
initial ease with  which  pollutant  levels   can  be  reduced
from uncontrolled  levels,  the  increasing  difficulty  due
to declining efficiency  thereafter and  the rapid increase
in cost  which  occurs  as the  last amounts   are controlled.
In this  last  segment  of  the  curve,  control usually takes
the form of partial  or complete  plant  shutdowns.

     The cost-effectiveness  curve describes   the  optimal
control strategy  for each level of risk reduction because
the most cost-effective  combination of  control options  is
employed at; each point  of the  curve.  The  origin _ in  Ex-
hibit 3-1  represents  the  uncontrolled  case in  which  the
plant is  allowed  to  operate  without  any  limitation  on
pollution levels  or health risk.   At  point A of the _curve
"(10 percent'-risk reduction over  the uncontrolled  condition)
there might- be  a   mix  of  control  options  for  the major
polluting processes.  At point B (80 percent risk  reduction)
full control of  all processes might be  in  place.  At point
C  (90 percent  risk reduction) some processes may have  been
shut down,  thus  resulting  in  a steeper increase in cost.
Because  different  pollutants give  rise  to  different  health
effects, the cost-effectiveness curve for  different  health
effects  might  have varying  shapes and  sequences of  treat-
ment options.   For  example,  the   curve for  cancer would
reflect  the  selection of  the  control options which limit
carcinogenic emissions.    Other  options  might  be selected
for other  health  effects  which  are  caused  by different
pollutants.

     Although  both  the   chlorinated  organics   and   copper
smelting industries have  some  control equipment in  place,
the development  of cost-effectiveness curves carried out  to


                             -37-

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                      Exhibit  3-1

          A TYPICAL  COST-EFFECTIVENESS CURVE
  Cost
(000  $)
            10%
       50%         80% 90% 100%

Health Risk Reduction  (%)
                              -38-

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.date has proceeded  as if  no equipment  were presently in-
stalled.  This approach  has  been taken because the control
cost estimates  available  to  PH3_are  stated based  on new
installation rather  than  on  incremental  improvements  to
equipment already  in place.   The result  of this approach
is that  the  order  of   control   option  selection  is that
which would  occur  if the plant were  beginning  with  no
equipment rather  than modifying its  existing equipment.*

     It is  useful  to compare the cost-effectiveness  of al-
ternative regulatory policies against the cost-effectiveness
curve.  For  example, a  policy  which mandates  an overall
reduction in  the  emissions  of a given  pollutant from all
sources within  a  plant  will have a certain  cost  and  result
in some reduction  in  health  risk.  This  policy  can be anal-
yzed and a  point  plotted as in  Exhibit  3-1,  point D.  Note
that the  risk  reduction level  achieved  is  50 percent and
that a  more  cost—effective  position  on the  curve  would
achieve the  same   risk  reduction at  a significant savings
in cost.   Point  D  represents  a policy  alternative  that
is far  less cost-effective than  the  maximum  cost-effective-
nes's represented  by  the  curve.   Point E,  however,   is  an
alternative that  is quite close to the  curve.   Any  policy
alternative can be compared  to the  cost-effectiveness curve
in this  way.   Because the curve represents  the  most cost-
effective way to  achieve  a  level  of  risk  reduction,  the
most cost-effective policy  can   at  best  be  on  the  curve,
and not below  it.   Many  alternatives  will  be  above  the
 curve.
 CUMULATIVE  ECONOMIC IMPACT ANALYSIS

      Cumulative  economic  impact  is  often  considered  by
 analyzing:

      •    profitability and capital availability,

      •    Likely price increases and inflation impacts, and

      •    Employment changes and plant shutdowns.
 *  It would  be  possible to develop  engineering cost esti-
    mates for retrofit  improvements to  equipment in place,
    The cost-effectiveness analysis could  then consider mod-
    ifications to plant's existing equipment.
                             -39-

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These impacts  are  analyzed  foe  specific  regulations  or
groups of regulations rather than for all points on  the cost-
effectiveness curve, _and  often  are considered for a period
of years rather than  a  single year.   Further, the analysis
is frequently  carried out  at  the  firm or  industry level
rather than at  the plant level.   Thus, #results from plant
analyses must be aggregated.

     Profitability and capital  availability can be analyzed
through direct  reference  to  income   statements  developed
from the  industry  approach.  Such  income  statements,  cal-
culated for each period of interest, will show profitability
of the plant,  firm or industry directly.  Capital availabil-
ity is closely linked to profitability  since profits provide
a major portion  of  internally  generated  capital  and allow
firms access to the capital markets for both debt and equity
funds.  Thus,  significant reductions  in profitability will
adversely impact a  firm's ability to  raise capital  through
both internal and external  sources.

     Price increases  and  resulting  inflation  impacts  are
perhaps the most difficult  impacts  to analyze.   Both the
cost-effectiveness analysis  and the  profitability analysis
rely on  estimates  of product  prices.  However,  if these
analyses indicate major  costs or reductions in profit, new
assumptions may  need to  be  made about product  price and
quantity and  the  analysis  carried out a  second  time.   In
short, the price elasticity for products must  be considered.
The final  cost-effectiveness curves and  income statements
derived from the approach will be based on assumptions about
price elasticity and prices.  These assumptions play  a major
part in  determining  profitability impacts  and employment
impacts and plant shutdowns.

     Once likely price  behavior  is determined, the  overall
impact on  inflation  can  be  estimated by  calculating the
increase  in  various  price  indices (Producer  Price  Index,
GUP Price Deflator)  due to the  increase in product  prices.
Such an  approach  ignores the  effects of these  price in-
creases on other commodities  in the economy  (the multiplier
effect);  these secondary  effects can be examined if desired.

     Finally, employment  changes and plant shutdowns can be
analyzed  by  comparing  the  cash  flow  generated from plant
operations less required  reinvestment  in the plant with the
plant's salvage  value  and  the potential  earnings  on the
firm's capital  in  other uses.  When analyzing  an  industry,
                             -40-

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marginal plants can often be identified  for further analysis
based on s.ize, age,  outmoded technology and  so forth.  Em-
ployment losses will  result both from the shutdown^ of mar-
ginal plants and  from the partial  shutdowns  that "occur' at
other plants.
MAJOR LIMITATIONS OF THE APPROACH

     The major limitations of the industry approach are re-
lated to  the  problems  of diversity,  complexity and uncer-
tainty.  As described  in Chapter  2, PHB  has  attempted to
generalize and  simplify  in  order  to  meet  the  first two
problems, and has  carried  out sensitivity  analysis in the
actual cases  analyzed  in  order  to  estimate the  range of
uncertainty in the  results due  to  these steps  as  well as
the uncertainty  in  the  input data.   The major  limitations
are discussed below.
Diversity and Generalization

     The diversity of industrial facilities,  exposure routes
and health effects  has been  mitigated in the  actual  case
studies by carrying  out the  analysis  on a  set of typical
plants or exposure routes  where necessary,  and considering
only eight health effects.   As discussed  previously,  the
consideration of  health effects only  clearly  limits  the
present ability of  the approach to find optimum strategies
for reducing  environmental effects.   However,  these addi-
tional effects can be  added to the approach as data become
available and interests dictate.

     The  need to   generalize  industrial   facilities  and
exposure routes, is  the first  basic source  of limitations
and depends  almost  completely  on  the  characteristics  of
the specific industry.  For example, the application of the
approach to  the  chlorinated  organic  solvents  industry  —
a highly  complex  process   industry  —  requires  extensive
generalization of plant configurations  and exposure routes.
On the  other  hand,   the   copper  smelting  case  requires
little generalization  of  plant  configurations due  to  a
relatively small number of  fairly simple plants  of interest.
Nevertheless the  copper  smelter  study  did  require  some
generalization of exposure  routes.
                            -41-

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Complexity and Simplification

     The  simplifications.... required  are the  second  ba_sic_
source of limitations.  The simplified industrial facilities
and pollution  control options  considered  are  not thought
by PHB to be  major limitations  in  the  approach.  However,
the simplifications required  to allow  analysis of exposure
routes and health effects are  more  serious.   Each of these
is discussed below.

     The mechanisms  through  which  human  populations  are
exposed to  industrial discharges  of pollution  are  highly
complex, and current understanding of them is not complete.
To analyze these routes, PHB utilized a number of air qual-
ity, water  quality and  ground  water  models  available to
EPA or  developed for  this  effort  with  SPA  staff.   These
models vary considerably  in their  accuracy.* For example,
air quality  models are  generally  the  best  developed  and
most accurate, and  exceed  water quality models  in perform-
ance.  Both  air  and  water  quality  models  far  exceed  the
current capabilities  of ground water models.   Although the
limitations of  air  and  water  quality  models  limit  the
accuracy of  the  results,  PHB  believes  that  these  models
yield results appropriate to the objectives of this effort.
However, the ground water  models used are sufficiently im-
precise to  require  extreme  caution when  evaluating  the
hazardous waste  aspects of the  analysis.

     The "other major  complexity  that  has  been simplified
in the  industry  approach concerns  the  incidence of health
effects.  As  explained previously,  the  industry  approach
does not predict absolute incidence  or changes  in  incidence
of health effects,  due  to  the uncertainty in toxicological
data.  Should  improved  data  become available, the industry
approach would  allow  calculation  of  the  cost  per  case
avoided.  This  cost  could  then  be compared  to  estimates
of the benefit of  such  avoidance in order to determine the
level of  reduction in health  risk which can be  justified
on a  cost-benefit  basis.   At  the  present  time,  however,
such analysis  cannot  be carried out and  thus  the overall
level of  risk  reduction desired must  be  based  on  Agency
judgment.  Given  the  selection of this level, however, the
industry approach  indicates  the  most  cost-effective  way
to meet the health risk reduction goal.
*  See  Appendix  B for a  further discussion of this  issue.


                            -42-

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Data Uncertainty

     The final source of limitations in the approach is the
level of uncertainty in the required input data and the re-
sulting uncertainty in the results.  The level of uncertainty
in the data is largely a function of the industry of interest,
and general limitations based  on  this  uncertainty are hard
to develop.  In  both  of the  case  studies, estimates of the
uncertainty have  been  developed   using  methods  described
below.  In addition,  estimates of  the uncertainty  in the
relative risk scores for different health effects have been
developed and are reported below.
SENSITIVITY ANALYSIS

    The industry approach has combined the available produc-
tion and  pollution data  with  the  available  exposure  and
health data to  allow the identification of  the most cost-
effective methods  to  minimize health  risks.   In so doing,
data of varying  accuracy are combined to arrive at a cost-
effective strategy  for  reducing risk.   This  discussion of
sensitivity analysis  reviews   the  potential   sources  and
magnitude of  uncertainty,  and  outlines the  approach  used
to measure the  sensitivity of  the  results  to these uncer-
tainties.
Sources of Error

     Exhibit 3-2  identifies  the  models  and data  used in
each component  of  the  problem.   For each,  an assessment
was made  of  accuracy.   As  shown  in Exhibit  3-2,  process
flow data, manufacturing and pollution  control costs, and
emission  factors  are  all  regarded  as  accurate  to ±30 to
35 percent.  This  is  the standard  error found  in engineer-
ing studies  which  are  done  without detailed laboratory
work or field visits.

     The  models used in the exposure area are less accurate.
The air  models,  while  regarded as  the most  advanced and
thoroughly tested,  are reliable to only ^150  to  500  percent.
The water models  are thought to be  less accurate,  but are
assumed to  have   errors   of j^SOO percent.   Finally,  the
ground water  exposure model is a  very  crude  representa-
tion of  a phenomena which is not well understood.  As  such
the actual exposure could be  an  order  of magnitude higher
or lower  than estimated.
                             -43-

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                        Exhibit 3-2

                ACCURACY OF MODELS AND DATA
Problem
Component
  Models  and
  Data  Used
  Accuracy of
Models and Data
Production Analysis  •  Process Flows

                     •  Manufacturing
                        Cost Data
                        30  to 35%
Pollution Analysis
•  Emission Factors

•  Pollution Control
   Equipment Costs
                                            +  30  to 35%
 Exposure  'Analysis
Models and Data Meas-
uring Dispersion of
Pollutants:

•  Air

•  Water

•  Hazardous Waste
                                            * 150% to 500%

                                            * 500%

                                            Order of Magnitude
 Health Effects
    Toxicity Scores    Order of Magnitude
                         Weighting of
                         Health  Effects
                       No Correct  Answer;
                       Matter of Judgment
                              -44-

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     The data employed  in  the  health effects area are also
uncertain.  The  available  toxicology information is incom-
plete and, in some, cases, contradictory.   Clement Associates
has stated  that an  order  of  magnitude   error  is  inherent
in the health effect scores.   In  the analysis,  these scores
are weighted to achieve a single health risk.   The weighting
of the scores is highly subjective and no "unique" weighting
scheme exists.*
Sensitivity Analysis Method

     In carrying  out sensitivity analysis  the*  distribution
about the  results could be  derived by analyzing many com-
binations  of  data.  One  method  of doing  this  is  to:   1)
determine  the  distribution  about  each  of  the  parameters
in the  analysis,  2) randomly  select a point estimate from
each distribution,  and  3)  derive  the cost-effective control
strategy given  these point estimates.  Steps 2 and 3  would
be repeated many  times  resulting  in a distribution of  cost-
effective  control strategies.  This "Monte Carlo"_ simula-
tion is  expensive  and  time  consuming  in  practice  and,
therefore, has  not, been employed  in this  study.

     To gain  insight  into  the  likely uncertainty  of  the
results of the   chlorinated.' solvent  and  copper  smelting
cases,  extreme  values  have been selected  for several  impor-
tant parameters  and   the  analysis  has.  been  carried  out
using'these  values.   If  the  results of  the   analysis  are
 insensitive  to  these changes,  then the analyst gains  confi-
dence  in  the results  obtained.   The  extreme  values  tested
are  described  below,   and  results  of  these  sensitivity
analyses  are   summarized  in Chapter  4  and  the  industry
briefing  packages.  Two  extreme value  analyses were  per-
 formed :

      1.    Alternative exposure measures were tested.

      2.    Health effects regarded as highly uncertain  were
           eliminated.
    The weights  are  not regarded as a source of error.  Al-
    ternative weighting schemes were discussed in Chapter 2,
    and the  effect  of  these  alternatives  is  described in
    Chapter 4.
                             -45-

-------
     Alternative Exposure Measures

     As shown in Exhibit 3-2, the exposure measures are not
as reliable as the production"and pollution data.  In order
to determine whether  differences in exposure  levels would
result in different  cost-effective  control strategies, the
following alternative levels  of exposure were  used  in the
chlorinated solvents model.*

     •    Air exposure was reduced 50 percent.

     •    Water exposure was  doubled.

     •    Hazardous waste exposure was increased tenfold.

These alternative  exposure  levels  were  chosen  since air
exposure has the  greatest impact on  risk.   Increasing air
exposure would  add  further support to the current results.
The aim  in  this  analysis is  to determine whether increased
risk in  the water and hazardous waste area would change the
cost-effective  pollution control strategy.  The results of
these alternative levels of exposure are given  in.Chapter 4.


     Alternative Health  Effects

     As  stated above, the health effect scores for pollutants
are highly uncertain.  Clement Associates estimated the level
of uncertainty associated with  each measure of relative risk
by assigning each score a value of 1 to 4,  with 1 represent-
ing the  least amount of  uncertainty and 4 the greatest amount
of uncertainty.  The uncertainty levels are defined in Table
3-1.  Of Clement's  109  relative risk  measures, only  12.8
percent  were  assigned a level  of uncertainty  of 1 and 16.5
percent  were  assigned an uncertainty level of  2.  The bulk
of the risk measures (58.7  percent) were assigned an uncer-
tainty level  of  3;  the  remaining 11.0  percent  were assigned
a level  of  4.   Exhibit  3-3  provides  Clement's estimated
level  of uncertainty for each relative  risk measure.
    This analysis was  not  performed on the  copper  smelting
    industry since exposure to water  pollutants  and  hazard-
    ous waste was not included in that study.
                             -46-

-------
                         Figure 3-1

              DEFINITION OF UNCERTAINTY LEVELS

Level of Uncertainty                  Criteria

       1                   Adequate human epidemiological
                           data.

       2                   Several adequate animal studies
                           with quantitative  dose-response
                           data.

       3                   Only one adequate animal study;
                           poor dose-response data.

       4                   Gross  assumptions were made.


     To determine  the cost-effective  strategy  which would
result if  only  the  more certain  health  effects were  con-
sidered, all  pollutant/health  effect  combinations  with a
level of  uncertainty  of 3  or .4  were  eliminated  from  the
analysis.   Again,  the results  of  this  analysis  are provided
in  Chapter 4.


     Generalization

     One  further  sensitivity  analysis was  carried  out  in
addition  to the  extreme  value  analyses  described  above.
When generalized  plant  configurations or  exposure  routes
are used,  uncertainty can be  created  by  the act of  gener-
alizing.   In the  case  study  of  the  chlorinated  solvents
industry  one generalized plant was used  to  represent seven
actual  plants   on  the  Mississippi River.   To   analyze  the
accuracy  of this  generalization,  each of the  seven  plants
was analyzed  individually  and  the  results  were  added.
The sum of the seven plants was compared  to the generalized
plant  to  determine   the validity of  the  generalization.
The results of  this  analysis are reviewed  in Chapter 4.
                             -47-

-------
                  Exhibit 3-3

ESTIMATED LEVEL OF CERTAINTY FOR HEALTH SCORES
(1 = Highest Certainty, 4 = Lowest Certainty)
	 1 . • •
Arauulc
bfll*VI>U
II IK {2-ttihylliexyl) i>litl>Hlata
n-ltuiyl cUliifitlu mill
•uf~lliityl clilurldd
itillllllllllll ,
C.irlioii 1 u» rnclilor Jilc
(IliliU'uittrin
2-i:i,iui,,,.i,L.iioi
1 «:I,KM,,I.,W
00
I lll-M-biilyl |i|iili.il.1ltt
t , l-Diuliloroxl luiim
i,4-l)l.:MJro|.lK:iH.|
lLl-l»lt:lll..r..|ir.i|.unu
1:1 !,«,.«
l.lliyl Uiluil.le
Kt.liy leuu
Ktliyluiiu dlclilm Ide
Kluorenu
lluxarli 1 in olioiu.'m:
IU::
-------
                                             Exhibit 3-3
                                             (Continued)

                           ESTIMATED LEVEL OF CERTAINTY FOR HEALTH SCORES
                           (1 « Highest Certainty,  4 = Lowest Certainty)
I
*>.
VO
I
" ^ t fi —I m


He i It y 1 til lie (*
htiitocliloruiictit y tune
Nlckul


Sul fur tl Ion lilc
T*ii i;u**Mot;i»utliy leita

Trmit* /c J tf-itlcli 1 oi o«t Ity 1 uiiti
1 I I- 1 1 It MiHuelhaiui
1 1 2-Tr iclilnruulhuiie
Tr Ichloruui liylcitc

Vinyl CMurUlx
Vinyl l
-------
INDUSTRY APPLICATIONS	CHAPTER 4
INTRODUCTION

     The industry  approach.to toxic pollutant control des-
cribed in Chapters  1, 2 and 3 has been applied to the chlo-.
rinated organic  solvents  and copper  smelting  industries..
The chlorinated solvents industry is a segment of  the organ~
ic chemicals  industry and  produces a number of chemicals;
that are used in other major  sectors of the  industry  (plas-
tics, silicones,  fluorocarbons)   as well  as  used directly
for their solvent  properties.  In addition,  the  chlorinated
solvents industry   represents  a  complex  process industry
with a  variety  of  plant locations  and associated exposure
routes. The  chlorinated  solvents industry is  in  relatively
good financial health.

     The copper smelting industry is a segment of the  copper
raining, smelting  and refining industry,  and  produces anode
and "fire-refined  copper.   The copper  smelting  industry _ is
less diverse  and  complex  than the  chemicals  industry with
respect to  production facilities  and  exposure  routes,  but
nevertheless  poses  some  interesting and difficult environ-
mental  problems.    Further,   the  industry  is  experiencing
financial difficulties.

     The detailed results  of PHB's  analysis of these  two in-
dustries are  presented in  briefings which are included_under
separate cover.   This chapter presents a  short  description
of each  of  these  industries  and a summary  of  the  results
for  each case study.  In  the material to follow,  the chlorin-
ated organic solvents case study  is  discussed  first,  followed
by  the  copper smelting  case study.

-------
CHLORINATED ORGANIC  SOLVENTS  INDUSTRY

     This section  of- Chapter-4 summarizes  the results  of
PHB's  application  of the industry approach  to  the  chlorin-
ated organic  solvents industry.   The  section  is organized
as  follows:

     •    Description of Industry,

     •    Pollution  Problems  of Concern,

     •    Cost-effective Control Strategies,

     •    Alternative Policies Examined

     •    Cumulative Economic Impacts, and

     •    Se-nsitivity of Results.


Description of Industry

     The chlorinated organics  case  study  focuses  on the
production of a  group of chloromethanes  and  chloroethanes.
Most of  the  processes used  to  produce  these products .in-
volve chlorination reactions.   Exhibit 4-1  shows the proc-
esses and products included in the study.  Ethylene  dichlo-
ride (EDC) is the major chloroethane  and  is largely consumed
in  the   manufacture   of  vinyl  chloride.   Vinyl chloride
is  consumed,  in  turn, in production of  polyvinyl chloride
and other  plastic resins.    Other  chloroethanes  are  used
primarily as  solvents.   Vinylidene chloride, a high value
chloroethane derived from EDC,   is polymerized  to  produce
plastic materials such as Saran.

     Chloromethanes  have somewhat different uses.  Methylene
chloride is used  in  paint removers  and  degreasing  agents.
Methyl chloride  is  used  in  the  production  of  silicone
resins and rubbers.   Two other  chloromethanes, chloroform
and carbon  tetrachloride, are  used primarily  to   produce
fluorocarbon refrigerants and propellants.  Some chloroform
is  also used to produce  fluorocarbon plastics.

     Exhibit 4-2 diagrams the processes  and  major material
flows included in the industry.  Production  of  chlorinated
organic  compounds occurs at several  different types  of
manufacturing facilities  which  can be  differentiated based
                           -51-

-------
                        Exhibit 4-1

             PROCESSES AND PRODUCTS INCLUDED IN
             CHLORINATED ORGANIC SEGMENT STUDY"
Process

1.   Chlorination of Methane
     Hydrochlorination of
     Methanol/Chlorination of
     Methyl Chloride

     Chlorination of Hydrocarbons
4.   Chlorination of EDC  I


5.   Direct Chlorination  of
     Ethylene

6.   Oxychlorination of Ethylene
7.   Pyrolysis of  EDC

8.   Chlorination  of Vinyl
     Chloride

9.   Chlorinaticn  of EDC II

10.  Dehydrochlorination of
     1,1,2  Trichloroethane

11.  Hydrochlorination of
     Vinylidene  Chloride
Products

Carbon Tetrachloride
Chloroform
Methylene Chloride
Methyl Chloride

Carbon Tetrachloride
Chloroform
Methylene Chloride

Tetrachloroethylene
Carbon Tetrachloride

Tetrachloroethylene
Trichloroethylene

1,2 Dichloroethane
(EDC)

1,2 Dichloroe'thane
(EDC)

Vinyl Chloride

1,1,1 Trichloroethane
 1,1,2 Trichloroethane

 Vinylidene Chloride


 1,1,1 Trichloroethane
                             -52-

-------
                                             exhibit  4-2


                                        PROCESS MATERIAL PLOWS

                                   FOR CHLORINATED ORGANICS SEGMENT
I
ut
cs — -
Itatliana »
IICI. — 1_».
Hatlianol - »
"•a
Pruf'ana
or Propy- 	 :«.
lene •
«*> 	 *
Ethyl ana 	 ^
ci.2 	 „
Glhyleiut .
IICI. 	 ^
Oxyqcn/ 	 ».
Air
Cblorlu-tlon
of
rtelhtna

r iiriiiyi i.uariuo

	 "»• ChlurufoiB
** i:arliou Tetrachlorld
in.
1
tlydrochlar In-t Ion
of
Hathauol


Chlorln-tlon
uf
llytlrocar-ona
MoCllV 1 tllOf lilo > . " • •-.. >I.B>^. IILil*
II ^ *.•••«• ••••*•«•• » Methyl CD* cm
a
or Ida
[ ' «,,„,»• C,,,or,(,a ' i.SS'mr^l.*!..



h IM*1

rhlorln-tlou

Ulroct
Clilorlnatlou

l>l<:liloru
Oiiyclilorliianlnn
of
Ethyl ana

of
i • fnc i
|

EOC^
»"y«olyalB vl Cliluilnat
• of • • • • . — ». at

.. 	 	 	 . IICI.

KI>C ' Cliloclntttloit • 	 1-

' ~ ' * °' 	 ^ ± |, o
— 	 	 ^ — *«; ii Uehydro- * "j II
. 	 1 	 	 	 	 . c|i|nr|n- f.
1,1. J Til- y' ntlou I
cliloroeiticne 	 » • *

Chloride
II O ____________ — .. 	 	 	 • 	
iloroatliyloiMi
fatrnchlorlile
fulrachloio-

aiity I ciiii
t- roc
• -*• Vltiyl Chloi lila
un
	 ^ 1.1,1 Trl-
cliloroelliane

If-^o- I.I.I Trl-
>lor- cliluriH:th_iie
utlon --*"

Chlufliln

-------
upon the mix  of products produced.  All  of the plants in-
cluded in  this  case  study  are  listed  in  Exhibit  4-3 and
are grouped based on  the type of  facility at which chlorin-
ated organic manufacture takes place.

     Eighteen companies  operate  the thirty-one chlorinated
organics facilities  in  the United  States.*  The companies
and the chlorinated  organics  plants they own are listed in
Exhibit 4-3.   Most of  these  companies  are major chemical
producers  involved  in many  segments of the industry.  Some
of these companies  also produce  consumer products derived
from their own  chemicals.

     Geographically  the  facilities  can  be divided  into four
different groups.  The southern  Louisiana/Mississippi  River
area has seven plants, mostly ethylene complexes with chloro-
ethane facilities.   Another group  of  plants  are situated
on the Texas Gulf Coast.  The  third region  containing  these
these plants is the Ohio River Valley.   This region includes
two plants  on  the  Kanawha River and two plants on the Ohio
River.  The  last group  of  plants  is  scattered  throughout
the country.    PHB's  analysis  to  date  has considered the
Mississippi River,  Texas  coast   and Kanawha  River areas.
These areas  include  15  plants  which account  for about 70
percent of  industry  production.


     Pollution  Problems  of  Concern

     A total of 46 pollutants  have  been identified  as  emis-
sions from the  11 processes into  the air, water and/or  soil.
The pollutants  arise  from  feedstock impurities,  competing
reactions,  and  incomplete  product  recovery during  produc-
tion.  These  pollutants are  shown   in  Exhibit  4-4 and can
be classified  into several groups,  including  conventionals
 (4), metals  (2),  and  a remaining  assortment  of  organic
compounds.

      In  terras   of  physical  quantity, the  vast majority of
pollution  from  the chlorinated solvents  industry  occurs as
    Seven of the thirty-one production facilities use unique
    or outmoded  production technology.   The  production  pro-
    cesses and material  flows  of  these  facilities  are  not
    reflected in Exhibits 4-1 and 4-2.  All of these facili-
    ties are listed as Miscellaneous in Exhibit 4-3.
                               -54-

-------
                         Exhibit 4-3

             CHLORINATED ORGANIC SOLVENT PLANTS
Integrated Chlorinated
Organics Plants	

         Company

     Allied Chemical
     Allied Chemical
     Diamond Shamrock
     Diamond Shamrock
     Dow Chemical
     Dow Chemical
     E.I. DuPont
     Ethyl Corp.
     B.F. Goodrich
     Houston Cheitu  (PPG)
     Shell Oil    :
     Stauffer Chemical
     Stauffer Chemical
     Vulcan Materials
       Region

La.-Mississippi River
Ohio River
Kanawha River
Texas Gulf Coast
Texas Gulf Coas't
Sacramento Deep Water Channel
Texas Gulf Coast
La.-Mississippi River
Tennessee River
La.-Calcasieu River
La.-Mississippi River
Los Angeles Harbor
Ohio River
La.-Mississippi River
 Ethylene  Complexes

      Dow  Chemical
      Dow  Chemical
      Shell Oil
      Union Carbide
      Union Carbide
Texas Gulf Coast
La.-Mississippi River
Texas Gulf Coast
La.-Mississippi River
Texas Gulf Coast
 Chlorine/Caustic Plants

      Vulcan Materials
 KS-Cowskin  Creek
 Methanol/Ammonia Plants

      Borden Chemical
 La.-Mississippi  River
                            -55-

-------
                         Exhibit 4-3
                         (Continued)

             CHLORINATED ORGANIC SOLVENT PLANTS
Gasoline Additives Plants

         Company                    Reg ion

     E.I. DuPont             Delaware River
     Ethyl Corp.             Texas Gulf Coast
Miscellaneous Plants

     Union Carbide           Kanawha River
     FMC Corporation         West Virginia
     Hooker Chemical and     Louisiana
       Plastics
     Stauffer Chemical       Alabama
     Eastman KodaJc           Texas
     Chemical Processors     Washington
     Monochem                Louisiana
     Upjohn                  Texas
                              -56-

-------
                                                        Exhibit 4-4

                                OCCURRENCE  OF  POLLUTANTS BY MEDIA  AND PROCESS
                                             CHLORINATED  ORGANICS SEGMENT
Pcooain |l |2
Medial A H 8 A H S
x x
X X
urlile
1 riithalat*


» xxxx
lie no!

x x
X X
iicocthylena
>rophQnol
11 | < IS
A H S A H a A H S
X X . X
XXX
x



XX X XX


XXX
XXX
x • x x

1 6
A H S A

X
X
X
XX X
X
X X

X
X
X
X X

1 7
M S
X
X


X

X
X

X
X

X
I a
A H S
X
X


X

x


X
X
X I

1 V
A MS
X
X


1 "
'•
n


X
X
X

1 10
A H a
X
X


X

X
X

X
X

X
1 11
A H S
X
H


N

X


X
X


Pol jutajtt

Uenzuno
UOO
Butyl Chi'
IH-n-nuly
L'nrboit To
Cailionn
Ch lot-ill
Chloroform
2-Cliloro|
Chromium
COD
Cyanlilu
1.2  1)1 cl>
2,4  Old.
1,2  D|chloru|>cu|iAnu
I,)  nlchloro|iropciia
Dimethyl fiUinr
Cthnliv
Rthyl Chloride
Klliy lent!
Klhylcnu Olchloclde
Itlu  2-i:ihylhuxyl  HhthaUte
Fluoicno
lleiiach lurotieitxeno
X  X


   X
A - Air
H - Holm
!i - Solid WoHte (llazardonsl

-------
                                             Exhibit; 4-4
                                             (Continued)

                          OCCURRENCE OF POLLUTANTS BY MEDIA AND PROCESS
                                    CHLORINATED ORGANICS  SEGMENT

Proc««i
I'ulltitaiit Hedi*l
'III 12 t i |4 IS
• A W 8 AM 8 A H 8 A W S A H H
1 i 17 IB 1 » 1
in i
AH6 A W S A H 3 AHS A H S AH
Hiix.icliloroliiitAitianc x
IUtHAi;h liiroctlianu
Ho
llmnol
Hcthyl Clilurl'lo
Hctlixlene UilorMo
XX XX X ' X
X
X X X X X X
X » • I X X X
Mnnochloroacety lene
Nickel
I'untaclilorncthaito
I'd

Pr
l.'IIOl

opann
T.I in
1.
1,1,2 Totcauliloroetltnna
1,1,2,2 Tut luclilornetlinnu
*l*c 1 1 rtcli 1 of out ti v 1 £titt
TOC
TSS
i,
i(
1,1 rrlchloroRtliann
1 t Tt-l^lkl.ir nja t ki n.kA
Tr Ichlorelliy teiin
2,
VI
4,6 Tr Ictiluroplionol
nyl Cliloil.le
Vluy tiltiiti; Clilorldo
X X
X

X
X

X X
xx xxx
x x xx x


XX XX XX X
I X XX XX X

X
X X XX X •
x x,
i
i
X X1
X

X
x x x x xx
: X
X
X X
X


X «
t

X X
X
X 1 X
XX X X X X i
X X X X
X X X X
X X

XXX X XX »
X
X X X X X X
x i x x ; x












X X
A - Air
H - H«ti:t
S - Snllil Hauttt (llazArilounl

-------
air emissions,  either  directly  from  process  and  storage
operations or  through  volatilization  of  water-borne  pol-
lutants from water  pollution  controJ  equipment and surface
waters such as rivers.  The industry is  also  responsible for
significant discharges  to  surface waters.  The plants exam-
ined to date  are sited in relatively  populated  areas  and
thus the  air  emissions result  in  some  degree  of exposure
for large numbers  of people.   In addition,  surface  waters
in these  areas provide a  significant  source  of drinking
water and enjoy  some amount of fish harvest, thus creating
possible exposure through  these routes  as well.

     Exhibit 4-5 shows  the control  technologies  considered
for each  process and  media  (air,  water or  solid  waste).
Treatment of air  emissions requires  that  individual emis-
sion control  systems  be  built  for  each  process  source.
Water discharged from all  processes is  combined and treated
in one  treatment  plant.   All  solid waste  is also treated
in one  facility.   The nature  of  air  emissions requires
that different controls be built for different air emission
sources at each process.   Water-borne  and  solid wastes are
treated without regard  to  their source.
     Cost-Effective Control Strategies

     Three regions  of  the  country have  been  studied   in
detail for this  case  study.   Together, the plants in these
regions account  for  over  70  percent  of  the  chlorinated
organic solvents produced  in  the United States.  The first
of these, the Mississippi  River  region, extends from Saton
Rouge to  New Orleans.   This  region has  been  used  as the
focus for most of the analyses.   The Texas Gulf Coast region
and the Kanawha River valley have been  studied  to determine
the consistency  of  the  results  from  region  to  region.

     For each of  these  regions  a  cost-effectiveness curve
was developed  using  the  mathematical programming  model
(discussed"in  Appendix  A).   In   the  Mississippi  region
seven plants  have  been  modeled  through  construction  of a
"sum" plant  designed  to  represent  the  combined  production,
pollution and  health  impacts  of  the  seven  plants.    By
constraining the model  to  reduce the total weighted health
impact of the sum plant by 30,  50,  85,  90,  95  and 99 percent
of the  uncontrolled  health  effects   a cost-effectiveness
curve was developed.  All  analyses  assumed  1985 conditions.
                              -59-

-------
                                              Exhibit  4-5

                         APPLICABLE  TECHNOLOGIES FOR POLLUTION CONTROL
                                     CHLORINATED SOLVENTS  SEGMENT
                                                        E»laa Ion/Control Technology


Proceaai
Process Description Absorber Incinerator
1.

2.



1.

4.

• j_
O
1
6.

7.
1.

t.

10.
Chlorlnatlon of x
Methane
llydrochlorinatton x
of Methanol/
Cli lor (nation of
Methyl Chloride
Chlorlnatlon of
Hydrocarbon*
Chlorlnatlon of
KOC 2
ulruct Chlorlna- x
lion of ethylena

Oxychlorlnatlon x
of Gthylenu
Pyrolyils of BOC x
Chlorlnatlon of x
Vinyl Chloride
Chlorlnatlon of x
EOC II
Dohydrochlorlna- x
Air
Storage! Mtacel laneouai
Condenser Punitive Control
x x

X X



X

X

X X


a x

X
X X

X X


Mater
1 -Stage Actl- J -Stags Actl- Activatod' Carbon
vated Sludge vated fifudqe Treatment
XX X

XX X



XX X

X X X

XX X


XX X

xx x
XX X

XX X

XX X
Solid Haate
Otenm
S t r 1 PP 1 ng
x

x



1 X

X

X


X

X
X

X

„

Inclneral Ion
x

X



X

X

X


X

X
X



X
    tlon of 1,1,2
    Tr Ichloroethane

II.  Mydrochlortnatlon
    of Vlnylldena
    Chloride

-------
     Exhibit 4-6 shows the cost-effectiveness curve for the
Mississippi sura plant.   This  curve shows the total cost to
plants in  this  region of achieving the  indicated reduction
in health  risk  from  the plant's  pollution.   The model has
determined the  least-cost  pollution  control  strategy  to
achieve each  level  of  risk  reduction.  That  strategy can
include the  addition  of  pollution  control equipment  to
control any combination of air, water or solid waste pollut-
ants, production shifts  or cutbacks, or process shutdowns.
The strategy  used  to achieve  the  indicated  risk reduction
will be discussed below.

     The curve  is  quite  flat through  the 90  percent risk
reduction  point,  after which  It  rises  steeply.   The flat
portion of* the  curve  corresponds  to  an  annual   cost  of
pollution  control  including  annualized  capital charges  of
$0.07 million  for  30 percent  risk  reduction, 50.48 million
for 50  percent, $4.30  million for 85  percent and  514.49
million for 90  percent.  The  relatively low  cost of achiev-
ing these  risk reduction  levels  reflects the  availability
of pollution  control  options which  recover chemicals for
use or  sale  by the  plant.   The  value  of  these recovered
chemicals  offsets  a large portion  of  the capital and  oper-
ating costs  of the  control  options.   The  cost to achieve
risk reduction  levels  beyond 90 percent  is great because
process shutdowns  and costly control  options  must be em-
ployed.

     It should  be noted that  total  health risk is calculated
by weighting  together the  relative risk of the  eight  health
effects with  a specified  set of weights.   For  most  of  the
analyses,  quality  of  life weights were  used.  Two  other
sets of  weighting   factors,   economic   and  equal   weights,
were also  used for some analyses.   These weighting  factors
are  discussed  in  detail  in  Chapter   2  and  Appendix   D.

      In  Exhibit 4-6,  the  cost-effectiveness curve for  the
Mississippi sum plant is shown for all three  sets of weights.
Note  that  the cost of risk reduction is virtually  identical
 through  the 90 percent  risk  reduction  point regardless  of
 the  weights used.   After that point, further risk  reduction
 is  less  costly to   achieve  if  one  chooses   the  economic
weights  rather than  the quality  of life or equal  weights.
This is due  to the  greater emphasis placed  on  carcinogenic
 effects  by the economic weights.   Carcinogenic effects  are
 easier to  control at risk  reduction levels above 90 percent.
                              -61-

-------
                                             COST OF  HEALTH RISK REDUCTION
                                     MISSISSPPI COST EFFECTIVE CONTROL CASES (1985)
                                    Quality Of Ufa
                                    Health Weights
                                             Economic
                                          Health Weights
                                     Equal
                                 Health WalgliU
                                         -4-
                                                                    O
I
cr»
             300
             •400
300
              200
              100
                 COST (mlttlonu of EOY 19B5 $)
             -100
                                            11
                          10
                     20
30
40
60
70
00
90
                                              PERCENT REDUCTION IN HEALTH RISK
                              THE RESULTS SHOWN HERE  ARE  PRELIMINARY AND SHOULD  NOT BE QUOTED.
                                                              100

-------
            k reduction  level  achieved for each individual
          ,<=ct is often different from  that achieved for the
         sum health  effect.   This is  a  result  of  the dif-
     , priorities the  weighting factors place  on  each ef-
   », the  difficulty  of controlling  the  pollutants  that
  id to each effect  and  the  absolute magnitude  of  the risk
 f each effect.  Exhibit 4-7 shows the risk reduction  level
achieved for each effect in  the Mississippi sura plant when
quality of life weights are used.  Note that certain effects,
like cancer  and  reproductive   toxicity,  generally have  a
higher risk  reduction   than   the  weighted  effect.   This
reflects both  the ease  with  which  these  effects can  be
reduced and  the  fact that  they account for a great propor-
tion of total  risk  even though their  weights may  be  lower
than average.  Other effects,  however, such as  rautagenicity
and teratogenicity, are  reduced much less  than  the weighted
effect despite  their  high weights.   This  is  due  to the
difficulty of  controlling  the  pollutants  that  cause them
and their small contribution to total  risk.*

     In Exhibit 4-8,  the level of :risk  reduction  and cost
of pollution control for the  current  control levels achieved
at the Mississippi plants is plotted.   The cost-effectiveness
curve using  the  quality of  life  weights  is  included for
reference.  Note  that  the  level of: risk reduction achieved
by current  controls  is  36 percent- if calculated using the
economic weights  and 28  percent if derived using the  other
weights.  The  current control points are  above  the  cost-
effectiveness curve,   indicating  that  the  same   level  of
risk reduction  could have been achieved  for approximately
$18 million  less  per  year.   Alternatively,  if this  addi-
tional 518  million  had  been  spent  to  reduce  health risk
then the  curve indicates  that a  90  percent  reduction  in
health risk  could have been  achieved.

     The primary cause of the higher cost of current controls
is  the  installation  and use of more costly water  treatment
systems than  is necessary to  achieve  the present level of
health risk  reduction.  This  system does achieve a  higher
level of  conventional  pollutant control  (such  as BOD, COD,
TSS, etc.)  than would be  achieved by strategies  primarily
 *   In  the uncontrolled  case,  the  relative  risk score  for
    cancer accounts  for  43 percent  of  the  total  weighted
    health score  while  mutagenicity and  teratogenicity  ac-
    count  for  less  than 1 percent.
                             -63-

-------
I
01
                                               Exhibit 4-7

                                 INDIVIDUAL HEALTH EFFECT RISK REDUCTIONS
                                                   VS.
                                  TOTAL WEIGHTED HEALTH EFFECT REDUCTION

                                         QUALITY OF LIFE WEIGHTS
                                          MISSISSIPPI SUM PLANT
Weighted Risk
Reduction (I)
Individual Health Effect
Risk Reduction
Cancer

Mutagenicity
Teratogenicity
Reproductive Toxicity
llepato Toxicity
Renal Toxicity
Other Effects*
Neurological Toxicity**
0


0

0
0
0
0
0
0
0
30


34.2

0
0
71.6
37.3
46.5
5.1
0
50


47.7

0
0
81.7
64.7
87.1
28.2
0
85


91.6
f
18.9
48.0
98.2
84.4
88.0
71.0
0
90


96.9

82.5
75.9
98.2
96.5
94.5
75.2
0
95


98.8

94.1
99.9
99.9
99.9
99.4
85.5
0
99


99.4

99.9
78.0
99.9
99.8
99.4
97.9
0
        *  Principally respiratory effects.

        ** No neurological effects are currently expected from chlorinated solvent plant
           pollutants.

-------
                                                        lixli tl>l t  i — o

                                            COST  OK  HEALTH  HISK REDUCTION
                                      MISSISSPPI  COST  EFFECTIVE CONTROL CASES (1005)
                       Quality Of Ufa
                       Houlth Weights
                                 Currant Control
                                 Quality Weights
 Current Control
Economic Weights
Currunt Control
 Equal Walghta
      O
ui
l
              500
              40Q
              300
              200
              10O
                 COST (millions of  EQY 1965 |)
-100
             10
                                   20
                                                  a
                                             30
                                         HO
                                                                l ,1.0. U.I.I I I til I I.LI IX. I, J HU.1J III !•> I MU 1IJ
                                                               50       BO       70        BO       90
                                                                                                100
                                                PERCENT KEOUCTIGN IN HEALTH RISK
                              THE  RESULTS SHOWN HERE AKE PRELIMINARY AMD SHOULD MOT OE QUOTED.

-------
aimed at reducing  health  risks.   Thus,  if the reduction of
environmental effects  were  included  in  the  analysis  the
current control  case  may  be a   cost-effective  strategy.

     Exhibit 4-9  is  a  process-by-process  listing   of  the
control options  employed  at  each  level of  risk reduction
and at the  current level of control.   Processes with NA  (not
applicable) are  not  present  in   the  Mississippi   region.
Note that even  at  the "zero"  risk  reduction point   certain
control options  are  in  place.  This  is due  to the profita-
bility of these  options that results  when the value of the
chemicals recovered  exceeds the  annual operating and .capi-
tal costs.   Thus the "zero"  risk  reduction level reflects
some risk  reduction  over  a  totally  uncontrolled  plant.
The "zero"   level  does,  however,  represent  the level of
health risk which  would arise from a plant not subject to
environmental regulation.

     Current air pollution controls reflect process,  storage
and fugitive emissions  control for  processes 5, 6  and 7.
Current water pollution control  consists  of a single acti-
vated sludge water  treatment system.  Other  controls listed
as currently  in place  are*  those  identified  as profitable
in the "zero" risk  reduction case.

     In moving  from lower to higher  risk  reduction  levels,
it is  possible   to  discern  a pattern  in  the  sequence of
control options  selected.   At  the 30  and SO percent  risk
reduction levels  more stringent air  pollution controls in
the form of gas absorbers,  storage tank condensers  and air
pollutant incinerators are  added.  To achieve  an 85  percent
risk reduction,  further  air  control,  treatment  of   some
process water   effluent  with a   single   activated  sludge
water treatment  system  equipped with steam  strippers,* and
the secure landfilling of  the residual  waste from hazardous
waste incineration  are used.  Op to the 85  percent reduction
level the cost of control is limited by the recovery  credits
which offset  most  of the  operating  costs  of the   air and
waste treatment options.  This causes  the cost-effectiveness
curve to be relatively  flat up to  this  point.
    Steam strippers reduce the quantity  of  priority  pollut-
    ants  in  the discharge  water  and remove  pollutants  that
    would have  become air  pollutants  through volatilization
    at  the activated  sludge unit.
                              -66-

-------
                                       CONTROL  STRATEGIES  SELECTED  FOR
                                         COST-EFFECTIVE RISK  REDUCTION1
                                              MISSISSIPPI SUM  PLANT

1. £lil urination of
Methane
2. Uydrocliluriitatlou
of Mathnnal/
Clilorluatlon of
lluthyl Chlorlda
J. Cltlorlnatlon of
_ Hydrocarbon*
*. Clilarliintltiii of
cue i
S. I'lrect L'hlor Inatlaii
of Ctliylcne
6. O«ychl urination
»f Elhyleiie
1. rydklyula ol
MtC
a. Cliltn liiatlon of
Vinyl Oil or Ida
9. Chlurlnatlon of
EUC II
10. UehydrocMorlnatlon
of 1,1.2 Trlcliloco-
c 1 ha »e
11. llydrochlurtiultlan
ut Vinyl Idunc
I'MurlJc
0
HA
Abaorber
Wa*te Incln.
•
Waate Jiicln.
Shutdown
Air Incln.
Ha at* Incla.
Uaatu loclit.
Air Incla.
Uaete Inciii.
Haale Inclu.
MA

Shutdown i
l
30
NA
Abaorboc
Wuuld Iiicln.
Want* Inuln.
Sliutiluwu
Air loclit.
Uattu Incla.
Atr Incln.
Waaie Inclo.
Air Incln.
Uama Incln.
Secure It
WuBlo Incla.
NA

Sliutdown
SO
NA
Almorber
Wiiata Inclu.
Condenser 111
Waulo lucln.
ShutJuwn
Air Incln.
CoiKjaimer III
Wadl« Incln.
Air Incln.
Waale Incln.
Air Inclu.
Uaute lac In.
Secure l.t
Haate Incla. •
HA
Air Incln.
Sliut^laun
•IIEAI.1II tFFECT R
Si
NA
Abaarber
Conilenaar 111
Act. SL/SS
Wnolc Incln.
Cecuro LF
SliutJuun
' Shutilown
Air Incln.
CoittUnaer III
Uantc Incln.
Air lucln.
Act. i!l./S3
Uuala Incln.
Air liicln.
Hauto Incln.
Secure I.F
Waste Incln.
Secura I.P
tu
Air Incln.
SliutJuwa
FSK HtllUCriOH (X
90
HA
Abaorber
Condenaur III
Fugitive CTI..
Act. SL/S3
Maate Incln.
Secura l.t
Sliutduun
Shutdown
Air Incln.
Ctmdeituer 111
Uaate Incln.
Air Incln.
Act. SL/3S
Mnate Inclu.
Air Incln.
Act. SI./SS
Uaale Inuln.
Secure I.F
Act. si./sa
Uuate lucln.
Sectire I.F
HA
Air Inciii.
Sliutdown
k 	
9)
HA
Shutdown
Shutdown
Sliutdoun
Air Inclu.
Cuinlunacr III
Fugltlvo
Wnate Inclu.
CMlbock
Shutdown
Air lucln.
Act. si./sa
iiecute I.F
Curluick
AU Inclu.
Act. St/SS
Waacc locln.
Secure tr
NA
Air Incln.
Act. SI/SS
Shutdown
99
MA
Aliaotber
C
-------
     Risk reduction  levels of  90, 95 and 99 percent require
a combination of  fugitive air  pollutant  controls  and more
extensive water  treatment*  in addition  to  process  shut-
downs and production cutbacks.   The  use of  these  options
significantly increases  the  costs of control.  These costs
now include  the  decrease  in  margin attributable  to lost
sales and  the  sale  of  less  profitable  products.   Because
market and price  responses  to the   intended  shutdowns  and
production shifts  are  not  included  in the  analysis,  the
actual events  likely  to occur at  a risk  reduction  level
greater than 90 percent are difficult to predict reliably.
Nevertheless, it  is clear  that major  market and  industry
impacts can  be expected at  these  extreme  risk reduction
levels.

     Exhibits 4-10  and  4-11  present  the  control  options
selected when  the  economic  and  equal  weights are  used.
Although minor differences appear in the sequence of options
selected, such as  the earlier use  of air  control  and  the
delayed use  of water  treatment,  the overall patterns  are
quite similar.
     In Exhibit  4-12,  the  cost-effectiveness  curves  for
iMississippi, Texas  and  Kanawha  sum  plants  are compared.
Note that despite  differences among the process configura-
tions and sizes  of the  plants  in these regions, the cost-
effectiveness curves  in percentage form are  quite similar.

     In Exhibits  4-13  and  4-14,  the  Texas  results  are
presented in detail.   Because  the Texas sura plant is  larger
than the  Mississippi  plant and  includes greater pollutant
loads, absolute  control  costs  are  higher,  equaling $600
million at the 99 percent risk reduction level.   The control
options employed  are  similar  to  the  Mississippi results.

     Exhibits 4-15  and  4-16 contain the results  for  Kanawha
which indicate far  less absolute cost  of control due  to the
presence of  only one  chlorinated organics  process  in the
region.  The  control   strategy   at  the  99  percent  risk
reduction level  is more  severe  than  in the  two preceding
cases in  that a total  plant  shutdown is the  most cost-
effective strategy  at  that point.
 *  More  extensive  in  terras  of  more  effluent from  additional
   processes  being  treated  in  a larger  treatment  facility.
                              -68-

-------
                                                              Exlltt>it 4 — 10
                                                CONTROL STRATEGIES  SELECTED FOR
                                                  COST-EFFECTIVE  RISK REDUCTION1
                                                       MISSISSIPPI  SUM PLANT
vo
 I
|,M,M>-SS - - 	 IIKAI.TII KFFfCT RISK HEUUI.TIUN (X)
	 1U_ 0 1Q ju jj go
|. Mil urluol lun ul
2. HydrochlorliMtloii
u( Mulhiuiot/
Oilorlnotlon ol
llcthyl Chlurldo
). Chlurlnotlon of
4. t'hlorluat lun uf
KIlC 1
5. Direct Chlurlnatlon
uf Cthylcuu
(,. Onychlur Inatlon
uf Kthylenu
). Pyrolyuls uf
0. Chloi'JnatJiMi of
Vinyl Chloride
9. L'hlorliiallon of
KliC ||
IU. Itthydroclilurlnetlon
uf 1.1.1 Trlchluro-
11. ll/drochlar Inntlon
uf Vlnylldcuc
HA'
Abaorber
Waata Incin.
*
Uaata Incln.
Shutdown
Air Incln.
Waate Incln.
Uaate Incln.
Air Incln.
Waate Incln.
Wattle Incln.
HA

Shutdown
NA
Absorber
Waulu Incln.
Maata Incln.
Shutdown
Air Incln.
Waste Incln.
Air Incln.
Waate Incln.
Air Incln.
Waala lucln.
Secure IF
Waale Incln.
IIA

Shutdown
NA
Abuorber
l
-------
                                                               X I? J. !».
                                                 CONTROL STRATEGIES  SELECTED  FOR
                                                  COST-EFFECTIVE  RISK  REDUCTION1
                                                       MISSISSIPPI  SUM  PLANT
o
I
                                             10
                                                          5u
                                                                       Hi
I:T HICK iitmiciioii
        90
                                                                                                 95
                                                                                                                       Ci.rrc/nt
1. Cli lot Inatlon u(
Iliithana
2. llydrochlorlnntlun
of Hotlninol/
Chlorlnatlon of
llulbyl Chloride
1. Chlot Inatlon of
llydrocurlioiitt
4. (.'lil or Inallciii of
MIC 1
5. Wired Chlor Inallmi
of Ltliylciie
6. Uxychlorluat loll
of Klhylenu
7. 1'yrulynlu uf
me
U. rblurliiallon of
Vinyl Clilorldu
9. Uilorlnatlnn o(
I-IIC II
10. Oehydruchlor Illation
of 1.1,2 Trlchloro-
etlianu
II. llyilior.hlorliijitton
of Vliiyll.luiui
Chloride
HA
Abuorher
Huala Incln.
Wane Incln.
Shutdown
Air Incln.
MnJIu 1 111; In.
llaaia Incln.
Air Incln.
Ujuta Inr.ln.
Ua*la Incln.
HA

Shutdown
HA
Abaorbar
WuMltt Inclu.
Witatn Incln.
Shutdown
Air Incln.
Uaiite Incln.
Uauta Incln.
Air Incln.
Uuate 1 nc In.
Unate Incln.
HA

Shutdown
HA
Abuortier
Unutu Incln.
Cundcnuor III
Uuata Inclu.
Shntdowii
Air Incln.
Uaate Incln.
Air Incln.
Waijle Incln.
Air Incln.
Unuto Incln.
Sucure I.F
Unit* Incln.
HA
Air Incln.
Shutdown
IIA
Ali*orli«r
Condmiaor III
Unite Incln.
tjecuru Lf
iihiildown
Shutdown
Air Incln.
Condenaar HI
Unutc Incln.
Air Incln.
Act. SL/S3
Waatc Incln.
Air Incln.
Wane Incln.
iicculu l.f
Waatci Incln.
Secuiu I-F
»
IIA
Air Incln.
Shutilown
IIA
Abaurber
Condcnttur 111
Act. S1./S3
Haute Incln.
Secnru l.f
Miuliluun
Shulduwn
Air Incln.
Cm.Jcj.aer 111
Alt' Incln.
Condcnuur 111
Act. SI./SS
Wuute Incln.
Air Incln.
Act. SI./SS
Wuute Incln.
.Stci.ru IK
Act. SI./SS
W.iato Incln.
Suctira I.I-
IIA
Air Incln.
Act. SI./SS
Shutdown
HA
Abaurbur
CundcnKttr III
Act. SI./SS
Ujtale Incln.
Secure ).f
Shutdown
Shutdown
Air Incln.
Coiiiliiiiuur HI
Fugitive
Mania Incln.
Air Incin.
Condenuer III
ruuitlve CTL.
Act. SUSS
Uuate Incln.
Cutback
Air Incln.
Act. SI./SS
Sucuru l.f
Cutback - 	 	
Air Incln.
Act. SI./SS
Haule Incln.
Secure If
HA
Air Incln.
Act. SI./SS
Shutdown
HA
Shutdown
Shutdown
Shutdown
Air Incln.
Coiidenaer HI
Fugitive CTI,.
Uaate Incln.
Shutdown
Shutdown
Shutdown
IIA
Shutdown
Shutdown
HA
Abnurbei
Act. St
Hjito Incln.
ACL. SL
Uaate Incln.
Shutdown
Air Incln.
Cuiiiloiiaur III
Fnultlve Cll..
Act. SI.
W.ialc Incln.
Air Incln.
Cundunaiir HI
Kualtlwo Cll.,
Act. SI.
Wunlii Incln.
Air Incln.
Fug!tJvft ItTI..
Act. SI. '
W.i ali: Incln.
Act. SI.
Unatu Incln.
HA
Act. SI.
Shutdown
            1.
                 U 'c<|uul'  health effect weighting acltanui.
           Hotel  Ai.y w.i.tu not Inclnaruted or ««cu(« landflllcd lu aent to a «unllai-y landfill.

-------
                             COST  Of  HEALTH RISK REDUCTION
                                 SUM  PLANT COMPARISONS
                       Mlaalaalppl Sum
                     Plonk Coat Curvo
                       'Kanawhq Sum
                     Plant Cotat Curva
                                 Texoa Sum Plant
                                   Coal Curvo
100
 flQ
 80
 70
 60
   COST (  parcont of uncontrolled groaa margini )
 30
 10
-10
                                                11111
                                                       I 1 I 1 I I 1 1 I I I 1 I I A i 1 1 i 1
            10
20
30
                                    60
70
80
90
100
                                 PERCENT HEDUCTION IN HEALTH R|SK
                THE  RESULTS SHOWN HERE ARE PRELIMINARY AND SHOULD NOT BE QUOTED

-------
                                     Exhibit 4-13

                          COST OF  HEALTH  RISK  REDUCTION


                        TEXAS COST EFFECTIVE CONTROL CASES (1985)

                                        Quality Of Ufa
                                        Health Weights
6OO
BOO
400
300
2OO
too
    COST (millions of EOY 1985 $)
                                             -f-
       '' "i hi i n i
           10
20
                                             50
                                  CO
70
                                                                                      l-LLl
BO
                                                                               00
100
                               PERCENT REDUCTION IN HEALTH RISK
               THE RESULTS SHOWN HERE ARE PRELIMINARY AND SHOULD NOT BE. QUOTED.

-------
                                                        Exhibit  4-14
                                                                    *
                                           CONTROL  STRATEGIES SELECTED  FOR
                                            COST-EFFECTIVE  RISK REDUCTION1
                                                      TEXAS  SUM  PLANT
mictss
-IIKAl.TII tffeCT DISK ((EDUCTION (I)

     US            90
                                                                                              95
Current
COBtrain
1. Oil urination of
Hetliano
1. llydi-ochlorinatloii
of llellianol/
Ch lot iiiatlan at
Metliyt Chloride
J. Chlorlnattaii of
llydTocnrbcme
4. Clt lor Illation »t
EOC t
i. Direct Culorliiatlou
of ethyUiiu
6. Uxychlor liialloii
ut Cthylena
1. I'yrolyale of
tbC
S. Chloitiiatlon of
Vinyl Clilotldo
9. Cl.lorlnutlt.il of
KUC 11
10. Uuliydruclilnrlnat Ian
of 1.1.2 Trlclitoro-
iitliaite
11. llydruclilurliiatluii
ut Vluy Ilitunu
Cliladda
Abaaruer
Uaate Inclii.
HA
Uaate Incln.
Shutdown
Air Incln.
Uaata Incln.
Air Incin.
Waate Incln.
Waate Incin.
Uaata Incln.
Uaat« Incln.

HA
Abaorlier
Condenser I"
Uaute Cue In.
HA
SliulJuwn
Siiulilown
Air Inclii.
Uattta Incln.
AU Incln.
Uaate Incln.
Air Incln.
Waata Incln.
Wuttte Incln.
Waato Incln.
Air Incln.
HA
Atiaurltar
Aonilcnaar III
Waata Incin.
HA
Uaat* litcln.
SlniCJuun
Air Inciii.
Uoate Incln.
Air Incln.
Act. SC/S3
Uaata Incln.
Air Incln.
Haita Incln.
Sccura I.P
Haata Incin.
Wntt« Incln.
Air Incln.
HA
Al'nurlicr
Coiulcnicr 111
Act. SI./S3
Haslc Incln.
Secure I.F
HA
Sliutduwii
SliuLdiiwn
Air Incia.
Con4cnaer III
fugitive CTL.
Wuule Incln.
Coudenacr III
Air Incln.
Act, SL/SS
Wadte Incln.
Air Incln.
Act. SL/S3
Waata Incln.
Secure LF
Ac.t. SU/SH
H»at« Incln.
Sccura I.F
AU lucln.
Cundcnaer III
F»Hltlvc CTL.
Act. SI./5S
Mail to Incln.
Air Incln.
Act. SI./SS
HA
Shutdown
MA
Shutdown
Shutdown
Air Incln.
Condcnaer III
Fugitive CTL..
Uaate Incln.
Air Incln.
Condenaar 111
Act. SL/SS
Uadte Incln.
Air Incln.
Act. SU/SS
Wauto Incln.
Secum U
Act. SI./SS
Uaate Incln.
Secure LF
Air liicln,
Condeuser III
r'ugUIve CTI..
Act. SL/SS
Uaoto Incln.
Air Incln.
Act. SI./SS
HA
SluitduwM
HA
Shutdown
Coitdenaor II
Act. SI./SS
Air Incin.
Coudenner III
Fugitive CTL.
Uaate laclii.
CM t back
Shutdown
Air Incln.
Act. SL/SS
Uuuto lucln.
Secure LF
Cutback
Air lucln.
Act. SL/SS
Haste 1 lie In.
Secure I.F
Incraaae
Shutdown
Air Inr.ln.
Act. SI./SS
HA
Slii^tduHii
HA
Shutdown
Shutdown
Air Incin.
Condenser III
Fugitive CTL.
Uaata Incln.
CtitUack
Shutdown
Shutdown
Air Incln.
Act. SL/SS
Uaate Incln.
Secure If
Increase
Air Incin.
Coadooaer 111
Fugitive CTL.
Act. Inc in.
Act. SI./SS
("Cfeaae
HA
Act. SL
HA
Act. SL
Uaate Incln.
Shutdown
Alt luu-lu.
Contlcnver HI
Fugitive CTL.
Act. SL
Uaate Inctn.
Air luciu.
Condeneor 111
Fugitive CTL.
Act. SL
Uastu Incln.
Air Incln.
Fugitive CTL.
Act. SI,
Uaata Incln.
Act. SL
Waste Inclu.
Act. SL
Act. SL
IIA
    lining 'i|uiillty af Ufa* li^nllli effect welglitlng Bcliciuo.

   (l.j|<:;  Any Wdulu itol lutiliiuiutud >>r t-ucuru luiidflll«id ia aant  ta n uuullnrf liiudl'lll.

-------
                                       exhibit '4_j.5

                             COST OP HEALTH RISK  REDUCTION


                       KANAWHA COST EFFECTIVE CONTROL CASES (1985)

                                        Quality Of Llfo
                                        Health Weights
 60
 50
   COST (millions of EOY 1985 $}
                                             4-
 30
 20
 10
-10
                                                             I I I I 1 1 I I I 1 I 1 I I I I 1 I I I 1 I I I I I
           10
20
30
60
70
60
too
                               PERCENT REDUCTION IN HEALTH RISK
               THE RESULTS  SHOWN HERE ARE PRELIMINARY AND SHOULD NOT DE QUOTED.

-------
                                                                 Exhibit 4-16

                                                   CONTROL  STRATEGIES SELECTED FOR
                                                    COST-EFFECTIVE  RISK REDUCTION1
                                                            KANAWHA SUM PLANT
         I'KDCKSS
Ul
l
                                               10
                                                             SO
-HEALTH m-ecr BISK REDUCTION ID	
     as           'jo            95
                                                                                                                  99
            (Jain*  'quality of Ufa' health affect weighting aclutuo.

            II.Uei  Any wuate uot luctoerateJ or secure lanUMIluJ In aeitt ti> a aunltary landfill.
                                                                                                                            Current
1. clitorlixulun of
Hvtliuuu
2. llyilroclilor iiiatlon
of timluMiul/
C'lilorlnntloii of
llelliyl Uilurlda
J. ChlarlnaClun of
llyJrucnrliotta
4. L'hlor Inatlon of
KIM: I
J. Ulruct Clilorlnation
of ElhyUne
6. UiyclilarlnatlAn
of Ktliylciiu
7. I'yrotyala of
KDC
8. Chlarlimtioii of
Vinyl UilorMo
9. Chlorlautluii of
III. Hiihyilroclilur Inatlan
of 1,1,2 Trlchloro-
ellinnu
11. Itydroulilurliiaclon
of Vtnylldeiie
HA
Abuorber
Haate Incln.
NA
HA
HA
HA
NA
HA
HA
IIA
NA
NA
Abaorber
Condeuaer 11
Uuata Inuin.
NA
HA
HA
HA
NA
HA
HA
HA
HA
HA
Abuorber
Condenaer II
Ha at a Incln.
NA
HA
HA
HA
HA
HA
HA
HA
NA
HA
Abaurbor
CouJunaar III
Fugitive CTL.
Uaata Inclo.
Secure LF
HA
IIA
HA
NA
tIA
HA
HA
NA
NA
tIA
Abaorter
Condenser 111
Fugitive CTL.
Act. JJI./SS
Uaate Incin.
Socurc I.F
HA
HA
HA
NA
IIA
HA
HA
IIA
NA
IIA
Ahautber
ConJcnaer 111
Fugitive frri..
Act. SL/SS
Uaate IncJn.
Secure LF
Cutback
HA
IIA
HA
NA
NA
HA
HA
NA
IIA
HA
Shutdown
HA
NA
NA
HA
HA
HA
NA
NA
HA
HA
ALeorber
Act. SU
Uaate Incln.
HA
HA
NA
HA
HA
HA
NA
HA
HA

-------
Alternative Policies Examined

     One of the  most  powerful capabilities of the industry
approach is its ability to evaluate  the  position of specific
regulatory alternatives  relative  to the cost-effectiveness
curve.  In  Exhibits  4-17,  4-18  and 4-19  the results  of
reducing the  emissions of  the  three most toxic pollutants
and the three major processes are presented.  The emissions
of the most toxic  pollutants  (chloroform, ethylene dichlo-
ride and vinyl chloride) were reduced to 75, 90 and 95 per-
cent of  their uncontrolled levels.  The  cost  of  this type
of control far exceeds the  cost of  the  same level of health
risk reduction on  the  cost-effective curve.  Also note that
an increase in the emission reduction from 90 to 95 percent
achieves only a  1  percent  reduction in  risk.

     Control of  processes  5,  6 and 7,  in the  form  of air
incinerators, 85 percent effective  condensers  and  the use
of an  activated  sludge  water treatment plant  is  almost as
cost effective as  the  most  efficient way  to achieve 23 per-
cent risk reduction.   Extensive  control of these processes
(air incineration, 95  percent condensers,  fugitive control,
and activated .sludge  with  stearn  stripper water treatment)
is somewhat less: effective in  that the  cost  of achieving
48 percent  risk  ^reduction  exceeds  the  most efficient cost
by approximately; S25  million.  Both  types  of process con-
trol are, in  this  case,  more cost-effective than the  indi-
vidual control  of  toxic pollutants.   Note,  however,  that
the range of  risk  reduction over which these relationships
hold is  narrow.    For example,  it  is  impossible  for any
combination of  controls  for  processes  5,  6 and  7   (other
than costly  shutdown)  to  achieve  greater  than  60  to  70
percent risk.reduction for  the entire plant.

     Plotting the  relative  cost-effectiveness  of  policy
options like  process  or  pollutant  specific control permits
the analyst to identify the merits of different  alternatives
and their cost  relative  to the lowest possible cost repre-
sented by  the cost-effectiveness  curve.   Similar analysis
could be carried out  for many policy alternatives.


Cumulative Economic Impacts

     By combining  the results of  the plant  models and  stan-
dard assumptions about book value and reinvestment behavior
                             -76-

-------
                                                   Exhibit 4-17

                                 COST OF  HEALTH RISK  REDUCTION:  MISSISSIPPI

                                      SENSITIVITY ANALYSIS: POLICY ALTERNATIVES
•vl
I
         Quality Of Ufa
         Health Weights


       75X Reduction Of
       Moat Potent Toxlca
              •f

       flOX Reduction Of
       Moat Potent Toxlca
        05* Reduction Of
       Most Potent Toxlca
               D

        Moderate Control
        Processes 5,6.
-------
                                                             Exhibit  4-18

                                                  CONTROL STRATEGIES  SELECTED
                                         FOR  MOST  HAZARDOUS CONSTITUENT  CONTROL1
                                                      MISSISSIPPI  SUM  PLANT
                                                                  -IIKAI.TU  tmcr »ISK INDUCTION (X)	
                                                                  	S0.42             601             61*
CO
 I
1.
2.
3.
4.
5.
6.
7.
a.
9.
10.
it.
Chlorlnatloit ul
Methane
llydroclilorlimtlon
ul Mothanul/
Chlorlnatlon of
Hutliyl Chloride
Cliloi lite t Ion of
Hydrocarbon*
Chlorlnatlon at
toe i
Direct Chlurlnatlon
of ethyl ana
0*yclilor (nation
of Etliyleiia
Fyrolyala at
EtlC
Chlarlnatton of
Vinyl Chloride
Cnlorlnatlun of
EDC 11
Ucliydroctilarlnatloa
of 1,1.1 Trlchluro-
etliano
llydruchlorlnatlon
of Vlnylldeno
ChlorlJe
HA
Absorber
Uuatd loclu.
UauC* I tic In.
filiutiluuu
Alt Iiicla.
Waatd liicln.
Waut* Incin.
Air lucln.
llaate lucln.
Waat« Incla.
NA

Sliutcloun
IIA
Abaocber
Maace Incin.
Coivlenacr II
Waat* Iiiclu.
Sliutiloun
Air lucln.
Haoto incln.
t'onilcn««r 11
Air Incln
MautA Incln.
Act. SL/S3
•Ale Incln.
Haute Incln.
Secure Lf
Cutback
Vftte Incln.
HA

Slmtiluwn
HA
AbaotUcr
Uaato Incln.
Cointenaef III
CuuJcnear III
Hnute Incln.
SliutJown
Air Inclu.
Candeiiaer III
Waste Incln.
Air Incln.
Waato Incln.
CiuiJcitaer I
Act. SL/SS
SliutJ»un
Uiiale Incln.
Air lucln.
HA
Air Incln.
Sliutdowa
IIA
Abaorbcr
Conileuaer III
Act. SL/SS
Haste Incln.
Secure l.f
Shutdown
Situ t down
Air Inctn.
Condense c 111
UaaCe Incln.
Air Incln.
Act. SI./SS
Uaste Incln.
Act. SI./SS
CoiiJcnaer III
Sliutdoun '
Hoflle Incln.
Secure l.t
Air Incln.
HA
Air Incln.
Shutdown
                       Using 'i|uallty nf life* kcaltli effect weighting /scheme.  Cheatcala controlIcJ arol  EDC, VCH and
                       Chlorofurn.

                       Currea|ioC. VfM, Clituraforn calaatona In all ucilla.

                       Currca|ionila to a 9)1 redaction In EUC. VUI. Chlurnform enlaaloim In ell nudla.
                                      t
                      I4<«t«*l  Any watttfl m»t lucloufjitcj ur ueturo luiktlMl Jc*l lu aeut lu u uaiiltacy  liikidfill.

-------
                                        Exhibit: 4-19
                       CONTROL STRATEGIES SELECTED FOR
                            PROCESS-SPECIFIC  CONTROL
                               MISSISSIPPI  SUM PLANT
                               —	IICAI.TII IWIXT  nir.K UCIMH.TIOH'

1.
2.
1.
4.
5.
*'
7.
U.
a.
10.
n.

riilor Inatlon of
McUi/tnc
llytlrGclilutin&t ton of
Motliitnol/Clilor I lift t ion
of Mntliyl Cliloilriu
Cli lor Ination of
llyjrocarlionn
Cliloi tnatlon of CDC I
Direct Cltloi inat Ion
of Kthylcno
Uxyclilnrlnot Ion of
KthyK-no
I'yrolyuin of i:i)C
Clilorin.it Ion of
Cli lor 1 nation of
CDC 1 1
Duliytlioelilor InaLlon of
1,1,2 Tr Icliloroutlianu
llyilroclilor inat ion
of Vinyl !<|.>n<: Cliloi l>lo
O
HA
Ahum liof
Vlautu Incln.
Man to Incln.
filintilown
Air Incln.
ll.ii) Ln Incin.
Uaul.il Incln.
Air Incln.
Haute Incln.
Ha 11 to Incln. 	
HA

iilnitiloun
2|2
HA
Aliuoi Ix.T
Hiiatu Incin.
Uaulu Incln.
Hlintdoun
Air Incin.
Hautn Incln.
Coiulaniicr 1
Act. ;il.
Air Incin.
Coiuluii'iur 1
Kaatu Incln.
Act. HI.
Air Incln.
I'lA.ito Incln.
Act. SI.
Haste Incln. 	
HA

tiliiitilown
•III1
HA
Ali:iOfl>cr
Wa:il:i; Incin.
Conilonu&r III
Uaf.lc Incln.
tiluitdown
Air Incin.
CondoiiHui: III
rmjitivc Ct 1 .
Wjutu Incin.
Act. Jil./li!j
Air fncin.
Uiinte Incln.
(.'oiulunaor III
I'u.j 1 1 1 v« Ct 1 .
Air (ne In.
fiKjitlvu Ctl .
Aft. SL/S!!
Waatc Incin.
Honto liict ii^. 	
NA

Mintilown
'll:iln«j  "<|>i.illly of  tlfo"  littallli effect  wi: lijlit ln<| ncliuim;.

^(.'01.:»<:ii|»»ii.l;( I u nioiloriito  cuiitiol of |>i OC.MI.'IUH 'j, (>, anil  I.

'('01 i'::.|iorKl.'i |» oxli.'iin I v«' control ol |>rot:<:iiiiun '->, d, ami  7.

IKilo:   Any  w.i.il-! nlil  inc IniM'nt >M| of 1:01:111'•:  l.in
-------
it is possible to construct income statements  for the plants
at each point on the cost-effectiveness curve.   These income
statements can be used as the basis for assessing cumulative
economic impacts  such as the  magnitude  of price increases
necessary to recover  Ipst profits.

     •Exhibits 4-20, 4-21 and  4-22  present  income statements
for the cost-effectiveness  curves  of  the Mississippi, Texas
and Kanawha  sum  plants.   These   income  statements  were
prepared by  estimating  Sales  and  General   Administration
expenses at  6  percent of the  cost of production,  interest
on the  debt  financed  portion of  the plants' book value,*
and depreciation  given a ten-year life for plant assets, a
five-year life  for  pollution  control  equipment  and straight
line depreciation.   The tax  rate  used  was  46 percent
* *
     The income  statements  show  that  at  the  uncontrolled
level the  Mississippi  and  Kanawha  plants  are  the  most
profitable with a  return  on  sales of  18.7  and  15.7 percent,
respectively, with  Texas  plants at 14.6 percent.  Texas is
the largest  area   in   terms   of  both   sales   and  capital
investment.  All  three  plants are  able  to achieve up to a
90 percent  risk reduction level  without a major impact on
profitability.  One  measure  of  this  fact  is  the required
price increase  each  plant  would  have  to  obtain  on  its
products to  recover the  net  income lost at the  85 percent
point.  The  Mississippi,  Texas  and  Kanawha  plants   would
require a  0.3,  0.5 and 1.1 percent increase,  respectively.
The increases  required  at  the  90  percent  level would be
1.1, 8.4  and  9.8  percent  for  these  plants.    It  is  not
possible to  determine  the  feasibility  of these  increases
at this time  due  to the  unavailability  of  price  elasticity
data.
 *   It  was  assumed that the plant would  reinvest  10  percent
    of  its  replacement  cost  per year,  and that 30  percent of
    plant book  value would  be  financed  by debt.   Interest
    was based  on an assumed  rate of  12  percent.   Inflation
    was assumed  to  be 8.5  percent per year.

 **  The  method used to develop these income  statements did
    not attempt  to account for  all  of the  complexities  that
    would surround  shutdown of  significant  portions of the
    plant.   If  permanent  shutdowns  occurred,  the  remaining
    book value  in these processes would  be  written  off and
    some revenue  from   salvage  value  might  be   realized.
                             -80-

-------
                                                 Exhibit  4-20

                                   INCOME STATEMENT -  FISCAL YEAR 1985
                                           MISSISSIPPI  SUM  PLANT
                                              (Figures  in MM Ss)
i
CO
Sales

1.6881
 Coat of Production

Pollution control
 Operating Coat

    Groau Margin

Other Bxponaua

    SGlft

    Interest

    Depreciation

Total Other fcxjJcnaea

Earnings lloforu Tax

Tax

Nut Income
                                                   30
                                                         'Health Kisk deduction (I)	

                                                           SO       US       90      9S
                                                                                          9!)
                                         1205.7   1206.2   1206.3   1160.0   1160.7    961.7    216.5
                                          615.7    645.7    645.7    604.2    601.2    510.1    M.S.3
4.7
555.3
I
3U.7
22.0
78.2
138.9
416.4
191.5
224.9
5.
555.

38.
22.
70.
139.
416.
191.
22-1.
1
4

7
0
5
2
2
5
7
5
555

3ft
22
70
136
'4 IB
192
225
.5
.1

.3
.0
.6
.9
.2
.4
. fl
6.
550.

36.
21.
78.
136.
413.
190.
221.
4
0

3
4
9
6
4
2
2
13
541

36
22
83
141
403
inr.
_2U
.0
.5

.2
.0
. I
.3
.2
.5
ol
2
428

31
20
00
133
295
135
_m
.7
.7

.8
.9
.8
.5
.2
.8
. \
4.5
66.7

8.7
16.4
73.1
98.2
(31. 5)
0.0
(31 .5)
                   The results  shown  here  are preliminary  and should  not be  quoted,

-------
                                                    Exhibit 4-21

                                      INCOME STATEMENT  - FISCAL  YEAR 1905
                                                  TEXAS SUM PLANT
                                                 (Figures  in MM $s)
i
00
Saleo

Lean i
 Coat of Production

Pollution Control
 Operating Coat

    Gross Margin

Other tixponsea

    SGfcA

    Interest

    Depreciation

Total Other Expensed

t:arnln
-------
00
u»
I
                                                 Exhibit  4-22

                                   INCOME  STATEMENT - FISCAL  YEAR  1905
                                              KANAWIIA SUM  PLANT
                                              (Figures in  MM $s)
                   Sales

                   Least
                   Coat of  I'roductloii

                   Pollution Control
                   Opera ting Coot
(1
119
66
,
SI
4
3
10
17
34
IS
_1S

.4
•>
.1
.*
.0
.0
.0
.0
.6
.9
J
(ill
119
66
1
51
4
3
10
17
34
IS
Ifli
A
.6
.7
.3
.(,
.0
.0 •
.1
.1
.5
.9
,i
.11 ma*
85
119.
66.
2.
50.
4.
3.
10.
17.
33.
IS.
18.
IWU
7
7
2
a
0
1
4
S
3
3
0
UUliUII
90
105.
61.
2.
41.
3.
3.
10.
17.
24.
11.
11.
l*|-
4
4
6
4
7
0
5
2
2
1
1
95
51
33
t
16
2
2
10
14
l
0
_i

.7
.8
.U
.1
.0
.!>
.0
.5
.6
.0
i«
99
0.
0.
0.
0.
0.
1.
9.
11.
(11.
0.
ILL,

0
0
0
0
0
7
4
1
1)
0
1)
    Gross

Otliur Expenses

    SGtA

    Interest

    Uopiociatlon

Total Other Expenneu

£arnlnna Uafore Tnx

Tax

Net Income
                   *Intcinicdiat« rink reduction  Icvola (leas titan 601)  were not run do to ncglitjibla
                    impact on  profitability.
                   The  results shown here are preliminary and should  not be  quoted.

-------
     At risk reduction  levels  above 90 percent major plant
impacts in the form  of  process  shutdowns  or net losses can
be seen.   Dislocations  of  this  magnitude  are difficult to
predict due to the market responses which would complicate
the final outcomes.
     Sensitivity Analyses

     As discussed  in Chapter  3,  two  types  of sensitivity
analysis were  performed on  the  chlorinated  organics model
to determine  sensitivity to error ranges in  the data.  The
results of these analyses  are  described below.

     The first  sensitivity  analysis  modified tfre exposure
element of the  analysis by  reducing  air  exposure by half,
doubling water  exposure and  increasing solid  waste exposure
by a factor  of 10.  The results  shown  in Exhibits 4-23 and
4-24 show  a  cost-effectiveness  curve  and control strategy
through the  90  percent risk reduction level  that is virtu-
ally ' identical  'for  both the  .sensitivity  analysis  and the
original analysis.   Past the  90  percent point the modified
exposure analysis  is  more  inexpensively  controlled.   'The
analysis suggests  that  the exposure element of the analysis
can be significantly modified without substantially changing
either the cost or most effective method  of risk  reduction.

     Exhibits  4-25 and 4-26 show the  results of  the second
sensitivity  analysis which  included  only those  health ef-
fects which  are  believed  to  be of  high certainty.  Once
again both  the cost-effectiveness curve and the selected
control strategies are  similar  up to  the  90 percent risk
reduction  level for  the sensitivity  and the original analy-
sis.  This   is  attributable  to  the  fact  that pollution
control equipment  aimed at  reducing discharges of a single
pollutant  often  reduces  discharges   of  many  pollutants.
Thus a strategy aimed at reducing the risks of a  few health
effects can  also  reduce  the  risks  of  many other  health
effects.

     An additional  sensitivity  analysis  was  performed  be-
cause  the  sum  plants  were  developed  by generalizing  the
orocess,  oroduction, pollution and exposure characteristics
of  the  actual plants in each  of  the  three  regions  studied.
To  test  the  quality  of this generalization  the  results  for
the  Mississippi sum  plant and the sum of  the analyses  of
                             -84-

-------
                                COST  OF HEALTH  UISK REDUCTIONS MISSISSIPPI
                                      SENSITIVITY ANALYSIS: MODIFIED EXPOSURE
                                         Coat Effective

                                             Curvo
                                                        Modified

                                                        Exposure
i
CO
IJl
 \
          SOO
          •400
300
          200
          100
             COST (millions  of EOY 1985 |)
                                                                                                 .1
          .inn I 111 i i 11111 L 11 LI I.LI 1111 n LIU i liiiiiiiiiliiiiiiiiiliiiin.nl LLU.I.I 11111 i M . ,. 1111 •..•..., I L ......,,

             0       10       20       30       40       50       60       70       QO        00       100
                                          PERCENT REDUCTION IN HEALTH RISK

                          THE RESULTS  SHOWN HERE  ARE PRELIMINARY AND SHOULD NOT BE QUOTED.

-------
                                                                Bxhibit  4-24
                                          CONTROL STRATEGIES  SELECTED  FOR COST-EFFECTIVE
                                              RISK REDUCTION1  - MISSISSIPPI  SUM  PLANT
                                              SENSITIVITY  ANALYSIS:  MODIFIED2 EXPOSURE
      I'ROCKSS
	iiiui.Tii EFFECT RISK lU'inicruiN (x)—
 50             fli             SO
                                                                                                                9S
1. Chlorlnatlnit of
Huthaiic
2, llyiirochlur liiatloii
of Hut liana I/
CMorlnatlon of
Mutliyl Chloride
3. Chlorlnatlun of
llydracarlione
4. Chlorlnatlun of
EI)C I
}. Direct Chlarinatlon
of Ethyl cue
6. Oxyclilodiiutloii
of Ethylcn*
7. ryrolyula of
EDO
0. Clilorlnut Ion of
Vlityl Uilorlda
9. Chlurluatloii of
KIU; it
10. Oehydiuclilorlnetlon
of 1.1.2 Trtchloro-
cilionn
11. llyiltoclilor {nation
of Vinyl Menu
Chlorldu
HA
AheorLcr
Uuate liicln.
Waal.li 1 nc In.
Shutdown
Air Incln.
Maata Incln.
Uncto Incln.
Air Incln.
Mania Incln,
llo*te Inoin.
HA

SliutUoun
U.\
Almorkur
Uuutc liicln.
Uuat« Incln.
Sliulilnun
Air Incln.
U«etc Incln.
Waste Incln.
i
Air Incln.
Uunta Incln.
Secure l.r
Hunt a Incln.
HA

Shutdown
HA
Auuortcr
Uuuta Inc. In.
Uatt* Incln.
Shutdown
Air Incln.
Condenser III
Want* Incln.
Uaate Incln.
Air Incln.
Maatu Incln.
Secure It
Vtttlu Incln.
IIA

Sliiildown
HA
Abaorkur
Act. SL
Uaute Incln.
Secure \.f
Conildiiaar lit
Act. SL
Uauta Incln.
Shutdown
Air Incln.
Uauta Incln.
Air Incln.
Uaata Incln.
Air liicln.
Waat* Iiicin.
Secure If
Act. SI.
Haute Incln.
Secure l.f
HA
Air Incln.
Slintdutm
HA
Atiuiifttr
ConJunuar III
Fugitive CTI..
Act. Sl./ba
Uaete Incln.
Secure I.F
Shutdown
Shutdown
Air Incln.
Uaate Incln.
Air Incln.
AcL. SL/63
Muatu Incln.
Air Incln.
Uaata Incln.
Secure l.f
Act. SI./SS
Maale Incln.
Secure I.F
HA
Air Jncln.
Shutdown
IIA
Abuorber
ConJcnucr III
Act. SL/SS
Waat* Incln.
Secure LF
Shutdown
Shutdown
Air Incln.
Coiidenaer III
Maete Incln.
Air Incln.
Conduuaer HI
Act. SL/SS
Waate Incln.
Air Incln.
Waate Incln.
Secure LF
Act. SI./SS
Waate Incln.
Secure I.F
NA
Air Incln.
Shutdown
NA
Shutdown
Shutdown
Shutdown
Air Incln.
Coiidenaitr III
Fugitive CTI..
Act. SI./SS
Waute Incln.
Shutdown
Act . In.: In.
Act. SI./SS
Secure: l.f
£iit|iack
Air Incln.
Act. SL/SS
Secure I.F
NA
Air liicln.
Act. SL/SS
Shutdown
I
00
CTv
I
             ' Uali»j 'ijuollty of  life*  health effect welyhlImj achcme.

             ^ llelallve to standartl. ux|>neur3 In mu 11 L|>11 «d by .S for air, 2 for water and 10 fot* tiAzardoua

             llotui Any wante  not  Inctnccnteil or aeuure  lamlflllcil la aent  to a  aanllary  Idiidflll.

-------
                                                     Exhibit  4-25

                                   COST  OF HEALTH  RISK  REDUCTION:   MISSISSIPPI

                                   SENSITIVITY  ANALYSIS:  HIGH CONFIDENCE HEALTH EFFECTS
                                              All Health
                                                Effects
                       High Confidence
                        Hoalth Effecta
oo
•vj
I
              500
              •400
              300
              200
              100
                 COST (mllllona of EOY 1965 |)
             -too
                   i i i i in i.Li.i-t LLI-II il u 11 i i i
10
20
30
                                                    -tO
                  i.t I 1.1 J M.I i,«J.I.UOJ
                  SO       60
70
                                                             60
90
100
                                              PERCENT REDUCTION IN HEALTH RISK
                             THE RESULTS SHOWN HERE ARE PRELIMINARY AND SHOULD  NOT BE QUOTED.

-------
                                                        Exhibit  4-26


                         CONTROL  STRATEGIES  SELECTED FOR COST-EFFECTIVE RISK  REDUCTION
                                                   MISSISSIPPI  SUM PLANT
                               SENSITIVITY ANALYSIS:   HIGH  CONFIDENCE HEALTH EFFECTS
     I-KCCKUS
                                                                -IIIIAI.TII KFFeCT RISK REDUCTION «)-
I
00
00
I

1. Clilorlnatlon of
Mctlmnc
2. lly.liocliloi InaCloti
of Hethanol/
Chlixlnutlun of
Methyl Chloildo
3. Cli lotl lint luu uf
llyilrucarljona
4. Chliirinal Jon uf
I-DC 1
3. Direct Chlarlnallon
ol I'Uhylunu
(,. Onycliloi Imit Ion
llf Kill) luill!
/. 1 )T..I) II IS ..(
Kin:
8. Clilor in/illoii uf
Vinyl CM.. ride
!). Cli tut ln.it lull of
i:i»: 11
1U. IU-liy.linclilorJii.il Ion
ol 1,1,2 Ulchloro-
et Ji'Mit;
1 1 . llyilmcliloi ln.it Ion
ul Vinyl till-in
Chlnr Idi:
II
NA
Al»iarl>cr
Unuto 1 no in.
Wautu Inoln.
Sliutilown
Air Incln.
Wasto 1 uc In,
Uuutc 1 11 tin.
Air In-. In.
Waste IMC In.
Uattlfe liirln.
NA

SlinliK'Wil
Jll
HA
Alinofliut
UilHlU lilt III.
W/idlu Int In.
SllulU«wii
Air 1 in: In.
Uaula lutln.
Air Int. In.
UiiHlo Jiirln.
All In. In.
ifilHdl IllC 111.
Sutum I.I'
Uiiutu die In.
HA

Slitiltltiwn
50
NA
Almutbcr
Uniite Inelit.
Uunlo Incln.
SlinCiliiun
Air Incln.
Woule Incln.
Air Incln.
Uuatu Incln.
Air 1m: In.
Uaata Incln.
Suiuire l.f
Uaate Incln.
NA
Air In.: In.
Shut Joint
05
NA
/bsotbtr
Wuale Incln.
Secure LP
Vlaatc Incln.
Shutdown
Air Incln.
Condcitoei til
H.iate Iiicln.
Air Incln.
Act. SI./SS
WnuLe Incln.
All Incln.
Mauce Incln.
Sccuni I.K
Uautn Incln.
Sctutc l.f
NA
AJ. liicin.
!ilintil»wn
•JO
NA
Abaorlui
Cunilunucr 111
Ace. SL/SS
Waata Incln.
Secyre LF
CumlciiRcr 111
Hnste Incli).
Sliutilown
Air Incln.
Coiulaiincr III
Hnslc lnclii.
Air Inclu.
Cuinli-iiaor til
Ai l . Sl./Sii
U.iule Inrln.
Air Incln.
llu a Ic lin-ln.
Set tut |.F
Acr. bl./«S
Waste Incln.
Sccuru l.f
NA
Air Incln.
Shutdown
'Jj
NA
Abuurhcr
ConJeiiaer HI
Act. si./as
W.iatc Incin.
Secure l.P
Shutdown
Shut down
Air Incln.
(,'oiidciittcr III
IMS to Incln.
Air Incln.
Coiidciincr III
Act. SI./SS
Wiiate Incln.
Air 1 uc in.
Art. SI./SS
ll.iale Incln.
Secure II-'
Air Int In.
Act. SI./SS
Uiisd: Incln.
Secure IK
NA
Air Incln.
Shutdown
9'J
NA
Shutdown
,Shuld»wii
Shutdown
Air Incln.
Oii.li-nl>.-.r HI
I'll i; (I I vi: C( 1 .
MiuiKK 'nci.n, ....
Air liifln.
Condenser | | i
Fug It tvc I'l 1 .
Act. si./;:.-:
IV till t: (lit III.
r.ni. ,. k
Al< Incln.
Act. SL/SS
:M:rni't! l.K
Ciil|..n k
tihut down
HA
Shutdown
Slmtili>wn
          IhilitB ''|n:illly of  life' health effect wul)ilit liif, uclieii.u.

         Nuiu;  Any wasli- nut lncliiurntf.il or nur.iirt: I nn.lf 11 l^.l la atMit i« « snnltniry lundfill.

-------
each individual  plant were compared.   In  Exhibit 4-27 the
sum plant's cost-effectiveness curve  is compared to the sum
of the  cost-effectiveness  curves  for each  of  the  seven
plants.  Although more  sophisticated techniques for gener-
alizing exposure  should  be developed to increase the accu-
racy and value  of generalized plant models, the curves are
very similar.   This suggests  that  the Mississippi sura plant
generalization  is  an  accurate representation  of the seven
plants in the region.

     A final  sensitivity analysis was performed to examine
the maximum individual risk levels  of the most  exposed pop-
ulation subgroups.  One  of the largest chlorinated solvent
plants located  in a densely  populated  area was chosen for
this analysis.   Further, only cancer  risks were estimated,
as the CAG unit risk factors are  the only accepted incidence
measures.  For  the particular plant examined,  six carcinogen
pollutants are  emitted  and the risks  are summed to compute
the  total risk  to each population subgroup.  The results  of
this analysis  indicate  that  at the  uncontrolled  level  96
people would  have an annual  individual cancer  risk  in the
range of  10~4  to  10~5.  Another  4490 people would have
risks  in the  range  of 10"5 to 10~6.


COPPER SMELTING INDUSTRY

     This  section summarizes  the preliminary results  of  the
toxics integration study  of  the  copper  smelting  industry
and  is organized as follows:*

     •     Description of the  industry,

     •    Pollution problems  of concern,

     -•    Cost-effective control strategies,

     •    Alternative policies examined,

     •    Cumulative  economic impacts, and

      •    Sensitivity of results.
    The copper smelting  industry  study will be completed by
    late August.
                             -89-

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                                                   lixhibit 4-27

                                       COST OF HEALTH  RISK  REDUCTION
                                  MISSISSPPI COST EFFECTIVE CONTROL CASES (1985)
                                           Mlaalaalppi
                                           Sum Plant
                                           	1	
O
 I
          500
           400
          300
           200
           100
              COST (millions of EOY 1985 |)
    Sum of
Individual Plants
                                                                    . -B—
          -100 l'i i in i ml numiil mi niii 11 mini i liiii.tiiiil t ii i u.i.iilii tin 11 iluijjiiMl if 14t111.1 • 11 • i... t
              0        10       20        30       40       50       60       70       00        90       100
                                           PERCENT REDUCTION IN HEALTH RISK
                          THE RESULTS SHOWN  HERE ARE PRELIMINARY AND SHOULD NOT BE QUOTED.

-------
Description of  Industry

     Copper smelting  is a  segment of  the  copper industry
which includes  raining,  milling,  smelting  and  refining.
The principal  product of  copper  smelters —  anode  copper
— is  produced 'via  a  series  of  roasting,   smelting  and
converting processes  (see  Exhibit 4-28).   These  are  high
temperature, energy  intensive  processes.  As  shown  in  Ex-
hibit 4-29,  13  plants, owned  by  5  companies,  produce  1.5
million metric  tons per year of primary  copper with a sales
value of  approximately  $2.8  billion  (1981 data).   These
plants are located for the  most part in  southwestern states
(Arizona, Utah, and New Mexico), close to the copper mines.

     Copper smelters  are  the  largest  single  sources  of
sulfur dioxide  (SC>2)  emissions  and are  significant sources
of particulate  emissions.   Many smelters are not  in compli-
ance with current regulations for  these  pollutants.  Copper
companies can apply  for extensions . in compliance deadlines
for SC>2  emissions  for  financial  reasons  by  applying  for
a nonferrous smelter  order (NSO)  under  Section  119  of  the
Clean Air Act.   Because of  the  financial difficulties  the
industry is currently experiencing and the  significant  air
emissions, EPA chose  to use the  industry  approach  to analyze
the copper smelting industry.

     Copper smelters  produce  large amounts  of  solid wastes
(2.5 tons of  slag  per  ton of  copper product) as  well  as
substantial air emissions.  Most  of  these  solid  wastes  are
nonhazardous.*  There is currently no model of the transport
of heavy metals to the ground water.  Therefore, solid waste
has not been included in this analysis.

     At most plants there are no water pollutants discharged
except during periods of  net  rainfall.  Thus,  water pollu-
tion is not a factor  in this analysis.
Pollution Problems of Concern

     Six major air  pollutants  have been considered in this
analysis — sulfur  dioxide  (SC>2),  total suspended particu-
lates (TSP),  arsenic,  lead,  cadmium  and  mercury.    Air
*  In fact,  some  experts  believe that the slag can be used
   to store hazardous wastes.
                          -91-

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                                               Exhibit  4-28

                                      COPPER SMELTER*  PRODUCTION
                                            MATERIAL BALANCE
                                             (Tons per  Day)
                         FUGITIVES FLUE GAS
                         (24.5)    (5/1.7)
FUGITIVES FLUE GAS
 (24.7)   (972.7)
              CONCENTRATES
                CQISJ
I
lO
N>
I
                          .SLAG
                          ((69S.4)
                                      "SMELTER"
                                                                                 -REFINERY"
                   *  This smelter  does not  include the roasting process  which would  precede
                     the reverberatory furnace.  Nine of  the thirteen  smelters studied have
                     a roaster  or  rotary kiln  drier.

                   Source: U.S.  Bureau of Mines  and PEDCo  Environmental,  Inc.

-------
emissions can  result  in  serious  health problems  such as
respiratory ailments  from 303  and TSP,  and  cancer,  rauta-
genicity and  neurobehavioral  toxicity  from  toxic  metals
(notably arsenic and  lead).
 •9
     Current controls  have  tended to focus on stack rather
than fugitive emissions.   Sulfur dioxide process emissions
are normally controlled  by  scrubbers and acid plants which
convert the  gas to  sulfuric acid.   Particulate emissions
are controlled  with  the  use  of  bag-house  fabric filters
and electrostatic  precipitators  (ESP).

     The fugitive  emissions  are  currently not  controlled at
most smelters.  The control of these emissions  would require
hoods  and  ventilation systems which collect  the emissions
and vent them  into a stack  or into one  of the process  con-
trol systems.


Cost-Effective  Strategy

     A cost-effectiveness curve  is being developed  for  each
smelter  included  in Exhibit 4-29.   Exhibit  4-30 displays  a
curve  for  a typical  smelter and  Exhibit  4-31 presents the
control options selected  for each.process unit at each level
of  health  risk reduction.  The  format  of these  exhibits _ is
similar  to   those  presented  for  the  chlorinated  organics
case  study.

      Preliminary  results indicate that  significant  reduc-
 tions  in  health risk  can be achieved for many  smelters  at
 relatively  low cost  if  fugitive  controls  are  installed.
 Stack  emissions account  for the majority of  the  emissions
 from  an  uncontrolled  smelter,   and  are cheaper to  control
on  a   per-pound basis  than  fugitive  emissions.   However,
 because  stack   emissions  are  discharged  at  high  levels
 (normally 500   feet or more), they result in far less expo-
 sure  than do  fugitive emissions.   Thus,  fugitive  controls
 are frequently a  more  cost-effective  manner of  reducing
 health risk.

      As  shown  in  Exhibit 4-31,  the use  of hoods and ventila-
 tion  systems at the  two  processes can  achieve  a  reduction
 in health risk of  90 percent.   Installation of a flue scrub-
 ber (stack control)  brings  about some  further reduction in
 health risk at a significant cost.  The most  cost-effective
 means of achieving  further  reduction in health  risk is  by
 curtailing production.
                              -93-

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                         Exhibit 4-29

                   PRIMARY COPPER SMELTERS*
          (Thousands, of  Metric  Tons, Copper Content)
Company

ASARCO,  Inc.
Location of Plant

El Paso, Texas
Hayden, Arizona
Tacoma, Washington
 Annual
Capacity

   104
   163
    91
Inspiration
  Consolidated
  Copper Company
Inspiration, Arizona
   136
Kennecott Copper Co,
McGill, Nevada
Hurley, New Mexico
Hayden, Arizona
Garfield, Utah
    45
    73
    73
   254
Newraont/
  Magma Copper Co,
San Manuel, Arizona
   182
Phelps Dodge Corp,
Douglas, Arizona
Morenci, Arizona
Ajo, Arizona
Hidalgo, New Mexico
   115
   161
    64
   127
Source:  Mineral Facts and Problems, Bureau of Mines, 1980
*  Excluding three small smelters with insignificant sulfu:
   dioxide emissions.
                           -94-

-------
                                                   Exhibit 4-30    •

                                          COST  OF HEALTH  RISK REDUCTION


                                           PLANT A COST-EFFECTIVENESS  CURVE  (1085)

                                     QUALITY OF LIFE     CURRENT CONTROL   COMPLIANCE CONTROL
                                     HEALTH WEIGHTS
I
VO
LSI
I
30000
              25000
              20000
15000
              10000
               3000
                    COST (THOUSANDS OF EOY 1005$)
                     mrmrT
              -5000
                            to
                      20

HJf.yij-'TiA>.4..1-1-1-l-l-l-l-'-V-H-1-1 j-t ^4 (-14
      40        50        SO
                                                PERCENT REDUCTION  IN HEALTH RISK

                                    THESE RESULTS ARE PRELIMINARY AND SHOULD NOT  BE QUOTED.
jJaajjatxj-iXu_ua-M-u.Ljjj. 10x1x1.
 70       BO       60       100

-------
                                              Exhibit 4-31

                CONTROL STRATEGIES SELECTED FOR COST-EFFECTIVE RISK REDUCTION1
                                                 PLANT A
I'KOCKSS
I.  Kiivtii burnt . tn Id
tSI'
Fluu scrub
ll»t til'
Ac Itl (ilant


         ""("•'it r "f life" IK: a ltd olfect uelglttlii); nrhciuu.

-------
     It should  be  noted that  stack  controls are important
for reducing environmental  effects  such  as crop damage and
visibility impairment.   For  many  smelters  the  secondary
(welfare-related) air quality  standard requires more strin-
gent control  than  the  primary  (health-related)  standard.
In addition,- the health  effects considered here*are the
result of  long-term exposure.   Stack  controls  may  be more
important  in  preventing extremely high  S02  concentrations
for short  periods  of time  and their related health conse-
quences .

     In a  few cases, smelters are  so isolated that no one
lives within  10  or  20  miles  of   the  plant.    For   these
smelters,  fugitive  controls bring about  little  or no reduc-
tion in health  risk.   Stack controls have a  greater effect
in these cases.  However, further analysis would be  required
to determine  whether the  actual level  of  health  risk in
these cases  warrants  either  stack  or  fugitive controls.

     The current control level for  most of  the smelters is
-far from  the cost-effectiveness curve  since current  con-
trols have focused  on stack rather  than  fugitive emissions.
Exhibit  4-30. illustrates   the current  control  point for
Plant A.   As can be seen in  the exhibit, the current  controls
achieve  a  11.5  percent  reduction in health risk at a  cost
of $7.6  million.

     Tn  many cases,  the  additional  controls  required to
achieve  compliance  again focus on stack rather than  fugitive
emissions.  Thus,  the compliance control point will also be
far from the cost-effectiveness curve except in those  cases
where  fugitive  controls are being   required.   Exhibit 4-30
illustrates the compliance control  point.  Once again, very
little  health improvement  is  achieved given the  high  level
of expenditures.  A  17.5  percent reduction  in health risk
is achieved at  a cost of $13 million.


Alternative Policies

     Alternative policies  for toxic  pollutant control  at
smelters will be analyzed, and the results will be  reported
 in late August.
                              -97-

-------
Cumulative  Economic  Impacts

     The  copper smelter study will assess the financial  and
economic  implications  of two alternative  control  strategies
— compliance  controls and  fugitive controls.  The  results
.of this study  will be  available in late  August.
Sensitivity Analysis

      For  most smelters, the  cost-effectiveness  of  fugitive
controls  for reducing health risk outweighs  the  cost-effec-
tiveness  of stack, controls  by a  factor  of  50.   Thus,  the
costs of  control,  emission   rates,  exposure models  and/or
the  health effects would have to  be  substantially  in error
in order   for  the  resulting  control strategy  to  change.
While the errors  are  thought  to be significant, particularly
in the  exposure  and health area,  the errors  are  not thought
to be  large  enough to make  the   results  invalid.   Further
sensitivity analysis  is   being   carried   out  and  will  be
reported  in late August.
                             -98-

-------