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

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

                     Putnam, Hayes & Bartlett, 'inc
                            50 Church Street
                          Cambridge, MA  02138
                             15 August 1981

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                                                            26453
TABLE OF CONTENTS                                APPENDICES
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-8
   Pollution Control Constraints	  .  A-10
   Health Effect Constraints	A-12
   Model Operation	A-l4
   Model Results	A-14
Appendix B
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-l2
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
Aooendix 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. We ins te in	D-2

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MATHEMATICAL PROGRAMMING FORMULATION	APPENDIX A
INTRODUCTION

     Mathematical programming  (MP)  is a  technique used to
calculate the  best  use  of  available resources.   Putnam,
Hayes &  Bartlett,   Inc.   (PHB)  developed  a  mathematical
programming model  for  the  chlorinated  organic  solvents
case study.  This  model  simulates  plant operations, pollu-
tion, and  the  resulting  health  effects  at  alternative
levels of pollution  control.

     Consider an   example  where  a   manufacturer  has   two
products and wants to know how much of each product to make
and the  best way  to  combine his resources to produce each.
In this  example,  resources might  include labor,  raw mater-
ials, and equipment.   The  manufacturer  wants to make  the
best use of  these three resources  in the production of  the
two products.

     An  M?  program  begins  with the  statement of a goal,
which is  expressed  in  the  "objective  function."  In   the
example, the manufacturer  might want to maximize  operating
cash"flows.   The   objective  function would  be established
to calculate  the  total margin,  based on the  unit cost of
each resource and  its  level of usage and the sales of each
product  and  revenues  received.   Because  the manufacturer
wants to decide on the  best sales  mix for the two products
and usage  of the  three resources,  the  levels  of   sales  and
usages are called  "decision variables."  This  type of prob-
lem is  referred  to  as  a  "cash flow  maximization" problem.

     Maximizing the  value  of  the  objective function occurs
subject  to  a series  of restrictions, called  "constraints."
n

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Constraints are  established  as  equations  which  limit  the
range of values  for decision variables.   One  set  of con-
straints might specify  a maximum  sales  level (demand)  for
each product.  Since this example is a cash flow maximization
problem, a maximum sales or production level must be  speci-
fied or the solution would be to sell an infinite amount of
profitable products.  Another  constraint  (or set  of con-
straints) might limit the usage  of the  resources.   For  ex-
ample, there may  be  only three employees available to pro-
duce the two  products.   Finally,  constraints must  be  set
to show how  much  of each resource  is  required  in the pro-
duction of each product  so  that the plant's internal mate-
rial balance is reflected in the model.

     The PHB  model  for  chlorinated organic  plants  uses  a
version of MP called mixed integer  programming.  Mixed inte-
ger programming allows the model to account for fixed costs
appropriately and to account for any potential economies of
scale.  Mixed integer programming allows some decision var-
iables to take on integer values.   If a process is operat-
ing, the  variable assumes  a value  of  one and  the  fixed
costs of  the process  are  incurred.   When  the  process  is
not operating the variable equals  zero and  the fixed costs
are avoided.

     As in the above  example,  the  PHB model seeks to maxi-
mize the operating  cash flows*  of the plant subject to  a
series of  constraints.   Production volumes, sales volumes,
and purchases  of  various factor inputs  are all calculated
so as to maximize operating  cash flow.  Decision variables
fall into one of four groups:

     •    Level of operation for production processes  (such
          as chlorination of ethylene),

     •    Level of sales for  chemical  products   (such  as
          methyl chloride, vinyl chloride),

     •    Level of usage for factor inputs  (such  as  labor
          and energy), and

     •    Level of operation for environmental  control  op-
          tions.
*  Operating cash flows include revenues less manufacturing
   costs and pollution control capital and operating costs.

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The selection of decision variable values is subject to six
types of constraints:

     •    Material balance (yields),

     •    Factor input (requirements),

     •    Capacity,

     •    Operating,

     •    Pollution  control, and

     •    Health risk.

Each of these constraints is explained below.

     Production flows among the specific  production process-
es at a  plant  are  defined  through  yield  relationships,
which indicate  how much output -of one  process  (an inter-
mediate product)  is  necessary  as  input  to the next.  These
are often  called   material balance   constraints,   because
they insure  that   eachintermediate product  (material)  is
produced in  an  amount consistent  with  the  needs  of down-
stream processes.

     Factor  input  requirements  are  coupled with production
process decision   variables  to  calculate  how  much  of   a
particular factor  input  (labor, power, water,  and so forth)
is necessary at a particular  process  given the production
level of  that process.   These are  also  called value added
constraints  because  they quantify  the  value  of  the input
factors used at each process.

     Capacity constraints  limit  the  production  level  at
each process to  the capacity  of  that  process.   Capacity
constraints  can also be"used to force the plant  to produce
at levels consistent with expected demand levels.

     Operating  constraints  insure  that plant operations are
consistent with a  variety of special limitations.

     Pollution  source  constraints  are coupled with produc-
tion process and  environmental control  technology decision
variables to insure that the  desired pollution control  is
achieved.
                             A-2

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     Health risk constraints  limit  the  relative   risk  of
occurrence of one  or more health  effects  (such as cancer)
or of  a  weighted  group  of health effects.  This  type  of
constraint acts to  limit  pollution levels  so as to achieve
a reduced level of  health risk.   Thus the health risk con-
straints force the  model  to  select the most cost-effective
mix of production  and  pollution  control decisions  in order
to reduce the risk of health effects.

     In the  following  pages  the objective  function of the
model and the various operating constraints, including pol-
lution control and health constraints, are described.  Equa-
tions which  are the basis for the mathematical programming
model of  the selected  chlorinated organics  are  included.
In addition  to the  equations,  a  list of the variables used
is included  in Exhibit A-l.
OBJECTIVE FUNCTION

    The objective  function used  is  a cash  flow objective
of the following form.

Maximize
the operating  =   1   ?iSi -  1  PjBj - I P^Bfc  -  £  Km1^
cash flows         i           j   J     k          m

     Where:
                  or
               Bj or
                     K
                      'Til
                      m
=  Market price of product
   i, factor input j or
   material k

=  Units of product i sold

38  Units of factor input j
   or material k purchased

*  Annualized capital cost of
   pollution control option m

»  Binary decision variable (0=off,
   l=on) for pollution control
   ootion m
Note that negative  signs  indicate reductions in cash  flow,
while positive signs are used to  indicate increases in cash
flow.
                            A-4

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        Exhibit A-l

   INDICES AND VARIABLES
USED IN THE MODEL EQUATIONS
  i  Products
  j  Factor Inputs
  k  Materials
  1  Health Effects
  m  Pollution Control Option
  p  Pollutant
  r  Processes

  s  Product Mix
Ai,s   Fraction of product i
       in mix s output

3j     Units bought of fac-
       tor input j

Bfc     Units bought of
       material k

Cr     Capacity of process r

Dm -    Binary decision var-
       iable for treatment
       option ra

Eifp   Emissions of pollu-
       tant p from product i

Em,i,p Emissions reduction
       of pollutant p from
       control option m for
       product i

Fj/i   Quantity of input j
       consumed or produced
       per unit of produc-
       tion of product i

H      Total combined health
       risk
                Hi


                J-i
                K
                 m
                N,
                Qp,t
       Risk of health effect 1   P
       (relates emission level
       to health risk) of pol-  QD/h
       lutant p
Total health risk of
effect 1

Quantity of input j
consumed or produced
in a fixed quantity in
process r

Annualized capital cost
of treatment option m

Binary decision variable
for process r

Binary decision variable
which indicates the section
of the utilization curve
a process is operating on

Market price of product i

Market price of input j

Quantity of pollutant p
emitted which has a health
effect

Total quantity of pollut-
ant emitted

The threshhold emission
level
                           ?,t
                                   ' then
                            » Q  - Or
                               P    -
            A-5

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        Exhibit A-l
        (Continued)

   INDICES AND VARIABLES
USED IN THE MODEL EQUATIONS
Rkfi   Units of material k
       consumed or produced in
       the production of i

Sj_     Units sold of product i

Sfc     Units sold of material
       k

Vs     Total quantity of
       output at product
       mix s
                        Weighting factor for
                        health effect 1.

                        Production volume of i

                        Production volume of i
                        produced by process r

                        Operating level of
                        treatment option m for
                        product i
            A-6

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MATERIAL BALANCE CONSTRAINTS

     Material balance  constraints  match process inputs  and
outputs of  chemicals.   They  are  generally  of  the  form:
                              Bk > 0
             i
     Where:    Xj. =  Production volume of product  i

             Rk  i ~  On its of material k consumed  or
                     produced per unit of i  produced

               Sfc =  Units of k sold

               Bfc =  Units of k bought


FACTOR  INPUT CONSTRAINTS

     These  constraints  assure that  the  inputs consumed  do
not exceed  the  sum  of  those produced  or  purchased.   They
are of  the  following form:


             I  Fj^Xi +  Jj/rNr + Bj  >.  0
     Where:   ?j,i s Quantity of  input j  consumed or
                     produced per unit of i produced

                Xj_ » Production of i

              Jj r = Quantity of  j consumed or
                     produced in  a fixed  quantity
                     when process r is being operated*

                Nr = Binary variable  which equals
                     1 when process r is  being
                     operated

                Bj - Purchased quantity of input j
     j  r is  generally  denominated  in dollars for fixed costs.
                             A-7

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CAPACITY CONSTRAINTS

     Capacity constraints prevent the  model from operating
a process above its  rated  capacity.   Their typical  fora is
illustrated below:

            I Xifr - CrNr £ 0
            1

     Where:  xi,r s  Production of product  i from
                     process r

               Cr -  Capacity of process r*

               Nr =  Binary variable which  equals 1
                     when process r is being operated
                     and 0 when it is not
OPERATING CONSTRAINTS

     Operating constraints are  used  to constrain the model
to simulate actual plant operating behavior.  A representa-
tive example  of  the  situations in which these constraints
are used is the  equilibrium  production of Methyl Chloride,
Methylene Chloride,  Chloroform  and Carbon Tetrachloride by
the chlorination  of  methane  process.   As  illustrated  in
Exhibit A-2, the output mix is dependent upon the molar ratio
of chlorine to  methane  in the  feed  to  the  reactor.   Thus
the ratio of chlorine to methane in the feed to the reactor
determines the  fraction  by  weight  of  each  of the  four
products in the  output.   Note  the choice  of a product mix
is independent  of the  choice  of total throughput of  all
products by  weight.    Thus  the  quantity  of   any  product
produced is determined by two choices.   These choices result
in a mix percent  which  when  multiplied by the total volume
of material processed  equals the quantity  of  each  product
manufactured.   This multiplication of  two decision variables
is nonlinear  and thus  not  amenable  to  continuous  mathe-
matical programming.   It  is  possible,  however, to select a
group of discrete product  mixes from  which  the model must
choose.  The model can  then  select  the operating level for
*  In  the  PH3  model,  capacities  are  selected  to reflect
   anticipated demand levels at the actual plants of inter-
   est.
                            A-8

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                         Exhibit A-2



      CHLOROMETHANES BY THERMAL CHLORINATIOH OF METHANE

           PRODUCT DISTRIBUTION — HASS AND McBEE
    U
    z
    O
        TOO
         80
    z


    O   60
     u
     LU

     O




     z
     UJ

     u
     as
     •-u
     a.

     a:

     <


     O
40





20




 0
--*- x      J
                      1         2        34


                  MCLAX RATIO CF CHLORINE TO METHANE
     Source:  4231.
Source:  SRI Chemical Economics Handbook.
                            A-9

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the process.   The  model  is  thus constructed  to treat  the
process as a number of separate processes,  only one of which
can be operated at any one time.

     In Exhibit A-3,  seven vertical  slices  of the product
mix function have been identified.   Each of these represents
a fixed product mix alternative  (the  total number of alter-
natives can be varied).  One  constraint is required to model
the choice  among   fixed  product  mix  alternatives  and   the
choice of  a  production level.   The  form  of  this equation
appears below.
     Where:    X^ =  Quantity of product i manufactured

             AifS =  Fraction of i  in the process  output  for
                     product mix s

               Vs =  Total quantity  of product manufactured
                     using product mix s
                     (Note:  These variables are  identified
                     as Special Ordered Set variables which
                     require .that only- one variable be non-
                     zero at  any  one time.  Thus only  one
                     product mix can be active.)

One equation of  this form  is  required for each product  the
process can produce.
POLLUTION CONTROL CONSTRAINTS

     Pollution treatment  options  are  generally  treated as
processes with  capacity  constraints  and   coefficients  in
the factor  input  constraints  to  capture   their  operating
and fixed costs.   As noted previously,  an annualized capital
cost for  each treatment  option  appears  in  the  objective
function.

     Only one  type  of constraint  is  specific to pollution
control.  This constraint  adds  total uncontrolled emissions,
deducts those emissions controlled and  sums  up total result-
ing emissions in Q.  It is of the following form:

     £ Bi,p xi -  II Em,i/p Xm/i - Qp,t £ 0
                     m
                            A-10

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                         Exhibit A-3
      CELOROMETHANES BY THERMAL CHLORINATION OF  M

           PRODUCT DISTRIBUTION — SASS AND McBEE
     U
     ~mt
     Q

     o
     z
     o
     LU
     ( ^
     V>




     Z
     LU

     U

     —
     e_



     <


     O
      Source: 423154
Source:  SRI Chemical Economics Handbook,

                      I         2         3         4


                   MOLAR RATIO OF CHLORJNE TO METHANE
                             A-li

-------
     Where:    Ei,o =  Emissions of pollutant p per unit of
                       product i produced

                 Xi «  Quantity of i produced

             Erari,p =  Emissions  reduction  of pollutant p
                       per unit  of  operation  of  treatment
                       option m for product i

               *m, i ~  Operating level of treatment  option
                       m for product i

               Qp,t =  Total quantity of  pollutant p emit-
                       ted.  An  upper  bound on  this vari-
                       able acts as an emissions limit

Note that the operating level of a treatment option and the
production level of a  product  are treated similarly.  This
reflects the  assumption  that  a  treatment  option   can  be
operated on  a  unit  of  product  basis.   Thus  a  treatment
facility can  be  operated  to  offset the emissions generated
in the production of each unit of product or at some lesser
level specified  in  terms  of   a  lower   production  level.
HEALTH EFFECT CONSTRAINTS

     The total  risk  of  each health effect arising from the
pollutants emitted  at  the  plant  is  calculated  using the
following constraint:

                 HI  -   I H^pQp


     Where:      H]_  =  Total risk of health effect 1

                H]_7p  *  Health  risk  of  effect  1 from a unit
                       of pollutant p  (this  is  a constant
                       which relates   emissions    level  to
                       health  risk)*

                 Q0  =   Quantity  of  pollutant  p  emitted
*  This  constant  is  developed  from  the  exposure analysis
   and health effect analysis.
                            A-12

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By placing an  upper  bound on HI,  the  risk from health ef-
fect 1  is  limited.   Because certain health  effects do not
appear until total plant emissions exceed  a threshold,*  a
special constraint  is  needed   to  calculate  QD  for  these
effects.  Threshold  effects occur  only for  that quantity
of pollutants  that  exceeds the  threshold.   The constraint
which calculates this quantity  appears  below:

          QP,h + Qp,t - Qp s  Q'

     Where:    Qp,t =  Total emissions  of pollutant  p

                 Qp -  Quantity of emissions by which
                       Qp,t exceeds Q1


               Qpfh =  Quantity of emissions by which
                       Qp/t is  less than Q1


                 Q' =  Threshold emission quantity
                  p
Note:  9^/h an<^  ®*>  are  Designated  special ordered set var-
       iables.  TKis  permits  only  one  variable  to  have a
       positive value at any one time;  the other  is required
       to equal  zero.  Under  no circumstances  can either
       have a negative value.

     The final  health risk  constraint combines  the total
health risks  of  each effect  into  one  health  risk number.
The weighting  factors which are used  in  the constraint  to
combine health  effects  are  described  in  Appendix  D.   The
constraint is formulated as follows:

          H - 2 WiHi  = 0


     Where:    H]_ *   As defined  above.

                H *   Total  combined   health   risk  from
                      plant.
                  *  Weighting  factor for health effect  1.
*  Thresholds are determined by comparing plant emissions to
   background levels in the plant's environment.
                            A-13

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3y placing  an upper bound  on K, the  combined health  risk
from the plant can be reduced.
MODEL OPERATION

     The cost  effectiveness  curves  are produced by running
the model with upper bounds on H which  reflect  a 30 percent,
50 percent,  80 percent,  90 percent,  95 percent and"99 per-
cent reduction  from its original uncontrolled value.  The
decline in  the  objective  function  from  its  uncontrolled
value is the cost plotted  in  the curve.
MODEL RESULTS

     In addition  to the detailed computer  output which  is
produced by  the  MP  solution  program,   summary  reports are
available which  contain  the  major  results of  the model.
Two of  these reports  for the Mississippi  River  sum plant
appear  in  Exhibits  A-4  and  A-5.   Both  reports  are  for
1985.  Exhibit  A-4 contains  the results  for  the  base  or
uncontrolled case.   Exhibit A-5  is  a report of the results
for the case in  which  the total  weighted health effect  is
reduced to   50  percent  of  its  value  in  the   base  case.

     In the  base  case  (Exhibit A-4)  plant revenues  are
approximately $1.2  billion, while  gross margin   (the objec-
tive function  value  without   annualized  capital   charges)
equals $555.3  million.   Capital  charges  of   $6  million
reflect the  annualized  capital  cost of  pollution  control
devices installed.   This charge reflects  the  capital  cost
of.profitable  control  options  which   were installed  for
their economic  benefit.  As  can be  seen in the profitable
pollution control  cost  summary,  the  operating  costs of the
control options  is exceeded  by  the recovery  credits  (the
value of chemicals  retrieved  by  pollution control for  sale
or internal  use)  to result in a $13.5  million  profit  from
the use of  these  controls.   This  profit also  exceeds the
combined operating  and  annualized   capital costs  of  the
devices.

     Relative incidence  measures of  each  health effect are
reflected in the health scores for each  effect.  The weight-
ing factors  used  to calculate the  weighted average health
score are the quality  of life weights  (discussed in Appen-
dix C)  normalized  to  sum to one.  Note that cancer has the
                            A-14

-------
                                                      Exhibit  A-4

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-------
                            Bxhlbit  A-5

MISSISSIPPI  SUM  PLANT  -  50  PERCENT  RISK REDUCTION
DI-IIKATING
                    nun rosin
IIITAI  Rl WNIM B
HITRAUNd (IRIIfif]  HAI'-OIM
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                                                             (II t. MB)
                                                             
-------
                          Exhibit A-5
                          (Continued)

      MISSISSIPPI  SUM PLANT  - 50 PERCENT RISK REDUCTION
ri mil 11 »»ii I. IIY fi-on tin

HIM 1 tifl>
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-------
highest score (14.62) followed by  other effects  (principally
respiratory effects)  at  7.90  or  renal  toxicity  at  6.41.
Other health effects have much lower scores.

     Indicators of overall pollution to the environment from
this plant  are  listed  under  pollution  quantities.   Air,
water or solid waste emissions which lead to health effects
are listed as  "chemicals  of  concern."   Process'water flow
and BOD  in  the  water effluent are listed  as supplementary
indications of the plant's environmental burden.

     Production levels for each process,  the process' capa-
city and  the  resulting capacity  utilization as determined
by the program  are listed next.   Utilization  of less than
100 percent  reflects  shortages  of  chemical intermediates
or, in pollution  constrained cases,  reduced production to
achieve reduced  risk  levels.   All  eleven  process  do  not
appear either  because  they  do  not  appear  in  the  region
(such as processes 1 and 9) or because they  are not econom-
ical to  operate.   Product  sales   are presented in pounds,
by weight * percent,  in dollars,   and  by percent  of total
dollar sales.   Product prices  in  1985  are also listed.

     The control  options  utilized are described next.  The
first type are those  with  a net cost to the firm  either as
a result" of  pollution  restrictions  or  of normal  plant
operations  (such  as  sanitary  landfill  for  all wastes  not
incinerated or  placed in  secure   landfills).   In  the base
case, only  the "2.5  million  pounds  of  waste   that  is_ the
residual from  waste  incineration  is placed   in  sanitary
landfills at  a  net cost  to  the plant.   The  percent  of
process waste  treated of 0.00 percent  actually reflects  a
percentage of  0.001  percent  (the  incineration  residual)
rounded  to  zero.   The second  type  of  control  option is
profitable for  the  plant  and  includes  gas  absorbers  for
process  vents  on process II,  air incinerators  for process
vents on  processes V  and  VII, and  waste  incineration  (at
99.999 percent  rounded  to  100.00 percent)  for  processes
II, III, V, VI, VII  and VIII.

     In  Exhibit  A-5,  operating gross margin net of  capital
charces  is  5543.8 million dollars,  50.49 million  below the
same'figure  for  the base case.  This reflects  the net  cost
of adding nonprofitable pollution  control devices to achieve
a 50  oercent reduction  in  health risk.   The nonprofitable
option costs  include  50.79  million  operating   cost  and  a
50.31 million  capital  charges which are  offset  by 50.63
million  recovery  credit.
                             A-19

-------
     The additional control options selected  to achieve the
50 percent risk  reduction included a  type III (95 percent
emission reduction)  condenser  on  the  storage  vents  of
processes III and  V,  air incinerators on the process vents
of processes  VI  and  X,  and  secure  landfilling  of  1.12
million pounds  of the  hazardous  waste  from process  VII.
All other control  options were  the  same as  those  selected
in the base case.
                             A-20

-------
EXPOSURE ASSESSMENT                              APPENDIX B
     This appendix  describes  the mathematical  models used
to estimate population exposure to concentrations  of pollut-
ants in the air,  surface  water and  ground water.   Whenever
possible/ EPA  exposure  models  and  data  have been  used.
The plan  for   this  appendix  is  to  describe  the approach
used in  air pollution  modeling, water  pollution modeling
and modeling of  ground water  contamination  from migration
of hazardous wastes.
AIR POLLUTION MODELING

     Two EPA air quality models were used -in  th;.s analysis.
The Human Exposure Model (HEM) was used for the chlorinated
solvents plants  and  the  Industrial  Source  Complex Model
(ISCM) was used  for  copper  smelters.  Both of these models
were used to  calculate  annual average concentrations.  The
HEM utilizes a Census Bureau population data base to esti-
mate population  exposure.   The ISCM  was  linked to  the HEM
so population  exposure  in  the vicinity of  copper smelters
could be estimated.

     The HEM was  developed  specifically to model synthetic
organic chemical  plants and  is  designed  to  determine the
population exposed to various  levels of organic chemicals."
* A description of the diffusion equations and auxiliary prc-
  arams is'given in Human Exposure  to Atmospheric Concentra-
  tions of Selected Chemicals,  volume  I,SPA  OAQPS,1980.

-------
The HEM produces two types of  output.   The first output is
a matrix  of  concentration levels  at  points  that  are  the
intersection of the wind  directions  and concentric circles
at varying distances from the point source.   (See Exhibit B-
1. )  The  model  can calculate  concentrations  for distances
as great  as  80  kilometers  from  the  pollution  source.

     The  second output uses the population database to cal-
culate population exposure.  'Using the longitude and latitude
of the  point  source  and the concentration   levels,  the
program calculates  the  population  exposed to  a pollutant.
The output includes a  map of the number  of  people exposed
to the pollutant within  each  "square"  in  the matrix (that
is, in each  "square"  surrounded by  4 points  in the concen-
tration matrix).  There  is  also a table giving a  dozen or
more concentration  levels, the  number of people exposed to
these concentrations, and the dosage received.  Exhibit B-2
is an example of this type of output.

     For  population  groups  out to  2  kilometers  from  the
source, the*EEM determines pollutant  concentration by taking
the population  center  at the nearest  point  in the concen-
tration matrix.   Outside  of   2  kilometers,   the  program
interpolates the  concentration  at   the population  center
from the  surrounding  matrix  points.   The  HEM uses  1978
population levels  which  have  been converted  to 1985 esti-
mates using Census Bureau growth rates.

     The  HEM  uses  a  number  of  standard  values  for input
parameters to  save computing  time.   Exhibit 3-3 lists the
standard  values  used  i'n  the  HEM.   Exhibit  B-4  lists  the
input requirements  for the  HEM.  Most of  this  information
is" available  from  engineering reports  prepared  for  EPA.

     The  HEM assumes flat terrain conditions and as indicated
in Exhibit 3-3 can  take account of photochemical decay.  How-
ever, for the pollutants  of  interest in this study most of
the decay rates were either unknown or  zero.

     The  HEM  has  access  to meteorological  data  from  311
U.S. weather (STAR) stations.  These data include information
on wind  speed,  wind direction and meteorological stability
classes.  These data  are, on  average, the  mean of about 10
years of  weather data  collected  at  STAR  stations  and are
kept on   record  at the  National  Climatic  Center.   Unless
otherwise specified,  the HEM  will  use data  from  the STAR
site closest to the specified  point  source.
                            B-2

-------
                         Exhibit  B-l

                    HUMAN EXPOSURE MODE]
                                                     population
                                                      exposed  to
                                                       specific
                                                        concentration
distance f
    plant
                                                            rom
                                  wind direction
Ambient concentrations are measured at each intersection of
wind direction vector and concentric circles.
                           3-3

-------
                         Exhibit 3-2
Concentration
   (aq/m2)

 1.00 x 10"4

 5.00 x 10~5

 2.50 x 10-5

 1.00 x 10"5

 5.00 x IQ-o

 2.50 x 10~6

 i.OO x 10"6

 5.00 x 10-7

 2.50 x 10~7

 1.00 x ID'7

 5.00 x 10-8

 2.50 x 10~8

 1.42 x 10-8
               EXPOSURE  PER POUND OF EMISSION
                 AT MISSISSIPPI RIVER PLANT
    Cumulative
Population Exposed

          129

          333

          558

         5656

       10,181

       11,965

       20,607

       54,088

      212,861

      947,264

    1,521,227

    1,614,931

    1,615,386
Cumulative
  Dosage

2.16 x ID"2

3.40 x 10-2

4.20 x ID"2

1.23 x 10-1

1.56 x 10-1

1.63 x 10-1

1.74 x 10-1

1.96 x 10-1

2.47 x 10-1
3.52 x 10-1
3.98 x 10-1

4.01 x 10-1

4.01 x 10-1
Source:  PHB Analysis.
                          B-4

-------
                        Exhibit B-3

           HUMAN EXPOSURE MODEL STANDARD VALUES

Wind speed categories:  (m/sec)

     1.50, 2.46, 4.47,  6.93, 9.61, 12.52

Stability classes:

     Daytime:    A, B,  C, D]_

     Nighttime:  D2/ E, F

Decay classes:
                                           Time of Dav
     Class     Description          Daytime       Nighttime

       I       Very Reactive        1.0 x 10~2    5.0 x 10~5

      II    .   Reactive             5.0 x 10~3    5 ..0 x iO"5

     III       Moderately Reactive  5.0 x 10~4        0

      IV       Unreactive               0             0


Downwind distances:

     20 km output: 0.2, 0.3, 0.5, 0.7, 1.0,  2.0,  5.0, 10.0,
                   15.0, 20.0 km.

     80 km output: 0.5, 1.0, 2.0, 5.0, 10.0,  15.0,  20.0,  40.0,
                   60.0, 80.0 km.

Wind directions:

     N, NNE, NE, ENE,  E, ESE, SE, SSE, S, S3W,  SW,  WSW, W,
     WNW, NW, NSW

Effective stack heights:  (meters)

     0.0, 5.0, 10.5,  20.0,  35.0
Source:  ?H3 Analysis.


                          3-5

-------
                        Exhibit 3-4
                 INPUTS REQUIRED TO RUN THE
                    HUMAN EXPOSURE MODEL
Pollutant Name
Facility Identification
     •    Latitude and Longtitude (degrees, minutes, and
          seconds)
     •    STAR Site
     •    Ambient Temperature
     a    Urban or Suburban
     •    Number of Sources of the Pollutant at the Facility
Source Information
     •    Emission Type  (Process Vent, Storage Vent, Fugitiv?
          Emissions, Stack)
     •    Emission Rate  (kg/year)
     •    Stack Height in Meters
     •    Building Cross-Sectional Area  (height x width)
     •    Vertical Stack or Nonvertical Stack/Vent?
     •    Stack Diameter in Meters
     •    Exit Velocity of Emissions
     •    Exit Temperature in Degrees Kelvin
Decay Rates - Daytime/Nighttime
    " (Reaction Rate Constant)
 Source:   PKB  Analysis.
                          3-6

-------
     The ISCM is a more sophisticated dispersion model used
widely by  EPA.   A  complete  description  of this  model  is
provided in  EPA's   Industrial  Source  Complex  Dispersion
Model User's Guide, published in  1979.   The ISCM model was
used for  copper smelters  because smelters  have  very tall
stacks and the  HEM  was not designed to model  sources with
tall stacks.   The  input  requirements  for  the   ISCM  are
similar to those  required  for the HEM.   The ISCM  can take
into account gravitational  settling;  however, no information
was available on deposition  rates for the substances exam-
ined in  the  smelter  study.   The ISCM  was linked  to the
population database of the HEM so the output is produced in
the same format as the HEM's output.

     Information on background levels is needed to determine
actual levels  of air  pollution.   For  the  copper smelrer
study, EPA regional staff provided information on background
levels of  sulfur dioxide and total suspended particulates.
Background data  on  heavy  metals were provided  by  Accurex,
Inc. in a report prepared for this project.*  The EPA Office
of Air Quality  Planning  and  Standards  provided information
on background  levels  of substances  emitted  by chlorinated
solvent plants.
ANALYSIS OF HUMAN EXPOSURE THROUGH
DRINKING WATER AND FISH CONSUMPTION

     Water pollutants  discharged  to the  surface  water may
cause the  contamination  of   drinking  water  supplies  and
supplies of fish.  Also,  in  the  case of  volatile organics,
the chemicals  discharged  into  the  water will  volatilize
into the air  resulting in additional  air emissions.  This
section will  present  the mathematical   formulas  used  to
determine,  for a  single  source,  incremental  human exposure
to toxic chemicals  through drinking water  and  consumption
of fish.   Exposure  from  water  pollutants  that  volatilize
into the air were calculated as described in the section on
air exposure.
   Estimated Arsenic, Lead, Cadmium, and Mercury Levels Con-
   tributed to the Environment 3y Four Nonferrous Smelters:
   Accurex Corporation, June 25, 1981.
                            3-7

-------
     Exposure from  drinking water  has  been  determined by
identifying all  drinking  water intakes downstream  of each
plant together  with the  number  of people  served  by these
intakes.   The incremental  chemical concentrations  at these
intakes arising  from a plant's operations are then derived.
Finally,  it  was assumed  that  each person  would  consume 2
liters of water  from these  supplies each day.

     EPA computer  models  and  computerised  databases  were
not as  readily   available  for  estimating  water  pollution
concentrations as  for  estimating  air pollution  concentra-
tions.  Standard  water quality  models were used  in this
analysis and extensive  effort  was  undertaken to gather the
needed input data.  It  is important to note  the assumptions
underlying the use of these models, specifically:

     •    Steady-state  conditions  are assumed, meaning that
          the polluting material flows into  the waterway at
          a constant rate in time.

     •    Characteristics of the waterway, such as velocity
          and river  flow-  rate, are assumed  to  be  constant
          with respect to time  and  distance  from the pollut-
          ing source.

     •    It is  assumed   that  pollutant  removal processes
          occur  in  accordance  with a  first-order reaction.

     The water quality model equations used  by PHB are dis-
played in  Exhibit B-5.   The  equations developed  estimate
exposure from both water and fish consumption.  The equation
used for estimating surface water  concentrations is adapted
from a recent SPA report.*

     By applying  appropriate  unit  risk  measures  to these
concentrations,   one can estimate the increased incidence of a
certain health  effect  due  to  pollution  from a  specified
source.  For  example,   to  estimate  carcinogenic risk  the
Water Quality Criteria  Documents give  unit risk  factors in
   Falco  et  al.,  "A  Screening Procedure  for Assessing the
   Transport and  Degradation of  Solid Waste  Constituents
   in Subsurface  and Surface Waters,"  to  be  published in
   Proceedings of the Society of  Environmental  Toxicology
   and Chemistrv.
                            B-8

-------
                       Exhibit B-5

             WATER QUALITY MODELING EQUATIONS
                        V(l-HcS)
                                                       (1)
              p.  .  C(xi)j
               = 1
                    jw
                                                       (2)
      f
                       '   i '  ex?  "
                          ^
                                    i-t-kS)
       = P
        •   j  •  v(-k
          Q    - K
                        v(H-kS)    1  - sx?
                                          V(l-fkS) j

                                     for KJ  r 0,  and
    Where:
C(X)
iw
              concentration  of  pollutant j  in  the  surface
              water as  a  function  of downstream  distance
              from the discharge point
       E-J  w = human  exposure  to pollutant  j  from drinking
              water

       E-;  f » human  exposure  through  consumption  of  fish
          •    contaminated by pollutant j

          i » a  drinking  water intake  downstream  of  the
              source

          j •  a   pollutant  for which   exposure   is  being
              calculated

Source:  PHB Analysis.

                            B-9

-------
                        Exhibit 3-5
                        (continued)
         pi = population served by drinking water  intake  i

         Wj = daily mass rate of discharge of pollutant j
              from the source

          Q = median daily flow rate of the river

          V = median velocity of the river

         Xj_ = downstream distance from the source  to drinking
              water intake i

          D = distance from the source to the ocean

         Pp = population exposed through fish consumption
              per unit of distance downstream of the" source

         Kj = a first-order reaction constant for principal
              removal process for pollutant j.   (The predomin-
              and removal process is volatilization for most
              of the pollutants under study.)

          k = sediment/pollutant partition coefficient

          S = suspended sediment concentration
Source:  ?K3 Analysis.
                          3-10

-------
units of risk per  microgram/Liter  (ug/L).   Thus, the total
risk would be equal  to the risk per  ug/L  times the number
of people exposed to various concentrations or:

     Total Risk  =  (Ejw "*" EjF^ ' un^t risk factor

It was found that the risk of cancer from eating  contaminated
fish was negligible in  comparison to the risk associated with
drinking water  consumption.   Furthermore,  subsets  of  the
population which consume much  more  than the  average intake
of fish  were  also  found to have very  low  levels of cancer
risk.

     For other  effects  Clement Associates  provides  risk
factors  in  units of  risk  per  mg/Xg  of  body  weight.   To
convert  to these units  it  has  been  assumed that an average
person weighs 70 kilograms and consumes 2 liters  of water
per day.

     Data regarding drinking  water  intakes and  populations
served were obtained from  EPA's STORET database.  The mass
rate of  discharge  Wj  at typical plants  is determined from
engineering reports.  These rates can  be reduced by appli-
cation of pollution  controls.   Flow rates for rivers were
obtained from  the U.S.  Geological  Survey  {U.S.G.S.)  and
river velocities  were   obtained from  the  U.S.  Army  Corps
of Engineers.   Distances  along the  river were estimated
from U.S.G.S. maps and  from  STORET  data.   The  number  of
persons  exposed  through fish consumption  was  estimated  by
dividing the  amount  of  fish  caught for human  consumption
downstream of the  source by  average fish  intake per person
(assumed to  be  6.5 grams daily  in  accordance with  the
Water Quality  Criteria  Documents).   The  amount   of  fish
caught for  human  consumption  in various  regions  was  ob-
tained   from   Fishery  Statistics  of the  United  States,
1976,  publisheoBytheU.S.DepartmentorCommerce.
Reaction constants  were obtained  from  EPA's   publication
entitled  Water  Related  Fate  of 129 Priority  Pollutants
(EPA 440  1479-029).    Sediment/pollutant  partition  coeffi-
cients were derived from actual water partition  coefficients
for the  pollutants  of  concern.   Data on suspended  sediment
concentrations were obtained from the  U.S.G.S.
                            3-11

-------
GROUND WATER CONTAMINATION FROM
HAZARDOUS WASTE

     The model used in this analysis  to  predict ground water
contamination from landfills  or  lagoons is  based upon work
described in  a  recent EPA paper.*   This  paper describes a
procedure for rapidly  screening  many compounds based upon
their physical  and  chemical  properties  for  potential  to
contaminate subsurface  waters.   A   range  of  estimates  of
the movement  and  persistence  of  specific compounds  is pre-
dicted based  upon a variety  of environmental conditions
that the  compounds  may  experience  at  a   disposal site.
This model is the most uncertain  of  the  exposure  models
used  in  this study due to the fact that little  is  known
about che migration  of contaminants  through  ground  water.
SPA is currently  developing  improved models for predic-ing
movement through  the ground  water.  These  models  may  be
available for use next year.

     The procedure used  in this study involves  three steps:

     o    Estimation of  release rates.

     •    Use of mathematical models to estimate concentra-
          tions as a function of  distance  from  the landfill.

     •    Estimation of  population exposure.

     The first step assumes that an uncontrolled release from
landfills and  lagoons  will occur.   In  the model described
by Falco  et  al,  two categories  of  contaminants, major  and
minor, are  designated.   The  major  contaminant  is  the  one
present in the highest  concentration.   All other contamin-
ants are  designated  as  minor  constituents.   For the major
contaminant,  the  concentration in water  leaching  out of a
disposal site  is  assumed  to  be  equal  to  its  solubility.
Solubility for  all  contaminants  in our  study is  included
   Falco  et al.,  "A  Screening Procedure for Assessing  the
   Transoort and  Degradation  of  Solid  Waste  Constituents
   in Subsurface  and  Surface  Waters,"  to  be published  in
   Proceedings  of  the Society  of  Environmental   Toxicology
   and Chemistry.
                             3-12

-------
in Water Related Environmental Fate of 129 Priority Pollut-
ants.  For all minor contaminants,  the initial concentration
is assumed to  be  the equilibrium concentration obtained by
partitioning between  sorbed  solid phase material  and dis-
solved material.   This  equilibrium concentration  is  based
on the  chemical-specific  "octanol water  partition coeffi-
cient"  (Kow).*

     Recent evidence  indicates  that some  materials  can be
transported through  the ground  as free  flowing liquids and
thus concentrations  could  exceed the  chemical's solubility
in water.  To compensate for this effect  it has been assumed
that the  initial   concentration  for all  contaminants,  not
just the  major contaminants,  leaching  out  of  a  disposal
site is equal  to  the  contaminant's water solubility.

     Once the contaminants  are released,  they  are transported
with ground water movement  and may eventually pollute  drink-
ing water wells.   To estimate  transport,  the procedure as-
sumes steady-state  concentrations  have been  achieved.  Fur-
ther, the  procedure  also  assumes that  the   soil  sorptive
capacity has  been  reached.   Given these,  assumptions,  the
differential equation that defines transport  and degradation
in ground water is:

         d£ _  -k  •  C
         dx       V

     Where:
           dC
           ^x"  =   change in concentration as a function of
                   distance

           C   =   concentration  of the contaminant in
                   ground water

           x   »   distance  from  disposal site

           V   =   velocity of ground water movement

           k   -   rate of  hydrolysis
 *  Kow  is obtained by  mixing the chemical  in a  container
   of two phases,  water and  octanol.   The   ratio  of  the
   chemical dissolved  in the octanol phase to the chemical
   dissolved  in  the water phase  is the Kow.
                            B-13

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     The solution to  this equation  is:

           C_  -  exp ,-k  •  *,


     Where:

          C0   =   the  initial concentration, i.e.,  the  con-
                  taminant's  water  solubility

          £_   =   the  fractional  concentration  at  a  distance
          Co      x  from  the  disposal site.


     In PHB's  analysis, hydrolysis is assumed to be  the only
 degradation process.   Also,  a  typical  ground water  movement
 velocity of 10 meters per  year is  assumed.

     Along with  hydrolysis,  dilution  is  another important
 process for  lowering  ground water  concentrations.  It  is
 assumed that  the  contaminants  will migrate  in  the direction
 of  ground water flow.  Without site specific information one
 does not know  the direction of  ground water flow nor  the mag-
 nitude of dilution.  Concentration in  ground water  when di-
 lution and degradation are taken into account is as  follows:

           c   *   Df9  ' Co  '  exP "* '  f

     Where:

         Dfg  =  dilution factor for diffusion  angle S.

      In the model it  is assumed that the contaminant will mix
 uniformly over a wedge  with an angle  of & on  its  face and
'side.  The model also assumes  that the maximum mixing depth
 beneath the surface is 500 meters.   Dilution after a certain
 distance  (x)  from  the disposal  site  is proportional to the
 volume of  the landfill divided  by the volume   of the  wedge
 underneath  the surface  at  distance x.   (See   Figure  3-1. )
                             S-14

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                         Figure 3-1

                     DILUTION GEOMETRY
     Landfill
     The equations  which  describe the dilution  factor are
presented in Exhibit B-6.

     Exhibit B-7 indicates the value of the dilution factor
for a given  set of input parameters and  for various diffusion
angles.  The  figure' indicates  as  the angle  of diffusion
decreases the concentration  increases.  In  this study ?H3
used a dilution angle of 2.8125-degrees so  that ground water
pollution would not be underestimated and because this dilu-
tion angle more closely approximates concentration profiles
given in the  literature.   Finally,  ground  water concentra-
tions are  estimated only  to a  distance  of  10  kilometers
*rom the  disposal  site.   At  the assumed  velocity of  10
meters per  year,   it would take  1000  years  to  migrate 10
kilometers.

     The first  two  steps  provide a procedure  for roughly
estimating  concentrations  "at  various  distances  from the
disposal site.   In  the analysis it  is   assumed  that the
hazardous waste  not incinerated  would be  disposed  of  in  a
sanitary landfill   on  site  at  the plant.   The  number _ of
oeoole exposed  to  contaminated ground water is  a  function
of  the  number of  people  who drink well water  in the  area
o-  interest.   EPA  provided  data on  the   number of people
who drink  ground water  in each  county in which the plants
of  interest  are   located.    Assuming  this   population  is
uniforalv distributed   within each  county  the   number of
oeoole at  varving  distances  from the  plant  can be calcu-
lat»d.   It  is"  also assumed  that no  drinking water  weu-ls
would  be  located  within  300 meters of  the disposal  site.
For a  2.8125 dilution  angle,  the number  of  people  exposed
to  contaminated drinking water  is assumed  to be:
                            B-15

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                       Exhibit B-6
                DILUTION FACTOR EQUATIONS
                W
Df° =  w + H*3 - -5I3
                                       for  (R < r)
                                       for  (r  < R < R'/TANS)
                                              — *
Where:
     W
     r

     d
    w/d
     x
     R
 rTR3/S3

      Sg
                                             R'
                                       for  (TANS 1
              =   volume  of hazardous waste  from  the  plant
              = — . /~"'w  a radius of  landfill
                 V  77d
              =   depth of landfill  (assumed  to be  5  meters)
              =   surface area  of  landfill
              =   distance from boundary  of  landfill
              =   r  + x   = distance  from  center of  landfill
              =   360/9
              «   surface area  of  dilution wedge  of angle  3
              -   wedge  volume  for diffusion of 9 degrees  in
                 XY and  YZ planes
              *   proportionality  constant which  depends on
                 angle  of diffusion
          R1   »  maximum depth of diffusion below surface,
                 assumed to be 500 meters
      R TA2JS   =  depth of diffusion below surface at dis-
                 tance R from center of landfill
                                                                  -i
Source:  PH3 Analysis
                           3-16

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                          Exhibit B-7

                DILUTION: ANGLE SENSITIVITY

                        W = 100,000 M3
                        d - 5 meters
                        r = 80 meters
                 Distance  From Landfill Center  (m)
             22.5 degrees
             11.25 degrees
             5.525 degrees
             2.3125  degress
Source:

-------
             ££.,  ,             9N
     P(R) .  12g f R2 - (300 + r) 2 J       for (3 >_ 300 + r)

     Where:  ?{R) = the  number  of  people  drinking  well
                    water at distance R.

                P - the average number of  people  per unit
                    area who drink well water in the vicin-
                    ity of the plant.

                r = radius of landfill

     The exposure  is   found  by multiplying  the number  of
people exposed at a given distance times the concentration
at that distance.

     The method  described above  is  the most  uncertain  of
the exposure models  used in  this  effort,  due  to  the fact
that little is  currently known about movement of  contaminants
through ground water.  In view of this, it  is  important to
keep several limitations  in mind:

     1.   The model does  not take  into account  the  time it
          takes  for the contaminant to migrate to the ground.
          water  (i.e.,  the  model   is   in   steady  state).

     2.   The model considers hydrolysis as  the only degra-
          dation process.  Other processes could be consid-
          ered if"  significant evidence  of  occurrence war-
          ranted.

     3.   The model assumes  uniform mixing in  a  wedged
          shape  volume.   Dilution of the  contaminant  as  a
          function of  distance  is proportional to the vol-
          ume of the wedge.

     4.   The model assumes  that  the contaminant  is trans-
          ported as  a dissolved  solute in  water.   Recent
          evidence has indicated  that   in  some situations
          solvents can be  transported   as   a  free  flowing
          liquid.  Thus,  concentrations  in ground water  may
          exceed their water solubility.

     5.   The model is  not   applicable  for transport  of
           trace  metals.

     6.    Site specific   information on  hydrogeology,  loca-
           tion of  wells   relative  to  disposal  sites  and so
           forth  are not  included  in  the  model.
                             B-18

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     Finally, PHB has assumed zero  risk when hazardous waste
is disposed of in a secure landfill.


ESTIMATION OF MAXIMUM INDIVIDUAL RISK

     The methods described in this  appendix have been used to
estimate aggregate  exposure  levels.   When  these  exposure
levels are combined with  information on dose-response rela-
tionships, total population  risk can be estimated.

     Regulatory authorities  are  often  concerned with indi-
vidual risk  levels  as well  as  aggregate  risk  levels.  PHB
has estimated  maximum individual  risk levels  for a large
chlorinated  solvent  plant  which  is   located   in  the most
densely populated  area  in  one  of  the  three  regions.  For
this analysis only  cancer risk was considered.

     The approach  adopted  examined  the  exposure  pattern
(i e   the"distribution of concentrations) of each pollutant
emitte^ '^om the  plant.   An example air  pollution exposure
pattern for  one pound of pollutant was provided  in Exhibit
3-2.   R1'sks  from exposure  to  water • pollution  were  ignored
in this"approach because the risks are very  small compared
to air pollution  and they are incurred by different popula-
tion  subgroups.

      By applying the CAG unit risk factors to the air expo-
su-e  pattern,  the risk  to  each  population subgroup  can  be
calculated.   For the particular plant  examined, six carcin-
oaenic pollutants are emitted and the  risks  were summed  to
comoute" the total  risk  to  each  population  subgroup._   The
results  for uncontrolled plant  operations  are  shown in the
 figure below.

                          Figure B-2

                   MAXIMUM INDIVIDUAL RISK


                                   Annual Individual
         Persons                      Cancer Risk

             96                       10-4 to 10~5
           1490
                                     10~5 to 10~6
                              3-19

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PROCEDURES FOR ESTIMATING
HEALTH RISK                       	APPENDIX C
     ?HB asked  Clement  Associates,  Inc. to  develop  an ap-
proach for  estimating  the  risks associated  with exposure
to pollutants which are released during copper smelting and
in the manufacture  of  chlorinated  solvents.  For  each of
these pollutants  the  following  eight health  effects  have
been evaluated:

     •    Carcinogenicity,

     •    Teratogenicity,

     •    Reproductive  tcxicity,

     •    Mutagenicity,

     •    Hepatotoxicity,

     •    Renal toxicity,

     •    Neurobehavioral toxicity, and

     •    Toxic effects on other organ systems.

     In  implementing  their  approach Clement has used  crude
linear dose-response  models to  estimate  incidence.   These
models have not gained acceptance for  low dose  extrapolation
for effects other than cancer.  In the absence  of better un-
derstanding of  dose-response  relationships   at  low   dose
levels,  it  cannot be claimed  that  these  models provide an
absolute measure  of risk.  Review  and further development

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of this  technique  by  EPA  should  improve  the predictive
value of these models.

     The next section of this  appendix describes the Clement
approach in detail.   Following this section  is an example
of the application of the approach  to a specific pollutant.
Clement has prepared  a  short  paper on  each pollutant which
summarizes the basis  for estimating health risks.  Because
of the volume of this material only one example  is included
in this appendix.   A  copy of  this material may be obtained
directly from Clement Associates or from EPA.

     It should be noted  that whenever CAG unit  risk factors
were available,  they were  used  by PHB  in  place of  the
Clement estimates.   In  almost all  cases the  CAG unit risk
factors and the Clement  estimates are comparable.  Further,
in the case of respiratory effects  associated with exposure
to sulfur  dioxide  SPA  supplied  a risk function  which  was
used rather than Clement's estimate.

     The Clement estimates when  combined  with the exposure
estimates described in Appendix B provide an overall measure
of health risk to  the exposed human population.  For example,
if the probability  of  occurrence of health  effect  i from
pollutant j at  concentration  C^  is denoted  by the Clement
score SCCfcl^j, then  the overall measure of  risk of health
effect i from pollutant  j is defined as follows:

                  I pj(cV • s«Vij


Where Pj(C^) "is the population exposed  to each concentration
of pollutant j.

     Summing over all pollutants — over the  j  subscript —
provides an estimate  of  the  overall  measures  of  risk  of
health effect i.  This  can be defined as:

                I  I  PtC)  • StC)
                          C-2

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TOXICS INTEGRATION PROGRAM SCORING OF
SELECTED POLLUTANTS FOR RELATIVE RISK
                                Prepared by:
                                Clement Associates, Inc.
                                1010 Wisconsin Avenue, N.W.
                                Washington, D.C.  20007
                                June 26, 1981
                                C-3

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INTRODUCTION
     At the  request of  Putnam,  Hayes  &  Bartlett,  Clement
Associates has evaluated 41 water and/or air pollutants for
carcinogenicity, teratogenicity, reproductive toxicity, mu-
tagenicity, hepatotoxicity, renal toxicity, neurobehavioral
toxicity and  toxic effects  on  other organ  systems.   The
chemicals evaluated are shown below.
           CHEMICALS SCORED FOR TOXIC EFFECTS
     Arsenic
     Benzene
     Bis(2-ethylhexyl) phthalate
     N-Butyl chloride
     Cadmium
     Carbon tetrachloride
     Chloroform
     2-Chlorophenol
     Chromium
     Di-n-butyl phthalate
     1,1,Dichloroe thane
     2,4-Dichlorophenol
     1,3-Dichloropropene
     Ethane
     Ethyl chloride
     Ethylene
     Ethylene dichloride
     Fluorene
     Hexachlorobenzene
     Hexachlorobutadiene
     Hexachloroethane
Lead
Mercury
Methanol
Methyl chloride
Methyl Ether
Methylene chloride
Monochloroace tylene
Nickel
Phenol
Propane
Sulfur dioxide
Tetrachloroethylene
Total Suspended Particulates
Trans/cis-dichloroethylene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
2,4,6-Trichloro?henol
Vinyl chloride
Vinylidene chloride
Using a semiquantitative  method  for relative risk ranking,
Clement assessed the strength of the available evidence for
each of the 41 chemicals  and estimated the relative  likeli-
hood that each chemical  is a human toxicant.  Where suffi-
cient data existed, an estimate was also made of  the proba-
bility that  a given  toxic  effect will  occur  in  exposed
humans per unit dose  of  exposure.   It. should be  emphasized
that this procedure is intended only for  the  purpose  of rel-
ative risk ranking of the  41 chemicals, and  cannot be used
to estimate how many  members of the exposed population are
at risk or  to estimate the  risk  to an exposed  individual.
                              C-4

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OUTLINE OF METHOD

1.   For each pollutant, Clement provides a score   (S) that
     represents the  probability  that  a  given  hazard will
     occur in exposed human populations.

2.   The effects that are scored are carcinogenicity, tera-
     togenicity, reproductive toxicity, mutagenicity, hepa-
     totoxicity, renal  toxicity,  neurobehavioral toxicity,
     and effects  in  other  organ  systems.   A  score  (S)  Is
     assigned for each  of these  forms  of toxicity for each
     pollutant.

3.   Clement did not use data from the  primary  literature
     to score these  pollutants.   Scoring was  based  solely
     on toxicity  data  provided in  EPA and  NIOSH  criteria
     documents, in IARC and NAS reviews, and in a few other
     readily available  secondary  sources.   Thus, the scor-
     ing system accommodates the  fact that secondary litera-
     ture often does not contain complete information, espe-
     cially on  dose—response  relations.   All  conclusions
     regarding toxicity  and  risks  are  thus  necessarily
     limited.

4.   The score S is a product of two measures of risk:

     T = probability that the pollutant is toxic to humans,
         based on inferences  from  animal data or on  direct
         measures of human toxicity.

     P = probability of occurrence  of the  toxic effect in
         exposed humans, assuming that the agent is a human
         toxicant.

5.   The score T is a function of the strength of scientif-
     ic evidence that a given pollutant  is  capable of pro-
     ducing toxic  effects  in humans.   It  is   derived  by
     considering evidence from human  studies,  animal stud-
     ies, and,  in  some  cases,  from in  vitro  studies.   It
     is also  based  on  knowledge  regarding  the  predictive
     power of animal and in vitro tests.  For toxic effects
     other than  carcinogenicity,  when the  value of  T  has
     a maximum value of 0.95, since even very strong  animal
     data may not  be 100% predictive  for humans for these
     effects.  It is not a measure of the absolute probabil-
     ity of human hazard.  No  such  absolute  measure can be
     defined.
                               C-5

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The score P takes one of three possible forms, depend-
ing on the nature of the hazard being scored:

a)   For carcinogens:

     P = risk per  unit dose of  carcinogen, and  it is
         taken directly  from  EPA assessments  of  car-
         cinogenic risk, times X (actual human  exposure-
         in mg/kg of body weight)

b)   For pollutants exhibiting other forms of  toxicity
     and yielding dichotomous responses:

     P » I/MED • X

     where

     I = observed incidence of effects  above  the con-
         trol incidence  at  the  minimum effective dose
         (MED)

     X = actual  human exposure in mg/kg of body weight

     It will be  assumed  that this  measure of  risk ap-
     plies everywhere  on the dose-response  curve for
     the pollutant.   Because  such  an assumption  is
     needed, it  cannot  be claimed  that ? is  an  abso-
     lute measure of  risk per  unit dose; however,  it
     is likely  that application  of this  approach  to
     all the pollutants  being  scored  will  lead  to   a
     ranking that  places the pollutants  in the  order
     of their  relative   risks.   No methods  have  been
     developed for  treating  dichotomous  dose-response
     data other  than carcinogenicity  for purposes  of
     estimating  risk  per  unit  dose   at   low doses.
     Presumably, the  method  used  to  treat  carcinoge-
     nicity  could also be adapted  to other  dichotoraous
     toxicity data.   However,  to  do  so  would  have
     required a  significant  development  effort, and
     could not  have  been accomplished within  the con-
     straints imposed on this contract, not the  least
     of which  was the  restriction on  use  of primary
     sources.  The  measure  I/MED  is  a   rough   first
     approximation of  the risk  per unit  dose of low
     doses,  and  at  least permits a  relative  risk  rank-
     ing.
                      C-6

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c)   For toxic agents giving rise to a graded response,
     ? is estimated as follows:

     1)   It is assumed that  if humans are exposed at
          the NOEL  or  MED for test  animals,  close to
          the entire population will  be affected.  Tra-
          ditionally, toxicologists  have  assumed .that
          the general population  is  likely to be more
          sensitive to toxic agents  than  a given test
          animal population.  Thus,  test  animal NOELs
          are considered insufficiently low to protect
          human health, and these NOELs are divided by
          safety factors  (see  below) to yield accept-
          able levels of  human  exposure.   Although it
          is far  from certain  that  most members  of
          the human  population  will  be affected at a
          test animal NOEL, such  an  assumption can be
          used in  the present  situation  because the
          purpose is  only  to  estimate relative  risks.
          Thus, all  compounds  rated will  be assumed
          to produce adverse effects in the same frac-
          tion of  an exposed human  population  (i.e.,
          near 100%),  when human  exposure is  at the
          test animal NOEL.-

               The use  of MED  is confined to   situa-
          tions in  which  an experimental  NOEL  is not
          available.  If  the MED  is  truly a  "minimum"
          effect dose, then it  should approximate the
          NOEL.

     2)   It is assumed that if  humans are exposed at
          specified fractions of  the NOEL or MED for
          test animals, no  significant  number of per-
          sons will  be  affected.   The denominator (f)
          of those  fractions depends on  the source of
          data from  which the NOEL  or MED  is  taken:

          a)   If the NOEL or MED is derived  from chron-
               ic studies, f = 100

          b)   If the NOEL or MED is derived  from sub-
               chronic  studies, f « 1,000

          c)   If the NOEL or MED is derived  from con-
               trolled studies of human exposure, f = 10
                          C-7

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     These values of f represent  the traditional safety
     factors used  in  toxicology to  assign acceptable
     human exposure levels for toxic agents  (NAS 1980) .
     Although their application  does not  ensure  that
     the derived exposure  level  is below  a threshold
     for the  entire  human population,  experience has
     shown that there  is  a high  probability that this
     is the  case.   Use of  such  an assumption  in the
     present scheme provides  consistency with current
     methods of toxicologicai  science  used  to assign
     acceptable intakes of agents giving rise to graded
     toxic effects.

3)   It is further assumed that at dose  levels between
     the NOEL (or MED) and the NOEL/f,  the probability
     that an  exposed  population  is above  a threshold
     is directly proportion to the dose.

          Thus, ? for pollutants causing  graded  toxic
     responses is given as follows:
     where

          X - the  actual  human exposure  in rag/kg of
              body weight

     NOTE:   If NOELs are not available,  MEDs will be
     used in the  above  formula.   It should  be  noted
     that this formulation  leads  not to relative risk
     per unit  dose,  but  to  the relative  risk  (i.e.,
     the actual exposure  (X)  is included in the above
     formula).  It again  must  be  emphasized  that this
     method yields,  at  best,  a relative risk ranking,
     and cannot  be  used  to  estimate  actual  risk.

If certain  toxic effects   (e.g., respiratory effects)
were thought to be  related  to  route of exposure, then
toxicity data  reflecting  only  the   relevant  route  of
exposure were  used  to score a  pollutant.   Otherwise,
all routes  of exposure  were  considered  relevant  to
risk assessment.
                           C-8

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8.   Where both acute and chronic effects of a given pollu-
     tant exist in  a  single organ  system,  the  scoring was
     based on the chronic effects because they are considered
     to be more relevant to human exposure to environmental
     pollutants.
DISCUSSION

Elimination of Certain
Compounds from Scoring

     Health effects scoring  was  not done for ethane, ethy-
lene, fluorene,  and  monochloroacetylene because  it  is  un-
likely that any  of these  compounds could be present in the
environment in quantities that could adversely affect human
health or environmental quality.

     Ethane and ethylene are hydrocarbon gases that for all
practical purposes  are  biologically  inert  (Patty  1963).
These two compounds  cause no  known systemic toxic effects
until they reach  sufficient  concentrations to exclude oxy-
gen, in which  case  the signs  and  symptoms of intoxication
are those of  oxygen  deprivation.   It  is  implausible that
either compound could be present in the open environment at
levels sufficient to exclude oxygen.

     Fluorene is  a   compound  whose toxicity  is  not  well
studied.  The 1979 NIOSH Registry of Toxic  Effects of Chemi-
cal Substances reports an oral LD$Q in rats of 5,000 mg/kg.
Fluorene is probably narcotic at higher vapor concentrations
but its systemic  toxicity is expected to be low.   It is un-
likely to pose any  significant threat  of impairment at the
concentration that might be expected in  the  open environment.

     Monochloroacetylene is not listed in chemical diction-
aries or  in  any  standard toxicology  resources.   The 40th
edition of The Handbook  of  Chemistry and Physics  describes
it as  an "unstable,  spontaneously  inflammable  gas."   It
appears that if  monochloroacetylene were released into the
environment it would  be immediately transformed  into some
other substance or substances.
                                 C-9

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Limitations in Scoring

     The development of a biologically meaningful procedure
for estimating the  probability  of adverse human health ef-
fects (i.e.,  the  risk)  due  "to  exposure  to  chemicals   is
beset with difficulties and scientific uncertainties.  Data
obtained from experimental studies in animals and from epid-
emiological investigations  in humans are  used  as  evidence
in describing the  nature  and extent of  chemically  induced
adverse health effects.  Using such data,  it  is not possible
simply to categorize chemicals  as  either toxic or nontoxic.
It is most unfortunate that toxicity  is not  recognized as a
concept rather than a finite event easily measured.   Accord-
ingly, risk and,  therefore,  safety  are  relative concepts.
Procedures for risk assessment  and safety  evaluation of po-
tentially toxic  chemicals are confounded  by poorly  defined
toxicological principles.  Moreover,  content'and quality  of
tcxicological information is  often quite  variable,   and the
interpretation of  a  study's  results  is   often  equivocal.

     As with  all  approaches  of  the type  used here,  the
method developed by Clement has inherent weaknesses  and un-
certainties, which include:

     1.   Lack of quantitative  data  for  some of the pollu-
          tants  that were scored

     2.   Inability to extrapolate the results of  in vitro
          mutagenicity studies  to humans

     3.   Utilization of arbitrary   (although traditionally
          used)  safety  factors  for  effects  having  graded
          responses

     4.   Unknown but  likely   interspecies  differences  in
          absorption, metabolism,  pharmacokinetics,  and ex-
          cretion.

     In addition, the system  penalizes those compounds that
have been the  most extensively studied relative to compounds
for which little or no health effects data exist (i.e., un-
tested is not "safer").  These weaknesses and uncertainties
are discussed in detail.

     An integral part of this  project was  to  provide  a quan-
titative measure of  the relative  probability of  occurrence
of toxic effects  in  exposed humans per unit dose cf exposure.
                          C-10

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Because of  the  time  and  resource  limitations   for  this
project, it was not possible to identify, acquire, and cri-
tically evaluate  primary literature  resources  for each of
the pollutants.  Therefore, the toxicity profiles were pri-
marily based  on  data reported  in  the IARC  monographs, HAS
reviews, EPA  water  quality criteria  documents  and  NIOSH
criteria documents.   The extent  and  validity  of the data
reported in these secondary sources were a major  limitation
in assigning ?-values for each of  the toxic endpoints eval-
uated.  The qualitative  nature  of the data  from the secon-
dary sources posed a major  problem.   In many cases detailed
quantitative data  on the  compounds  of interest  were not
available.  An  additional  problem  posed   by   the use  of
secondary literature  sources  was  their emphasis  on a pre-
dominant effect or route of exposure.  The EPA  water crite-
ria documents  emphasize  carcinogenicity and   acute  toxic
effects.  The  NIO*SH  criteria  documents emphasize  the  inha-
lation and dermal  routes of exposure, and primarily report
on effects to  the principle target organs.

     In Clement's  method for  determining  the  strength of
evidence for  a given toxic endpoinn, those compounds  that
have been  extensively studied are penalized  when they are
compared to compounds for which  there is a paucity of data.
In the absence of empirical data  for  a given toxic endpoint
for a  compound,  Clement  has  arbitrarily  elected  not to
apply some minimum scoring  factor for the  effect and has
applied a  score  of  0 when  an effect  has not been studied.
However, Clement  is  not  assuming  that the compound does not
produce that  effect.  Rather, Clement assumes that there is
too much  uncertainty to  estimate  a  scoring  factor in the
absence of empirical data that would be biologically meaning-
ful and scientifically  justifiable.

     Ideally,  the probability of  exposure to multiple  toxic
compounds  requires a consideration of their  interacting ef-
fects.  Concurrent exposures  may  alter  the rates  of absorp-
tion, metabolism, or excretion  of  one or more of  the inter-
acting  chemicals.   The  biological effects  resulting   from
multiple exposure  may be altered,  with responses  equal to,
greater than,  or less than  the  sum of effects  of  the  indi-
vidual  chemicals.  While Clement is aware that potentiation,
 interactive  effects,  the state-of-the-art is not sufficient-
 ly developed to allow for this.   Very few studies  have  been
                               C-ll

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performed to  investigate interactive  effects  in  low-dose,
chronic experiments.

     The use of safety factors is a crude  form of extrapola-
tion.  The  no-observed-effect level  (NOEL)  is  divided by
some safety  factor,  e.g.,  100,  to  arrive at an acceptable
exposure level  in  humans.   Application of a safety factor
assumes that the factor used reduces the risk  to  a negligible
level.  The  shortcomings of  safety  factors are  obvious.
They are chosen  arbitrarily,  and do not reflect the sensi-
tivity of the  measurement  used to derive the NOEL nor the
relevance of the animal data  to  the biological  response in
humans.  In  addition,   since  the NOEL  is by definition  a
likely subthreshold  dose  level,  safety   factors   are  not
applicable for agents producing nonthreshold  effects.  Math-
ematical models  exist  for  estimating risks  associated  with
dichotomous responses,  such  as  cancer.    Because  graded
responses are  difficult to   quantify,  safety  factors  are
applied in determining  risks  associated with certain types
of biological  responses.  While  the safety  factor  approach
has several substantial limitations,  it is  the traditional
method used by regulatory  agencies to- account  for possible
inter-species  differences  in  susceptibility,  for  uncer-
tanties inherent in  animal  testing due to biological vari-
ability, and  for the  limited number of  test  animals  that
can practically be used (NAS 1980).  No single safety factor
margin has been  designated  as a  universal standard for all
chemicals.  With  experience  a  reasonable range  of safety
factors has  emerged  in regulatory  toxicology and  these
safety factors has  emerged   in  regulatory  toxicology  and
these"safety factors were the ones chosen by Clement.   How-
ever, as  pointed  out  above,  the  choice  of  such safety
factors is  without a  systematic scientific  basis and in-
troduces uncertainty  as to the  true  risk  associated  with
exposure to a  given chemical.

     Uncertainties exist in both  the  low-dose extrapolation
procedures used by Clement, and  in the extensions  of extra-
polated results  to humans.   The  extension of dose-response
data obtained  from animals  to humans  poses two  different
problems:  the estimation  of species  sensitivity  and the
estimation of  appropriate  "scaling11   factors   (conversion
factors for  extrapolation  of animal data to  humans,   such
as body  weight,  surface  area,   metabolic  rate,  and   life
expectancy).   There  is  a paucity  of  data  on  the  concordance
between the  doses  effective  in  humans  and doses  effective
in the most  sensitive  animal species.  Clement has assumed
                             C-12

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that for all toxic endpoints, humans are the most sensitive
animal species,  although empirically  this  may  not  be the
case.  In the absence of empirical data we have  arbitrarily
applied safety factors to the data.

     An additional  source  of  uncertainty  is  interspecies
and intraspecies differences in the absorption,  metabolism,
pharmacokinetics, and  excretion  of  chemicals.   These dif-
ferences may be  both quantitative and qualitative and may
be influenced  by the exposure conditions,  dose  level, and
the presence of  one  or more interactive chemicals.  Intra-
species differences have been extensively documented in the
literature.  In  addition,  there  may be  special  subpopula-
tions with  increased sensitivity  for  a  particular effect
due to exposure  to a given chemical  (NAS 1930).

     The importance of interspecies differences  was evident
in methanol, one of  the  chemicals  studied.   There are sig-
nificant qualitative  differences  in  the  metabolism  and
quantitative differences in the excretion kinetics of meth-
anol given  to  nonprimate versus primate  species.  Because
of these differences  nonprimates  are  not considered  to be
an appropriate model  for the toxic  effects  of methanol in
humans.  It is not  known whether this  is the  case for the
other chemicals  evaluated  by Clement.    In  this  absence of
empirical data,  such  differences  must  be  considered  an
imporcant uncertainty factor.

     One of the major uncertainties in this project was the
extension of the results of mutagenicity  tests  to humans.
Mutagenicity tests include,  but  are  not limited to, assays
for induction or repair  of  DNA damage; mutagenesis  in bac-
teria, yeast,  or Drosophila  melanoqaster;   mutagenesis in
mammalian somatic cells;  mutagenesis  in mammalian germinal
cells; and tests for neoplastic transformation of mammalian
cells in culture.   Evidence is also acquired  from studies
in whole  animals and  from  data  showing  damage  to  human
chromosomes.  The validity  of extrapolating such  data to
predict human  mutagenic  risk is not  established, and this
adds further uncertainty  to  the  risk assessment procedure.

     Clement has  been  unable  to  devise  a  procedure  than
allows for  the  extension of  results   obtained in  in  vitro
svstems to humans.  For  compounds that have been tested for
mutagenic activity  in  an  in  vivo  mammalian  test  system
                             C-13

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(e.g., heritable translocation assay, dominant lethal test,
sperm abnormality test), P-values have been calculated when
quantitative data are available in the secondary literature.
However, for compounds  assayed  only in  an in vitro system,
Clement cannot, at  this time,  calculate the probability of
a mutagenic effect in exposed  humans per unit dose of expos-
ure.
CONCLUSION

     Given the  above  limitations, the claims  made for the
scoring system  must be  limited.   Thus,  it yields at best a
relative measure  of  risk for the  41  compounds scored.  It
cannot be used  to estimate actual risk.

     Nevertheless, while there are weaknesses in  the system,
the underlying  concept represents an ideal goal for assess-
ment of  risks  from exposure  to  toxic  substances.  Further
development work  should  allow imDroveraents  in raanv areas.
                              C-14

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                          REFERENCES

 INTERNATIONAL AGENCY  FOR RESEARCH ON CANCER  (IARC).   1980.
 An evaluation  of chemicals  and  industrial processes  asso-
 ciated with  cancer  in  humans  based  on human  and  animal
 data:  IARC  Monographs,  Volumes 1-20.  Cancer Res.  40:1-12

 NATIONAL ACADEMY  OF  SCIENCES (NAS).   1980.   Drinking  Water
 and Health.  Washington, D.  C.

 PATTY, F.  A.   1963.   Industrial  Hygiene  and  Toxicology.
.2nd ed.  Interscience  Publishers, New York
                             C-15

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CHEMICAL:  ARSENIC

     Arsenic is  a human carcinogen  causing  skin cancer in
persons exposed  to  inorganic  arsenic through drugs, drink-
ing water,  and  pesticides.   Lung cancer has  been shown to
result from  exposure   to  airborne  arsenic  compounds  in
pesticide manufacture  in smelter  workers.   Cancer  of the
liver has  also   been  associated  with  occupational  arsenic
exposure.

     The evidence  that  arsenic  is  rautagenic  is equivocal
but strongly suggestive.  Inorganic arsenic compounds cause
terata and  other adverse  reproductive effects  in  animals
and the  evidence  is   strongly  suggestive  that  it  causes
similar effects  in humans.

     Arsenic also  causes noncancerous skin  lesions  and is
neurotoxic.
                              C-16

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SUMMARY OF EVIDENCE FOR CARCINOGENICITY

     Arsenic (As) in the drinking watar has been correlated
with skin  cancer in a village  in  Taiwan;  the incidence of
cancer at water concentrations less than 0.29  ppm  (0.008 ing/
kg/day) was  2.6  per 1,000  residents,  21.4 at  0.60 ppm or
less (0.017  mg/kg/day)  (Tseng  1977,  as  reported  bv USEPA
1980).

     IARC  (1980)  has  concluded that  there  is sufficient
evidence that inorganic arsenic compounds  are skin  and lung
carcinogens  in humans.

     The value for  ?  15.94 x  10~3 (ug/m3)-l]  j_s taken from
an assessment  of risk  for respiratory  cancer  in workers
exposed to arsenic atmospheres; the calculation is  based on
epidemiology studies  (Clement 1980).
T = 1.0

P « 27.8  (isgAg/day)"1  •  X
                          C-17

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SUMMARY 0? EVIDENCE FOR MUTAGENICITY

     There is substantial evidence that exposure to arsenic
compounds either  in  an  occupational  setting or  via drug
products is  correlated  with  an  increased  incidence  of
chromosomal aberrations  in  humans  (IARC 1980, USEPA  1980).
However, in no  case was  a quantitative dose-response rela-
tionship shown.   Many  of  these  reports  also  showed  the
presence of confounding  factors  such as cigarette smoking,
X-ray exposure,  other  metals,  and   treatment   with  other
drugs.

     In bacterial systems,  sodium arsenite caused mutations
in Sscherichia  coli WP2  and Bacillus  subtilis,  but  not in
Salmonella (Ames  test)  (Nishioka  1975, Kada  et  al.,  1980,
Lofroth 197S;  as  reported  by IARC  1980).   Arsenate  was
also negative  in  the  Ames test and positive  in  the B. sub-
tilis system  (Lofroth 1978, .Kada et  al.  1980;  as reported
by IARC 1980).   Both  arsenite and arsenate induced chromo-
somal aberrations   in  cultured  mammalian  cells including
human lymphocytes  (Oppenhim 1965,  Paton  1972;  as reported
by IARC'1980)".

     Administration of 10 or 100  mg/liter  of sodium arsenite
in drinking water in rats caused a slight increase in chromo-
somal aberrations  in mouse  bone marrow cells,   but arsenic
was not active  in dominant lethal  assays  in mice at  levels
of 100 mg/liter in  drinking water or  at oral  doses of 0.25,
0.5, and 1 mg/kg (Sram 1976, Gencik et al.  1977;  as reported
by IARC 1980).

     The evidence  for mutagenesis of arsenic is equivocal
but strongly  suggestive.   The T-value for this  effect  is
0.55.  P  is  calculated  assuming an  incidence of 1 percent
(0.01) at an MED of 10 ing/liter of sodium arsenite in  drink-
ing water, equivalent to 1.37 mgAg/day as  elemental arsenic.
T = 0.55

? = 7.30 x  10~3
                           C-18

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SUMMARY OF EVIDENCE FOR TERATOGENICITY

     An epidemiology  study  indicated  that  there  was  an
increased incidence of multiple malformations  among children
born to women who worked at a smelter compared to women who
lived in the area, but did  not work at the smelter.  Arsenic,
however, was  only one  of  several  "potentially  genotoxic"
agents present and no exposure  levels were given (Nordstrom
1978 a, b, c, and d; as reported by IARC 1980).

     In animal studies, various arsenic  compounds have been
shown to be teratogenic in a number of different species by
various routes  (IARC  1980,   USEPA  1980).    The  following
table is compiled from reports  in IARC 1980 and USEPA 1980.
                                        Dose
 Soecies   Route
Compound
Author
 Chicken   Egg          Unspecified  Unspecified  Farm 1977
            injection
 Golden    IV or I?   Sodium arsenate   15-25
  hamster
                          Fenti 1977
Mouse
.Mouse
Mouse
Rat
Rat
I?
IP
IP
IP
I?
Sodium
Sodium
Sodium
Sodium
Sodium
arsenate
arsenate
arsenate
arsenate
arsenate
45
10-12
40
20-40
45
Hood 1972
Hood 1972
Hood 1978
3eaudoin
1974
Burk 1977
     In neither secondary reference were incidences of mal-
formations reported,  nor was  there a NOEL  for teratogenesis
given in any of the studies.  For the purpose of calculating
?, the MED  is  10  mgAg of  sodium arsenite,  assuming an  in-
cidence of  malformations   of   10  percent   at  this  dose.
T = 0.35

? = 1.73 x lO-2  (mgAg/dayr1  •  X
                          C-19

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SUMMARY OF EVIDENCE FOR REPRODUCTIVE TOXICITY

     Fetal mice  given  10-12 mg/kg  of  arsenate while  in
utero showed a  significant (p<0.05)  increase in mortality.

     Sodium arsenate at 40 ng/kg-given to the dam intraper-
itoneally caused  fetal death  and a reduction in fetal body
weight in mice (Hood et al. 1977, as reported by USEPA 1980)".

     Oral administration  of  10-40  mg/kg  of sodium arsenate
on days 9, 10,  or 11 of pregnancy caused an  increased number
of resorptions in ICR mice (Matsumoto et al. 1973,  as reported
by IARC 1980).   No incidence data were given.  For the purpose
of calculating P, a 10 percent  increase in  the incidence of
resorptions at  10 mg/kg  of  sodium  arsenate was  assumed.
T = 0.55

P = 2.48 x 10~2
                             C-20

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SUMMARY OF EVIDENCE  FOR HEPATOTOXICITY

     Hepatomegaly was reported in "the majority of patients"
who consumed arsenic-contaminated soy sauce,  but both  liver
function tests  and   biopsies  revealed  "few  abnormalities"
(Mizuta et  al.  1956, as  reported  by USEPA 1980).   Infants
fed formula  made with  arsenic-contaminated  powdered  milk
also showed hepatomegaly, but no further data  were oresented
(USEPA 1980).

     Because of the  limitations of  these reports and in the
absence of further  evidence,  arsenic  cannot  be considered
hepatoxic.
                             C-21

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SUMMARY OF EVIDENCE FOR RENAL TOXICITY

     There were no studies  available  for review from which
to assess the renal toxicity of arsenic.
                             C-22

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SUMMARY OF EFFECTS ON OTHER ORGAN SYSTEMS

     Chronic exposure to  arsenic has been  associated with
progressive changes in the skin,  which may ultimately result
in skin  cancer.   The sequelae  begin  with melanosis  and
progress to keratoses, which  have been called precancerous
(USEPA 1980).  No specific data were given, but the effects
were observed  in  the Taiwanese people  (Tseng  et  al.  1963,
as reported by  USEPA 1980); thus ?  cannot  be established.
     1.0


                               C-23

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SUMMARY OF EVIDENCE FOR NEUROBEHAVIORAL TOXICITY

     Various authors have reported peripheral neuropathy in
humans occupational!/  exposed  to  inorganic  arsenic;  the
symptoms and  signs  are  for  a  progressive  polyneuropathy
involving both  motor and  sensory nerves  and particularly
affecting distal extremities  and myelinated  long-axon neu-
rons  (USEPA 1980) .

     Quantitative  data for exposure are limited.  Peripheral
neuropathies were  reported  in  44/220 patients poisoned with
arsenic-contaminated soy sauce; the total dose was estimated
to be 60 mg (0.86  mgAg/ 70-kg man)  (Mizuta  et al. 1956, as
reported by USEPA  1980).  Polyneuropathies were reported in
37/74 patients ingesting arsenic trioxide or  arsenic sulfide
at 0.05  or  0.15 mgAg/cay  (Tay  and  Shea 1975,  as reported
bv USEPA 1980).   Japanese   infants fed  arsenic-contaminated
formula showed  CNS damage  (epilepsy,  mental retardation),
hearing and visual pathologic  effects,  and brain wave  (EEC)
abnormalities at a total  intake of 90-140 mg (18-28 mgAg)
(USEPA 1980).   The calculation of P uses  f  = 10 and MED =
0.05
     1.0

     X - 0.005 .
       0.045
                           C-24

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                          REFERENCES

CLEMENT ASSOCIATES,  INC.   1980.  Assessment of Human Respi-
ratory Cancer Risk Due to Arsenic Exposure in  the Workplace.
September  5, 1980.

INTERNATIONAL AGENCY FOR RESEARCH ON CANCER  (IARC).  1980.
IARC Monographs  on the Evaluation of  Carcinogenic Risk of
Chemicals  to Humans.  Vol.  23:   Some  Metals and Metallic
Compounds.  World  Health  Organization,  Lyon,  France.

U.S. ENVIRONMENTAL PROTECTION AGENCY  (USEPA).  1980.  Ambi-
ent Water  Quality  Criteria  for  Arsenic.   Office  of  Water
Regulations and  Standards, Criteria and Standards  Division,
Washington, D.C.  October  1980.  EPA 440/5-80-021.
                             C-25

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ALTERNATIVE WEIGHTING  SYSTEMS
FOR SIGHT HEALTH  EFFECTS	APPENDIX D


     Having developed  relative  risk  measures  for  each of
eight health  effects,  it  is possible to define  total  risk
as a weighted sum of these measures.  Although  it is  impos-
sible to objectively determine a unique set of weights", it
is interesting  to explore  the  sensitivity.of  results to a
range of  weighting systems.   To assist  PHB  in  performing
such a  sensitivity analysis,  Dr.  Milton Weinstein  of the
Harvard School  of Public  Health proposed a methodology for
deriving alternative  weighting  systems reflecting  one or
more of the following  factors:

     e    Years of  life lost per case

     •    Quality of life  lost per case

     •    Direct  costs of medical treatment per case

     •    Indirect  costs (earnings lost  due  to  morbidity
          and premature death)  per case

Dr. Weinstein's methodology  is presented  in  his  paper en-
titled Method for  Assigning Weights  to Health   Effects in
Integrated Risk Reduction Models"datedMay28,1981.The
first section of  this  appendix will  present  this paper in
its entirety.   The  second  section  of  the appendix  will
discuss FSB's implementation of the methodology outlined in
Dr. Weinstein1s paper.

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METHODS FOR ASSIGNING WEIGHTS
TO HEALTH EFFECTS IN INTEGRATED
RISK-REDUCTION MODELS
                                 Milton C. Weinstein, Ph.D.

                                 May 28, 1981
                            D-2

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1.  INTRODUCTION
1.1.  Objectives

     We are  given a set of scores, Sj_, which  will  serve as
proxies for the  increased  incidence rates  for  several  toxic
effects of concern (i = 1,  2,  ..., n).  We need not assume
that these  scores  have any  quantitative  significance in
absolute terms,  but  we must assume  that  they  do provide
meaningful estimates  of the  relative  increases in  incidence
rates for  the several toxic effects.   Thus,   in  a linear
model, any positive multiple of the  vector of scores  (Si_)
is functionally  equivalent to the  original  set.

     The task  at hand is to  develop a meaningful objective
function, f(S]_,  £2,  • •.,  Sn),  that   reflects  the overall
health impact  on the  society of  this  multivariate perturba-
tion of prevailing disease incidence  rates.   Assuming  that
impact is, as  a  first-order approximation, proportional to
incidence (i.e./  that  the  impact  per case  is constant),
the problem  reduces to that  of  assigning a set of  weights ,
wj_, to each  of  the  toxic  effects, such  that  the  function
     f(Si, S2,  ...,  Sn)  =  ^  wisi
                           i=l

becomes the measure  of societal health impact.  As  for the
scores themselves, the weights  need  not  have any absolute
meaning; we  only  require  that  the  ratios,  wj_/wj ,  reflect
the relative  health  impacts  of  effects  i   and  j.   Thus,
without loss  of  generality,  and to  minimize the illusion
that the weights have any absolute significance, it may be
desirable to  normalize  them  to sum  to  unity after having
developed them  in admittedly  arbitrary units.

     The weights  are a means  to an  end —  that of exploring
the efficiency  frontier  for pollution reduction — and not
an end in themselves.  They enable one to  compare quantities
that are  inherently  incommensurable except by  invoking
painfully restrictive assumptions  about  the  social cost of
illness/ In  economic theory,  such  assumptions  are often
made by  postulating the  existence  of  willingness-to-pay
values, the sums of  which  provide  the sought-for  numeraire.
In practice, the  problem is multidimensional,  and  no measure
that is  both  objective  and comprehensive .exists.   We  can
                            D-3

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achieve objectivity  only  by excluding  from  consideration
those dimensions of health  (e.g., pain) that are  inherently
subjective; we  can  be  comprehensive  only  by  introducing
value judgments into the process  (e.g., by assigning quality-
of-life weights  to time spent  in various disease states).
Hence, perhaps  more useful  than a  unique set  of weights
would be an efficient  strategy for exploring the  efficiency
frontier in the model,  by varying the weights  across the n-
simplex of  possible values.   For  example,  much  could be
learned by allocating  the weights to the  vertices
(1, 0,  0,  ...), (0,  1, 0,...),  etc.,  or to  the  midpoints
of the edges  (0.5, 0.5, 0, 0, ...), (0.5, 0,  0.5, 0,  ...),
etc., or  to  the  centroid  (1/n,  1/n,  1/n,  ...)  of the
n-simplex.  However,  given  limited  resources  with  which
to experiment  with the model, a  small  subset of  plausible
and more-or-less  defensible  weight  combinations  might be
useful.  The  objective, then,  is to develop  such weights
that reflect,  in each  of several defensible  senses  of the
term, the social health impact of toxic effects in question.


1.2.  Ideal Versus Practical
      Assessment of Weights

     Ideally,  the  data entering  into the weighting process
(i.e., the  toxic  effects   scores)  would  be  expressed in
terms of specific human diseases, and would be  disaggregated
in the form of age-specific  incidence rates, with  attention
to the  latency period  between  exposure  and  effect.    With
disease-, age-,  and time-specific  data of  this  kind, the
weighting system could be  similarly  disaggregated,  with  a
separate weight, wj_jt,  assigned  to a case of disease i  in a
person of  age  j in  year t.  This  would  make possible the
use of  disease-specific  models  of  the   cost  and  health
consequences of increased incidence, and would  add credibil-
ity to the weights.

     Unfortunately, the ideal  is not  possible  under the
present circumstances.   The level of  scientific  knowledge
does not  provide  a  basis  for  estimating  objectively the
disease-age-time-specific increases  in  incidence.  I would
argue that  this   could be   done  subjectively   by  expert
toxicologlsts, but perhaps  the scope and objectives of  this
study do  not   justify  that  level  of effort.   Perhaps, on
another occasion,  such an exercise  might be  attempted; in
that event,  the more   theoretically  satisfying  method of
assessing weights  (which  is referred  to below,  somewhat
                            D-4

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hyperbolically,  as   the  "ideal")   might   be   attempted   as
well.  Such  an  approach is sketched out  below,  in  addition
to the  "practical"  approach  recommended  for  the  immediate
task, not  for theoretical  reasons, but  to accentuate  the
limitations  of  the admittedly blunt instruments with  which
we are operating  at  present.


2.  VALUED ATTRIBUTES

     Any approach to   developing  a  set  of  weights  must
recognize the  existence  of  at least the following conse-
quences of an episode  of  illness:

     I.  Health  care resource  costs

     II.  Loss of life expectancy

     III.  Impaired  quality  of life (including  disability)

Health care  resource   costs  are  the  costs  of detection,
treatment and  rehabilitation  for the disease  in question.
They are coirraonly,  and uncontroversially, measured in dol-
lars.  Loss  of  life  expectancy  requires  no  explanation,
except to point out that its only natural unit of  measurement
is years.   Impaired  quality  of life encompasses  the  dis-
ability, pain,  suffering, anxiety,   and  other  personal  ef-
fects of illness.  To  these  we might also  add  effects  on
the quality  of  the  life of  others,  such  as  family  and
friends.  There  is no  natural  unit  of measurement for  these
effects.

     Two conceptual  frameworks have  been  applied  to  make
commensurate these consequences.  In benefit-cost analysis,
one seeks economic equivalents, in  dollars,  for all  econ-
omically measurable  attributes.  These  are conventionally
classified as direct costs,  indirect costs, and intangible
costs.  The direct costs  are the health care resource  costs
(category I).   The  indirect  costs,  using  a  human capital
approach, consist of the  value of  productivity  lost due to
premature mortality  (category  II)   and   due   to morbidity
(category III).   The aspects  of death  and disease  included
in categories II  and III, but not  captured by the  economic
measure, are the  intangible costs;  except for  a few enter-
prising attempts  to  assess  willingness   to  pay  to   avoid
these effects,  these  are  usually  excluded  from analysis.
                              D-5

-------
     Another approach,  founded  in multiattribute  utility
theory, is to seek a common unit of  health effect (categories
II and  III).   This  is usually  done  by  assigning  weights
(between 0 and 1) to  each  possible health  state (1  = well,
0 * dead), such that the overall measure of  loss  is expressed
in "quality-adjusted"  years  of  life  expectancy.   (Such  a
linear weighting places  rather  rigid restrictions  on the
form of the  implicit utility  function.)   Some  researchers
have developed scales for  a wide  range  of  health status
levels.  The commensuration of direct cost, in dollars, and
quality-adjusted life  years  is  more troublesome,  but could
be accomplished by exploring a range of values per quality-
ad justed" year  of  life or,  alternatively,  by ignoring the
direct costs altogether and  focusing  on health effects per
se.

     In developing a  set  of weights,  it  seems .reasonable,
therefore, to "consider  at  least   the  following   implicit
utility functions:

     1.   Weight diseases  in proportion to  loss of  life ex-
          pectancy per case;

     2.   Weight diseases  in proportion to  loss of  quality-
          adjusted  life   expectancy   per   case,    suitably
           (though subjectively)  defined;

     3.   Weight diseases  in proportion  to   direct  health
          care cost per case;

     4.   Weight diseases  in proportion to  total   economic
          cost per case (direct  plus  indirect);

     5.   Weight diseases  in   proportion   to  Ac  + A.ALE,
          where  Ac  is direct  cost, ALE is loss of life
          expectancy  per case,  and A is a  weight  (i.e., a
          shadow price) that is  allowed to  vary;

     6.   Weight diseases  in  proportion   to  Ac + AAQALS,
          where AQALE is  loss  of  quality-adjusted  life ex-
          pectancy per case, and \ is a weight  (i.e.,  a shadow
          price) that is allowed to vary.
                              D-6

-------
The weights,  for  each  condition,  might be  inferred from
existing cost-effectiveness  studies of  treatment or screen-
ing in  the  corresponding   diseases   (e.g. ,  dialysis  for
renal disease,  amniocentesis  for  genetic   birth  defects,
surgery for  cancer  of the pancreas)   or from willingness-
to-pay studies  in life-threatening or  chronic conditions.
My recommendation  for now would be to assign weights based
on rules 1, 2,  3,  and 4,  since these are easily understood,
although a  more  theoretically  appealing  scheme  would  be
based on rule 6.
3.  ASSESSMENT OF WEIGHTS:
    THE "IDEAL"

     What I  shall  call  the  "ideal"  methodology (which is
really far  from  that but,  by comparison  with "the proposed
"practical" approach, might seem so) takes as input estimates
(or proxies)  of  disease-age-time-specific incidence rates.
Although the  level  of  detail  can  be  overdone,  given the
paucity of objective evidence,"I do believe  that scientific
experts can at  least bound the  range  of  specific diseases
that might  occur  and,   if  pressed,  could' quantify  their
beliefs in the form of subjective probabilities.

     The salient  characteristic  of  this   "ideal"  method
would be its  reliance on  simulated  cohort analyses for each
disease entity.  Either a probability tree model or a Markov
state-transition model would  be  used to simulate the course
of events  following the  incidence  of  disease.   There  are
numerous examples in the  literature of  both  kinds of models
applied to cost-effectiveness analyses of medical interven-
tions.  Consider  the data that would be  required  in order
to use  such  a  model  to  estimate  the  main  attributes  of
outcome:

     I.  Resource Cost.   The  model  would  require estimates
     of the probabilities that various medical interventions
     would be applied  at  various stages of  the illness, of
     the probabilities  of  consequences of  those interven-
     tions (including  test results and  subsequent induced
     treatment costs),  and   of  the  unit   costs  of  each
     intervention  (e.g.,  hospital  days,   drugs,  physician
     time, institutional  stay).  By averaging out the prob-
     ability  tree,  taking care  to discount downstream costs
     to present value, an expected cost per  episode of ill-
     ness could be  generated.
                            D-7

-------
     II.   Life  Expectancy.   Age-specific survival rates ob-
     tained  by  extrapolating  from  the  medical  literature
     could be used to project life expectancy under various
     treatment  options.  Data on utilization patterns could
     then be used to  average out across  treatment options
     to yield a life expectancy.  Comparison with life-table
     values  yields the net loss in life  expectancy.  Future
     years of life lost may  be  discounted to present value
     (see Weinstein  in New  Enaland  Journal of  Medicine,
     1977),  if  desired.

     IIA.  Economic  Cost  of  Life  Expectancy.   Survival
     curves  generated  by  the  life-table  method  can  be
     combined with data  (Cooper  and Rice,  1976)  on  mean
     age-specific earnings,  and  suitably  discounted,  to
     generate an  estimate  of the  expected,  present-value,
     loss of productivity.

     III.  Quality-Adjusted Life Expectancy.  A probability
     tree or Markov chain  approach  could  be used (and  both
     have been  used)  to  project expected  numbers  of years
     spent  in   each  of  several  defined  health  states.
     Weights mav  be  assigned  to  these  states  either  by
     relying on"  available  health  states   indexes  (e.g.,
     Kaplan, Bush, and Patrick  in Health Services Research,
     1976),  or  bv subjectively  assigning weights.  Quality-
     adjusted years  of  life  lost  may  be   discounted  to
     present value, if desired.

     'IIIA.  Economic Cost of Morbidity.    If  desired,  only
     those health states  associated  with  inability to work
     mav be  considered,  and these may  be valued  according
     to"foregone  earnings  and discounted  to present value.

     Th^s method  is  not  easy  to  implement.  Subjectivity
and expert  opinion will  be  required.   There  are special
problems  in  assigning values  to the  teratologic  effects,
considering  that  some  health  states may be considered worse
than death.  (A loss of more  than one quality-adjusted year
oer vear spent  in that  state would be conceivable. )   Problems
of "how to assicr. values to spontaneous or elective  abortions,
t-o -:-^°rtilitv" or other reproductive effects,  do not fall
^ea*-lv~w
-------
4.  ASSESSMENT OF  WEIGHTS:  A  PRACTICAL METHODOLOGY

     Finally, consider  the  following, extremely crude meth-
odology for  use  in  the present  study.   The only advantage
of this methodology  is  that it can be implemented in a few
days' time.   Moreover,  since  the toxic effects scores will
be expressed  in  terms  of  broad disease categories,  so will
the weights.  It is  not clear that weights derived by this
methodology have  any   substantial  advantage  over  merely
exploring the range  of possible weight vectors, as if they
were chosen  at   random.   On the  other hand,  at  least the
conceptual basis for the  methodology  is sound, even if the
data base for implementing  it  is woefully  imprecise.

     The methodology will  be   described   in  the  following
sections:  1)  the  required   data  base;   2)  methods  for
estimating the major components of impact  (direct cost per
case, life  lost  per  case,  quality-of-life  lost  per  case,
and economic  equivalents of the  latter  two);  3) methods for
combining the  components  into  a  single  weight, wj_,  for
each toxic effect.
4.1.  Data Base

     The data  on impacts  by  broad  disease category may be
obtained from  Cooper,  3. S.,  and Rice, D. P., The economic
cost of illness  revisited,  Social Security Bulletin  39: 21-
36, 1976.  Since only the relative weights are ofconcern,
it  is  of  no  consequence that  these  data are  from  1972.

     In order  to apply these  broad  categories of  illness to
the toxic  effects of  concern,  some arbitrary translations
are needed.  For example, the following may be defensible:

     1.  carcinogenicity 	>   neoplasms

     2.  teratogenicity       r»   congenital anomalies

     3.  reproductive  toxicity	* complications  of  pregnancy
                                    and  childbirth

     4.  hepatotoxicity  	*   diseases of the digestive
                                    system

     5.  renal toxicity 	>  diseases of the genito-
                                    urinary system
                            D-9

-------
     6.  neurotoxicity 	* diseases of  the nervous
                                   system and  sense  organs

     7.  behavioral toxicity	=* mental disorders

     8.  other organ  toxicity	^diseases of  the respiratory
                                   system

Since we are  concerned only with a  proxy  for the cost per
case, we need not be concerned  that  these disease  categories
do not match  cleanly  (e.g.,  reproductive toxicity includes
some "diseases of  the genitourinary  system";  teratogenicity
includes some  "mental  disorders,"  etc.).   The  implicit
assumption is that the cost per  case can be approximated by
the cost per  case  in the corresponding  disease  category.
If desired, weights based  on two or  more disease  categories
can be  averaged  to   arrive at a weight  for  a  particular
toxic effect.  However, since  this  is  not a major obstacle,
the rest  of  this  discussion  assumes  that   a  one-to-one
correspondence between toxic effects and disease categories,
as described above, will be followed.

     Having defined  the  categories  of disease  for purposes
of accessing the NCHS  (National Center for Health Statistics)
data base, consider the data required  for the  assessment of
weights.  All data elements  are" subscripted  by i,  where  i
indexes the disease categories.

     a.  Prevalence and Incidence Data

         i.      Pj_ =  prevalence  of  disease  category  i

         ii.     Ii =  incidence (per year) of  disease
                      category  i

         iii.    Ni =  mean  duration  (years)  of diseases  in
                      category  i

         iv.     Mj. =  case  fatality  rate  (per  year) in
                      category  i

         v.      DI «  deaths  (per year) in category i

         Anv  three of the five  (i)-(v)  are  sufficient to
         determine the others,  by  virtue  of  the following
         identities that   hold  in   the  steady  state   (and
         which,  in this  crude procedure,  may be  assumed to
         hold):
                              D-10

-------
        Di » ?£  x Mi

Deaths  (Dj_)  are  available  from  Cooper  and  Rice
(1976).  Therefore  we  need two from  among  (Pj_,  Ij_,
Nj_, and MI).   If it  is  possible to  get  prevalence
and incidence  data  from  NCHS or  other sources,  then
that is sufficient.  If it is possible to get  one
but not the other,  then  an independent (subjective)
estimate of  either  duration  (Nj_)  or  case-fatality
rate (Mj_)  is  required.  If  neither prevalence  nor
incidence is  available,  then both   Nj_ and Mj_  will
have to be assessed subjectively.   I  recommend  that
an epidemiologist  be  consulted  for the  subjective
estimates, if  needed.

b.  Direct Cost  Data

        Ci =   direct  costs  per  year  (U.S.)   for
             category  i

c.  Mortality  Data

        Yi =  years  of   life  lost  (U.S.)  owing  to
             deaths in one year  in  category  i

       YCi =  earnings  lost  'U.S.)  owing to  deaths
             in  one year in category  i

d.  Morbidity  Data

        Zi =  person-years  of work  lost  (U.S.)  per
             year owing  to disease  category  i

       ZCi =  earnings lost  (U.S.)  per year owing
             to  disability in category i

e.  Quality-of-Life Data (Subjective)

        Qi = loss of quality-adjusted  life  for  each
             person-year lost from  work

        Q.; = loss of quality-adjusted  life  for  each
             year of  disease  not  lost  from  work
                    D-ll

-------
Data on direct costs, mortality, and morbidity are obtainable
from Cooper  and Rice.   The quality  of life  data  (Q,  Q1 )
reflect subjective  judgments  and  must be assessed  indepen-
dently.  These  reflect  the  extent to which years lost from
work captures  the  adverse effects on quality  of life (Q1),
and the severity of  the major adverse effects  (Q).


4.2.  Calculation.of Components
      of Impact
     4.2.1.  Direct Cost Weight

     The weight for direct cost  is calculated as


     wCi = NI*  . Ci/?i,

where Nj_*  is the  present value of  a  unit annuity  of Nj_
years.  This, has  the  effect  of discounting the  stream of
costs to present value, as of  the time of  incidence.  Since
all costs*  may  be  thought  of  as  real  dollars  (i'.e.,  no
assumed increase  in  unit cost  over  time), a real discount
rate of 4-6  percent seems reasonable.
     4.2.2.  Mortality Weight

     The weight   for  life  years   lost   is   calculated  as
     This  is  tantamount  to:
     wYj_
where  the  first  factor  is  the  number  of years  lost per
death, and the  second  factor is the case fatality rate for
the disease  category.

     Alternatively,  life-years  may  be  discounted  to present
value, in which case
                              D-12

-------
     wYi
where (Yj_/D^)*  is  the present  value  of a  unit  annuity of
Yi/Di
     4.2.3.  Cost-of-Mortality
             Weight
     A weight  which  values  life  years  lost  in  terms  of
foregone earnings  is  calculated as
     4.2.4.  Morbidity Weight  (wZjJ

     The weight  for person-years lost from  work  is calcu-
lated as

     wZi - Ni*  (Zi/Pi),

where Nj_*  is  the present value  of  an annuity  of N^ years.


     4.2.5.  Cost-of -Morbidity
             Weight  (wZCj_)

     A weight which values  disability from work in  terms of
foregone earnings  is  calculated  as

     wZCi = Ni*  (ZCi/?i)


     4.2.6.  Quality-of-Life-Lost
             Weight
     A weight that reflects the subjective impact on quality
of life is calculated  as


     wQi  « Ni*  [QiZi + Q[(?i  -  ZiJl/Pi

          =  (Qi) (wZi) + Q^CNi*  - wZi)
                              D-13

-------
4.3.  Pooling  the  Component
      Weights

     Alternative procedures  for pooling  the  weight  compo-
nents were  described in  Section 2.   To  review, these  are
as follows:

     a.  wj_ =  wYj_  (life  expectancy)

     b.  wj_ =  wQj_  + wYj_  (quality-adjusted  life  expectancy)

     c.  wj. =  wCj,  (direct cost)

     d.  Wj_ =  wCj_  +  wYCj_  •(• wSCj_  (economic cost)

     e.  wj_ =  wCj_  + X wY^  (economic cost, assigning  value
               to life  other  than human capital)

     f.  Wj_ =  wCj_  T  /.(wQj_ +  wYj_)  (economic cost, assigning
               value  to morbidity and  mortality other  than
               human  capital)


5.  RECOMMENDATION

     My suggestion would  be to  use  (a),  (b),  and  (d)  to
develop three  sets  of weights  to supplement the arbitrary
sets of the form (1, 0,  0, ...), (0,  1,  0,  ...), etc.,  and
(1/n, 1/n,  ...).


6.  APPENDIX ON  DISEASE  CATEGORIES

     Cooper and Rice, and  the NCHS, use ICDA codes to define
the broad  disease categories.   Other  data bases,   such as
those of  insurance companies, may use similar  coding.   The
codes are:

     neoplasms (ICDA 140-239)
     mental disorders  (ICDA  290-315)
     diseases  of  the nervous system and  sense  organs (ICDA
        320-389)
     diseases  of   the   respiratory  system  (ICDA  460-519}
     diseases  of  the digestive  system  (ICDA 520-577)
     diseases  of   the  genitourinary system (ICDA^  530-629)
     comolications of  pregnancy, etc.  (ICDA 630-673)
     congenital  anomalies (ICDA 740-759)
                             D-14


-------
IMPLEMENTATION OF METHODOLOGY

     This section will discuss the derivation of  alternative
weighting systems which  rank the eight health effects con-
sidered in  the  analysis according  to  economic cost, years
of life lost, and quality of  life lost per case.  All weights
presented here are defined  according to Dr. Weinstein's paper
as follows:
Weight

Direct Cost Weight
Cost of Mortality
Weight
Cost of Morbidity
Weight
Mortality Weight


Morbidity Weight
Quality of  Life
Weight
Quality Adjusted
Life  Expectancy
Weight
Variable
  Name

  wC
  wYC
  wZC
  wY
 wQALE
Interpretation

The present value of all
medical treatment costs
per case

The present value of fore-
gone earnings due to
mortality per case

The present value of fore-
gone earnings due to
morbidity per case

The number of years of
life lost per case

The number of years lost
from work per case

The subjective impact on
quality of life, measured
in equivalent years of
life lost

The sum of wYj_ and vQj_
Exhibit  D-l  shows  the  derivation of  the weights and Exhibits
D-2 and  D-3 translate these weights into alternative indices.

      EPA staff were consulted on the selection of a weight-
ing scheme.   Because of resource limitations,  ?HB wished  to
                             D-15

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                                                             Exhibit  D-l

                                DERIVATION  OF WEIGHTS  FOR  BASIC  DISEASE  CATEGORIES
                                                                      Coinpl Icatlons Dlucnuoa uf  Dlaeauei of   Dlaeaauu  Dlacaaea of
                                                           Congenital of  t'i c'jiiiiiicy   Digestive  f!en Hour I nary of Nervous Respiratory
 I
M
a\
             C|- direct coata per year for
                 category I (In Millions)9
             Y|- years of life loat owing to
                 deutha  In year (In thotigandol9
             YC'i-oai nlngs loat owing to deaths
                 (In lull lions discounted at 4t)9  12,633
             11" pet non-yeara of work loat due to
                 disability (In thouaando)9

             ZC i-eainlinia lost owing to disability
                 (In Millions)9


             11* Incidence par year
             l)|- deaths  per year
             Mj» moan duration (yra)
             M,» caaa fatality rate (t)3

             Pj- prevalenca of dlaeaao
             M| «  « 4%

             o,10
             n(10
Direct Coat Weight

Coat of Mortality Height

Coat of Morbidity Height

Total economic Cont Weight

Mortality Weight

Morbidity Weight

Oua'.lly of Life Height

Duality Adjusted Life Expectancy
  Height                              6.237

*  lixoluileu dental services.
'* r.ncludus eye glanues.
Neo^laama
3,672
5, 101
9 12,63]
to
115
Ity
U62
1,020,61)1)'
352,800
2. 12
u. e
2, 100,000*
2.06
.6
.3
»J,TJO
$12,378 •
$846
$17,022
5.506
.11
.651
Anomalies
381
942
1,284
26
2311
250, ODD1
15,050
1B.08
.3
4,500,000
13.2
.6
.1
$1,1111
55,136
$690
$6,952
3.76U
.10
1. J7
t Oil idli I rid
2,607
IB
DO
48
245
4,161,000S 3,
700
.13*
.1
540,930' 21,
.13
.75
.375
$627
?19
?5U
$704
. OO'J
.01
.053
Uyntom
5,519*
1,402
1,781
299
2,606
320,000s
75,004
6.42
.4
361,000s
5. B
.3
.1
$1,499
$1,139
$708
$1,346
.422
.09
.590
System
4,471
390
736
164
1,249
1,514,000s
27.215
3.8*
.5
5,603.000s
3.6
.3
.1
$2.832
$486
S791
$4,109
.258
.11
. 1H2
Uystem
4,051«*
476
1,060
482
3,944
663,000s 5,
16,644
10. 72
.2
7,111,000s SI,
0.9
.3
.1
$5,070
$1,599
$4,936
$11,605
.710
.73
1.036
Syatem
5,931
1,934
3,434
U40
7,089
528,000s
111,596
9.3*
.2
407,000s
7.9
.2
.1
$911
$621
$1,009
$2,621
.350
.15
.1105
                                                                5.138
                                                                             .062
                                                                                         1.02
                                                                                                      .640
                                                                                                                 1.754
                                                                                                                             1.155
              6
              7
              8
              9
              III
   Calculated baned on 1981  ratio of deaths to new cusos o« reported by American Cancer .Society
   (Ainiirlcnn Cancer Society,  1981 Fact and figures, p. U).
   Calculated as Pj T  I(.
   Calculated aa l>, t  P..
   National Center for Health Statistics - Number of cancer patients discharged from  hospitals  In 1972.
   National Center for Health Stallatlca - Health Interview Surveys.
   Hat limited bailed on  convcroat Ion with I'atrlcla Adams of National Center for Health  Statistics.
   Soui I:IM   March of Dimes.
   Msl I MI,111:1) b.inod on  Information from March of Dimes.
   iiuuiri!:   Cooper fc It Ice.
   Uiiurci.-:   Hllli.n C.  Heliiiiteln.

-------
                              Exhibit D-2

            ALTERNATIVE INDICES FOR BASIC DISEASE  CATEGORIES
                                                             Quality
                                                             Adjusted
1.   Neoplasms

2.   Congenital Anomalies

3,   Diseases of Nervous
    System

4.   Diseases of
    Genitourinary System

5.   Diseases of Digestive
    System

6.   Diseases of Respiratory
    System

7.   Complications of
    Pregnancy 5 Childbirth   .01
                           ••^•^••^•^•B

                           1.00
Economic
Costs
.37
.15
.25
.09
.07
•v
.06
i .01
Years of
Life Lost
.50
.34
.07
.03
.04
.03
^
Quality of
Life Lost •
.13
.28
.21
.08
.12
.16
.01
Life
Expectancv
.39
.32
."
.04
.06
.07
.
1.00
1.00
1.00
                                     D-17

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                              Exhibit D-3

            ALTERNATIVE  INDICES  FOR EIGHT HEALTH EFFECTS*
Cancer  (1)

Mutagenicity  (2)

Teratogenicity  (2)

Neurological
  Disorder  (3)

Reproductive
  Toxicity
  [(2) +  (7)] * 2

Kidney Disease  {4}

Hepatotoxicity  (5)

Other (6)

Economic
Costs
.30
.12
.12
.20
.07
.07
.06 -
.05

Years of
Life Lost
.33
.22
.22
.04
.11
.02
.03
.02

Quality of
Life Lost
.09
.20
.20
.15
.10
.06
.09
.12
Quality
Adjusted
Life
Expectancy
.26
.22
.22
.07
.11
.03
.04
.05
                       1.00
1.00
1.00
1.00
   Numbers in parentheses correspond to basic disease categories  i:
   Exhibit D-2.
                                D-18

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select one  scheme on which most of the analyses were to  be
conducted.*   The  SPA   particioants   reached   agreement  on
these points:

     •    An  acceptable  scheme   should  include several  or
          all of  the  health  effects.   This  excludes weight-
          ing schemes  considering only   a single  health
          effect  such as cancer.

     •    Although   an  equal weight   scheme is  more attrac-
          tive  than a  single  health  effect   scheme,   it
          would mask  differences   in  relative importance
          among health  effects  that most  people intuitively
          feel  are  significant.   An  unequal weight scheme
          is preferable to an equal weight  scheme.

     •    Among the  unequal weight  schemes,   all had some
          attractive  characteristics,  but the   EPA partici-
          pants generally agreed  that  weighting  solely  on
          the basis of   ecoraomic. costs of  the  diseases   or
          years of  life lost missed  some  important charac-
          teristics of  the difference among the health ef-
          fects.  The quality of life lost  scheme was more
          attractive  than the others,  although it  was in-
          herently  more subjective.  The participants recog-
          nized that  all  the weighting  schemes were based
          on limited  data.   Choosing the  quality  .of  life
          lost  measures  would  acknowledge  the subjective
          nature  of the  exercise.   It would  minimize the
          possibility of  a   reader  assuming  (incocrectly)
          that  the  economic  cost and  years of  life  lost
          weights had more inherent validity than they de-
          serve,  simply because they are more data-oriented.

     •    Sensitivity analysis  to  test  the  effects of alter-
          native  weighting schemes on  the  study's results
          was deemed  important  by  the  EPA participants.

     Thus, PH3  used the quality of life lost weights as the
basis for most  analysis and  performed sensitivity analysis
with equal  weight  and  an  average  of  the  economic  cost and
vears of life lost  schemes.
*  The  effect  of  alternate  health  weighting  schemes was
   tested, as reported  in  Chapter  4.
                             D-19

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The principal  sources  of data for this analysis were:

•    The Economic  Cost  of  Illness  Revisited  by  Bar-
     bara S. Cooper  and Dorothy P. Rice, Social Secur-
     ity Bulletin  39:21-36,  1976.   This  article pro-
     vided aggregated  1972 data on direct costs, years
     of life  lost, earnings  lost, deaths,  and person
     years of  work lost for each of the disease cate-
     gories. For  purposes  of.this analysis, the costs
     of dental services and  eyeglasses  have been ex-
     cluded from   the  derivation  of  direct  cost  per
     case.

•    The National  Center for Health  Statistics   (NCHS)
     which provided  information on prevalence and inci-
     dence for all disease categories except cancer and
     congenital anomalies.   These data  were obtained
     from health  interview surveys  conducted periodi-
     cally by  NCHS.  Where data were  gathered for years
     other than 1972,   the  figures  have been adjusted
     for population  growth.   NCHS also provided an es-
     timate of the number of cancer patients discharged
     from hospitals  in  1972  which has  been used as  a
     proxy for prevalence of cancer in the  absence of
     better data.

•    Cancer Facts  and  Figures,  1981  published  by the
     American  Cancer Society.  This publication provid-
     ed data   on   estimated  incidence  of  cancer  and
     cancer deaths  in  1981.  The ratio  of  incidence
     to deaths has  been applied  to 1972 deaths  (from
     Cooper and Rice)  to  yield  an  estimate  of 1972
     incidence.

«    The March of  Dimes organization,   which provided
     estimates of incidence and prevalence  of congeni-
     tal anomalies.

«    Milton C. Weinstein provided the  quality  of life
     weights  shown in  Exhibit D-l.
                        D-20

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