<^_?^%
      \
  W8
£»
 m
  ^ ppot^
Integrated Review Plan for the
Primary National Ambient Air
Quality Standard for Sulfur
Dioxide
External Review Draft

-------
                                         EPA-452/P-14-005
                                             March 2014
     Integrated Review Plan for the
Primary National Ambient Air Quality
       Standard for Sulfur Dioxide
               External Review Draft
             U. S. Environmental Protection Agency

             National Center for Environmental Assessment
                Office of Research and Development
                         and
              Office of Air Quality Planning and Standards
                  Office of Air and Radiation

               Research Triangle Park, North Carolina
                      March 2014

-------
                                   DISCLAIMER

       This draft integrated review plan serves as a public information document and as a
management tool for the U.S. Environmental Protection Agency's National Center for
Environmental Assessment and the Office of Air Quality Planning and Standards in conducting
the review of the national ambient air quality standard for sulfur oxides.  The approach described
in this draft plan may be modified for presentation in the final plan to reflect consultation with
the Clean Air Scientific Advisory Committee and public comments. Subsequent modifications
to the plan may result from information developed during this review,  and in consideration of
advice and comments received from the Clean Air Scientific Advisory Committee and the public
during the course of the review. Mention of trade names or commercial products does not
constitute endorsement or recommendation for use.
Do Not Quote or Cite                   ii                                  March 2014

-------
                         TABLE OF CONTENTS
LIST OF FIGURES	v
LIST OF TABLES	vi
LIST OF ACRONYMS/ABBREVIATIONS	vii
1.    INTRODUCTION	1-1
    1.1   LEGISLATIVE REQUIREMENTS	1-1
    1.2   OVERVIEW OF THE NAAQS REVIEW PROCESS	1-3
    1.3   HISTORY OF THE REVIEW OF AIR QUALITY CRITERIA FOR SULFUR
          OXIDES AND THE NAAQS FOR SULFUR DIOXIDE	1-7
    1.4   SCOPE OF THE CURRENT REVIEW	1-10
2.    STATUS AND SCHEDULE	2-1
3.    KEY POLICY-RELEVANT IS SUES	3-1
    3.1   CONSIDERATIONS AND CONCLUSIONS IN LAST REVIEW	3-1
          3.1.1     Need for Revision	3-2
          3.1.2     Elements of aRevised Standard	3-5
          3.1.3     Areas of Uncertainty	3-10
    3.2   GENERAL APPROACH FOR THE CURRENT REVIEW	3-11
4.    SCIENCE ASSESSMENT	4-1
    4.1   SCOPE OF THE ISA	4-1
    4.2   ORGANIZATION OF THE ISA	4-1
    4.3   ASSESSMENT APPROACH	4-2
          4.3.1     Introduction	4-2
          4.3.2     Literature Search and Selection of Relevant Studies	4-4
          4.3.3     Evaluation of Individual Study Quality	4-5
          4.3.4     Integration of Evidence and Determination of Causality	4-8
          4.3.5     Quality Management	4-9
    4.4   SPECIFIC ISSUES TO BE ADDRESSED IN THE ISA	4-10
    4.5   SCIENTIFIC AND PUBLIC REVIEW	4-17
5.    QUANTITATIVE RISK AND EXPOSURE ASSESSMENTS	5-1
    5.1   OVERVIEW OF RISK AND EXPOSURE ASSESSMENT FROM PRIOR
          REVIEW	5-2
          5.1.1 Key Observations	5-4
          5.1.2 Key Uncertainties	5-6
    5.2   CONSIDERATION OF QUANTITATIVE ASSESSMENTS FOR THIS REVIEW
          5-6
          5.2.1     Ambient Air Quality Characterization	5-7
          5.2.2     Exposure Assessment	5-8
          5.2.3     Risk Assessment	5-9
          5.2.4     Uncertainty and Variability	5-13
    5.3   PUBLIC AND SCIENTIFIC REVIEW	5-13
6.    AMBIENT AIR MONITORING	6-1
    6.1   CONSIDERATION OF SAMPLING AND ANALYSIS METHODS	6-1
    6.2   CONSIDERATION OF AIR MONITORING NETWORK REQUIREMENTS.... 6-1
7.    POLICY ASSESSMENT/RULEMAKING	7-1
Do Not Quote or Cite                 iii                              March 2014

-------
    7.1   POLICY ASSESSMENT	7-1
    7.2   RULEMAKING	7-2
8.   REFERENCES	8-1
APPENDIX A	A-l
Do Not Quote or Cite                iv                             March 2014

-------
                          LIST OF FIGURES
Figure 1-1 Overview of the NAAQS Review Process	1-4
Figure 3-1 Overview of General Approach for Review of Primary SOi Standard	3-13
Figure 4.1. General Process for Development of Integrated Science Assessments (ISAs)..4-3
Do Not Quote or Cite                 v                               March 2014

-------
                            LIST OF TABLES
Table 1-1. History of the primary national ambient air quality standard(s) for sulfur
        dioxide since 1971	1-8
Table 2-1. Anticipated schedule for the SO2 NAAQS Review	2-2
Table 5-1. The numbers of SO2 monitors 2003 to 2012	5-8
Table 5-2. Primary uncertainties associated with the exposure and risk assessments in the
        previous review and the potential use of new information for reducing these
        uncertainties	5-10
Do Not Quote or Cite                  vi                                March 2014

-------
                  LIST OF ACRONYMS/ABBREVIATIONS
AMMS
AQCD
AQS
CAA
CASAC
CBS A
CFR
C-R
ED
EPA
FEM
FEVi

FR
FRM
HA
IRP
ISA
Km
MSA
NAAQS
NCEA
NO2
O3
OAQPS
OAR
OMB
ORD
PA
PM
ppb
ppm
PRB
REA
SES
SLAMS
SO2
Air Monitoring and Methods Subcommittee
Air Quality Criteria Document
EPA's Air Quality System
Clean Air Act
Clean Air Scientific Advisory Committee
Consolidated Business Statistical Area
Code of Federal Regulations
Concentration-response
Emergency department
Environmental Protection Agency
Federal Equivalent Method
Forced expiratory volume in one second, volume of air exhaled in first
second of exhalation
Federal Register
Federal Reference Method
Hospital admissions
Integrated Review Plan
Integrated Science Assessment
Kilometer
Metropolitan Statistical Area
National Ambient Air Quality Standards
National Center for Environmental Assessment
Nitrogen dioxide
Ozone
Office of Air Quality Planning and Standards
Office of Air and Radiation
Office of Management and Budget
Office of Research and Development
Policy Assessment
Particulate matter
Parts per billion
Parts per million
Policy-relevant background
Risk and Exposure Assessment
Socioeconomic status
State and local air monitoring stations
Sulfur dioxide
Do Not Quote or Cite
                  vn
                                                     March 2014

-------
 i                                1.     INTRODUCTION

 2           The U.S. Environmental Protection Agency (EPA) is conducting a review of the primary
 3    (health-based) national ambient air quality standard (NAAQS) for sulfur oxides (SOx).  This
 4    draft Integrated Review Plan (IRP) presents the planned approach for the review. This review
 5    will provide an integrative assessment of relevant scientific information for SOx and will focus
 6    on the basic elements that define the NAAQS: the indicator,1 averaging time,2 form,3 and level.4
 7    The EPA Administrator will consider these elements collectively in evaluating the protection to
 8    public health afforded by the primary standard(s).
 9           This document is organized into eight chapters. Chapter 1 presents the legislative
10    requirements for the review of the NAAQS, background information on the review process,
11    scope of the current review, and an overview of past reviews of the primary SCh NAAQS.
12    Chapter 2 presents the status and schedule for the current review.  Chapter 3 summarizes the
13    approach in the last review and presents a set of policy-relevant questions that will serve to focus
14    the current review on the critical scientific and policy issues.  Chapters 4 through 7 discuss the
15    planned scope and organization of key assessment documents, the planned approaches for
16    preparing these documents, specific ambient air quality monitoring considerations, as well as
17    plans for scientific and public review of these documents.  Complete reference citations are
18    provided in chapter 8.

19    1.1    LEGISLATIVE REQUIREMENTS
20           Two sections of the Clean Air Act (CAA) govern the establishment and revision of the
21    NAAQS.  Section 108 (42 U.S.C. 7408) directs the Administrator to identify and list "air
22    pollutants" that "in his judgment, may reasonably be anticipated to endanger public health and
23    welfare" and whose "presence ... in  the ambient air results from numerous or diverse mobile or
24    stationary sources" and to issue air quality criteria for those that are listed. Air quality criteria
25    are intended to "accurately reflect the latest scientific knowledge useful in indicating the kind
26    and extent of identifiable effects on public health or welfare which may be expected from the
27    presence of [a] pollutant in ambient air ... ."
      1 The "indicator" of a standard defines the chemical species or mixture that is measured in determining whether an
      area attains the standard.
      2 The "averaging time" defines the time period over which ambient measurements are averaged (e.g., 1-hour, 8-hour,
      24-hour, annual).
      3 The "form" of a standard defines the air quality statistic that is compared to the level of the standard in determining
      whether an area attains the standard. For example, the form of the current 1-hour SO2 standard is the three-year
      average of the 99th percentile of the annual distribution of 1 -hour daily maximum SO2 concentrations.
      4 The "level" defines the allowable concentration of the criteria pollutant in the ambient air.
      Do Not Quote or Cite                    1 -1                                    March 2013

-------
 1            Section 109 (42 U.S.C. 7409) directs the Administrator to propose and promulgate
 2    "primary" and "secondary" NAAQS for pollutants for which air quality criteria are issued.5
 3    Section 109(b)(l) defines a primary standard as one "the attainment and maintenance of which in
 4    the judgment of the Administrator, based on such criteria and allowing an adequate margin of
 5    safely, are requisite to protect the public health."6 A secondary standard, as defined in section
 6    109(b)(2), must "specify a level of air quality the attainment and maintenance of which, in the
 7    judgment of the Administrator, based on such criteria, is required to protect the public welfare
 8    from any known or anticipated adverse effects associated with the presence of [the] pollutant in
 9    the ambient air."7
10           The requirement that primary standards provide an adequate margin of safety was
11    intended to address uncertainties associated with inconclusive scientific and technical
12    information available at the time of standard setting.  It was also intended to provide a reasonable
13    degree of protection against hazards that research has not yet identified.  See Lead Industries
14    Association v. EPA, 647 F.2d 1130, 1154 (D.C. Cir 1980), cert, denied. 449 U.S. 1042 (1980);
15    American Petroleum Institute v. Costle, 665 F.2d  1176,  1186 (D.C. Cir. 1981), cert, denied. 455
16    U.S. 1034(1982). Both kinds of uncertainties  are components of the risk associated with
17    pollution at levels below those at which human health effects can be said to occur with
18    reasonable scientific certainty. Thus, in selecting primary standards that include an adequate
19    margin of safety, the Administrator is seeking not only to prevent pollution levels that have been
20    demonstrated to be harmful but also to prevent lower pollutant levels that may pose an
21    unacceptable risk of harm, even if the risk is not precisely identified as to nature or degree. The
22    CAA does not require the Administrator to establish a primary NAAQS at a zero-risk level or at
23    background concentration levels, see Lead Industries v. EPA, 647 F.2d at 1156 n.51, Mississippi
24    v. EPA, 723 F.  3d 246,  255, 262-63 (D.C. Cir.  2013), but rather at a level that reduces risk
25    sufficiently so as to protect public health with an adequate margin of safety.
26            In addressing the requirement for an adequate margin of safety, the EPA considers such
27    factors as the nature and severity of the health effects involved, the size of the sensitive
28    population(s), and the kind and degree of uncertainties.  The selection of any  particular approach
29    to providing an adequate margin of safety is a policy choice left specifically to the
      5 As discussed in section 1.4 below, this document describes the review of the primary SCh standard. The
      secondary 862 standard will be separately reviewed in conjunction with review of the secondary NC>2 standard.
      6 The legislative history of section 109 indicates that a primary standard is to be set at "the maximum permissible
      ambient air level.. . which will protect the health of any [sensitive] group of the population," and that for this
      purpose "reference should be made to a representative sample of persons comprising the sensitive group rather than
      to a single person in such a group" [S. Rep. No. 91-1196, 91st Cong., 2d Sess.  10 (1970)].
      7 Welfare effects as defined in section 302(h) [42 U.S.C. 7602(h)] include, but are not limited to, "effects on soils,
      water, crops, vegetation, man-made materials, animals, wildlife, weather, visibility and climate, damage to and
      deterioration of property, and hazards to transportation,  as well as effects on economic values and on personal
      comfort and well-being."
      Do Not Quote or Cite                     1-2                                     March 2013

-------
 1    Administrator's judgment.  See Lead Industries Association v. EPA, supra, 647 F.2d at 1161-62;
 2    Mississippi v. EPA, 723 F. 3d at 265.
 3           In setting standards that are "requisite" to protect public health and welfare, as provided
 4    in section 109(b), the EPA's task is to establish standards that are neither more nor less stringent
 5    than necessary for these purposes. In so doing, the EPA may not consider the costs of
 6    implementing the standards. See generally, Whitman v. American Trucking Associations, 531
 7    U.S. 457, 465-472, 475-76 (2001).  Likewise, "[attainability and technological feasibility are not
 8    relevant considerations in the promulgation of national ambient air quality standards." American
 9    Petroleum Institute v. Costle, 665 F. 2d at 1185.
10           Section 109(d)(l) requires that "not later than December 31, 1980, and at 5-year
11    intervals thereafter, the Administrator shall complete a thorough review of the criteria
12    published under section 108 and the national ambient air quality standards . . . and shall make
13    such revisions in such criteria and standards and promulgate such new standards as may be
14    appropriate . . . ." Section 109(d)(2) requires that an independent scientific review committee
15    "shall complete a review of the criteria .  . .  and the national primary and secondary ambient air
16    quality standards . . . and shall recommend to the Administrator any new . . . standards and
17    revisions of existing criteria and standards as may be appropriate . .  . ."  Since the early 1980s,
18    this independent review function has been performed by the Clean Air Scientific Advisory
19    Committee (CASAC) of EPA's Science Advisory Board.8

20    1.2    OVERVIEW OF THE NAAQS  REVIEW PROCESS
21           The current process for reviewing the NAAQS includes four major phases: (1) planning,
22    (2) science assessment, (3) risk/exposure assessment, and (4) policy assessment and rulemaking.
23    Figure 1-1 provides an overview of this process, and each phase is described in more detail
24    below.9
      8 Lists of CASAC members and of members of the CASAC Sulfur Oxides Primary NAAQS Review Panel are
      available at: http://yosemite.epa.gov/sab/sabproduct.nsfAVebCASAC/CommitteesandMembership7OpenDocument.
      9 The EPA maintains a website on which key documents developed for NAAQS reviews are made available
      (http://www.epa.gov/ttn/naaqs/). The EPA's NAAQS review process has evolved over time. Information on the
      current process is available at: http://www.epa.gov/ttn/naaqs/review.html. As discussed in section 1.3 below, this
      process was generally followed in the primary SO2 NAAQS review completed in 2010 with the exception that there
      was not a separate Policy Assessment document issued; rather the Risk and Exposure Assessment (U.S. EPA 2009,)
      included a policy assessment chapter (i.e., Chapter 10).
      Do Not Quote or Cite                   1-3                                   March 2013

-------
             Workshop on
          science-policy issues
Integrated Review Plan (IRP): timeline and key
 policy-relevant issues and scientific questions
             Peer-reviewed
            scientific studies
        Integrated Science Assessment (ISA): evaluation and
               synthesis of most policy-relevant studies
                                                       Risk/Exposure Assessment (REA):
                                                   quantitative assessment, as warranted, focused
                                                   on key results, observations, and uncertainties
                    Clean Air Scientific
                   Advisory Committee
                     (CASAC) review
                                                                      Public comment
                                                          Policy Assessment (PA): staff analysis of
                                                           policy options based on integration and
                                                        interpretation of information in the ISA and REA
                                                                        Agency decision
                                                                        making and draft
                                                                         proposal notice
                                    Public hearings
                                    and comments
                                      on proposal
                      Agency decision
                      making and draft
                         final notice
                     EPA final
                   decisions on
                   •- standards
Figure 1-1 Overview of the NAAQS Review Prdtess
Do Not Quote or Cite
       1-4
March 2013

-------
 1          The planning phase of the NAAQS review process begins with a science policy
 2   workshop, which is intended to identify issues and questions to frame the review. Drawing from
 3   the workshop discussions, a draft IRP is prepared jointly by EPA's National Center for
 4   Environmental Assessment (NCEA), within the Office of Research and Development (ORD),
 5   and EPA's Office of Air Quality Planning and Standards (OAQPS), within the Office of Air and
 6   Radiation (OAR).  The draft IRP is made available for CASAC review and for public comment.
 7   The final IRP is prepared in consideration of CASAC and public comments. This document
 8   presents the current plan and specifies the schedule for the entire review, the process for
 9   conducting the review, and the key policy-relevant science issues that will guide the review.
10          The second phase of the review, the science assessment, involves the preparation of an
11   Integrated Science Assessment (ISA) and supplementary materials. The ISA, prepared by
12   NCEA, provides a concise review, synthesis, and evaluation of the most policy-relevant science,
13   including key science judgments that are important to the design and scope of exposure and risk
14   assessments, as well as other aspects of the NAAQS  review. The ISA and its supplementary
15   materials provide a comprehensive assessment of the current scientific literature pertaining to
16   known and anticipated effects on public health and welfare associated with the presence of the
17   pollutant in the ambient air, emphasizing  information that has become available since the last air
18   quality criteria review in order to reflect the current state of knowledge. As such, the ISA forms
19   the scientific foundation for each NAAQS review and is intended to provide information useful
20   in forming judgments about air quality indicator(s), form(s), averaging time(s) and level(s) for
21   the NAAQS. The current review process generally includes production of a first and second
22   draft ISA, both of which undergo CASAC and public review prior to completion of the final
23   ISA.  Chapter 4 below provides a more detailed description of the planned scope, organization
24   and assessment approach for the ISA and its supporting materials.
25          In the third phase, the risk/exposure assessment phase, OAQPS staff considers
26   information and conclusions presented in the ISA, with regard to support provided for the
27   development of quantitative assessments of the risks and/or exposures for health and/or welfare
28   effects. As an initial step, staff prepare a  planning document (REA Planning Document) that
29   considers the extent to which newly available scientific evidence and tools/methodologies
30   warrant the conduct of quantitative risk and exposure assessments.  As discussed in Chapter 5
31   below, the REA Planning Document focuses on the degree to which important uncertainties in
32   the last review may be addressed by new  information available in this review.  Specifically, the
33   document considers the extent to which newly available data, methods,  and tools might be
34   expected to appreciably affect the assessment results, or address important gaps in our
35   understanding of the exposures and risks associated with SO2.  To the extent warranted, this
36   document outlines a general plan, including scope and methods, for conducting assessments.  The
      Do Not Quote or Cite                   1-5                                  March 2013

-------
 1    REA Planning Document is generally prepared in conjunction with the first draft ISA and is
 2    presented for consultation with CASAC and for public comment. When an assessment is
 3    performed, one or more drafts of each risk and exposure assessment document (REA) undergoes
 4    CASAC and public review, with the initial draft REA generally being reviewed in conjunction
 5    with review of the second draft ISA, prior to completion of the final REA.  The REA provides
 6    concise presentations of methods, key results, observations, and related uncertainties. Chapter 5
 7    below discusses consideration of potential quantitative human health-related assessments for this
 8    review.
 9          The review process ends with the policy assessment and rulemaking phase. The Policy
10    Assessment (PA) is a document, prepared prior to issuance of proposed and final rules, that
11    provides a transparent presentation of OAQPS staff analysis and presents staff conclusions
12    regarding the adequacy of the current standards and, if revision is considered, what revisions
13    may be appropriate.  The PA integrates and interprets the information from the ISA and REA to
14    frame policy options for consideration by the Administrator. Such an evaluation of policy
15    implications is intended to help "bridge the gap" between the Agency's scientific assessments,
16    presented in the ISA and REA, and the judgments required of the EPA Administrator in
17    determining whether it is appropriate to retain or revise the NAAQS.  In so doing, the PA is also
18    intended to facilitate CAS AC's advice to the Agency and recommendations to the Administrator
19    on the adequacy of the existing standards or revisions that may be appropriate to consider, as
20    provided for in the CAA.  In evaluating the adequacy of the current standards and, as
21    appropriate, a range of alternative standards, the PA considers the available scientific evidence
22    and, as available, quantitative risk-based  analyses, together with related limitations and
23    uncertainties. The PA focuses on the information that is most pertinent to evaluating the basic
24    elements of national ambient air quality standards: indicator, averaging time, form, and level.
25    One or more drafts of a PA are released for CASAC review and public comment prior to
26    completion of the final PA.
27          Following issuance of the final PA and consideration of conclusions presented therein,
28    the Agency develops  and publishes a notice of proposed rulemaking that communicates the
29    Administrator's proposed decisions regarding the standards review. A draft notice undergoes
30    interagency review involving other federal agencies prior to publication.10  Materials upon
31    which this decision is based, including the documents described above, are made available to the
      10 Where implementation of the proposed decision would have an annual effect on the economy of $100 million or
      more, e.g., by necessitating the implementation of emissions controls, the EPA develops and releases a draft
      regulatory impact analysis (RIA) concurrent with the notice of proposed rulemaking. This activity is conducted
      under Executive Order 12866. The RIA is conducted completely independent of and, by statute, is not considered in
      decisions regarding the review of the NAAQS.
      Do Not Quote or Cite                    1-6                                    March 2013

-------
 1   public in the regulatory docket for the review.11  A public comment period, during which public
 2   hearings are generally held, follows publication of the notice of proposed rulemaking. Taking
 3   into account comments received on the proposed rule,12 the Agency develops a final rule which
 4   undergoes interagency review prior to publication to complete the rulemaking process. Chapter
 5   7 discusses the development of the PA and the rulemaking steps for this review.
 6
 7   1.3   HISTORY OF THE REVIEW OF AIR QUALITY CRITERIA FOR
 8   SULFUR OXIDES AND THE NAAQS FOR SULFUR DIOXIDE
 9          The  EPA completed the initial review of the air quality criteria for sulfur oxides in 1969
10   (34 FR 1988). Based on this review, the EPA in initially promulgating NAAQS for sulfur oxides
11   in 1971, established the indicator as SCh. The 1971 primary standards were set at 0.14 parts per
12   million (ppm) averaged over a 24-hour period, not to be exceeded more than once per year, and
13   0.030 ppm annual arithmetic mean.13 Since then, the Agency has completed multiple reviews of
14   the air quality criteria and standards, as summarized in Table 1-1.
15
     11 All documents in the docket are listed in the www.regulations.gov index. Publicly available docket materials are
     available either electronically at www.regulations.gov or in hard copy at the Air and Radiation Docket and
     Information Center. The docket ID number for this review is EPA-HQ-OAR-2013-0566.
     12 When issuing the final rulemaking, the Agency responds to all significant comments on the proposed rule.
     13 Note that 0.14 ppm is equivalent to 140 parts per billion (ppb) and 0.030 ppm is equivalent to 30 ppb.
     Do Not Quote or Cite                   1-7                                   March 2013

-------
 1
 2
    Table 1-1. History of the primary national ambient air quality standard(s) for sulfur
                                   dioxide since 197114
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
Final
Rule/Decision
1971
36 FR at 8186
Apr 30, 1971
1996
61FRat25566
May 22, 1996
2010
75 FR at 35520
June 22, 20 10
Indicator
SO2
Averaging
Time
24-hour and
Annual Avg
Level
24-hour: 140 ppb
Annual Avg: 30
ppb15
Form
24-hour std: one
allowable exceedance
Annual std: Annual
arithmetic average
Both the 24-hour and annual average standards retained without revision
S02
1-hour
75 ppb
99th percentile,
averaged over 3
years16
24-hour and annual SO2 standards revoked.
       In 1982, the EPA published the Air Quality Criteria for P articulate Matter and Sulfur
Oxides (U.S. EPA 1982) along with an addendum of newly published controlled human
exposure studies, which updated the scientific criteria upon which the initial standards were
based (U.S. EPA 1982). In 1986, a second addendum was published presenting newly available
evidence from epidemiologic and controlled human exposure studies (U.S. EPA 1986). In 1988,
the EPA published a proposed decision not to revise the existing standards (53 FR 14926).
However, the EPA specifically requested public comment on the alternative of revising the
current standards and adding a new 1-hour primary standard of 0.4 ppm to protect against short-
term peak exposures.
       As a result of public comments on the 1988 proposal and other post-proposal
developments, the EPA published a second proposal on November 15, 1994 (59 FR 58958). The
1994 re-proposal was based in part on a supplement to the  second addendum of the criteria
document, which evaluated new findings on short-term SCh exposures in asthmatics (U.S. EPA
1994). As in the 1988 proposal, the EPA proposed to retain the existing 24-hour and annual
standards. The EPA also solicited comment on three regulatory alternatives to further reduce the
health risk posed by exposure to high 5-minute peaks of SCh if additional protection were judged
     14 In 1971 (36 FR 8186), a 3-hour secondary standard was set at 500 ppb to provide protection against adverse
     welfare effects.
     15 The initial level of the 24-hr SO2 standard was 0.140 ppm which is equal to 140 ppb. The initial level of the
     annual SO2 standard was 0.03 ppm which is equal to 30 ppb.
     16The form of the 1-hour standard is the 3-year average of the 99th percentile of the yearly distribution of 1-hour
     daily maximum SO2 concentrations.
     Do Not Quote or Cite
                                        1-8
March 2013

-------
 1    to be necessary. The three alternatives were: 1) Revising the existing primary SCh NAAQS by
 2    adding a new 5-minute standard of 0.60 ppm SCh; 2) establishing a new regulatory program
 3    under section 303 of the Act to supplement protection provided by the existing NAAQS, with a
 4    trigger level of 0.60 ppm SCh, one expected exceedance; and 3) augmenting implementation of
 5    existing standards by focusing on those sources or source types likely to produce high 5-minute
 6    peak concentrations of SCh.
 7          In assessing the regulatory options mentioned above, the Administrator concluded that
 8    the likely frequency of 5-minute concentrations of concern should also be a consideration in
 9    assessing the overall public health risks.  Based upon an exposure analysis conducted by the
10    EPA, the Administrator concluded that exposure of asthmatics to SCh at levels that can reliably
11    elicit adverse health effects was likely to be a rare event when viewed in the context of the entire
12    population of asthmatics.  As a result, the Administrator judged that 5-minute peak SCh levels
13    did not pose a broad public health problem when viewed from a national perspective, and a 5-
14    minute standard was not promulgated. In addition, no other regulatory alternative was finalized
15    and the 24-hour and annual average primary SCh standards were retained in  1996 (61 FR 25566).
16          The American Lung Association and the Environmental Defense Fund challenged EPA's
17    decision not to establish a 5-minute standard. On January 30, 1998, the Court of Appeals for the
18    District of Columbia found that the EPA had failed to adequately explain its determination that
19    no revision to the SCh NAAQS was appropriate and remanded the decision back to EPA for
20    further explanation. Specifically, the court required the EPA to provide additional rationale to
21    support the Agency judgment that 5-minute peaks of SCh do not pose a public health problem
22    from a national perspective even  though these peaks will likely cause adverse health impacts in a
23    subset of asthmatics. In response, the EPA collected and analyzed additional air quality data
24    focused on 5-minute concentrations of SCh and used this information to inform the last review of
25    the SO2 NAAQS.
26          On June 22, 2010, the EPA revised the primary SO2 NAAQS to provide requisite
27    protection of public health with an adequate margin of safety. Specifically, after concluding that
28    the then-existing 24-hour and annual standards were inadequate to protect public health with an
29    adequate margin of safety (see section 3.1.1), the EPA established a new  1-hour SO2 standard at
30    a level of 75 ppb, based on the 3-year average of the annual 99th percentile of 1-hour daily
31    maximum concentrations (see section 3.1.2).  This standard was promulgated to provide
32    substantial protection against SO2-related health effects associated with short-term exposures
33    ranging from 5-minutes to 24-hours. More specifically, EPA concluded that a 1-hour SO2
34    standard at 75 ppb would provide substantial protection against the adverse respiratory effects
35    (e.g., decrements in lung function and/or respiratory symptoms) reported in exercising asthmatics
36    following 5-10 minute exposures in controlled human exposure studies, as well as the more
      Do Not Quote or Cite                   1-9                                  March 2013

-------
 1    serious health associations reported in epidemiologic studies of mostly 1- and 24-hours (e.g.,
 2    respiratory-related emergency department visits and hospitalizations).  In the last review, the
 3    EPA also revoked the then-existing 24-hour and annual primary standards because neither of
 4    these standards would likely provide additional public health protection given a 1-hour standard
 5    at 75 ppb (see section 3.1.2).  The decision to set a 1-hour standard at 75 ppb to in part, provide
 6    substantial protection against 5- minute concentrations of SCh resulting in adverse respiratory
 7    effects in exercising asthmatics, also satisfied the DC Circuit Court remand of 1996.
 8          As mentioned above, in the last review substantial weight was placed on preventing
 9    health effects associated with 5-minute peak SCh concentrations. Thus, as part of the final
10    rulemaking, the EPA for the first time required state reporting of either the highest 5-minute
11    concentration for each hour of the day, or all twelve 5-minute concentrations for each hour of the
12    day (see chapter 6).  The rationale for this requirement was that this additional monitored data
13    could then be used in future reviews to evaluate the extent to which the 1-hour SCh NAAQS at
14    75 ppb provides protection against 5-minute peaks of concern.
15          After publication of the final rule, a number of industry groups and states filed petitions
16    for review maintaining that the 1-hour SCh NAAQS at 75 ppb was overly stringent or otherwise
17    arbitrary. The D.C. Circuit rejected these challenges, upholding the standard in its  entirety.
18    National Environmental Development Association's Clean Air Project v. EPA, 686 F. 3d 803
19    (D.C. Cir. 2012).
20
21    1.4   SCOPE OF THE CURRENT REVIEW
22          Sulfur oxides include all forms of oxidized sulfur compounds including the gases SCh
23    and SCb as well as their gaseous and particulate reaction products (e.g., sulfates; see 34 FR
24    1988).  As in previous reviews of the SCh NAAQS, this review will focus on effects associated
25    with the gaseous species only. Effects associated with the particulate species (e.g., sulfate) are
26    addressed in the review of the NAAQS for particulate matter (PM) (78 FR 30866, January 15,
27    2013; U.S. EPA 2009).
28          Consistent with the review completed in 2010, this review is focused on the primary SCh
29    standard and as such, will only consider relevant scientific information related to potential health
30    effects associated with exposure to sulfur oxides.  The EPA is separately reviewing the
31    secondary SCh standard in conjunction with a review of the secondary NCh standard (78 FR
32    53452, August 29, 2013).17
      17 Additional information on the ongoing review of the secondary NO2 and SO2 standards is available at:
      http://www.epa.gov/ttn/naaqs/standards/no2so2sec/index.html.
      Do Not Quote or Cite                   1-10                                   March 2013

-------
                    2.     STATUS AND SCHEDULE

       In May of 2013, the EPA announced the initiation of the current periodic review of the
air quality criteria for SOx and the primary SCh NAAQS, and also issued a call for information
in the Federal Register (78 FR 27387).  Also, as an initial step in the NAAQS review process
described in Section 1.1 above, EPA invited a wide range of external and internal EPA experts,
representing a variety of areas of expertise (e.g., epidemiology, human and animal toxicology,
statistics, risk/exposure analysis, atmospheric science), to participate in a workshop to discuss
the policy-relevant science to inform development of this plan. This workshop was held June
12-13, 2013, in Research Triangle Park, NC (78 FR 27387). This workshop provided an
opportunity for the participants to broadly discuss the key policy-relevant issues around which
EPA would structure the SCh NAAQS review and to discuss the most meaningful new science
that would be available to inform our understanding of these issues.  Based in part on the
workshop discussions, the EPA developed this draft IRP outlining the schedule, the process, and
the policy-relevant science issues identified as key to guiding the evaluation of the  air quality
criteria for sulfur oxides and the review of the primary SCh NAAQS.
       Table 2-1 outlines the schedule under which the Agency is currently conducting this
review. The scope of the review and the key documents to be prepared during the review are
discussed throughout the rest of this document.
Do Not Quote or Cite                   2-1                                  March 2014

-------
                 Table 2-1. Anticipated schedule for the SO2 NAAQS Review
 Stage of Review
Major Milestone
Draft Target Date
Integrated Plan (IRP)





Integrated Science
Assessment (ISA)



Risk/Exposure
Assessment (REA)
Literature Search
Call for Information
Workshop on science/policy issues
Draft IRP
CASAC/public review on draft IRP
Final IRP
First draft ISA
CASAC/public review first draft ISA
Second draft ISA
CASAC/public review second draft ISA
Final ISA
REA Planning Document
CASAC consultation/public review REA
Ongoing
May 10, 2013
June 12-13 2013
March 20 14
April 22, 2014
July 2014
October 20 14
January 2015
July 2015
October 20 15
January 2016
February 2015
March 20 15
                         Planning Document
                         If warranted:
                            First draft REA
                            CASAC/public review of first draft REA
                            Second draft REA
                            CASAC/public review of second draft REA
                            Final REA
 Policy Assessment
 (PA)/Rulemaking
First Draft PA                                September 2015

CASAC review/public review first draft PA       October 2015
Second Draft PA (if warranted)                 June 2016
CASAC/public review second draft PA           July 201619
Final PA                                    December 2016
Notice of proposed rulemaking                 May 2017
Notice of final rulemaking                     February 2018
18 An updated REA may not be warranted for the reviews of the SO2 primary NAAQS
19The anticipated schedule presented in Table 2-1 includes preparation of two draft PAs for CASAC and public
review. In NAAQS reviews in which the newly available information calls into question the adequacy of the current
standard(s), a second draft PA is typically prepared to include staff consideration of potential alternative standards.
However, in NAAQS reviews where a new REA is not developed and where staff preliminarily conclude in a first
draft PA that it is appropriate to consider retaining the current standards without revision, the EPA may decide that
there is no new substantive information that we would intend to add that would provide a basis for preparing a
second draft PA. If the Agency determines that a second draft PA is not warranted, CASAC and public comments
on the first draft PA will be considered in preparing the final PA and the schedule for the review will be revised
accordingly.
Do Not Quote or Cite
                   2-2
                 March 2014

-------
 i                 3.     KEY POLICY-RELEVANT ISSUES

 2          The overarching question in each NAAQS review is:
 3            •  Does the currently available scientific evidence and exposure/risk-based
 4               information support or call into question the adequacy of the protection
 5               afforded by the current standard(s)?
 6          As appropriate, a review also addresses a second overarching question:
 7            •  What alternative standard(s), if any, are supported by the currently available
 8               scientific evidence and exposure/risk-based information and are appropriate
 9               for consideration?
10          To inform our consideration of these overarching questions in the current review, we have
11   identified key policy-relevant issues to be considered. These key issues reflect aspects of the
12   health effects evidence, air quality information, and exposure/risk information that, in our
13   judgment, are likely to be particularly important to informing the Administrator's decisions.
14   They build upon the key  issues that were important in previous reviews.
15          Section 3.1 below describes the key considerations and conclusions from the last review
16   with regard to the adequacy of the then-current primary SCh standards (section 3.1.1), and with
17   regard to the elements for a revised standard judged in that review to provide requisite public
18   health protection (section 3.1.2). Section 3.2 summarizes our general approach for reviewing the
19   primary SCh standard in the current review and outlines the key policy-relevant issues. These
20   issues are presented as a  series of questions that will frame our approach to considering the
21   extent to which the available  evidence and information support retaining or revising the current
22   primary standard for SCh.
23
24   3.1    CONSIDERATIONS AND CONCLUSIONS IN LAST REVIEW
25          The last review of the primary NAAQS for SCh was completed in 2010 (75 FR at 35520,
26   June 22, 2010). In that review, the EPA considered key controlled human exposure studies from
27   previous reviews as well  as the significantly expanded body of health effects evidence that had
28   emerged since the last review was completed in 1996.20  In addition, EPA also considered
29   exposure and risk estimates regarding potential respiratory effects in exercising asthmatics
30   following 5-10 minute exposures to SCh, as well as CASAC advice and public comments.
31   Taking all this information together, the EPA established a new short-term standard to provide
     20 Documents related to the SO2 NAAQS reviews completed in 2010 and 1996 are available at:
     http://www.epa.gov/ttn/naaqs/standards/so2/s_so2_index.html

     Do Not Quote or Cite                   3-1                                  March 2014

-------
 1    increased protection for asthmatics and other at-risk populations21 against an array of adverse
 2    respiratory effects that have been linked to short-term SCh exposures in both controlled human
 3    exposure and epidemiologic studies (75 FR at 35525 to 35527 and U.S. EPA 2008, section 5.5).
 4    Specifically, the EPA established a short-term standard defined by the 3-year average of the 99th
 5    percentile of the yearly distribution of 1-hour daily maximum SCh concentrations, with a level of
 6    75 ppb. In addition to setting a new short-term standard, the then-existing 24-hour and annual
 7    standards were revoked based largely on the recognition that a 1-hour standard set at 75 ppb
 8    would have the effect of generally maintaining 24-hour and annual SCh concentrations well
 9    below the levels of those standards (75 FR at 35550).
10           Key policy-relevant aspects of the Administrator's decisions with regard to the need to
11    revise the primary SCh NAAQS, and with regard to the elements of the revised standard, are
12    described below in sections 3.1.1 and 3.1.2, respectively. Areas of uncertainty identified in the
13    last review are noted in section 3.1.3.
14
15    3.1.1  Need for Revision
16           The Administrator concluded in the last review that the then-existing 24-hour and annual
17    SCh standards were not adequate to protect public health,  including the health of at-risk
18    populations, from the effects associated with short-term exposures to SCh (75 FR at 35520, June
19    22, 2010).  As described below, this conclusion was based on the extensive body of health
20    evidence assessed in the 2008 ISA (U.S.  EPA 2008), including the assessment of the policy -
21    relevant aspects of that evidence,22 quantitative exposure and risk analyses presented in the 2009
22    REA (U.S. EPA 2009), public comments, and the advice and recommendations of CASAC
23    (Samet, 2009).
24           As an initial consideration in reaching this conclusion, the Administrator noted the ISA
25    judgement that the findings of controlled human exposure, epidemiologic, and animal
26    toxicological studies collectively provided evidence "sufficient to infer a causal relationship "
27    between short-term SCh exposures ranging from 5-minutes to 24-hours and respiratory morbidity
28    (75 FR at 35535). The ISA described the "definitive evidence" for this conclusion as being the
29    results of 5-10 minute controlled human exposure studies demonstrating decrements in lung
      21 As used here and similarly throughout this document, the term population refers to persons having a quality or
      characteristic in common, such as a specific pre-existing illness or a specific age or lifestage. A lifestage refers to a
      distinguishable time frame in an individual's life characterized by unique and relatively stable behavioral and/or
      physiological characteristics that are associated with development and growth. Identifying at-risk populations
      includes consideration of intrinsic (e.g., genetic or developmental aspects) or acquired (e.g., disease or smoking
      status) factors that increase the risk of health effects occurring with exposure to sulfur oxides as well as extrinsic,
      nonbiological factors such as those related to socioeconomic status, reduced access to health care, or exposure.
      22 As noted in section 1.3 above, due to changes in the NAAQS process, the last review of the SO2 NAAQS did not
      include a separate Policy Assessment. Rather, the REA for that review included a Policy Assessment chapter.

      Do Not Quote or Cite                    3-2                                    March 2014

-------
 1    function and/or respiratory symptoms in exercising asthmatics (U.S. EPA 2008, section 5.2).  In
 2    brief, the ISA examined numerous controlled human exposure studies and found that moderate
 3    or greater decrements in lung function (i.e., > 15% decline in Forced Expiratory Volume (FEVi)
 4    and/or > 100% increase in specific airway resistance (sRaw)) occurred in some exercising
 5    asthmatics exposed to SCh concentrations as low as 200-300 ppb for 5-10 minutes. The ISA also
 6    found that among asthmatics, both the percentage of individuals affected, and the severity of the
 7    response increased with increasing SCh concentrations. That is, at 5-10 minute concentrations
 8    ranging from 200-300 ppb, the lowest levels tested in free breathing chamber studies,
 9    approximately 5-30% percent of exercising asthmatics experienced moderate or greater
10    decrements in lung function (U.S. EPA 2008, Table 3-1). At concentrations of 400-600 ppb,
11    moderate  or greater decrements in lung function occurred in approximately 20- 60% of
12    exercising asthmatics, and compared to exposures at 200-300 ppb, a larger percentage of
13    asthmatics experienced severe decrements in lung function (i.e., > 20% decrease in FEVi and/or
14    > 200% increase in sRaw; U.S. EPA 2008, Table 3-1). Moreover, at SCh concentrations > 400
15    ppb, moderate or greater decrements in lung function were often statistically significant at the
16    group mean level and were frequently accompanied by respiratory symptoms (U.S. EPA 2008,
17    Table 3-1).
18          In considering the controlled human exposure studies with respect to adequacy of the
19    then-current standards, the Administrator first judged that 5-10 minute SCh exposures > 400 ppb
20    and > 200 ppb can result in adverse health effects in exercising asthmatics (75 FR at 35536).
21    This judgment was based on ATS guidelines, explicit CASAC consensus written advice, as well
22    as recommendations and judgments made by EPA in previous NAAQS reviews (see 75 FR at
23    35526 and 75 FR at 35536). The Administrator therefore particularly noted analyses in the REA
24    that utilized benchmark concentrations derived from the controlled human exposure evidence.  In
25    the REA,  5-minute benchmark concentrations ranged from 100 ppb to 400 ppb (see below,
26    section 5.1), with 5-minute benchmark concentrations of 200 ppb and 400 ppb noted by the
27    Administrator as being particularly important. These benchmark levels were highlighted because
28    in free-breathing controlled human exposure studies: (1) 400 ppb represented the lowest
29    concentration at which moderate or greater lung function decrements occurred which were often
30    statistically significant at the group mean level and were frequently accompanied by respiratory
31    symptoms; and (2) 200 ppb was the lowest level at which moderate or greater decrements  in lung
32    function were found in some individuals.23
33          Given the emphasis on the 200 ppb and 400 ppb benchmarks, the Administrator
34    particularly noted the modeled exposure analysis results for the St. Louis case study presented in
      23 200 ppb was also the lowest level tested in free-breathing controlled human exposure studies.

      Do Not Quote or Cite                  3-3                                  March 2014

-------
 1    the REA (see below, section 5.1). This analysis estimated that given air quality simulated to just
 2    meet the then-existing SCh NAAQS, substantial percentages of asthmatic children at moderate or
 3    greater exertion would be exposed, at least once annually, to air quality exceeding the 200 ppb
 4    and 400 ppb 5-minute benchmarks (75 FR at 35536).  The Administrator judged these 5-minute
 5    exposures to be significant from a public health perspective due to their estimated frequency:
 6    approximately 24% of asthmatic children at moderate or greater exertion in St. Louis were
 7    estimated to be exposed at least once per year to air quality exceeding the 5- minute 400 ppb
 8    benchmark. Additionally, approximately 73% of asthmatic children in St. Louis at moderate or
 9    greater exertion were estimated to be exposed at least once per year to air quality exceeding the
10    5-minute 200 ppb benchmark (75 FR at 35536).
11          With respect to the epidemiologic evidence, the ISA characterized epidemiologic studies
12    of respiratory symptoms, emergency department visits and hospital admissions as providing
13    "supporting evidence" for the causal relationship between short-term exposure to SCh and
14    respiratory morbidity. The ISA found that numerous epidemiologic studies reported positive
15    associations between ambient SCh concentrations and respiratory symptoms in children, as well
16    as emergency department visits and hospitalizations for all respiratory causes and asthma across
17    multiple age groups. The ISA concluded that these epidemiologic studies were consistent and
18    coherent. This evidence was consistent in that associations were reported in studies conducted in
19    numerous locations and with a variety of methodological approaches (U.S. EPA 2008, section
20    5.2). It was coherent in that respiratory symptom results from epidemiologic studies of short-
21    term (predominantly 1-hour  daily maximum or 24-hour average) SCh concentrations were
22    generally in agreement with  respiratory symptom  results from controlled human exposure studies
23    of 5-10 minutes.  Moreover, while recognizing the uncertainties associated with separating the
24    effects of SCh from those of co-occurring pollutants, the ISA concluded that' 'the limited
25    available evidence indicates  that the effect of SCh on respiratory health outcomes appears to be
26    generally robust and independent of the effects of gaseous co-pollutants, including NCh and Cb,
27    as well as particulate copollutants, particularly PIVfo.s" (U.S. EPA 2008, section 5.3).
28          In considering the epidemiologic evidence, the Administrator acknowledged uncertainties
29    with these  studies (e.g.,  potential confounding by  co-pollutants), but agreed with judgments in
30    the ISA that the epidemiologic evidence, supported by the controlled human exposure evidence,
31    generally indicated that  the effects seen in these studies were attributable to exposure to SCh,
32    rather than co-pollutants. With respect to the adequacy of the SCh NAAQS, the Administrator
33    noted that many of these epidemiologic studies reported associations between short-term (mostly
34    1-hour daily maximum and 24-hour average) SCh concentrations and respiratory symptoms,
35    emergency department visits, and hospital admissions in locations meeting the then-existing 24-
      Do Not Quote or Cite                   3-4                                  March 2014

-------
 1    hour and annual standards (75 FR at 35535), thereby further indicating that the these standards
 2    were not adequately protecting public health.
 3          The Administrator also agreed with specific CASAC advice when reaching the decision
 4    that the then-existing standards were not adequate to protect public health with an adequate
 5    margin of safety. Specifically, CASAC advised that: "the current 24-hour and annual standards
 6    are not adequate to protect public health, especially in relation to short-term exposures to SCh
 7    (5-10  minutes) by exercising asthmatics" (Samet, 2009, p. 15).
 8          Based on the considerations summarized above, the Administrator concluded that the
 9    then-existing 24-hour and annual primary SChNAAQS were not adequate to protect public
10    health with an adequate margin of safely and that these standards should be revised in order to
11    provide increased public health protection against respiratory effects associated with short-term
12    exposures, particularly for susceptible populations such as asthmatics and children. Upon
13    consideration of approaches to revising these standards, the Administrator concluded that it was
14    appropriate to set a new short-term standard, as described below.
15    3.1.2  Elements of a Revised Standard
16          When considering alternative standards to provide requisite public health protection, the
17    Administrator concluded it was appropriate to set a new 1-hour SCh standard at a level of 75 ppb,
18    based  on the 3-year average of the 99th percentile of the yearly distribution of 1-hour daily
19    maximum concentrations. The rationale and approach for setting the 1-hour standard is
20    presented below in terms of the individual elements of a NAAQS: indicator, averaging time,
21    form, and level. Notably, given a new 1-hour standard  at 75 ppb, the previous 24-hour and
22    annual standards were revoked because neither of these standards was likely to provide
23    additional public health protection (74 FR at 35550).
24    Indicator
25          In previous reviews, the EPA focused on SCh as the most appropriate indicator for sulfur
26    oxides because the available scientific information regarding health effects was overwhelmingly
27    indexed by SCh. In the most recent review, this continued to be the case. Controlled human
28    exposure  studies and animal toxicological studies provided specific evidence for health effects
29    following exposures to SCh. In addition, epidemiologic studies typically reported effects
30    associated with SCh concentrations. Thus, based on the information available in the last review
31    and consistent with the views of  CASAC that: ' 'for indicator, SCh is clearly the preferred
32    choice" (Samet 2009, p. 14), the Administrator concluded it was appropriate to continue to use
33    SCh as the indicator for a standard that was intended to address effects associated with exposure
34    to SCh, alone  or in combination with other gaseous sulfur oxides (75 FR at 35536).  In so doing,
35    the EPA recognized that measures leading to reductions in population exposures to SCh will also
36    likely  reduce exposures to other  sulfur oxides (75 FR at 35536).

      Do Not Quote or Cite                   3-5                                   March 2014

-------
 1    Averaging Time
 2           When considering the level of support available for specific averaging times, the
 3    Administrator first considered the strength of evidence from controlled human exposure and
 4    epidemiologic studies. As noted above (see section 3.1.1), controlled human exposure studies
 5    exposed exercising asthmatics to SCh for 5 -10 minutes and consistently found decrements in
 6    lung function and/or respiratory symptoms. Importantly, the ISA described the controlled human
 7    exposure studies as being the "definitive evidence" for its conclusion that there existed a causal
 8    relationship between short-term (5-minutes to 24-hours) SCh exposure and respiratory morbidity
 9    (U.S. EPA 2008, section 5.2). Supporting the controlled human exposure evidence were
10    epidemiologic studies describing positive associations between short-term (e.g., 1-hour daily
11    maximum and 24-hour average) SCh levels and respiratory symptoms as well as hospital
12    admissions and emergency department visits for all respiratory causes and asthma (U.S. EPA
13    2008, Tables 5.4 and 5.5).  Taken together, it was judged that controlled human exposure studies
14    provided support for an averaging time that protected against 5-10 minute peak exposures, while
15    epidemiologic evidence provided support for an averaging time that protected against both 1-
16    hour and 24-hour exposures (U.S. EPA 2009, section 10.5.2.1).24
17           In further considering an appropriate averaging time, the Administrator took into account
18    air quality analyses from the REA examining the potential for 24-hour and 1-hour averaging
19    times to protect against 5-minute peak concentrations. Results of these analyses suggested that a
20    standard based on 24-hour average SCh concentrations would not likely be an effective or
21    efficient approach for addressing 5-minute peak SCh concentrations. That is, using a 24-hour
22    average standard to address 5-minute peaks would likely result in over-controlling in some areas,
23    while under-controlling in others (U.S. EPA 2009, section 10.5.2.2). In contrast, these analyses
24    suggested that a standard with a 1-hour averaging time would be more efficient and effective at
25    limiting 5-minute peaks of SCh (U.S. EPA 2009, section 10.5.2.2).  In additional air quality
26    analyses, the REA suggested that a 1-hour standard (given an appropriate form  and level) could
27    likely provide protection against 99th percentile 1-hour daily maximum and 99th percentile 24-
28    hour average SCh concentrations found in locations where emergency department visit and
29    hospital admission studies using multi-pollutant models with PM reported statistically significant
30    associations with ambient SCh (75 FR at 35539 and U.S. EPA 2009, section 10.5.2.2). 25
31    Considering this information, the Administrator concluded that a 1-hour standard (given an
      24 The ISA did note that effects observed in epidemiologic studies also may have been due, at least in part, and
      especially in 24-hour epidemiologic studies, to shorter-term peaks of SCh (see U.S. EPA 2008, section 5.2). More
      specifically, the ISA noted "that it is possible that these associations are determined in large part by peak exposures
      within a 24-hour period" (U.S. EPA 2008, section 5.2).
      25 Since SO2 is a pre-cursor to PM (e.g., sulfates), there was special consideration given to epidemiologic studies that
      used multipollutant models to separate the estimated SC>2 associations from that of PM.

      Do Not Quote or Cite                   3-6                                   March 2014

-------
 1    appropriate form and level) was an appropriate means of controlling short-term exposures to SCh
 2    ranging from 5-minutes to 24-hours (74 FR at 35539).
 3          The Administrator further noted that establishing a 1-hour averaging time was in
 4    agreement with CASAC recommendations (74 FR at 35539). That is, CASAC stated that they
 5    were "in agreement with having a short-term standard and finds that the RE A supports a one-
 6    hour standard as protective of public health" (Samet 2009, p. 1).  CASAC also stated that a
 7    "one-hour standard is the preferred averaging time'' (Samet 2009, p. 15).
 8          Based solely on the controlled human exposure evidence, the Administrator also
 9    considered a 5-minute averaging time in the last review. However, such an approach was not
10    favored. With respect to a 5-minute standard, there were concerns about standard stability.
11    Specific concerns related to the number of monitors  needed and the placement of such monitors
12    given the temporal and spatial heterogeneity of 5-minute SCh concentrations (74 FR at 35539).
13    However, as noted above, the Administrator judged that a 1-hour averaging time, given an
14    appropriate form and level, could adequately limit 5-minute SCh exposures and provide a more
15    stable regulatory target than setting a 5-minute standard. Consequently, the Administrator judged
16    that a 5-minute averaging time was not the preferred approach to provide adequate public health
17    protection (74 FR at 35539).
18    Form
19          The "form" of a standard defines the air quality statistic that is to be compared to the
20    level of the standard in determining whether an area attains the NAAQS.  In the last review,
21    controlled human exposure evidence presented in the ISA indicated that the percentage of
22    asthmatics affected and the severity of the response increased with increasing SCh
23    concentrations. Thus, a concentration-based form averaged over three years was judged by the
24    Administrator to be most appropriate (74 FR at 35541). This was because compared to an
25    exceedance-based form, a concentration-based form averaged over three years would give more
26    weight to years when 1-hour SCh concentrations  are well above the level of the standard, than to
27    years when 1- hour SCh concentrations are just above the level of the standard. The
28    Administrator also noted that a concentration-based  form averaged over 3 years would likely be
29    appreciably more stable than a no exceedance-based form (75 FR at 35541). Establishing a
30    concentration-based form was also in agreement with specific CASAC  advice stating that' 'there
31    is adequate information to justify the use of a concentration-based form averaged over 3 years''
32    (Samet 2009, p.  16)
33          In selecting a specific concentration-based form, the Administrator considered health
34    evidence from the ISA as well as air quality and exposure information from the REA. In the ISA,
35    it was noted that a few epidemiologic studies reported an increase in SCh-related respiratory
36    health effects at the upper end of the distribution  of ambient SCh concentrations (i.e., above 90th


      Do Not Quote or Cite                   3-7                                   March 2014

-------
 1    percentile SCh concentrations; see U.S. EPA 2008, section 5.3). In the REA, air quality and
 2    exposure analyses suggested that a 99th percentile form was likely to be appreciably more
 3    effective at limiting 5-minute peak exposures of concern than a 98th percentile form (at a given
 4    standard level; U.S. EPA 2009, section 10.5.3, and U.S. EPA 2009, Figures 7-27 and 7-28).
 5    Taken together, the Administrator concluded that a 99th percentile form (at an appropriate level)
 6    would limit both the upper end of the distribution of ambient SCh concentrations reported in
 7    some epidemiologic studies to be associated with increased risk of SCh-related respiratory
 8    morbidity effects (e.g., emergency department visits), as well as 5-minute peak SCh
 9    concentrations resulting in decrements in lung function and/or respiratory symptoms in
10    controlled human exposure studies (75 FR at 35541).
11    Level
12          Controlled human exposure evidence was described in the ISA as providing the definitive
13    evidence for a causal association between short-term exposure to SCh and respiratory morbidity.
14    The Administrator therefore placed considerable emphasis on these studies when selecting the
15    level of a new 1-hour standard. In particular, the Administrator wanted the level of a 1-hour
16    standard to provide substantial protection against the 200 ppb and 400 ppb 5-minute benchmarks
17    identified from these studies. As noted above (see section 3.1.1), these benchmark levels were
18    highlighted because in free-breathing controlled human exposure studies of exercising
19    asthmatics: (1) 400 ppb represented the lowest concentration where moderate or greater lung
20    function decrements occurred which were often statistically significant at the group mean level
21    and were frequently accompanied by respiratory symptoms;  and (2) 200 ppb was the lowest level
22    at which moderate or greater decrements in lung function were found in some asthmatics.26
23          Analyses in the REA described the varying degrees of protection different 1-hour
24    standard levels could provide against 5-minute benchmark concentrations of 200 ppb and 400
25    ppb (see below section 5.1).  Considering these analyses, the Administrator judged that a 1-hour
26    standard level of 100 ppb would appropriately limit the occurrence  of 5-minute benchmark
27    concentrations > 200 or 400 ppb (74 FR at 35547).  That is, the St. Louis exposure simulation
28    estimated that a 1-hour standard at 100 ppb would likely protect > 99% of asthmatic children in
29    that city  at moderate or greater exertion from experiencing at least one 5-minute exposure > 400
30    ppb per year, and approximately 97% of those asthmatic children at moderate or greater exertion
31    from experiencing at least one exposure > 200 ppb per year (74 FR at 35547). Moreover, the
32    40-county air  quality analysis from the REA (see below section 5.1) estimated that a 100 ppb 1-
33    hour standard would allow at most 2 days per year on average in any county when estimated 5-
34    minute daily maximum SCh  concentrations exceed the 400 ppb benchmark, and at most 13 days
      26 As noted in section 3.1.1, 200 ppb was also the lowest level tested in free-breathing controlled human exposure
      studies.

      Do Not Quote or Cite                   3-8                                  March 2014

-------
 1    per year on average when 5-minute daily maximum SCh concentrations exceed the 200 ppb
 2    benchmark27 (74 FR at 35546). Furthermore, given a simulated 1-hour 100 ppb standard level,
 3    most of the counties in that air quality analysis were estimated to experience 0 days per year on
 4    average when 5-minute daily maximum SCh concentrations exceed the 400 ppb benchmark and
 5    < 3 days per year on average when 5-minute daily maximum  SCh concentrations were estimated
 6    to exceed the 200 ppb benchmark (74 FR at 35546).
 7           In considering the epidemiologic evidence with respect to level, the Administrator noted
 8    that there were more than 50 peer-reviewed epidemiologic studies published worldwide
 9    evaluating SCh since the prior review (75 FR at 35547). The Administrator also noted that these
10    studies generally reported positive, although not always statistically significant associations
11    between more serious health outcomes (i.e. respiratory-related emergency department visits and
12    hospitalizations) and ambient SCh concentrations (75 FR at 35547). She further agreed with the
13    ISA finding that the controlled human exposure evidence lends biological plausibility to the
14    effects reported in epidemiologic studies (75 FR at 35547), and that when evaluated as a whole,
15    the results of epidemiologic studies were generally independent of the effects of gaseous and
16    particulate co-pollutants (74 FR at 35544 and 75 FR 35547).  Taken together, the Administrator
17    judged it appropriate to place emphasis on the epidemiologic evidence when further considering
18    the appropriate level of a new 1-hour standard.
19           In considering the epidemiologic evidence with respect to level, the Administrator placed
20    primary emphasis on ten U.S. epidemiologic studies (some conducted in multiple locations)
21    reporting mostly positive and sometimes statistically significant associations between ambient
22    SCh concentrations and emergency department visit and hospital admissions in locations where
23    99th percentile 1-hour daily maximum SCh levels ranged from approximately 50-460 ppb  (74 FR
24    at 35547). The Administrator further noted that within this broader range of SCh concentrations
25    there was a cluster of three epidemiologic studies between 78-150 ppb (for the 99th percentile of
26    the 1-hour daily maximum SCh concentrations) where  the SCh effect estimate remained positive
27    and statistically significant in multipollutant models with PM (NYDOH (2006), Ito et al., (2007),
28    and Schwartz et al., (1995)).  The Administrator judged these three studies were of particular
29    relevance because they  supported both the conclusion that SCh effects were generally
30    independent of PM and that these associations occurred in cities with 1-hour daily maximum,
31    99th percentile concentrations in the range of 78-150 ppb (74 FR at 35547).
32           Weighing all of the evidence  presented above, the Administrator concluded that the
33    epidemiologic studies provided strong support for setting a standard that limited the 99th
      27 The REA considered 5-minute air quality data reported from the existing network of ambient monitors. However,
      since the number and geographic scope of monitors reporting 5-minute SO2 concentrations was very limited, the
      REA used statistically estimated 5-minute concentrations derived from measured 1-hour SO2 concentrations in the
      40 county air quality analysis (see below, section 5.1).

      Do Not Quote or Cite                   3-9                                   March 2014

-------
 1    percentile of the distribution of 1-hour daily maximum SCh concentrations to 75 ppb. This
 2    judgment took into account the strong determinations in the ISA, based on a much broader body
 3    of evidence, that there is a causal relationship between exposure to SCh and the types of
 4    respiratory morbidity effects reported in these studies (74 FR at 35548).  This judgement also
 5    considered that a standard level of 75 ppb was consistent with the range of levels recommended
 6    by CASAC (75 FR at 35548).  Finally, the Administrator acknowledged that there were some
 7    epidemiologic studies suggesting effects due to SCh at concentrations as low as 50 ppb, but did
 8    not find that evidence strong enough to warrant a standard at that level or below (74 FR at
 9    35548).
10    Revoking the Then-Existing 24-hour and Annual Standards
11          In addition to setting a new 1-hour standard at  75 ppb,  the then-current 24-hour and
12    annual standards were revoked in the last review based largely on the recognition that a 1-hour
13    standard set at 75 ppb would have the effect of generally maintaining 24-hour and annual SCh
14    concentrations well below the levels of those standards (75 FR at 35550). In addition, the annual
15    standard was also revoked because of the lack of evidence supporting a relationship between
16    long-term SCh exposures and adverse health effects. That is, the ISA judged the health evidence
17    linking long-term SCh exposure to adverse health effects to be "inadequate" to infer the presence
18    or absence of a causal relationship (75 FR at 35550 and U.S EPA 2008, section 5.5).
19    3.1.3 Areas of Uncertainty
20          While the available scientific information informing the review completed in 2010 was
21    stronger and more consistent than in previous reviews  and provided a strong basis for decisions
22    made in that review,  the Agency recognized that important uncertainties and limitations remain
23    in our understanding of several policy-relevant issues.  These uncertainties were generally
24    related to:  (1) statistical relationships between 5-minute concentrations and longer averaging
25    times (e.g., 1-hour, 3-hour, 24-hour), including the extent to which these longer averaging times
26    can limit 5-minute concentrations of concern (i.e., 5-minute benchmarks) identified from
27    controlled human exposure studies; (2) understanding the role of SCh within the complex
28    ambient mixture of co-occurring pollutants (e.g., PM2.5, ozone, NCh); (3) understanding the
29    range of ambient concentrations in which we have confidence that the health effects observed in
30    epidemiologic studies are attributable to SCh; (4) the extent to which monitored ambient SCh
31    concentrations used in epidemiologic studies reflect exposures in study populations and;  (5)
32    characterization of SCh exposures and risk including alternative  approaches for estimating risks
33    associated with air quality simulated to just meet current or alternative standards.
34
      Do Not Quote or Cite                  3-10                                  March 2014

-------
 1    3.2    GENERAL APPROACH FOR THE CURRENT REVIEW
 2           The approach for this review builds on the substantial body of work done during the
 3    course of the last review, and will take into account the more recent scientific information and air
 4    quality data now available to inform our understanding of the key policy-relevant issues. The
 5    approach described below is most fundamentally based on using the EPA's assessment of the
 6    current scientific evidence and associated quantitative analyses to inform the Administrator's
 7    judgments regarding primary standards for sulfur oxides that are requisite to protect public health
 8    with an adequate margin of safety. This approach will involve translating scientific and technical
 9    information into the basis for addressing  a series of key policy-relevant questions using both
10    evidence- and exposure/risk-based considerations.28
11           Figure 3-1 summarizes the general approach, including consideration of the policy -
12    relevant questions which will frame the current review. The ISA, REA (if warranted), and PA
13    developed in this new review will provide the basis for addressing the key policy-relevant
14    questions and will inform the Administrator's judgment as to the adequacy of the current primary
15    SCh standard and decisions  as to whether to retain or revise this standard.  This approach
16    recognizes that the available health effects evidence generally  reflects a continuum, consisting of
17    ambient concentrations at which scientists generally agree that health effects are likely to occur,
18    through lower concentrations at which the likelihood and magnitude of the response become
19    increasingly uncertain.  Furthermore, this approach is consistent with the requirements of the
20    NAAQS provisions  of the CAA and with how the EPA and the courts have historically
21    interpreted the CAA. As discussed in section 1.1 above, these provisions require the
22    Administrator to establish primary standards that, in the Administrator's judgment, are requisite
23    to protect public health with an adequate margin of safety. In so doing, the Administrator seeks
24    to establish standards that are neither more nor less stringent than  necessary for this purpose.
25    The CAA does not require that primary standards be set at a zero-risk level, but rather at a level
26    that avoids unacceptable risks to public health.  The four basic elements of the NAAQS (i.e.,
27    indicator, averaging time, form, and  level) will be considered collectively in evaluating the
28    health protection afforded by the current  standard or any alternative standards considered.
29           We note that the final decision on the adequacy of the current standard and, if
30    appropriate, potential alternative standards, is largely a public health policy judgment to be made
31    by the Administrator. The Administrator's final decision must draw upon scientific information
32    and analyses about health effects, population exposure and risks, as well as judgments about how
33    to consider the range and magnitude of uncertainties that are inherent in the scientific evidence
      28 Evidence-based considerations include those related to the health effects evidence assessed and characterized in
      the ISA. Exposure/risk-based considerations draw from the results of the quantitative analyses.

      Do Not Quote or Cite                  3-11                                   March 2014

-------
1    and analyses.  As in the previous review as well as other recent NAAQS reviews, the EPA will
2    consider the implications of placing more or less weight or emphasis on different aspects of the
3    scientific evidence and exposure/risk-based information to inform the public health policy
4   judgments that the Administrator will make in reaching final decisions on whether to retain or
5    revise the current standard in this review.
6
    Do Not Quote or Cite                  3-12                                  March 2014

-------
                         Adequacy of the Current 1-Hour SCh Standard?

                                                 I
             Evidence-based Considerations
       > Does currently available evidence and
       related uncertainties strengthen or call into
       question prior conclusions?
          > Evidence of health effects not
          previously identified?
          > Evidence of effects at lower
          concentrations than previously observed or
          in areas that would have likely met current
          standard?
          > Expanded understanding of at-risk
          populations and lifestages?
       >Does newly available information call into
       question any of the basic elements of the
       standard?
                                                   Risk/Exposure-based Considerations
                                                 > Nature, magnitude, and uncertainties of
                                                 estimated exposures and risks remaining
                                                 upon just meeting the current 1-hour
                                                 standard?
                                                 > Relationship between 1 -hour standard and
                                                 5-minute peaks/24-hour average concentrations?
                                                 > Importance of remaining risks from public
                                                 health perspective?
                                                 > Uncertainties in the exposure and risk
                                                 estimates?
                                      Does information
                                      call into question
                                     adequacy of current
                                         1-hour SO 2
                                          standard?
                                                                           Consider  \
                                                                           retaining
                                                                           current 1 -
                                                                           hour SO2
                                                                           standard  I
                      Consideration of Potential Alternative Standard(s)
                        Elements of Potential Alternative Standard(s)

                                         > Indicator
                                         > Averaging times
                                         > Forms
                                         > Levels
1
2
3
4
                         Potential alternative standard(s) for consideration
Figure 3-1 Overview of General Approach for Review of Primary SOi Standard
     Do Not Quote or Cite
                                             3-13
March 2014

-------
 1           The initial overarching question in reviewing the adequacy of the current primary SCh
 2    NAAQS is whether the available body of scientific evidence, assessed in the ISA and used as a
 3    basis for developing or interpreting risk/exposure analyses, supports or calls into question the
 4    scientific conclusions reached in the last review regarding health effects related to exposures to
 5    sulfur oxides. The evaluation of the available scientific evidence and risk/exposure information
 6    with regard to adequacy of the current standard will focus on key policy-relevant issues by
 7    addressing a series of questions including the following:
 8       •   To what extent has new information altered the scientific support for the occurrence  of
 9           health effects as a result of short- and/or long-term exposure to sulfur oxides in the
10           ambient air?

11              o  What evidence is available from recent studies focused on specific chemical
12                 components within the broader group of sulfur oxides (e.g., SCh, SOs) to inform
13                 our understanding of the nature of exposures that are linked to various health
14                 outcomes?
15              o  To what extent is key scientific evidence becoming available to improve our
16                 understanding of the health effects associated with various time periods of
17                 exposures, including short-term (e.g., 5-minute, 1-hour, 24-hour) and chronic
18                 exposures (e.g., months to years)?
19              o  At what pollutant concentrations do these health effects occur? Is there evidence
20                 of effects at exposure concentrations lower than have been previously observed or
21                 in areas that would likely meet the current SCh primary standard?
22              o  To what extent are health effects associated with exposures to sulfur oxides,
23                 including SCh, as opposed to one or more co-occurring pollutants (e.g., PM2.5,
24                 ozone, NO2)?
25              o  What are the important uncertainties and limitations associated with the scientific
26                 evidence?

27       •   Has new information altered our understanding of human lifestages and populations  that
28           are particularly at increased risk for experiencing health effects associated with exposure
29           to sulfur oxides?
30              o  Is there new information to shed light on the nature of the exposure-response
31                 relationship in different at-risk lifestages and/or populations?
32              o  Is there new or emerging evidence on health effects beyond respiratory effects in
33                 asthmatics, children, and the elderly that suggest additional at-risk populations
34                 and lifestages should be given increased focus in this review?

35       •   What are the air quality relationships between short-term and longer-term exposures
36           to SCh?

37              o  As noted in section 1.3, as part of the final rulemaking the EPA for the first time
38                 required state reporting of either the highest 5-minute concentration for each  hour
39                 of the day, or all twelve 5-minute concentrations for each hour of the day. To
      Do Not Quote or Cite                  3-14                                   March 2014

-------
 1                 what extent can this 5-minute monitoring data collected since the last review be
 2                 used to further characterize the relationship between 5-minute peaks and longer
 3                 term (e.g., 1-hour, 3-hour, 24-hour) average concentrations?

 4              o  What are the important uncertainties associated with using a 1-hour NAAQS to
 5                 protect against 5-minute peak concentrations of concern?

 6       •  To what extent does risk or exposure information suggest that exposures of concern (i.e.,
 7          exposures above benchmark levels) are likely to occur with recent ambient SCh
 8          concentrations or with concentrations that just meet the current SCh standard?

 9              o  Are  the estimated risks/exposures considered in this review of sufficient
10                 magnitude such that the health effects might reasonably be judged to be important
11                 from a public health perspective?

12              o  What are the important uncertainties associated with any risk/exposure estimates?

13       •  To what extent have important uncertainties identified in the last review been reduced
14          and/or have new uncertainties emerged?

15       •  To what extent does newly available information reinforce or call into question any of the
16          basic elements of the current primary SCh standard?
17          If the evidence suggests that revision of the current standard might be appropriate, the
18    EPA will evaluate how the standard might be revised.  Specifically, we will evaluate how the
19    scientific information and assessments inform decisions regarding the  basic elements of the
20    primary  SCh NAAQS: indicator, averaging time, form and level. These elements will be
21    considered collectively in evaluating the health protection afforded by the current or any
22    alternative standard(s) considered. Specific policy-relevant questions related to these standard
23    elements include:
24       •  To what extent does any new information provide support for the continued use  of SCh as
25          the indicator for sulfur oxides?  Is there evidence to support using an indicator in
26          addition to,  or in place of SCh?

27       •  To what extent does the health effects evidence evaluated in the ISA continue to provide
28          support for the existing  1-hour averaging time! Does the currently  available information
29          provide support for considering any different averaging times'?

30       •  To what extent do air quality analyses conducted since the last review suggest a  standard
31          with an averaging time of 1-hour or longer can protect against  5-minute and/or 24-hour
32          concentrations of concern? Do these air quality analyses provide support for considering
33          any different averaging times!

34       •  To what extent do the ISA, air quality analyses, and other information provide support for
35          consideration of alternative standard forms?
      Do Not Quote or Cite                   3-15                                  March 2014

-------
1        •  What range of alternative standard levels should be considered based on the scientific
2           evidence evaluated in the ISA, air quality analyses and, if available, in the REA29 ?

3        •  What are the important uncertainties and limitations in the available evidence and
4           assessments and how might those uncertainties and limitations be taken into
5           consideration in identifying alternative standard indicators, averaging times, forms,
6           and/or levels?
     29 As outlined in Table 2-1 and discussed in Chapter 5 below, the REA Planning Document will consider the extent
     to which newly available scientific evidence and tools/methodologies warrant the conduct of new quantitative risk
     and exposure assessments. To the extent completely new assessments are not developed for this review, assessments
     from the last review may be interpreted in light of the newly available information in addressing the key policy
     questions for the review.


     Do Not Quote or Cite                    3-16                                      March 2014

-------
 i                         4.     SCIENCE ASSESSMENT

 2          The ISA comprises the science assessment phase of the SCh NAAQS review. As
 3    described in section 1.4 above, this assessment focuses on updating the air quality criteria
 4    associated with health evidence to inform the review of the primary SCh standard only.30
 5
 6    4.1   SCOPE  OF THE ISA
 7          The ISA will critically evaluate and integrate the scientific information on exposure and
 8    health effects associated with SOx in ambient air in the discipline areas of atmospheric science,
 9    human exposure,  dosimetry, epidemiology, controlled human exposure, and toxicology.  The
10    purpose of the discussions within the ISA is not to provide a detailed literature review but to
11    draw upon the existing body of evidence to synthesize the current state of knowledge on the most
12    relevant issues pertinent to the review of the NAAQS for SCh, to identify changes in the
13    scientific evidence base since the previous review, and to describe remaining or newly identified
14    uncertainties. The ISA discussions will be designed to focus on the key policy-relevant
15    questions described in Section 3.4.
16          The current ISA will focus on literature published since the 2008 SOx ISA and integrate
17    this newer evidence with evidence considered in the last review.  Key findings, conclusions, and
18    uncertainties from the 2008 ISA for SOx will be briefly summarized at the beginning of the ISA
19    and individual sections.  The results of recent studies will be integrated with previous findings.
20    In evaluation of controlled human exposure and animal toxicological studies, emphasis will be
21    placed on studies  that examine health effects relevant to humans and on SOx concentrations that
22    represent the range of human exposures across various ambient microenvironments. However,
23    in recognition of the fact that controlled human exposure and animal toxicological studies do not
24    necessarily reflect effects in the most sensitive populations, studies at higher exposure
25    concentrations will be included when they provide information relevant to previously unreported
26    effects, evidence of the potential biological mechanism for an observed effect, or information on
27    exposure-response relationships.
28    4.2   ORGANIZATION OF THE ISA
29          The organization of the ISA for health criteria of SOx will be consistent with that used in
30    the recent assessments for other criteria pollutants, e.g., the ISA for Ozone and Related
      30Note that evidence related to environmental effects of SOX will be considered separately in the science assessment
      conducted as part of the review of the secondary NAAQS forNCh and SCh.
      Do Not Quote or Cite                  4-1                                  March 2014

-------
 1    Photochemical Oxidants (U.S. EPA, 2013b). The ISA will begin with a discussion of major legal
 2    and historical aspects of prior review documents as well as procedures for the assessment of
 3    scientific information.  An integrative synthesis chapter will summarize the key information for
 4    each topic area, the causal determinations for relationships between exposure to SOx and health
 5    effects, information describing the extent to which health effects can be attributable specifically
 6    to SOx, and other uncertainties related to the interpretation of scientific information. The
 7    integrative synthesis chapter also will present a discussion of policy-relevant issues such as the
 8    exposure averaging times and lags associated with health effects, the concentration-response
 9    relationships including whether or not the evidence supports identification of a discernible
10    threshold below which effects are not likely to occur, and the public health significance of health
11    effects associated with exposure to SOx. Subsequent chapters are organized by subject area (see
12    draft outline of the ISA in Appendix A) and contain the detailed evaluation of results of recent
13    studies integrated with previous findings (see section 4.4 for specific issues to be addressed).
14    Sections for each major health effect category (e.g.,  respiratory effects) conclude with a causal
15    determination about the relationship with relevant exposures to SOx.  The ISA will conclude
16    with a chapter that examines exposure and health outcome data to draw conclusions about
17    potential at-risk lifestages and populations.
18          The ISA may be supplemented with additional materials if required to support
19    information contained within the ISA.  These supplementary materials may include more
20    detailed and comprehensive coverage of relevant publications and may accompany the ISA or be
21    available in electronic form as output from the Health and Environmental Research Online
22    (HERO) database developed by EPA (http://hero.epa.gov/). Supplementary information
23    available in the HERO database will be presented as electronic links in the ISA.
24    4.3   ASSESSMENT APPROACH
25    4.3.1  Introduction
26          The NCEA-RTP is responsible for preparing the ISA for SOx health criteria. In each
27    NAAQS review, development of the science assessment begins with a "Call for Information"
28    published in the Federal Register. This notice announces EPA's initiation of activities in the
29    preparation of the ISA for the specific NAAQS review and invites the public to assist through the
30    submission of research studies in the identified subject areas. This and subsequent key
31    components of the process currently followed for the development of an ISA (i.e., the
32    development process) are presented in Figure 3.1 and are described in greater detail in the
33    Preamble to the ISA for Lead (U.S. EPA, 2013a). How the ISA fits into the larger NAAQS
34    review process is briefly described in Section 1.2, the Overview of the Review Process.
35
      Do Not Quote or Cite                   4-2                                  March 2014

-------
                                           Literature Search and
                                              Study Selection
                                   Evaluation of Individual Study uuani,
       After study selection, the quality of individual studies is evaluated by EPA or outside experts in the fields of
       atmospheric science, exposure assessment, dosimetry, animal toxicology, controlled human exposure studies,
       epidemiology, ecology and other welfare effects, considering the design, methods, conduct, and documentation of
       each study. Strengths and limitations of individual studies that may affect the interpretation of the study are
       considered.
               Develop Initial Sections
       Review and summarize new study results and
       findings and conclusions from previous
       assessments by category of outcome/effect and
       by discipline, e.g., toxicological studies of lung
       function.
                    Peer Input Consultation
             Review of initial draft materials by scientists
             from both outside and within EPA in public
             meeting or public teleconference.
                             Evaluation, Synthesis and Integration of Evidence
        Integrate evidence from scientific disciplines -forexample, toxicological, controlled human exposure and
        epidemiologic study findings for particular health outcome. Evaluate evidence for related groups of endpoints or
        outcomes to draw conclusions regarding health or welfare effect categories, integrating  health or welfare effects
        evidence with information on mode of action and exposure assessment.
                   Development of Scientific Conclusions and Causal Determinations
       Characterize weight of evidence and develop judgments regarding causality for health or welfare effect categories.
       Develop conclusions regarding concentration- or dose-response relationships, potentially at-risk populations,
       lifestages, or ecosystems.
         Draft Integrated Science Assessment
       Evaluation and integration of newly published studies
                       after each draft
           Clean Air Scientific Advisory Committee
          Independent review of draft documents for scientific
          quality and sound implementation of causal
          framework; anticipated review of two drafts of ISA in
          public meetings.
                                                                        Public Comments
                                                                 Comments on draft ISA solicited by EPA
         Final Integrated Science Assessment
     Figure 4.1. General Process for Development of Integrated Science Assessments (ISAs)
3    (Modified from Figure III of the Preamble to the ISA for Lead, U.S. EPA, 2013a)

4            Important aspects of the development of the  ISA are described in the sections below,

5    including the approach for searching the literature, identifying relevant publications, evaluating
     Do Not Quote or Cite
4-3
March 2014

-------
 1    individual study quality, synthesizing and integrating the evidence, and developing scientific
 2    conclusions and causality determinations. These responsibilities are undertaken by expert
 3    authors of the ISA chapters which include EPA staff with extensive knowledge in their
 4    respective fields and extramural scientists solicited by EPA for their expertise in specific fields.
 5    This section of the IRP also presents specific policy-relevant questions developed from input
 6    received at the SOx kickoff workshop.  These questions are intended to guide the development of
 7    the ISA.  The process for scientific and public review of drafts of the ISA is described in Section
 8    4.3.
 9    4.3.2 Literature Search and  Selection  of Relevant Studies
10          The NCEA-RTP uses a structured approach to identify relevant studies for consideration
11    and inclusion in the ISA. A Federal Register notice is published to announce the initiation of a
12    review and to request information, including relevant literature, from the public. The EPA
13    maintains an ongoing, multi-tiered literature search process that includes extensive manual and
14    computer-aided citation mining of databases on specific topics in a variety of disciplines using as
15    keywords terms such as  SOx, SCh, sulfur oxide(s), or sulfur dioxide. The search strategies are
16    designed a priori and iteratively modified to optimize identification of pertinent publications.  In
17    addition, papers are identified for inclusion in several other ways: specialized searches on
18    specific topics; relational searches that identify recent publications that have cited references
19    from previous assessments; identification of relevant literature by external scientific experts;
20    recommendations from the public and CASAC during the call for information and external
21    review process; and review of citations in previous assessments. The studies identified will
22    include research published or accepted for publication from January 2008, which slightly
23    precedes the publication end date for studies reviewed in the  2008  SOx ISA, through
24    approximately two months before the release of the second external review draft of the ISA
25    (target of June 2015, see Table 2-1).
26          References identified through this multipronged search strategy are reviewed for
27    relevance. Some publications are excluded based on screening of the title. Publications
28    considered for inclusion in the ISA after reading the title are  listed in the Health and
29    Environmental Research Online (HERO) database (http://hero.epa.gov).  Studies and reports that
30    have undergone scientific peer review and have been published or  accepted for publication are
31    considered for inclusion in the ISA.
32          From the group of considered references, references are selected for inclusion in the ISA
33    based on review of the abstract and  full text. The references cited in the ISA include a hyperlink
34    to the HERO database. The selection process is based on the extent to which the study is
35    potentially informative and policy-relevant. Potentially policy-relevant and informative studies
36    include those that provide a basis for or describe the relationship between the criteria pollutant

      Do Not Quote or Cite                   4-4                                   March 2014

-------
 1    and effects, in particular, those studies that offer innovation in method or design and studies that
 2    reduce uncertainty on critical issues. Uncertainty can be addressed, for example, by analyses of
 3    potential confounding or effect modification by copollutants or other factors, analyses of
 4    concentration-response or dose-response relationships, or analyses related to time between
 5    exposure and response.  The ISA will  generally emphasize studies published since the 2008 SOx
 6    ISA; however, evidence from previous studies will be included to integrate with results from
 7    recent studies and, in some cases, characterize the key policy-relevant information in a particular
 8    subject area. Analyses conducted by the EPA using publicly available data, for example, air
 9    quality and emissions data, also are considered for inclusion in the ISA.  The combination of
10    approaches described above is intended to produce the comprehensive collection of pertinent
11    studies needed to address the key scientific issues that form the basis of the ISA.
12    4.3.3  Evaluation of Individual Study Quality
13           After selecting studies  for inclusion, individual study quality is evaluated by considering
14    the design, methods, conduct,  and documentation of each study, but not whether the results are
15    positive, negative, or null.  This uniform approach aims to consider the strengths, limitations, and
16    possible roles of chance, confounding, and other biases that may affect the interpretation of the
17    results from individual studies. In assessing the scientific quality of studies, the  following
18    parameters are considered:
19       •   How clearly were the study design, study groups, methods, data, and results presented to
20           allow for study evaluation?
21       •   To what extent are the  air quality data, exposure, or dose metrics of adequate quality to
22           serve as credible exposure indicators?
23       •   Were the study populations, subjects, or animal models adequately selected, and are they
24           sufficiently well defined to allow for meaningful comparisons between study or exposure
25           groups?
26       •   Are the statistical analyses appropriate, properly performed, and properly interpreted?
27       •   Are likely covariates (i.e., potential confounding factors, modifying factors) adequately
28           controlled for or taken  into account in the study design or statistical analyses?
29       •   Are the health endpoint measurements meaningful, valid, and reliable?
30    Additional considerations specific to particular scientific disciplines are discussed below.
31    Atmospheric Science and Exposure Assessment
32           Atmospheric science and exposure assessment studies focus on measurement of, behavior
33    of, and exposure to ambient air pollution using quality-assured field,  experimental, and/or
34    modeling techniques. The most informative measurement-based studies will include detailed
35    descriptive statistics for high-quality measurements taken at varying spatial and temporal scales.
36    These studies will also include a clear and comprehensive description of measurement

      Do Not Quote or Cite                   4-5                                  March 2014

-------
 1    techniques and quality control procedures used. Quality control metrics (e.g., method detection
 2    limits) and quantitative relationships between and within pollutant measurements (e.g.,
 3    regression model coefficients, intercepts, and fit statistics) should be provided when appropriate.
 4    Measurements including contrasting conditions for various time periods (e.g., weekday/weekend,
 5    season), populations, regions, and categories (e.g., urban/rural, proximity to various source
 6    sectors) are particularly useful. The most informative modeling-based studies will incorporate
 7    appropriate chemistry, transport, dispersion, and/or exposure modeling techniques with a clear
 8    and comprehensive description of model science,  evaluation procedures, and metrics.
 9           Exposure measurement error, which refers to the uncertainty associated with the exposure
10    metrics used to represent exposure of an individual or population, can be an important
11    contributor to uncertainty in air pollution epidemiologic study results. Exposure measurement
12    error can influence observed epidemiologic associations between ambient pollutant
13    concentrations and health outcomes by biasing effect estimates toward or away from the null and
14    widening confidence intervals around those estimates (Zeger et al., 2000). Factors that could
15    influence exposure estimates include, but are not limited to, nonambient sources of exposure,
16    topography of the natural and built environment, meteorology, air quality measurement
17    instrument or model uncertainties, time-activity patterns, and the infiltration into indoor
18    environments. Additional information present in high-quality exposure studies includes location
19    and activity information from diaries, questionnaires, global positioning system data, or other
20    means, as well as information on  commuting patterns. In general, atmospheric science and
21    exposure studies focusing on the variety of locations pertinent to the range of exposures in the
22    U.S. will have maximum value in informing review of the NAAQS.
23    Epidemiology
24           In evaluating quality of epidemiologic studies, EPA additionally considers whether a
25    given study: (1) presents quantitative information on associations of health effects with short- or
26    long-term exposures that represent ambient concentrations of SOx across various
27    microenvironments; (2) examines health effects of SOx; (3) assesses SOx  as a component of a
28    complex mixture of air pollutants by considering concentrations of copollutants, correlations of
29    SOx with these copollutants, potential copollutant interactions (e.g.,  synergistic effects of SOx
30    with other pollutants),  potential copollutant confounding (e.g., bias of associations  observed
31    between SOx and health endpoints by the effects of copollutants), and other methods to assess
32    the independent effect of SOx;  (4) evaluates health endpoints not previously extensively
33    researched;  (5) evaluates lifestages and populations that potentially are at increased risk of health
34    effects related to SOx; (6) examines other potential confounding factors or effect modifiers (e.g.,
35    socioeconomic status); and (7)  examines important methodological issues (e.g., lag or time
36    period between exposure and effects, model specifications, thresholds, mortality displacement)

      Do Not Quote or Cite                   4-6                                   March 2014

-------
 1    related to the health effects of exposure to SOx.  Among epidemiologic studies characterized as
 2    high quality by these parameters, emphasis will be given to multicity studies that employ
 3    standard methodological analyses for evaluating effects of SOx across cities, provide overall
 4    estimates for effects by pooling information across cities, and examine consistency of results
 5    across cities. To address specific issues relevant to standard setting in the U.S., such as regional
 6    heterogeneity in effects, emphasis will be placed on studies that involve exposures that are
 7    relevant to current U.S. populations (e.g., studies conducted in the U.S. or Canada).
 8    Controlled Human Exposure and Animal Toxicology
 9          Controlled human exposure and animal toxicological studies experimentally evaluate the
10    health effects of administered exposures in human volunteers and animal models under highly
11    controlled laboratory conditions. Controlled human exposure studies are also referred to as
12    human clinical studies and, as noted above, provided the definitive evidence for a causal
13    relationship between short-term exposure to SCh and respiratory morbidity in the previous
14    review. These experiments allow investigators to expose subjects to known concentrations of
15    SOx under carefully regulated environmental conditions and activity levels. In addition to the
16    general quality considerations discussed previously, evaluation of controlled human exposure
17    and animal  toxicological studies includes assessing the design and methodology of each study
18    with focus on (1) characterization of the intake dose, dosing regimen (e.g., duration, activity
19    level), and exposure route; (2) characterization of the pollutant(s); (3) sample size and statistical
20    power to detect differences; and (4) control of other variables that could influence the occurrence
21    of effects. The evaluation of study design generally includes consideration of factors that
22    minimize bias in results such as randomization, blinding and allocation concealment of study
23    subjects, investigators, and research staff, and unexplained loss of animals or
24    withdrawal/exclusion of subjects. Additionally, studies must include appropriate control groups
25    and exposures to allow for accurate interpretation of results relative to exposure. Emphasis is
26    placed on studies that address concentration-dependent responses or time-course of responses
27    and studies that investigate potentially at-risk lifestages and populations (e.g., with pre-existing
28    disease), recognizing that controlled human exposure studies typically examine effects in groups
29    of relatively healthy individuals, often adults, who do not represent the full range of
30    susceptibilities in the general population. In addition, consideration will be given to studies that
31    investigate exposure to SOx separately and in combination with other pollutants such as ozone
32    and particulate matter.
33          Controlled human exposure or animal toxicological studies that approximate expected
34    human exposures in terms of concentration, duration, and route of exposure are of particular
35    interest. Relevant pollutant exposures are considered to be those generally within two orders of
36    magnitude of ambient concentrations measured across various microenvironments. Studies using

      Do Not Quote or Cite                    4-7                                   March 2014

-------
 1    higher concentration exposures or doses will be considered to the extent that they provide
 2    information relevant to understanding mode of action or mechanisms, interspecies variation, or
 3    at-risk human lifestages and populations. In vitro studies may be included if they provide
 4    mechanistic insight or support results demonstrated in vivo.
 5    4.3.4 Integration of Evidence and Determination of Causality
 6          EPA has developed a consistent and transparent basis for integration of scientific evidence
 7    and evaluation of the causal nature of air pollution-related health or welfare effects for use in
 8    developing IS As, as described in the online Preamble to the ISA for Lead (U.S. EPA, 2013 a).
 9    Evidence from across scientific disciplines for related health effects is evaluated, synthesized,
10    and integrated to develop  conclusions and causality determinations. This includes consideration
11    of strengths and weaknesses in the overall collection of studies across disciplines. Confidence in
12    the body of evidence is based on evaluation of study design and quality. The relative importance
13    of different types of evidence to the conclusions varies by pollutant or assessment, as does the
14    availability of different types of evidence for causality determination. Consideration of human
15    health effects is informed  by controlled human exposure, epidemiologic, and toxicological
16    studies. Other evidence including mechanistic evidence, toxicokinetics, and exposure assessment
17    may be highlighted if it is relevant to the evaluation of health effects and if it is  of sufficient
18    importance to affect the overall evaluation. Scientists will also evaluate uncertainty in the
19    scientific evidence, considering issues such as generalizing results from a small number of
20    controlled human exposure subjects to the broader population, quantitative extrapolations of
21    observed pollutant-induced pathophysiological alterations from laboratory animals to humans,
22    confounding by co-exposure to other ambient pollutants or meteorological factors, the potential
23    for effects due to exposure to air pollution mixtures, and the influence of exposure measurement
24    error on epidemiologic study findings.
25          The ISA will evaluate the evidence for causal relationships between observed health
26    outcomes and SOx exposures using a five-level  hierarchy that classifies the weight of evidence
27    for causation. Determination of causality involves the evaluation and integration of evidence
28    across disciplines for major outcome categories (e.g., respiratory effects) or groups of related
29    endpoints. Key considerations in drawing conclusions about causality include consistency of
30    findings for an endpoint across studies, biological plausibility, and coherence of the evidence
31    across disciplines and across related endpoints, including key events that inform modes of action
32    (see Table I in Preamble to the ISA for Lead, U.S. EPA, 2013a). In discussing the causal
33    determination, EPA characterizes the evidence on which the judgment is based, including

      Do Not Quote or Cite                    4-8                                   March 2014

-------
 1    strength of evidence for individual endpoints within the outcome category or group of related
 2    endpoints. The ISA will place emphasis on studies conducted with SOx exposure concentrations
 3    representative of those across various ambient microenvironments. However, studies that provide
 4    evidence for biological plausibility and modes of action, which are conducted at higher exposure
 5    concentrations than those typically associated with health effects in humans, may be included in
 6    the ISA. In addition, EPA evaluates evidence relevant to understand the quantitative
 7    relationships between pollutant exposures and health effects. This includes evaluating the
 8    concentration-response or dose-response relationships and, to the extent possible, drawing
 9    conclusions on the levels at which effects are observed.
10    4.3.5  Quality Management
11          NCEA participates in the Agency-wide Quality Management System, which requires the
12    development of a Quality Management Plan (QMP). Implementation of the ORD-wide and
13    NCEA QMP ensures that all data generated or used by NCEA scientists "have a degree of
14    confidence in the quality of the data; and, are of the type and quality appropriate for their
15    intended use"  and that all information disseminated by NCEA adheres to a high standard for
16    quality including objectivity, utility, and integrity.  Quality assurance (QA) measures detailed in
17    the QMP are being employed for the current SOx review, including the development of the ISA
18    for health criteria of SOx.  The NCEA QA staff are responsible for the review and approval of
19    quality-related documentation. NCEA scientists are responsible for the evaluation (and
20    documentation) of all inputs to the ISA, including primary (new) and secondary (existing) data,
21    to ensure their quality is appropriate for their intended purpose. NCEA adheres to the use of
22    Data Quality Objectives, which clarify project objectives, define the appropriate type of data
23    used in the project, and specify tolerable levels of confidence in the data and tolerable levels of
24    potential decision errors that will be used as the basis for establishing the quality and quantity of
25    data needed to identify the most appropriate inputs to the science assessment. The approaches
26    utilized to search the literature and criteria for study selection and evaluation were detailed in the
27    two preceding subsections. Generally, NCEA scientists rely on scientific information found in
28    peer-reviewed journal articles, books, and government reports. Where information is integrated,
29    re-analyzed, modeled, or reduced from multiple sources to create new figures, tables, or
30    summation, the data generated are considered to be new and are documented and subjected to
31    rigorous quality assurance and quality control measures to ensure their accuracy, validity, and
32    reproducibility.

      Do Not Quote or Cite                   4-9                                  March 2014

-------
 1    4.4   SPECIFIC ISSUES TO BE ADDRESSED IN THE ISA
 2          The organization of the ISA for SOx health criteria will be consistent with that used in
 3    the recent assessments for other criteria pollutants (e.g., ISA for Ch, U.S. EPA, 2013b).
 4    Development of the ISA will be guided by policy-relevant questions that frame the entire review
 5    of the primary SCh NAAQS. These policy-relevant questions are related to two overarching
 6    issues. The first issue is whether new evidence reinforces or calls into question the evidence
 7    presented and evaluated in the last NAAQS review with respect to factors such as the
 8    concentrations of SOx exposure associated with health effects and plausibility of health effects
 9    caused by SOx exposure. The second issue is whether uncertainties from the last review have
10    been reduced and/or whether new uncertainties have emerged. Specific questions that will be
11    addressed in  the ISA are listed subsequently by topic area. In the ISA, these topic areas will be
12    discussed in separate chapters or sections. The beginning of the ISA will include an integrative
13    synthesis chapter that summarizes the key information for each topic area and the causal
14    determinations. The integrative synthesis chapter also presents a discussion of policy-relevant
15    issues such as the exposure metrics, averaging times, and lags associated with health effects, the
16    concentration-response relationship including threshold for effects, and public health
17    significance of health effects associated with exposure to SOx (see Appendix).
18
19       A. Air Quality and Atmospheric Chemistry:  The ISA will present and evaluate data related
20          to ambient concentrations of SOx; sources leading to the presence of SOx in the
21          atmosphere; and chemical reactions that determine the formation, degradation, and
22          lifetime of SOx in the atmosphere. The 2008 SOx ISA concluded that most SO2 is
23          emitted from elevated point sources such as the stacks of power plants and industrial
24          facilities, many  of which are located in the eastern U.S., leading to a strong east-west
25          gradient in SO2  concentrations. SO2 is removed from the atmosphere both by deposition
26          and by oxidation to sulfate, resulting in a typical atmospheric lifetime of <1 to 4 days,
27          depending on local conditions. Mean U.S. daily 1-hour max SO2 concentrations in 2003-
28          05 were approximately  13 ppb, with a 99th percentile value of 95 ppb and a maximum
29          value of approximately 700 ppb. The large differences between 99th percentile and
30          maximum values suggest that the maxima are strongly limited spatially and temporally
31          and are not a major determinant of the mean values. At the time of the 2008 SOx ISA, the


      Do Not Quote or Cite                   4-10                                  March 2014

-------
 1          very limited 5-minute SCh data available showed that the median hourly maximum 5-
 2          minute average ranged from 1-8 ppb, while the 99th percentile value ranged from 21-184
 3          ppb, depending on location (U.S. EPA, 2008, section 5.1).  In the current ISA, description
 4          of the atmospheric chemistry of SOx will include both gaseous and particulate species in
 5          order to provide a complete analysis, although the health effects of particulate SOx are
 6          discussed in the review of the NAAQS for particulate matter (PM). SCh is the most
 7          important of the gas-phase sulfur oxides for both atmospheric chemistry and health
 8          effects and is expected to be the focus of the ISA.  SOx is usually defined to include sulfur
 9          trioxide (SOs) and gas-phase sulfuric acid (tfeSO/O as well, but neither species is present
10          in the atmosphere in concentrations significant for human exposures. In the current
11          review, specific policy-relevant questions related to air quality and atmospheric
12          chemistry that will be addressed include the following:
13       •  What are the main and emerging sources of ambient gas-phase SOx, and how have new
14          fuels, emission standards, and technologies changed the magnitude and composition of
15          SOx emissions?
16       •  What progress has been made in improving measurements and reducing interference
17          problems in measuring  SOx, particularly for concentrations near the method detection
18          limit?  What limitations still remain?
19       •  Based on recent air quality and emissions data, what are current emissions and
20          concentrations of SOx? How have emissions and concentrations of SOx changed since
21          the 2008 SOx ISA?  To what extent can other techniques, such as satellite data and
22          dispersion modeling, be used to improve the characterization of SOx concentrations?
23       •  What spatial and temporal patterns can be seen in SOx concentrations?  In particular,
24          what patterns can be seen near point and other sources of SOx? What do monitoring,
25          satellite data, and dispersion modeling results indicate regarding spatial patterns on
26          neighborhood, urban, regional,  and national scales?
27       •  What are the relationships among SOx concentrations measured with different averaging
28          times (e.g., 5-minute, 1-hour, 24-hour)? How well do 1-hour or longer averaging time
29          concentrations represent peak exposures to  SOx?
30       •  What are the relationships among SOx concentrations and concentrations of other
31          pollutants, such as sulfate, other components of particulate matter, and gaseous
32          pollutants?
33       •  What are the capabilities of air  quality models for estimating SOx concentrations,
34          particularly at the upper end of the air quality distribution?
35       •  Based on air quality and emissions data on SOx and atmospheric chemistry models, what
36          are likely background concentrations of SOx in the absence of anthropogenic emissions?
      Do Not Quote or Cite                  4-11                                  March 2014

-------
 1    B.     Human Exposure to Ambient SOx: The ISA will evaluate the factors that influence
 2          human exposure to ambient SOx and the uncertainties associated with extrapolation from
 3          ambient concentrations to personal exposures to SOx of ambient origin, particularly in
 4          the context of interpreting results from epidemiologic studies. As described in the 2008
 5          SOx ISA, many exposure studies were unable to characterize the relationship between
 6          personal exposure and ambient SO2 due to indoor and outdoor concentrations that were
 7          below the detection limit of passive personal samplers. However, in studies with personal
 8          measurements above detection limits, a reasonably strong association was observed
 9          between personal SO2 exposure and ambient concentrations (U.S. EPA, 2008, section
10          5.3). At the time of the 2008 SOx ISA, no studies had evaluated the relationship between
11          community average exposure and ambient concentrations, which is more directly relevant
12          to many epidemiologic study designs, although the ISA concluded that intracommunity
13          variations in the personal-ambient relationship would generally tend to widen the
14          confidence interval rather than bias the  effect estimate. Uncertainties differ according to
15          the exposure period of interest as most short-term exposure studies  (e.g., population-level
16          studies using time-series analyses, field/panel studies) rely on temporal variation in
17          exposure while long-term exposure studies (e.g., longitudinal cohort studies) rely on
18          spatial variability of exposure. In the current review, specific policy-relevant questions
19          related to exposure that will be addressed include the following:
20       •  What are the relationships between SOx measured at stationary monitoring sites and
21          personal exposure to SOx over different time scales? What evidence is available
22          regarding these relationships in environments near point sources, ports, or other sources?
23          What uncertainties remain regarding these exposures of interest?
24       •  What new information is available regarding microenvironmental SOx concentrations
25          and personal exposures to SOx? What are the capabilities of currently available exposure
26          measurement techniques?
27       •  What new information exists regarding characterization of error in  SOx exposure
28          assessment and how it influences personal-ambient exposure relationships?
29       •  What information is available regarding differences in SOx exposure patterns and
30          personal-ambient exposure relationships among various lifestages and populations,
31          particularly at-risk groups?
32       •  What new information exists regarding SOx measurements in a multipollutant context?
33          What are the relationships between SOx exposures and exposures for  other pollutants,
34          such as sulfate, other components of particulate matter, and gaseous pollutants?
      Do Not Quote or Cite                  4-12                                   March 2014

-------
 1       •  How does uncertainty in exposure estimates inform interpretation of epidemiologic,
 2          controlled human exposure, and toxicological studies?
 3       C. Dosimetry and Modes of Action: The ISA will evaluate literature focusing on dosimetry
 4          and modes of action that may underlie the health outcomes associated with exposure to
 5          SOx. These topic areas will be evaluated using both human and animal data.  The 2008
 6          SOx ISA concluded that SCh is readily absorbed in the nasal passages due to its high
 7          water solubility; with increased ventilation rates during exercise, the pattern of SCh
 8          absorption shifts from the upper airways to the tracheobronchial airways in conjunction
 9          with a shift from nasal to oronasal breathing (U.S. EPA, 2008, section 5.2). The
10          compound most directly responsible for the health effects may be the inhaled SCh and/or
11          its chemical reaction products such as hydrogen ions, bisulfite anions and sulfite anions
12          which are formed when SCh contacts the fluids lining the airway. One of the principal
13          effects of inhaled SO2 is bronchoconstriction, mediated by chemosensitive receptors that
14          trigger nervous system reflexes. Preexisting inflammation may lead to enhanced
15          sensitivity in asthmatics due to enhanced release of mediators, alterations in the
16          autonomic nervous system, and/or sensitization of the chemosensitive receptors. In the
17          current review, specific policy-relevant questions related to  dosimetry and modes of
18          action that will be addressed include the following:
19       •  What SOx reaction products can be found in the respiratory tract cells, tissues, or fluids
20          that may serve as markers of SOx exposure and effect?
21       •  What information is available on the following dosimetric and mechanistic factors:
22                 o  The regional pattern of SOx-induced injury/perturbation in the respiratory
23                    tract?
24                 o  Inter-individual variability of responses that may enhance the risk of an
25                    adverse health effect?
26                 o  Homology of responses between animals and humans?
27       •  What are the potential biological mechanisms underlying responses to SOx at or near
28          environmentally relevant exposures?
29       •  What new information is available related to the modes of action for health effects
30          associated with exposure to SOx?
31       •  Do interactions between inhaled SOx and other inhaled pollutants influence the
32          mechanisms underlying the toxic potential of SOx?
      Do Not Quote or Cite                  4-13                                  March 2014

-------
 1       •  What are the effects of host factors such as lifestage, sex, pre-existing disease, genetic
 2          background, and physical activity on SOx uptake, cellular and tissue responses, and their
 3          underlying mechanisms? Are there critical windows of exposure (e.g.  prenatal) that result
 4          in different effects and/or effects at lower exposures?
 5       •  What information is available to discern the relative contributions to internal SOx
 6          compounds of SOx derived exogenously from ambient exposures and SOx derived from
 7          endogenous biological processes?
 8    D.   Health Effects: The 2008 SOx ISA concluded that there is a causal relationship between
 9         respiratory morbidity and short-term exposure to SO2, based on consistent and coherent
10         evidence from controlled human exposure, epidemiologic, and animal toxicological
11         studies. The definitive evidence for the causal relationship came from controlled human
12         exposure studies that reported respiratory symptoms  and decreased lung function in
13         exercising asthmatics following 5-10 minute exposures to SO2; in addition, numerous
14         epidemiologic studies reported associations between short-term SO2 exposures and
15         respiratory symptoms and hospitalizations (U.S. EPA, 2008, section 5.2). The ISA also
16         concluded that the evidence  is suggestive of a causal relationship between short-term
17         exposure to SO2 and mortality, and that the evidence is inadequate to infer a causal
18         relationship between short-term exposure to SO2 and cardiovascular effects or between
19         long-term exposure to SO2 and morbidity and mortality. The current ISA will evaluate the
20         literature related to respiratory, cardiovascular, reproductive and developmental health
21         effects, mortality, and cancer associated with SOx exposure. Other health effects may also
22         be evaluated, such as those related to the central nervous system. Health effects that occur
23         following both short- and long-term exposures will be evaluated as examined in
24         epidemiologic, controlled human exposure, and animal toxicological studies, and causality
25         determinations will be developed for each type of health effect.  Efforts will be directed at
26         identifying the lower concentrations at which effects are observed, including effects in
27         populations and lifestages potentially at increased risk of SOx -induced health effects, and
28         assessing the role of SOx within the broader mixture of ambient pollutants. The discussion
29         of health effects also will be integrated with relevant information on dosimetry and modes
30         of action. In the current review, specific policy-relevant questions related to health effects
31         that will be addressed include the following:
32       •  What do controlled human  exposure, animal toxicological, and epidemiologic studies
33          indicate regarding the relationship between short-term (i.e., minutes to one month)

      Do Not Quote or Cite                   4-14                                  March 2014

-------
 1           exposures to SOx and health effects of concern, including the nature and time course, in
 2           healthy individuals and in those with pre-existing disease states (e.g., people with asthma
 3           or cardiovascular disease) or other factors (e.g., lifestage, genetic variants, nutritional
 4           deficiencies) that potentially modify the risk of SOx-induced health effects? What
 5           information is available that reduces uncertainties identified in the previous ISA, such as
 6           exposure measurement error and the potential for copollutant confounding?

 7       •   How do results of recent  studies expand current understanding of the relationships
 8           between long-term (i.e. more than one month to years) exposure to SOx and chronic
 9           respiratory effects manifested as permanent lung tissue damage, a reduction in baseline
10           lung function, or a reduction in lung function growth?  To what extent does long-term
11           SOx exposure promote exacerbation and development of asthma or other chronic lung
12           diseases, cardiovascular diseases, and other conditions?  Are there certain lifestages that
13           are especially vulnerable to the development of these chronic conditions? What is the
14           relationship between SOx exposure  and all-cause mortality and cause-specific mortality?

15       •   To what extent does the scientific evidence support the occurrence of health effects from
16           long-term SOx exposure  at ambient concentrations that are lower than those previously
17           observed?  If so, what uncertainties  are related to these associations and are the health
18           effects in question important from a public health perspective?

19       •   To what extent does short-term or long-term exposure to SOx contribute to health effects
20           beyond the respiratory and cardiovascular systems (e.g.,  reproductive, developmental,
21           cancer)?

22       •   What is the extent of coherence of findings for small changes in lung function, airway
23           hyperresponsiveness, heart rate variability, and vasomotor function and changes in health
24           effects such as hospital admissions,  emergency department visits, and mortality? What
25           other biomarkers of early effect may be used in the  assessment of health effects?

26       •   What evidence is available regarding the shape of concentration-response relationships
27           between short-term and long-term SOx exposure and health effects?

28       •   What evidence is available regarding the nature of health effects from the combination of
29           SOx and other ambient air pollutants in comparison to health effects following exposure
30           to SOx alone?

31       •   What do results from studies conducted in  environments near SOx sources indicate about
32           the health effects of long-term or repeated  SOx exposures?

33       •   To what extent does information across scientific disciplines on the pattern of SOx
34           exposure (e.g., peak, repeated peak, average) provide understanding of the time course
35           for changes in health effects? What information is available on time-activity patterns of
36           study subjects such as time spent outdoors or activity levels that can aid in the
37           understanding of the nature of exposure or dosimetry of ambient SOx concentrations that
38           are associated with health effects?

39       •   To what extent do data across scientific disciplines provide information on health effects
40           related to various short-term SOx exposure indices or averaging times relevant to the  1-
41           hour standard? What data exist comparing associations of health effects among various
42           short-term SOx exposure metrics (e.g.,  1-hour versus 24-hour)?
      Do Not Quote or Cite                   4-15                                  March 2014

-------
 1       •  What information is available regarding the effect of long-term, low-concentration
 2          exposure to SOx on an individual's sensitivity to short-term but higher concentration
 3          exposures?
 4       •  What evidence is available regarding health effects related to long-term exposure
 5          windows other than annual or lifetime average (e.g., preconception, pregnancy average)?
 6          What data are available comparing associations  of health effects among various long-
 7          term SOx exposure metrics (e.g., annual, seasonal, pregnancy average)? Are there critical
 8          windows of human development that are associated with the development of chronic
 9          respiratory disease?
10       •  To what extent are the observed epidemiologic health effect associations attributable to
11          ambient SOx, another ambient pollutant, or to the pollutant mixtures that SOx may be
12          representing? To what extent do findings from experimental studies provide biological
13          plausibility?
14    E.     Populations and Lifestages Potentially at Increased Risk of SOx-Induced Health Effects:
15          The 2008 SOx ISA found substantial evidence from epidemiologic and controlled human
16          exposure studies that asthmatic individuals are more susceptible to respiratory health
17          effects from SO2 exposures than the general public (U.S. EPA, 2008, section 5.4).  The
18          ISA also presented  limited evidence that children and older adults (> 65 years) are
19          potentially at increased risk of SO2-induced respiratory effects.  Since completion of the
20          2008 ISA, EPA has developed a framework to provide a consistent and transparent basis
21          for classifying the weight of evidence about whether populations and/or lifestages are at
22          increased risk according to one of four levels: adequate evidence, suggestive evidence,
23          inadequate evidence, and evidence of no effect (see Table 5-1 of ISA for Lead, U.S. EPA,
24          2013a).  In the framework, key considerations in drawing such conclusions include
25          consistency of findings for a factor within a discipline and coherence of the evidence
26          across disciplines. The current ISA will  examine exposure and health outcome data to
27          draw conclusions about specific populations or lifestages that are potentially at increased
28          risk of SOx-induced health effects. Estimation of the sizes of potential populations and
29          lifestages at increased risk and discussion of the public health significance of the health
30          outcomes characterized to result from ambient SOx exposure may be included.  Potential
31          populations or lifestages at increased risk can be characterized by a variety of factors:
32          intrinsic factors (biological factors such  as age, genetic variants), extrinsic factors
33          (nonbiological factors such as diet, lower socioeconomic status), and/or factors affecting
34          dose or exposure (age, outdoor activity or work).  It is important to note that some factors
      Do Not Quote or Cite                   4-16                                  March 2014

-------
 1          (e.g., age) are interconnected and may influence risk through multiple avenues. In the

 2          current review, specific policy-relevant questions related to populations and lifestages

 3          potentially at increased risk of SOx-induced health effects that will be addressed include:

 4       •  Based on evidence integrated across studies and disciplines that examine factors which
 5          may increase exposure to SOx and/or risk of SOx-induced health effects, what
 6          conclusions can be drawn about the presence of at-risk lifestages (e.g., fetuses, children,
 7          older adults) and/or populations?

 8       •  Studies from which disciplines contribute information about particular at-risk lifestages
 9          and populations, and to what extent does limited or lack of information from specific
10          disciplines produce uncertainty in conclusions about at-risk lifestages and populations?

11       •  How does new information augment that evaluated in the 2008 SOx ISA regarding
12          populations with pre-existing respiratory disease or genetic variants as well as lifestages
13          potentially at increased risk of SOx-induced health effects?

14       •  What information is available that provides insight as to whether an at-risk lifestage or
15          population has higher exposure or dose of SOx and/or has a greater biological response to
16          a given exposure?

17       •  What is the extent of the coherence of evidence regarding potential at-risk lifestages or
18          populations for both short- and long-term exposures to SOx?

19       •  What quantitative information is available that characterizes the magnitude of greater
20          biological response or risk of health effects in at-risk  lifestages or populations?
21

22    4.5   SCIENTIFIC AND PUBLIC REVIEW

23          Drafts of the ISA will be made available for review by the CAS AC SOx primary
24    NAAQS review panel and public as indicated in Figure 4-1 above; availability of draft
25    documents will be announced in the Federal Register. The CAS AC  panel will review the draft
26    ISA documents and discuss their comments in public meetings that will be announced in the
27    Federal Register. EPA will take into account comments, advice, and recommendations received
28    from the CASAC panel and from the public in revising draft  ISA documents. EPA has
29    established a public docket for the development of the ISA. After appropriate revision based on
30    comments received from CASAC and the public, the final document will be made available on
31    an EPA website and in hard copy. A notice announcing the availability of the final ISA will be
3 2    publi shed in the Federal Register.
      Do Not Quote or Cite                  4-17                                  March 2014

-------
 i            5.     QUANTITATIVE RISK AND EXPOSURE
 2                                  ASSESSMENTS

 3          Within the context of NAAQS reviews, quantitative risk and exposure assessments
 4   (REAs) are designed to estimate human exposure and health risks associated with existing and
 5   potential alternative standards.  The appropriate scope of any REA will be informed by the
 6   availability of scientific information from the ISA as well as air quality information and
 7   information on data and models that may help to address important uncertainties or provide
 8   additional insights beyond those provided by previous REAs. As a result, the first step in the
 9   REA planning process is an assessment of the appropriate scope of the REA, which includes a
10   determination of whether a distinct REA document is needed. As part of this planning process,
11   we evaluate the REA for the previous SCh NAAQS review in the context of the extent to which
12   important uncertainties may be addressed by new information available since the previous
13   review and the extent to which new information may change results of the REA in important
14   ways or may allow for additional analyses that can address important gaps in our understanding
15   of the exposures and risks associated with SCh.
16          This phase of the NAAQS review begins with the preparation of a REA Planning
17   Document and considers the extent to which newly available scientific evidence and
18   tools/methodologies provide support for conducting quantitative risk and exposure assessments.
19   To the extent warranted, the scope and methods for components of exposure/risk assessments
20   will be described.  As outlined  in Table 2-1  above, the EPA plans to issue this REA Planning
21   Document in February 2015. This document will be the subject of a CAS AC consultation and
22   will be made available to the public for review and comment. CASAC advice and public
23   comments on  this draft IRP will be considered in developing the REA Planning Document. If
24   warranted, one or more drafts of an REA will then be prepared and released for CASAC review
25   and public comment prior to completion of a final REA.
26          The information newly  available in this review will be considered in light of the
27   comprehensive, complex  and resource-intensive  quantitative assessments of human exposure and
28   health risks documented in the  2009 REA as discussed in section 5.1 below. As discussed in
29   section 5.2 below, the REA Planning Document will consider the available scientific evidence,
30   tools and methodologies in light of areas of uncertainty  identified in the 2009 REA and the
31   potential for new analyses to provide notably different exposure and risk estimates, with lower
32   associated uncertainty. CASAC advice and comments from the public on this draft IRP, as well
33   as the availability of resources, will also inform development of the REA Planning Document.
     Do Not Quote or Cite                  5-1                                 March 2014

-------
 1    5.1   OVERVIEW OF RISK AND EXPOSURE ASSESSMENT FROM
 2    PRIOR REVIEW
 3          In the previous review of the primary SCh NAAQS, the REA focused the quantitative
 4    exposure and risk analyses on 5-minute levels of SCh in excess of potential health effect
 5    benchmark values derived from the controlled human exposure literature. These benchmark
 6    levels are not potential standards, but rather are concentrations which represent "exposures of
 7    potential concern" which are used in the analyses to estimate potential exposures and risks
 8    associated with 5-minute concentrations of SCh. The health effect benchmark values used in the
 9    REA were derived primarily from the ISA's evaluation of the 5-10 minute controlled human
10    exposure literature.  As noted above, the ISA concluded that moderate or greater decrements in
11    lung function occurred in approximately 5 - 30% of exercising asthmatics following exposure to
12    200 - 300 ppb SCh for 5 - 10 minutes. In addition, the ISA concluded that moderate or greater
13    decrements in lung function occurred in approximately 20 - 60% of exercising asthmatics
14    following exposure to 400 - 600 ppb SCh for 5-10 minutes. The ISA also concluded that at SCh
15    concentrations > 400 ppb, statistically significant moderate or greater decrements in lung
16    function at the group mean level have often been reported and  are frequently  accompanied by
17    respiratory symptoms. Moreover, small SCh-induced lung function decrements have been
18    observed in exercising asthmatics at concentrations as low as 100 ppb when SCh is administered
19    via mouthpiece. Taken together, the REA concluded it was appropriate to examine potential 5-
20    minute benchmark values in the range of 100 - 400 ppb.
21          The purpose of the assessments in the SCh REA was to characterize air quality,
22    exposures, and health risks associated with recent ambient levels of SCh, with SCh levels that
23    could be associated with just meeting the then-existing SCh standards (i.e., 30 ppb annual
24    average and 140 ppb daily average) and with SCh levels that could be associated with just
25    meeting alternative 1-hour daily maximum standards.  The SCh REA utilized three approaches to
26    characterize health risks and are briefly described with the following.
27          In the first approach, measured 5-minute maximum SCh concentrations (1997 - 2007)
28    from  98 ambient monitors were evaluated for exceedances of the 5-minute potential health effect
29    benchmark levels, counting the number of days (per monitor and per year) a particular 5-minute
30    benchmark concentration was exceeded and considering unadjusted, as is annual average, daily
31    average, and 1-hour daily maximum SCh concentrations. In addition, 5-minute SCh maximum
32    concentrations were statistically estimated31 using all available monitors that  measured 1-hour
      31The approach for statistically estimating 5-minute maximum concentrations from 1-hour concentrations was based
      on a characterization of ratios of measured 5-minute maximum concentrations to measured 1-hour average

      Do Not Quote or Cite                  5-2                                  March 2014

-------
 1    SCh (1997 - 2006) to generate a similar output (i.e., the number of days per monitor per year a
 2    benchmark concentration was exceeded considering as is air quality). Then, 5-minute maximum
 3    concentrations were statistically estimated in 40 selected U.S. counties (2001 - 2006), though
 4    using 1-hour SCh concentrations as is and, those adjusted to just meet the then-existing annual
 5    and daily standards, and concentrations adjusted to just meet potential 1-hour daily maximum
 6    alternative standards.  In this analysis, all U.S. monitoring sites where SCh data have been
 7    collected were included in this analysis and, as such, the results generated were considered a
 8    broad characterization of national air quality and potential human exposures that might be
 9    associated with these concentrations.
10          In the second approach, we used EPA's Air Pollutants Exposure (APEX) model (US
11    EPA, 2012a,b), a Monte Carlo simulation model that can be used to simulate a large number of
12    randomly sampled individuals within specified locations, generating estimates of population
13    exposure.  APEX simulates exposures in indoor, outdoor, and in-vehicle  microenvironments
14    while taking into consideration the movement of individuals through time and space. APEX
15    estimated 5-minute daily maximum exposures simulated asthmatics may experience while at
16    moderate or greater exertion (e.g., while exercising) and compared these exposures to the same
17    5-minute potential health effect benchmark levels. Two case study areas were selected for this
18    exposure modeling: Greene County, Missouri, and three counties within the St. Louis
19    Metropolitan Statistical Area (MSA). For these two case study areas, year 2002 census block-
20    level hourly SCh concentrations were estimated by EPA's AERMOD (a dispersion model), input
21    to APEX and combined with the same statistical model used for estimating 5-minute peaks
22    described from the hourly SCh concentrations above.  Several modeled air quality scenarios were
23    considered, including as is air quality, air quality adjusted to just meet the then-existing
24    standards,  and air quality adjusted to just meet potential  alternative 1-hour daily maximum
25    standards.  Output from this exposure modeling were the number and percent of asthmatics in
26    each study area experiencing  at least one 5-minute daily maximum exposure at or above the
27    potential health effect benchmark levels while at moderate or greater exertion.
28          In the third approach,  exposure-response relationships derived from controlled human
29    exposure studies were used in conjunction with the outputs of the St. Louis and Greene County
30    exposure analysis to estimate health impacts. More specifically, in each location we estimated
31    the number and percent of all asthmatics or asthmatic  children at moderate or greater exertion
32    expected to experience moderate or greater decrements in lung function defined in terms of sRaw
33    or FEVi and considering the same air quality scenarios mentioned above.

      concentrations (Section 7.2.3 of the 2009 SO2 REA). Nineteen separate ratio distributions were developed from the
      measurement data, stratified by seven 1-hour concentration levels and three concentration variability levels.

      Do Not Quote or Cite                   5-3                                   March 2014

-------
 1          As mentioned above for each of these approaches, ambient SCh concentrations and
 2    exposures were characterized by considering as is air quality (unadjusted concentrations) and
 3    several hypothetical air quality scenarios. Each of the hypothetical air quality scenarios had an
 4    ambient concentration target,  derived from the form and level of the then-existing NAAQS or
 5    from potential alternative standards. Staff chose a proportional approach to adjust the SCh
 6    concentrations to simulate each of the current and alternative air quality standard scenarios.  A
 7    proportional approach was selected based on the mostly linear relationship between older high
 8    concentration years of air quality when compared with recent low concentration years at several
 9    locations  (2009 SCh REA, Section 7.4.2.5).
10          The approach used to  evaluate uncertainty was adapted from guidelines outlining how to
11    conduct a qualitative uncertainty characterization (WHO, 2008), though staff also performed
12    several quantitative sensitivity analyses to iteratively inform both model development and the
13    qualitative uncertainty characterization, where possible. While it may be considered ideal to
14    follow a tiered approach in the REA to quantitatively characterize all identified uncertainties,
15    staff selected the mainly qualitative approach given the limited data available to inform
16    probabilistic analyses and time and resource constraints.
17          The following identifies the key observations and uncertainties from the prior SCh REA.
18
19    5.1.1 Key Observations
20
21    Ambient Air Quality Characterization
22       •  An increased probability of any 5-minute benchmark exceedance was consistently related
23          to either increased 24-hour average or 1-hour daily maximum  concentrations.
24       •  For any of the air quality scenarios considered, the probability of exceeding the 5-minute
25          maximum benchmark levels was  consistently greater at monitors sited in low-population
26          density areas compared with high-population density areas.
27       •  Unadjusted as is air quality at ambient monitors measuring 5-minute maximum
28          concentrations:
29              o  Measured daily and annual average concentrations were below that of the existing
30                 standards at all monitors, though measured 5-minute maximum ambient
31                 concentrations were present above the potential health  effect benchmark levels.
32                 (2009 SCh REA, Appendix A, Table A.5-1)
33                    •  Nearly  70% of the monitor site-years analyzed  had at least one daily 5-
34                       minute maximum concentration above  100 ppb and over 20% had > 25
35                       days with a daily 5-minute maximum concentration above 100 ppb.
36                    •  About 44% of the  monitor site-years analyzed had at least one  5-minute
37                       daily maximum concentration > 200 ppb, 25%  had at least one > 300 ppb,
38                       and 17% had at least one > 400 ppb.

      Do Not Quote or Cite                   5-4                                  March 2014

-------
 1       •  Air quality adjusted to simulate just meeting the then-existing annual standard in the 40
 2          selected U.S. counties
 3              o  All counties evaluated were estimated to have multiple days per year where 5-
 4                 minute daily maximum ambient SCh concentrations are > 100 ppb. For example,
 5                 most counties are estimated to have, on average, 100 days or more per year with
 6                 5-minute daily maximum SCh concentrations > 100 ppb (2009 SCh REA, Table 7-
 7                 11).
 8              o  Fewer benchmark exceedances were estimated to occur with higher benchmark
 9                 levels.  For example, five of the forty counties were estimated to have 60 or more
10                 days per year with 5-minute maximum SCh concentrations that exceed 300 ppb
11                 (2009 SCh REA, Table 7-13).

12       •  Air quality adjusted to potential 1-hour daily maximum alternative standard levels:
13              o  Far fewer days per year with 5-minute maximum SCh concentrations > 300 ppb
14                 and > 400 ppb (about 0 to 5 days/year) were estimated when adjusting air quality
15                 to just meet potential alternative standard levels of 100 and 150 ppb than
16                 compared with air quality adjusted to just meet the current standards (frequently
17                 25 or more days/year) and the potential alternative standard levels of 200 and 250
18                 ppb (about 5 to 20 days/year) (2009 SCh REA, Tables 7-13 and 7-14).
19    Exposure Assessment

20       •  St. Louis had both a greater number and percent of asthmatic children and adults exposed
21          above the benchmark levels than did Greene County for all air quality scenarios, largely a
22          function of both the greater population density and the much greater SCh emissions
23          density in St. Louis (2009 SCh REA, Section 8.9.2).

24       •  Estimated exposures above 5-minute potential health effect benchmark levels at moderate
25          or greater exertion using APEX occurred most frequently outdoors (around 50 to > 90%,
26          depending on the air quality scenario and modeling domain) (2009 SCh REA, Figure 8-
27          21).

28       •  Simulating air quality that just meets the then-existing annual standard in either the
29          Greene County or St. Louis Study areas resulted in the greatest number and percent of
30          asthmatic persons exposed at all benchmark levels (2009 SCh REA, Figures 8-16 and  8-
31          19).

32       •  The exposure results using as is air quality were similar to that estimated using air quality
33          adjusted to a 99th percentile 1-hour daily maximum of 50 or 100 ppb in either study area
34          (2009 SCh REA, Figures 8-16 and 8-19).
35    Health Risk Assessment
36       •  In terms of estimated percentage of all asthmatics or asthmatic children experiencing one
37          or more lung function responses, estimated risks are greater for asthmatic children (2009
38          SCh REA, Tables 9-5 and 9-8, respectively), likely because they spend more time
39          outdoors and at higher exertion levels than adults.
40              o  For example, approximately  13% of all asthmatics were estimated to experience
41                 at least one moderate lung function response (defined as an increase in sRaw >
      Do Not Quote or Cite                  5-5                                  March 2014

-------
 1                 100% (2009 SO2 REA, Table 9-5), while approximately 19% of asthmatic
 2                 children experienced a similar response (2009 SCh REA, Table 9-8).

 3       •  A broad range of SCh exposure concentration intervals selected, some as high as 500 ppb,
 4          contributes to the estimated risks of experiencing one or more lung function responses
 5          per year for some of the standards considered in the assessment. For potential alternative
 6          1-hour standards in the range of 100 to 150 ppb, SCh exposure concentration intervals
 7          below 200 ppb contribute to most of the estimated risks of experiencing one or more lung
 8          function responses per year (2009 SCh REA, Figures 9-7 and 9-8).
 9
10    5.1.2 Key Uncertainties

11       •  Uncertainty in the statistical model used to estimate 5-minute maximum SCh
12          concentrations from 1-hour SCh concentrations.

13       •  Uncertainty in the spatial and temporal representativeness of the SCh ambient monitoring
14          network.

15       •  Uncertainties associated with the proportional air quality adjustment procedure that was
16          used to simulate just meeting the then-existing standard and  several alternative 1-hour
17          daily maximum standards.

18       •  Uncertainties related to the exposure model inputs and exposure estimates which are an
19          important input to the risk assessment.

20       •  Uncertainty about the shape of the exposure-response relationship for lung function
21          responses at levels well below 200 ppb, the lowest level examined in free-breathing
22          single-pollutant controlled human exposure studies.

23       •  Uncertainty with respect to how well the estimated exposure-response relationships
24          reflect asthmatics with more severe disease than those tested in chamber studies.

25       •  Uncertainty about whether the presence of other pollutants in the ambient  air would
26          enhance the SCh-related responses observed in the controlled human exposure studies.

27       •  Uncertainty about the extent to which the risk estimates presented for the two modeled
28          areas in Missouri are representative of other locations in the  U.S. with significant SCh
29          point and area sources.
30
31    5.2   CONSIDERATION OF QUANTITATIVE ASSESSMENTS FOR THIS
32    REVIEW

33          This discussion is focused particularly on considering the extent to which newly available
34    scientific evidence and tools/methodologies are available to inform our understanding of the key
35    areas of uncertainty identified in the 2009 REA.  As outlined in Table  2-1 above, the EPA plans
36    to release an REA Planning Document for consultation with CAS AC and for public comments in
37    February 2015 that will consider the extent to which new quantitative risk and exposure
38    assessments would be appropriate to conduct in the current review.  CAS AC review and public
39    comments on this draft IRP will be considered in developing the REA Planning Document.
     Do Not Quote or Cite                   5-6                                 March 2014

-------
 1           Some key areas being considered by staff, including types of data, methodologies and
 2    tools, are identified and summarized below, with a focus on the three approaches used to
 3    estimate exposure and health risk: an air quality characterization, an exposure assessment, and a
 4    health risk assessment.
 5    5.2.1   Ambient Air  Quality Characterization
 6           The goals of an SCh ambient air quality characterization in a new quantitative risk and
 7    exposure assessment would be (1) to estimate short- and long-term ambient concentration levels
 8    that consider unadjusted SCh air quality and air quality adjusted to just meeting the existing and
 9    any potential alternative SCh standards; (2) to develop quantitative relationships between short-
10    term peak concentrations and time-averaged concentrations; and (3) to identify key assumptions
11    and uncertainties.
12           For the analyses conducted during the last review, ambient SCh monitoring data were
13    available up to mid-2007 (2006 was the most recent year with complete data at that time). Since
14    that review, additional 5-minute data have become available (Table 5-1), particularly during the
15    most recent years (2010-2012). Ambient monitors reporting all twelve 5-minute values per hour
16    are tabulated in the 2nd column; monitors which report one maximum 5-minute value per hour
17    are in the 3rd column; and hourly average monitors not included in the two preceding columns
18    are counted in the last column.  Given the greatly expanded number of monitors, it is possible
19    that we could develop a new statistical model to estimate 5-minute concentrations from hourly
20    concentrations. Additional ambient monitoring attributes (e.g., proximity to selected emission
21    sources) could be considered in its design. Output from this new model could be compared with
22    that generated using the statistical model used in the prior air quality characterization. In
23    addition, relationships between 5-minute peak concentrations and longer averaging times (e.g.,
24    greater than 1-hour but less than 24-hour) would be considered. And finally,  new completeness
25    criteria could be proposed in development of this new statistical model to potentially ensure the
26    quality and representativeness of available measurements that are used.
27           Table 5-2 summarizes the potential areas where additional information, if available,
28    would provide reasonable substance to address key uncertainties identified in the previous
29    review.  These will be considered, in addition to the above factors, in deciding the extent to
30    which new quantitative  risk and exposure assessments would be appropriate to conduct in the
31    current review.
      Do Not Quote or Cite                   5-7                                   March 2014

-------
                       Table 5-1.  The numbers of SO2 monitors 2003 to 201232
Year
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
Monitors Reporting 5-
Minute Continuous
Concentrations1
6
6
6
4
4
3
2
149
194
195
Monitors Reporting 5-
Minute Maximum
Concentrations2
40
32
24
24
22
20
20
31
183
185
Monitors Reporting
1-Hour
Concentrations2
528
524
510
498
499
471
440
435
435
450
 2         1 5-minute continuous monitors with at least 20,000 values/year (about 20% data
 3          completeness).
 4         2 5-minute maximum and hourly with at least 50% data completeness (4,380 values/year).
 5
 6    5.2.2  Exposure Assessment

 7           The goals of an SCh exposure assessment in a new quantitative risk and exposure
 8    assessment would be (1) to estimate short- and long-term exposures to ambient concentrations
 9    through air quality and modeling analyses considering current air quality for SCh and air quality
10    levels just meeting the current and any potential alternative SCh standards; (2) compare
11    estimated exposures to potential health effect benchmark levels; and (3) to identify key
12    assumptions and uncertainties.  Our assessment of uncertainties in the prior SCh REA and the
13    potential utility and impact of newly available information regarding the conduct of a new
14    exposure assessment could consider the following:

15    •  Factors that may contribute to greater personal exposures including the impacts of important
16       sources of SCh (e.g., outdoor point sources).

17    •  Factors that may contribute to lessened personal exposures including infiltration and the
18       decay of SCh indoors.

19    •  Impact of human behavior (e.g., time spent indoors or outdoors, time spent near sources,
20       timing of exposure event, breathing rate) in influencing the magnitude and duration of
21       exposures, and frequency of repeated short-term peak exposures.

22    •  Population living in close proximity to local sources  or otherwise living in areas with
23       elevated SCh concentrations.

24    •  Frequency and (temporal and spatial) variability of peak air quality levels at concentrations
25       and averaging times of significance.
      32 In the last review, the final rulemaking required States to report either the highest 5-minute concentration for each
      hour of the day, or all twelve 5-minute concentrations for each hour of the day (see section 1.3)
      Do Not Quote or Cite
5-8
March 2014

-------
 1          As done was done previously, APEX could be used though we would employ the latest
 2    version the model33 (US EPA, 2012a; 2012b) to estimate 5-minute or long-term exposures of
 3    interest.  Table 5-2 summarizes the potential areas where additional information regarding the
 4    assessment of exposure, if available, would provide reasonable substance to address key
 5    uncertainties identified in the previous review.  These will be considered, in addition to the
 6    above factors, in deciding the extent to which new quantitative risk and exposure assessments
 7    would be appropriate to conduct in the current review.
 8    5.2.3 Risk Assessment
 9          The goals of a SCh risk assessment in a new quantitative risk and exposure assessment
10    would be (1) to estimate the number/percent of people at risk of adverse health effects following
11    exposure to SCh concentrations considering current air quality for SCh and air quality levels just
12    meeting the current and any potential alternative SCh standards; (2) to provide distributions of
13    health risk estimates over a range of ambient SCh concentrations; and (3) to identify key
14    assumptions and uncertainties.  Our assessment of uncertainties in the prior SCh REA and the
15    potential utility and impact of newly available information regarding the conduct of a new risk
16    assessment could consider the following:
17    •  The level and averaging time associated with potential health effect benchmark levels,
18       particularly if there are newly identified at-risk study groups.
19    •  New controlled human exposure studies having the same responses reported in the last
20       review (i.e., sRaw and FEVi) or newly identified adverse responses that could form the basis
21       for the development of exposure-response (E-R) relationships.
22    •  New epidemiologic study(s) that provide(s)  concentration-response (C-R) relationships based
23       on data collected in environmentally-relevant settings. Depending on the type of health
24       response function(s) available, ambient SCh concentration data would be used for
25       characterizing risks and would be most appropriately applied in areas where the
26       epidemiologic study was performed.
27
28       Table 5-2 summarizes the potential areas where additional information regarding the
29    assessment of risk, if available, would provide reasonable substance to address key uncertainties
30    identified in the previous review. These will be considered, in addition to the above factors, in
31    deciding the extent to which new quantitative risk and exposure assessments would be
32    appropriate to conduct in the current review.
      33 APEX is also referred to as the Total Risk Integrated Methodology/Exposure (TRIM.Expo) model (see
      http://www.epa.gov/ttn/fera/trim gen.html for general details on TRIM).

      Do Not Quote or Cite                   5-9                                   March 2014

-------
1    Table 5-2.  Primary uncertainties associated with the exposure and risk assessments in the
2    previous review and the potential use of new information for reducing these uncertainties
    Component of
    Assessment
Uncertainty/Limitation
Remaining From Prior REA
Consideration of Potential
Utility of Information Newly
Available in This Review
For the Assessment
    Air quality characterization
    Characterize relationships
    between 5-minute peak
    concentrations and longer
    averaging times.
    Develop predictive
    relationships to
    approximate the probability
    of occurrence of 5-minute
    peak concentrations given
    hourly average
    concentrations and site
    specific data for use in
    locations without 5-minute
    ambient monitors.
    The estimated number of
    exceedances of potential
    health effect benchmark
    levels occurring at
    monitors located across the
    U.S.
Ambient monitor spatial and
temporal representativeness
regarding the limited number
of monitors reporting 5-minute
SCh concentrations.
Uncertainty of the statistical
model used to estimate 5-
minute maximum SCh
concentrations at monitors that
reported only 1-hour SCh
concentrations.
Ambient monitor spatial and
temporal representativeness
There are now more monitors
reporting 5-minute
concentrations compared with
that used in the last review.

A new characterization of
monitor site attributes and
emissions sources influencing
both 5-minute and hourly SCh
ambient monitoring
concentrations could be
performed.
     Selection of potential
     health effect benchmark
     levels
The health effect benchmark
levels used in the SCh REA
were derived from the ISA's
evaluation of the 5-10 minute
controlled human exposure
literature.

The subjects participating in
these human exposure studies
were exercising asthmatics and
do not include individuals who
may be most susceptible to the
respiratory effects of SCh (e.g.,
the most severe asthmatics).

Since the majority of controlled
human exposure studies
investigating lung function
New estimates of benchmark
exceedances could be
developed if there are studies
newly available that indicate
alternative benchmark levels
exist outside of the range
already considered in the 2009
SCh REA.
    Do Not Quote or Cite
            5-10
                   March 2014

-------
Component of
Assessment
Uncertainty/Limitation
Remaining From Prior REA
Consideration of Potential
Utility of Information Newly
Available in This Review
For the Assessment
                            responses to SCh were
                            conducted with adult subjects,
                            the risk assessment relies on
                            data from adult asthmatic
                            subjects to estimate exposure-
                            response relationships that have
                            been applied to all asthmatic
                            individuals, including children.
Approach used to simulate
just meeting potential air
quality standard scenarios
The proportional adjustment
factors derived from an area's
design monitor are applied to
adjust all ambient monitors
within the given study area.
Deviation from  proportionality
at any monitor could result in
either over or under-estimation
of concentrations.
A different methodology
could be used if there are
studies newly available that
indicate an improved
alternative approach to
adjusting air quality.
Exposure assessment
The estimated number of
people with exposures
above the potential health
effect benchmarks in
different locations
Uncertainty in some of the
exposure model input data
(e.g., activity patterns, indoor
decay rates, air exchange rates)
It is possible that there could
be additional data and/or
analyses that could be reduce
this uncertainty to some
extent.
Representativeness of
study areas
The modeling approach used in
the prior REA to assessing
exposures was resource
intensive;  therefore, the
geographic scope of this
analysis was limited to two
study areas, albeit having two
differing emissions and
population densities.	
The availability of recently
collected 5-minute ambient
monitor concentrations and
consideration of other air
quality input data sources
(e.g., dispersion model) could
allow for exposure estimates
to be developed in other study
areas.
Risk assessment based on clinical exposure studies
Probabilistic exposure-
response relationships
A generally common and
important uncertainty in human
exposure studies is the limited
number of study subjects as
well as limits to the type of pre-
existing health conditions
subjects may have, particularly
if the health condition affords
the subject  with heightened
The availability of new
clinical studies could reduce
the uncertainty associated
with probabilistic exposure-
response relationships.
Do Not Quote or Cite
            5-11
                   March 2014

-------
Component of
Assessment
Uncertainty/Limitation
Remaining From Prior REA
Consideration of Potential
Utility of Information Newly
Available in This Review
For the Assessment
                           effects sensitivity to the
                           pollutant exposure.

                           There remains greater
                           uncertainty in responses below
                           200 ppb because of the lack of
                           experimental data.	
Risk assessment based on epidemiologic studies
City-specific
concentration-response
relationships
In the last SCh NAAQS review,
the REA concluded that the
epidemiologic evidence was
not appropriate for use in
quantitative risk analyses.
The ability to conduct an
epidemiology-based risk
assessment for SCh would
depend on the availability of
concentration-response
relationships from new
epidemiologic studies
sufficient to reduce the
uncertainty to an acceptable
level.

A risk characterization based
on epidemiologic studies also
requires baseline incidence
rates and population data for
the risk assessment locations.
Do Not Quote or Cite
            5-12
                   March 2014

-------
 1
 2   5.2.4  Uncertainty and Variability
 3          The uncertainty and variability inherent in characterizing ambient air quality and in
 4   estimating exposure and risk would also be evaluated in a new quantitative risk and exposure
 5   assessment.  Uncertainty reflects the degree of confidence in the representativeness of models or
 6   model components.  Variability can be described in terms of empirical quantities that are
 7   inherently variable across time and space or between individuals (Cullen and Frey, 1999).
 8   Consistent with prior NAAQS REAs including the last SCh REA, EPA would consider using the
 9   approach described in WHO (2008), whereas a tiered approach to assessing uncertainty and
10   variability in exposure and risk estimates will be employed, beginning with a qualitative analysis
11   and progressing to a quantitative analysis only if warranted and if data are available to support
12   such an analysis.
13   5.3   PUBLIC AND SCIENTIFIC REVIEW
14          The CASAC review panel on the SCh primary NAAQS will be consulted on the
15   risk/exposure assessment REA Planning Document at a public meeting. The panel will also
16   review drafts of the risk/exposure assessment. The panel will review the draft document and
17   discuss their comments in a public meeting announced in the Federal Register. Based on
18   CASAC's past practice, EPA expects that key CASAC advice and recommendations for revision
19   of the document will be conveyed by the CASAC chair in a letter to the EPA Administrator. In
20   revising the draft risk/exposure assessment for SCh, EPA will take into account any such advice
21   and recommendations. EPA will also consider comments received from CASAC or from the
22   public at the meeting itself and any written public comments. EPA anticipates  preparing a
23   second draft of the risk/exposure assessment for CASAC review and public comment. After
24   appropriate revision, the final document will be made available on an EPA website and
25   subsequently printed, with its public availability being announced in the Federal Register.
     Do Not Quote or Cite                  5-13                                 March 2014

-------
 i                    6.    AMBIENT AIR MONITORING

 2          In the course of NAAQS reviews, aspects of the methods for measuring ambient levels of
 3   the NAAQS pollutant, as well as the current network of monitors, including their physical
 4   locations and monitoring objectives, are reviewed.  The methods for sampling and analysis of
 5   each NAAQS pollutant are generally reviewed in conjunction with consideration of the indicator
 6   element for each NAAQS. Consideration of the ambient air monitoring network generally
 7   informs the interpretation of current data on ambient air concentrations and includes an
 8   assessment of the adequacy of the monitoring network for determining compliance with the
 9   existing or, as appropriate, a potentially revised NAAQS.  This chapter describes plans for
10   considering these aspects of the ambient air monitoring program for sulfur oxides which includes
11   the indicator SCh.
12
13   6.1        CONSIDERATION OF SAMPLING AND ANALYSIS METHODS
14          In order for the data to be used to determine compliance, ambient SCh concentration data
15   must be obtained using Federal Reference Methods (FRMs) or Federal Equivalent Methods
16   (FEMs) which are designated by the Agency in accordance with 40 CFR Part 50 and Part 53.
17   As described earlier, SCh is the indicator for the sulfur oxides NAAQS, and has been routinely
18   measured by UV fluorescence FEMs since the 1980s. The SCh concentration data produced by
19   modern FEM analyzers are routinely logged by state and local agencies whom report the hourly
20   average and either the maximum 5-minute value (one of twelve  5-minute periods) in the hour or
21   all twelve 5-minute averages within the hour to EPA's Air Quality System (AQS).
22          The Agency is unaware of any recent technological advances in SCh measurements or
23   forthcoming modifications to existing  methods that should be considered in this NAAQS review.
24   Therefore, the EPA does not anticipate raising any specific sampling and analysis methods issues
25   for consideration in this  integrated review plan.
26   6.2   CONSIDERATION OF AIR MONITORING NETWORK
27         REQUIREMENTS
28          The ambient air quality monitoring networks for criteria  pollutants  support three major
29   objectives: (1) to provide air pollution data to the general public in a timely manner; (2) to


     Do Not Quote or Cite                  6-1                                 March 2014

-------
 1    support compliance with NAAQS and emissions strategy development; and (3) to support air
 2    pollution research studies. A review of the available SCh monitoring network and data was
 3    performed as part of the primary SCh NAAQS review completed in 2010. Subsequent to that
 4    review, and in conjunction with revising the primary standards, the Agency promulgated
 5    minimum monitoring requirements to support the implementation of a new primary 1-hour SCh
 6    standard. The 2010 action introduced minimum requirements based upon the use of a Population
 7    Weighted Emissions Index (PWEI). The PWEI utilizes both population and emissions data
 8    within Core Based  Statistical Areas (CBSAs) to determine if monitoring is required in a CBSA
 9    and, if so, how many monitors are required.  The intent of using the PWEI to require monitors is
10    to focus monitoring into areas where there is a higher proximity of population and SCh
11    emissions. In effect, areas with a higher calculated PWEI value are expected to have higher
12    potential for population exposure to peak, short-term SCh emissions.
13          Historically, the data used to determine compliance with the SCh NAAQS have been
14    largely based upon data obtained from ambient monitors operated by state, local, and tribal air
15    monitoring agencies. These monitors are either required due to federal regulation contained in
16    40 CFR Part 58, Appendix D, state implementation plans, industrial permits, or other state or
17    local requirements  or voluntary actions. While monitoring data are a mainstay in determining
18    compliance for all other criteria pollutants, SCh is unique in that there is a precedent to also use
19    dispersion modeling in the implementation of its NAAQS. This is notable because the use of
20    modeling in lieu of monitoring  can potentially reduce the necessary size and distribution of a
21    compliance monitoring network.  As a result, the final monitoring requirements promulgated as
22    part of the 2010 SCh NAAQS revision reflected this potentiality.34
23          As of December 2013, the ambient SCh monitoring network is estimated to have 431
24    monitors in operation nationwide. This number far exceeds the approximate 129 required by
25    PWEI.
      34 The best available rationale and description of the Agency's current thinking on the SO2 implementation is "Next
      Steps for Area Designations and Implementation of the Sulfur Dioxide National Ambient Air Quality Standard,"
      also known as the "strategy paper," which was released in February of 2013
      (http://www.epa.gov/airquality/sulfurdioxide/pdfs/20130207SO2StrategyPaper.pdf).

      Do Not Quote or Cite                   6-2                                   March 2014

-------
 i              7.    POLICY ASSESSMENT/RULEMAKING

 2    7.1    POLICY ASSESSMENT
 3          The PA, like the previous OAQPS Staff Paper, is a document that provides a transparent
 4    OAQPS staff analysis and staff conclusions regarding the adequacy of the current standard and
 5    potential alternatives that are appropriate to consider prior to the issuance of proposed and final
 6    rules.  The PA integrates and interprets the information from the ISA and REA(s) to frame policy
 7    options for consideration by the Administrator.  The PA is also intended to facilitate CASAC's
 8    advice to the Agency and recommendations to the Administrator on the adequacy of the existing
 9    standard or revisions that may be appropriate to consider. Staff conclusions in the PA are based
10    on the information contained in the ISA and, as available, the REA, and  any additional staff
11    evaluations and assessments discussed in the PA.  In so doing, the discussion in the PA is framed
12    by consideration of a series of policy-relevant questions drawn from those outlined  in chapter 3,
13    including the fundamental questions associated with the adequacy of the current standard and, as
14    appropriate, consideration of an alternative standard(s) in terms of the specific elements of the
15    standard: indicator, averaging time, level, and form.
16          The PA for the current review will identify conceptual evidence-based and risk/exposure-
17    based approaches for reaching public  health policy judgments. It will discuss the implications of
18    the science and quantitative assessments for the adequacy of the current primary standard and for
19    any alternative  standards under consideration.  The PA will also describe a broad range of policy
20    options for standard setting, identifying the range for which the staff identifies support within the
21    available information. In so doing, the PA will describe the underlying interpretations of the
22    scientific evidence and risk/exposure information that might support such alternative policy
23    options that could be considered by the Administrator in making decisions for the primary SCh
24    standard. Additionally, the PA will identify key uncertainties and limitations in the underlying
25    scientific information and in our assessments. The PA will also highlight areas for future health-
26    related research, model development,  and data collection.
27          In identifying a range of primary standard options for the Administrator to consider, it is
28    recognized that the final decision will be largely a public health policy judgment. A final
29    decision must draw upon scientific information and analyses about health effects and risks, as
30    well as judgments about how to deal with the range of uncertainties that  are inherent in the
31    scientific evidence and analyses.  Staffs approach to informing these judgments recognizes that
32    the available health effects evidence generally reflects a continuum consisting of ambient
33    concentrations at which scientists generally agree that health effects are likely to occur, through
34    lower concentrations at which the likelihood and magnitude of the response become increasingly


      Do Not Quote or Cite                  7-1                                   March 2014

-------
 1    uncertain.  This approach is consistent with the requirements of the NAAQS provisions of the
 2    CAA and with how the EPA and the courts have historically interpreted the Act. These
 3    provisions require the Administrator to establish primary standards that are requisite to protect
 4    public health and are neither more nor less stringent than necessary for this purpose.  As
 5    discussed in section  1.1 above, the provisions do not require that primary standards be set at a
 6    zero-risk level, but rather at a level that avoids unacceptable risks to public health,  including the
 7    health of at-risk populations35.
 8           Staff will prepare at least one draft of the PA document for CAS AC review and public
 9    comment.  The draft PA document will be distributed to the CASAC Sulfur Oxides Primary
10    NAAQS Review Panel for their consideration and provided to the public for review and
11    comment.  Review by the CASAC Panel will be discussed at public meetings that will be
12    announced in the Federal Register. Based on past practice by CASAC, the EPA expects that
13    CASAC would summarize their key advice and recommendations for revision of the document
14    in a letter to the EPA Administrator. In revising the draft PA document, OAQPS will take into
15    account any such recommendations, and also consider comments received from CASAC and
16    from the public, at the meeting itself, and any written comments received.  The final document
17    will be made available on an EPA website, with its public availability announced in the Federal
18    Register.
19
20    7.2    RULEMAKING
21           Following  issuance of the final PA and the EPA management consideration of staff
22    analyses and conclusions presented therein, and taking into consideration CASAC  advice and
23    recommendations, the Agency will develop a notice of proposed rulemaking. The  proposed
24    rulemaking notice conveys the Administrator's proposed conclusions regarding the adequacy of
25    the current standard(s) and any revision that may be appropriate. A draft notice of proposed
26    rulemaking will be submitted to the Office of Management and Budget (OMB) for interagency
27    review, in which OMB and other federal agencies are provided the opportunity for review and
28    comment.  After the completion of interagency review, the EPA will publish the notice in the
29    Federal Register seeking comment on proposed agency action - namely whether or not to revise
30    the current standard, and if so, how.  Monitoring rule changes associated with review of the
      35 The at-risk population groups identified in a NAAQS review may include low income or minority groups. Where
      low income/minority groups are among the at-risk populations, the rulemaking decision will be based on providing
      protection for these and other at-risk populations and lifestages (e.g., children, older adults, persons with pre-
      existing heart and lung disease). To the extent that low income/minority groups are not among the at-risk
      populations identified in the ISA, a decision based on providing protection of the at-risk lifestages and populations
      would be expected to provide protection for the  low income/minority groups.

      Do Not Quote or Cite                    7-2                                    March 2014

-------
 1    primary SCh standard, and drawing from considerations outlined in Chapter 6 above, will be
 2    developed and proposed, as appropriate, in conjunction with this NAAQS rulemaking.
 3           At the time of publication of the notice of proposed rulemaking, all materials on which
 4    the proposal is based are made available in the public docket for the rulemaking.36 Publication
 5    of the proposal notice is followed by a public comment period, generally lasting 60 to 90 days,
 6    during which the public is invited to  submit comments on the proposal to the rulemaking docket.
 7    EPA also will provide opportunity for a public hearing on any proposed action. Taking into
 8    account comments received on the proposed action, the Agency will then develop a notice of
 9    final rulemaking, which again undergoes OMB-coordinated interagency review prior to issuance
10    by the EPA of the final rule. At the time of final rulemaking, the Agency responds to all
11    significant comments on the proposed action.37 Publication of the final action in the Federal
12    Register completes the process.
13
14
15
16
17
      36 The rulemaking docket for the current primary SO2 NAAQS review is identified as EPA-HQ-OAR-2013-0566.
      This docket has incorporated the ISA docket (EPA-HQ-ORD-2013-0357) by reference. Both dockets are publicly
      accessible at www.regulations.gov.
      37 For example, Agency responses to all substantive comments on the 2009 notice of proposed rulemaking in the last
      review were provided in the preamble to the final rule and in a document titled Responses to Significant Comments
      on the 2009 Proposed Rule on the Primary National Ambient Air Quality Standards for Sulfur Dioxide, available at:
      http.V/www. epa.gov/ttn/naaqs/standards/so2/s_so2_cr_rc. html

      Do Not Quote or Cite                    7-3                                    March 2014

-------
                                 8.     REFERENCES
1.   Cullen ACandFrey HC (1999).  Probabilistic Techniques in Exposure Assessment. A handbook for dealing
    with variability and uncertainty in models and inputs.  New York, NY. Plenum Press.

2.   McCurdy, T., Glen, G., Smith, L., Lakkadi, Y. (2000).  The National Exposure Research Laboratory's
    Consolidated Human Activity Database.  J Expo Anal Environ Epidemiol. 10: 566-578.

3.   Morgan M.G.; Henrion M. (1990). Uncertainty: A Guide To Dealing with Uncertainty in Qualitative Risk and
    Policy Analysis. Cambridge University Press.

4.   Samet JM. (2009). Letter to EPA Administrator Lisa P. Jackson: Clean Air Scientific Advisory Committee's
    (CASAC) Review of EPA's Risk and Exposure Assessment to Support the Review of the SO2 Primary National
    Ambient Air Quality Standards: Second Draft. EPA-CASAC-09-007, May 18, 2009. Sulfur Dioxide Review
    Docket. Docket ID No. EPA-HQ-OAR-2007- 0352-0035. Available at http://www.regulations.gov.

5.   EPA.  (1982). Air Quality Criteria for Paniculate Matter and Sulfur Oxides. US EPA, Research Triangle Park,
    NC: Office of Health and Environmental Assessment.

6.   EPA.  (1986). Second Addendum to Air Quality Criteria for Paniculate Matter and Sulfur Oxides (1982):
    Assessment of Newly Available Health Effects Information. US EPA, Research Triangle Park, NC: Office of
    Health and Environmental Assessment.

7.   U.S. EPA (1994). Supplement to the Second Addendum (1986) to Air Quality Criteria for Paniculate Matter
    and Sulfur Oxides (1982): Assessment of New Findings on Sulfur Dioxide and Acute Exposure Health Effects
    in Asthmatic Individuals EPA/600/FP-93/002.

8.   U.S. EPA (2004). AERMOD : Description of Model Formulation.  Office of Air Quality Planning and
    Standards.  EPA-454/R-03-004. Available at: http://www.epa.gov/scram001/7thconf/aermod/aermod_mfd.pdf.

9.   U.S. EPA (2007). Green Book Nonattainment Areas for Criteria Pollutants. Available at:
    http://www.epa.gov/air/oaqps/greenbk/index.html.

10.  U.S. EPA (2008). Integrated Science Assessment (ISA) for Sulfur Oxides - Health Criteria (Final Report).
    EPA/600/R-08/047F. Available at: http://cfpub.epa.gov/ncea/cfm/recordisplav.cfm?deid=198843.
11.  U.S. EPA (2009). Risk and Exposure Assessment to Support the Review of the SOa Primary National Ambient
    Air Quality Standard. EPA-452/P-09-007.  July 2009. Available at:
    http://www.epa.gOv/ttn/naaqs/standards/so2/s so2crrea.html.

12.  U.S. Environmental Protection Agency (2012a). Total Risk Integrated Methodology (TRIM) - Air Pollutants
    Exposure Model Documentation (TRIM.Expo / APEX, Version 4.4) Volume I: User's Guide. Office of Air
    Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC.  EPA-
    452/B-12-001a.  Available at: http://www.epa.gov/ttn/fera/human _apex.html

13.  U.S. Environmental Protection Agency (2012b). Total Risk Integrated Methodology (TRIM) - Air Pollutants
    Exposure Model Documentation (TRIM.Expo / APEX, Version 4.4) Volume II: Technical Support Document.
    Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, Research Triangle Park,
    NC. EPA-452/B-12-001b. Available at: http://www.epa.gov/ttn/fera/human_apex.html

14.  U.S. Environmental Protection Agency. (2013a) Integrated Science Assessment for Lead (Final Report). U.S.
    Environmental Protection Agency, Washington, DC, EPA/600/R-10/075F... Available at:
    http://www.epa.gov/ttn/naaqs/standards/pb/sjb 2010  isa.html.


    Do Not Quote or Cite                     8-1                                 March 2014

-------
15.  U.S. Environmental Protection Agency (2013b). Integrated Science Assessment of Ozone and Related
    Photochemical Oxidants (Final Report). U.S. Environmental Protection Agency, Washington, DC. EPA/600/R-
    10/076F. Available at: http://www.epa.gov/ttn/naaqs/standards/ozone/s_o3_2008_isa.html

16.  WHO (2006). Air Quality Guidelines. Global Update 2005. Paniculate matter, ozone, nitrogen dioxide and
    sulfur dioxide Summary of Risk Assessment. World Health Organization. Available at,
    http://www.euro.who.int/InformationSources/Publications/Catalogue/20070323  1

17.  WHO. (2008). WHO/IPCS Harmonization Project Document No. 6. Part 1: Guidance Document on
    Characterizing and Communicating Uncertainty in Exposure Assessment. Geneva, World Health Organization,
    International Programme on Chemical Safety. Available at:
    http://www.who.int/ipcs/methods/harmonization/areas/exposure/en
    Do Not Quote or Cite                     8-2                                 March 2014

-------
                               APPENDIX A
      DRAFT OUTLINE FOR INTEGRATED SCIENCE ASSESSMENT FOR
                     SULFUR OXIDES - HEALTH CRITERIA
Preamble
(will be available online)
Preface
Executive Summary

Chapter 1
1.1
1.2
1.3
1.4
1.5
1.6

Chapter 2
2.1
2.2
2.3
2.4
2.5
2.6
2.7

Chapter 3
3.1
3.2
o o
J.J
3.4
Process of ISA Development
EPA Framework for Causal Determination
Public Health Impact
Concepts in Evaluating Adversity of Health Effects

Legislative Requirements for the NAAQS Review
History of the Primary NAAQS for Sulfur Dioxide
Integrative Summary
Policy-relevant Questions for Sulfur Dioxide NAAQS Review
ISA Development and Scope
Sulfur Oxides Sources, Ambient Concentrations, Exposure
Health Effects Evidence
     Exposure, Dosimetry, and Modes of Action
     Comparison of 2008 ISA and Current Conclusions
     Key Evidence for Evaluated Health Effects
Policy-Relevant Considerations
     Concentration-Response and Thresholds
     Exposure Averaging Times and Lags
     At-risk Populations
     Adverse Health Effects, Public Health Significance
Summary

Atmospheric Behavior of Sulfur Oxides
Introduction
Sources
Atmospheric Chemistry and Fate
Monitoring
Atmospheric Concentrations of Sulfur Oxides
Modeling
Summary and Conclusions

Exposure to Ambient Sulfur Oxides
Introduction
General Considerations
Exposure Measurement
Exposure-related Metrics
   Do Not Quote or Cite
           A-l
March 2014

-------
3.5                         Exposure Modeling
3.6                         Implications for Epidemiologic Studies
3.7                         Summary and Conclusions

Chapter 4                   Integrated Health Effects Exposure to Sulfur Oxides
4.1                         Introduction
4.2                         Dosimetry and Mode of Action
4.3                         Respiratory Morbidity
                                 Peak (5-10 min) and Short-Term (1+ hr) Exposure
                                 Long-Term Exposure
4.4                         Cardiovascular Morbidity (Short-Term and Long-Term)
4.5                         Other Morbidity
                                 Reproductive and Developmental
                                 Cancer
                                 Neurological/Other Emerging Outcomes
4.6                         Mortality (Short-Term and Long-Term Exposure)
4.7                         Summary and Conclusions
Chapter 5                   Potential At-risk Lifestages and Populations
                            Introduction and Summary of 2008 ISA Key Findings
                            Review of Evidence for Specific Lifestages or Factors
                                 Influencing Health Effects of Sulfur Oxides such as:
                                 Children, Older Adults, Socioeconomic Status, Diet, Sex,
                                 Pre-existing Disease, Genetic Variants
                            Summary and Conclusions
   Do Not Quote or Cite                 A-2                             March 2014

-------
[This page intentionally left blank.]

-------
United States                          Office of Air Quality Planning and Standards          Publication No. EPA-452/P-14-005
Environmental Protection               Health and Environmental Impacts Division                               March 2014
Agency                                      Research Triangle Park, NC

-------