July 29, 1999 EPA-SAB-EEC-99-COM-004 Ms. Carol M. Browner The Administrator U. S. Environmental Protection Agency 401 M Street, SW Washington, DC 20460 RE: Commentary on the Need for Research on Risk Reduction Options for Particulate Matter 2.5 (PM2 5) Dear Ms. Browner: The Science Advisory Board recommends that research on options for reducing risks from Particulate Matter 2.5 (PM25) be conducted in parallel with research on the relationship of PM25 to health effects. The strategic exploration of potential PM25 risk reduction options will ensure that information is available to address both primary and secondary particulate matter standards in a timely manner. In 1997, the Environmental Protection Agency (EPA) retained its regulatory position on PM10 and initiated action on PM25, recognizing both the differences between the two size fractions and studies showing an association between PM2 5 and health effects. EPA has begun a major research program on PM25, guided by input from the National Research Council. The Board applauds EPA's emphasis on gathering critical scientific information to better characterize the nature and extent of the risks involved, including the potential causative agents, and their primary and secondary sources. At the same time, even a simple value-of-information analysis would indicate that early exploration of potential risk reduction options associated with PM2 5 would have significant benefit because this research is likely to decrease the time required to reduce the risks once they are more fully understood. The Board acknowledges that the Agency has initiated source control research and encourages it to expand the scope to include a wider range of options. Early research into reducing PM2 5 may have benefits in addition to reducing risks to human health. Such research will generate important data for visibility programs, for example, and provide information relevant to the control of ecological risks resulting from PM25. Even a modest investment in examining potential risk reduction options could decrease the time required to take action. Planning for risk reduction research should consider both a number of hypotheses about the sources of risk and a variety of options for intervention. Chapter 4 of the SAB's soon-to-be- released Integrated Risk Project report discusses a wide range of possible risk reduction options including control technology, pollution prevention, and market incentives. Research on a limited ------- number of promising options will ipmove the scientific basis for regulatory decision making and associated technical support programs. The following research themes are examples of those that could be considered: a) Approaches that enhance and explore technologies which capture particles and which can capture both primary particles and secondary particulate matter precursors. b) Development of source-specific "chemical fingerprints" to better understand contributions of specific sources to atmospheric concentrations of PM25. c) The linkage between source processes (e.g., combustion conditions, secondary PM25 formation) and composition of PM25. Waiting for complete definitive information before expanding the risk reduction research program will lengthen the time before test results and evaluations of various risk reduction options are available. The time needed to test and evaluate a risk reduction option depends upon the nature of the option, the opportunities for testing it, and the quality & quantity of the data needed for decision-making. For some options, such as those involving technology development and/or adaptation, the time between the decision to evaluate and the availability of the results may be measured in years. During this time, people will continue to be at risk. When the results of the health research are available, we may learn that not all the risk reduction research was germane to the reduction of health risks. However, it is more likely that some, even a good deal, of that research will result in the substantial reduction of risks sooner, rather than later. Furthermore, all of the risk reduction research is likely to be relevant to comprehensive fine particle control strategy decision-making because health effects are not the only problem associated with fine particles. There are other regulatory considerations and programs, such as the regional haze program, and the secondary PM2 5 standard. Therefore, the risk reduction research results are likely to serve a variety of regulatory programs. In developing this commentary, we have drawn upon the Committee's early work, the expertise and experience of its members, interactions with key individuals, both inside and outside of the Agency, and briefings and discussion at several public meetings. Relevant Committee reports include reviews of the National Risk Management Research Laboratory (SAB 1997a), Technology Innovation Program (SAB 1995a), and verification programs (SAB 1995b,1995c,and 1997b). The EEC members' experience with control technology is reflected in their service on National Research Council committees as well as on advisory boards of other organizations that deal with control technology issues. As to the future, we plan to enter discussions with the ORD Board of Scientific Counselors (BOSC) to see how we might be of assistance as they initiate a study of the way in which the Agency is carrying out the research plan on particulate matter. Further, we would be ------- happy to meet with appropriate Agency personnel to discuss how these ideas might be carried out and look forward to continued participation in the Clean Air Scientific Advisory Committee's Technical Subcommittee for Fine Particle Monitoring. We look forward to your reaction to this commentary. Sincerely, ience Advisory Board , 'Inyang, Environmental Engineering " Science Advisory Board ommittee JoASTrt "Slama-Crjlnt} Subcommittee on Sources W PI Environmental Engineering Committee ------- U.S. ENVIRONMENTAL PROTECTION AGENCY Science Advisory Board Environmental Engineering Committee (FY99) CHAIR Dr. Hilary I. Inyang, University Professor and Director, Center for Environmental Engineering, Science, and Technology (CEEST), University of Massachusetts, Lowell, MA MEMBERS Dr. Edgar Berkey, Vice President and Chief Science Officer, Concurrent Technologies Corporation, Pittsburgh, PA Dr. Calvin C. Chien, Senior, Environmental Fellow, E. I. DuPont Company, Wilmington, DE Mr. Terry Foecke, President, Waste Reduction Institute, St. Paul, MN Dr. Nina Bergan French, President, SKY+, Oakland, CA Dr. Domenico Grasso, Head of Department of Civil and Environmental Engineering, Environmental Research Institute, University of Connecticut, Storrs, CT Dr. JoAnn Slama Lighty, Associate Dean for Academic Affairs, Associate Professor of Chemi cal Engine ering, Univer sity of Utah, Salt Lake City, UT Dr. John P. Maney, President, Environmental Measurements Assessment, 5 Whipple Road, Hamilton, MA Dr. Michael J. McFarland, Associate Professor, Utah State University, 130 South 1000 East, River Heights, UT Ms. Lynne M. Preslo, Senior Vice President, Technical Programs, Earth Tech, Long Beach, CA Science Advisory Board Staff Mrs. Kathleen W. Conway, DFO, Science Advisory Board, U.S. EPA, Washington, DC ------- Mrs. Dorothy M. Clark, Committee Secretary, Science Advisory Board, U.S. EPA, Washington, DC ------- U.S. ENVIRONMENTAL PROTECTION AGENCY Science Advisory Board Environmental Engineering Committee (FY99) Subcommittee on Sources of PM25 CHAIR Dr. JoAnn Slama Lighty, Associate Dean for Academic Affairs, Associate Professor of Chemi cal Engine ering, Univer sity of Utah, Salt Lake City, UT MEMBERS Dr. Edgar Berkey, Vice President and Chief Science Officer, Concurrent Technologies Corporation, Pittsburgh, PA Dr. Hilary I. Inyang, University Professor and Director, Center for Environmental Engineering, Science and Technology (CEEST), University of Massachusetts, Lowell, MA Dr. Nina Bergan French, President, SKY+, Oakland, CA Dr. Michael J. McFarland, Associate Professor, Utah State University, River Heights, UT Science Advisory Board Staff Mrs. Kathleen W. Conway, DFO, Science Advisory Board, U.S. EPA, Washington, DC Ms. Mary Winston, Committee Secretary, Science Advisory Board, U.S. EPA, Washington, DC in ------- REFERENCES SAB. 1995a. Technology Innovation Program, EPA-SAB-EEC-95-013, Environmental Engineering Committee, Science Advisory Board, U.S. Environmental Protection Agency, Washington, DC. SAB. 1995b. Environmental Technology Innovation and Commercialization Enhancement Program EPA-SAB-EEC-95-016, Environmental Engineering Committee, Science Advisory Board, U.S. Environmental Protection Agency, Washington, DC. SAB. 1995c. Verification of Innovative Continuous Air Emission Monitors EPA-SAB-EEC- 95-018, Environmental Engineering Committee, Science Advisory Board, U.S. Environmental Protection Agency, Washington, DC. SAB. 1997 aSuperfund Innovative Technology Evaluation Program, EPA-SAB-EEC-97-005, Environmental Engineering Committee, Science Advisory Board, U.S. Environmental Protection Agency, Washington, DC. SAB. 1997b. National Risk Management Research Laboratory EP A-SAB-EEC-97-011 EP A- SAB-EEC-95-013, Environmental Engineering Committee, Science Advisory Board, U.S. Environmental Protection Agency, Washington, DC. IV ------- NOTICE This report has been written as part of the activities of the Science Advisory Board, a public advisory group providing extramural scientific information and advice to the Administrator and other officials of the Environmental Protection Agency. The Board is structured to provide balanced, expert assessment of scientific matters related to problems facing the Agency. This report has not been reviewed for approval by the Agency and, hence, the contents of this report do not necessarily represent the views and policies of the Environmental Protection Agency, nor of other agencies in the Executive Branch of the Federal government, nor does mention of trade names or commercial products constitute a recommendation for use. Distribution and Availability: This Science Advisory Board report is provided to the EPA Administrator, senior Agency management, appropriate program staff, interested members of the public, and is posted on the SAB website (www.epa.gov/sab). Information on its availability is also provided in the SAB's monthly newsletter (Happenings at the Science Advisory Board). Additional copies and further information are available from the SAB Staff. ------- |