ML20083A259

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Response Opposing NRC & Applicant Motions for Summary Disposition of Contention 8F1 Re Coal Emissions Health Effects.Nrc & Applicant Should Abide by Same Rules as Intervenors
ML20083A259
Person / Time
Site: Harris  Duke Energy icon.png
Issue date: 12/16/1983
From: Eddleman W
EDDLEMAN, W.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20083A262 List:
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8312200233
Download: ML20083A259 (24)
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Text

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l zi UNITED STATES OF AMERICA NUCLEAR BEGULATOBY COMMISSION '85 05019 5i:04 y e ~- ~

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' Glenn Dr. O. Bri James H.ght Carpenter James L. Kelley, Chairman In the Matter of

) Dockets 50 400 OL CABOLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )

Units 1 arx1 2) ) ASLPP No. 82-L6F-01

) OL Wells Eddlenan's Resnonse to Staff & Apnlicants '

Motions for Sunnary Disnosition of Contention 8F1 (coal emissions health effects)

First, much of Staff's and Applicants ' statenents, arguments and affidavits disnute the validity of the emissions number for coal particulates (1151 4 metric tons ner year) given in Table S-3 All such goings-on are challenges to N9C rules. Intervenons are not allowed to disnute the values of emissions given in Table S-3 In fairness, neither should Staff or Apulicants be allowed to.

If they want to change the values, they can institute (or netition for) a rulemaking, or they can file netitions for a variance from the rule under 10 CFR 2.758. To date, it annears Staff and Annlicants have not done either of these things. Therefore, all their assertions regarding the actual amount of narticulates to be discharged should be ignored, and the figure of 11514 netric tons given in Table S-3 of 10 CPR 51.20, and statements and argunents based on that figure, should be the only things considered by the Board regavding contention 8F1. Staff and Applicants should play by the sane rules intervenovs 8312200233 031216 have to. DR ADOCK 05000 3 .

O In the FES',1 consideration of health effects of coal na-ticulates appears as part of a single sentence in Appendix C (p.C-h) stating that the Staff has found that "these emissions" add about "'O 02%

(two-hundredths of one percent) of the national annual releases" for each of these snecies (including particulates).

Contention 8F(1) does not even annear in Annendix J of the FFS, listing admitted contentions and what section(s) of the FES deal with them. This is true ever. though that appendix lists content $ons that have long since been thrown out as need-for-nower issues (""22A and B) and others on which both Staff and Apolicants have effectively moved for sunnary disposition. (See up J-1 thru J-4)

The contention says that the health effects of coal particulates "have not been analyzed (or) given sufficient weight

in the DES, and the FES, on its face, annears to not analyze or give weight to these health effects.

However, Applicants ' affiant Leonard D. Hamilton, when he deals with the actual S-3 number of 115h metric tons ner reactor-year of narticulates, effectively supports the contention. He calculates t n

[ (Affidavit in Sunnort of Anplicants ' Motion for Summary Disposition l

of Wells Eddleman's Contention 8P(1)", Dec. 6 '83 , page 7) that coal narticulate the health effects of this level of emissions from the nlants actually 4

sunnlying various gas diffusion (uranium enrichment) facilities range from 0.1 deaths year (Jonpa plant and Kyger plant), to 0.11 deaths for the Shawnee plant, 0.29 for the Bull Run plant, and 0.kh l for the Clifty plant. While he states these figu"es are uncertain, he says the " coefficient is statistically greater than zero" (ou 7 8)

(the " coefficient" is in fact 1.3 + 0.6 deaths / yea" per 10b versons per microgram ner cubic meter of fine narticulates (FP), ibid, n.7).

I While Anplicants' affiant stresses the uncertainties in this analysis, Applicants, in their sunplemental responses to interrogatories on 8F(1)

(Dec. 6 '83) admit the effects could be " extremely small" (answer to 8f1-1(a), p.2 ibid). The Harvard damage coefficient cited by Dr.

Hamilton is not zero, and the fact that, due to possible errors in data used to ddrive it (Hamilton, affidavit u.8) it cannot be absolutely proved to be nonzero is not strong enough efidence for sunmary disnosition on this issue.

To see this, connare the treatment of radiation health effects in the FES: It asserts'*D.008 cancer deaths / year from this (2-unit) facility"'(p.5-35) due to nuclear waste transnortation (spent fuel etc) and radiological imnacts of the niant, which it sneaks of in sevewal pages of text (however ill-documented it may be). Mo"eover, the Staff figured (p.5-31) about 12 changces in 100 that one of the workers at the plant would die of cancer due to on-the-job radiation exposure. Similar small numbers, e.g. O.3 genetic defects, have discussion and a part of Annendix C concerning Unen.

If Applicants' affiant Hamilton *s right, the S-3 emissions l

from coal n1 ants (particulates) would uroduce 0.1 to 0.kk deaths l

l per reactor year, based en a statistically significant damage estimate from such particulates by Harvard University Energy & Environmental Policy Center. (Dr. Hamilton used the midpoint of the estinate, i.e.

1 3 deaths /10b persons-year ner microgran per m3 fine earticulates ) .

Those are comparable or larger numbers than the Staff radiation death and genetic effect numbers cited above. Yet the FFS nrovides no l analysis connarable to that for radiation health effects as to the coal narticulates included in Table S-3 Note that the FES states (as to radiation health effects) "Most authorities agree that a reasonable -- and nrobably conservative -- estimate of the effects of low levels of radiation exnosure to a large number of people is within the range of about 10 to 500 potential cance" deaths

-h-(although zero is not excluded by the data) per million verson-rens.

(p.5-53, top, emnhasis added). So even though zero deaths are not excluded, in Staff's view, for the radiation deaths due to Shearon Harris oneration, they are considered (radiation deaths) and calculated somehow. This isn't done for the coal particulates, even thoagh Dr. Hamilton's own data show that a reasonable, conservative estimate for such deaths (based on health effects data statistically significantly different from zero -- p.7 of his affidavit), is 0.1-0.hk deaths / year, per Harris unit (Table S-3 is for one reactor,10, CFR 51.20).

Dr. Hamilton also gives a figure for mortably over the entire

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US using the same damage function (taking fine carticulates at half the 1145 MT/ year Table S-3 particulate emissions due to Harris per unit) on page 8 of his affidavit. It is 0.67 excess deaths ner year.

Since the Staff takes the 11h5 netric tons of navticulates to be 0.02% of US total emissions (FES page C-4), we can infer from this figure that in the US, 5000 tines 0.67 deaths ner year would be l

caused by coal narticulates in total (3350 deaths / year). It is clear that this estimate of deaths (0.67/ reference reactor year) is large connared to any radiation health effects estimate in the FES, including uranium m'ning/ nuclear f uel cycle deaths which are the largest effect of radiation mentioned, ranging in Staff's opinion from about 0.27 deaths /RRY (100 - year estimate) to 2 deaths /RRY (1000-year estimate; both from rage C-8, nuclear fuel cycle effects).

This brings me to a fundamental misconcention in Dr.

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, Hamilton's affidavit. He noints out that EPA has (in a , ,1982 staff document) estimated total narticulate concentrations of ex $$ to 110 micrograes/ cubic meter of TP (total narticulates) are of concern.

l He quotes them as saying (affidavit, p.h, bottom) that the 110 pg/m3 end of the range "may not include any margin of safety" (and then he uses that number, effectlysly, by taking 55 ug/m3 of fine narticulates, l

l

-5 (fine particulates being about half of total narticulates, see ibid n.8).

But the additional emissions of narticulates from the S-3 Table do not occur in a vacQum, i.e. they do not go into air with zero particulates in it. Rather, they go into air that already has a varticulate loading. So without at this noint going into the carcinongenic effects of particulates in the basis of 8F(1) (which Dr. Hamilton ignores),

we can say that the additional effect of the particulates added by the Table S-3 emissions will reasonably be related to health effects in pronortion to their amount, since the average loading of parbiculates in air is already in the 55 microgram ner cubic meter range (reference: 3/15/82 TOTAL SUSPENDED PA9TICULATES data for North Carolina,1981, see geometric mean and arithmetic mean for numerous stations renorting in NC). (c6ny attached, Exhibit 1).

(the forwarding letter from NC Div. of Enviro. Mgt, air cuality section, as Exhibit 2, is also attached). This comnletely undermines the alleged validity of noint 12 (p.5) of Hamilton's affidavit.

If particulate levels are already at or above the 55 ug/m 3 level, added narticulates (enrichment of fuel for Harris is an added use of electricity) would add to health effects.

Given this fact, Dr. Hamilton's own estimates as stated above i

show health effects from coal particulates at or above levels of health effects of radiation that were much better considered in the FES/LES than coal narticulates were.

l Of course, Applicants and Staff imnroperly connare estimated deaths due to coal particulates (and radiation) to total deaths that otherwise occur, but the point of the NEPA cost-benefit analysis for Harris is not to compare it to all other causes of death, but to connare its benefits to its environmental costs (including added deaths).

I note also that Dr. Hamilton for Applicants All but ignores the health effects of particulates other than deaths, thougP thesex are well known (aggravation of respiratory diseases, etc.: See, e.g.

Health Effects of the Gas-Aerosol Comnlex, Environmental Health Perspectives Dec. 1979 (copy attached) at p.197, bottom of 1st column and ton of second. See also, re acutely harmful effects, j ibid. pp 199-200. Note, p.200, it says health effects would be pronortional to.the density of the local ponulation, sunnorting Dr. Hamilton's numerical analysis on n/7 of his affidavit).

1 Dr.Hamiltononlysaysthatacut'eeffectsofexposureto coal particulates require the exposure be long-standing (iten l

16, affidavit p.8) . What is more long-standing than the oneration of a uraniun enrichment facility (load factor over 90%) for 30 years or so to enrich fuel for a Harris nuclear plant running for a 30-or-so year lifetime? The high load factor means the emissions will be near continuous (coal plants running sonewhere or other all the time l

to suoply the enrichment plant's continuous demand for nower), and

! the 30 years exeosure is certainly "long-standing". Dr. Hamilton i

doesn't really address these problems in his single paragraph aboutacuteandnon=deatheffectsofcoalyarticulates,andsurely therein does not orovide enough information for summary disposition as to these health effects.

Another counter to Applicants affiant saying health effects l

l may be zero is that of Perera & Ahned, 9espirable Particles (already i given to Applicants on discovery), pp h0-hh (cony of those tages l

These pages describe fine particle health effects in detail, w/refs.

attached). On page 41 it says a 1 percent reduction in total particulates could lead to an 0.23 to 0.89 percent reduction in pollution-related mortality. The pollution-related nortality alone in the US is estinated (Perera & Ahmed, n.1, cony attached) at 15000 to 100,000 Der year.

Thus, if we take the Staff DES (page C-4) estinate that 11k54 0.0$

MT of coal particulates is o.02% of US total emissions, they could be expected to cause a change of (0.23 to 0.89)xO.02 percent in the 15000 to 100p00 deaths per year due to pollution. This

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number increase in deaths ner year, ish.6to17.8)x10 out of the 1.5 x 10b to 1 x 10 5 pollution-related &atths.

Thus, the upper limit of deaths would be 17.8 per year due to the S-3 emissions (17.8 x 10-3 x 10 5 ), while the lower limit would be 0.69 deaths / year (4.6 x 10 x 1.5 x 10'b). Note that the lower. limit here matches Dr. Hanilton's 0.67 deaths year fairly closely.

Staff takes a different anuroach (motion for summary disposition of Eddlenan contention 8F(1), December 2,1983). Admitting (ibid u.7) specific that the FES contains no _ . ' analysis of coal narticulate health effects, they clain these effects are insignificant while the FE_S only covers significant health effects (p.7, cuoting their affiant Billues at 5). As shown above, this argument is false on its face if one reads the DES /YES, which devote considerable space and specific discussion of health effects much smaller than those which, on the basis of Derera & Ahned's book or Dr. Hamilton's analysis for Applicants, occur from 1154 MT of coal particulates on a nationwide basis or a local basis near uranium-enrichment plants.

Staff characterizes my concerns with health effects (n.11) as " bald assertions" because I don't nyself know what the level of respiratory diseases, etc, would be if 115h MT of coal particulates were added to existing pollution levels. I suggest they read the basis documents of contention 8F2(1), which were cited on dis covery I

to by Anplicants (Staff has done no discovery on this contention)

Staff has not requested any of the

10/6/83 WE resnonse at 1h-15 i

documents cited in that resnonse, nor those in the basis of 8F1.

Neither Applicants' nor Staff's affiant states that he has reviewed ANY of these. Without review of these documents, how can their analysis be sufficient to dismiss this contention?

As noted above, the statements by Staff affiant Dr. Billuns about coal emissions not consistent with Table S-3 (e.g. up5-lh i 1

i of his affidavit) are a challenge to the rules and must not be considered in this croceeding.

As to the innact of the Thble S-3 narticulate emissions themselves, (

Dr. Billups anpears to argue baldly (pp2-3) that they are insignfficant, based on WASH 4248, He challenges the WASH-12h8 values on nage h, ,

S-3  !

arguing the emissions levels are conservative. So what? The value of emissions itself, he never describes any health effects analysis for.

These 1154 MT of narticulates are the issue in this proceeding.

Dr. Billups does advance the theory (p.k) that the eauivalent of h5 MWe is drawn fron he entire TVA power grid ner WASH-1[h8. f 6 9

  • reah sg 9%fNes 41(Al f.t 114; However, as shown abovt re US total particulate emissions and their health effects, there are health effects fron such a spread-out emission of coal particulates. In narticular, North Carolina is Exhibit 1 of ten down-wind of TVA, and NC particulate levels shown in attachment (referenced above) are often at or above the 55 ug/m3EPA says is of concern. Added narticulate would add to health effects therefron.

In sum, Anplicants' and Staff's arguments fail to even l

address (nor have their affiants evidently read) the health effects documents cited on discovery October 6 to Annlicants in resnonse to interrogatory 8F1-6 (copy attached, Exhibit h).

Most of their affidavits and argunent challenges the S-3 release value for coal narticulates,115h Metric Tons / year, which they may not do. ,

I Both Perera & Ahmed (un47 above) & Dr. Hamilton show health effects considered.

from coal narticulates at or above FES radiation effects

Dr. Hamilton is wrong to attribute zero health offects to additional particulate levels (which he figures by ' reasonable assumptions"

, his affidavit, up-3-h) to be added by the 115h MT of emissions in table S-3, because the actual narticulate levels i (e.g. in NC, Exhibit 1) are already at the EPA level of concern 3

($$ ug/m ) cited by Dr. Hamilton hinself (affid, pp h-5). Added pollution will thus add to the health effects, which Dr. Hamilton calculates himself at 0.1 to 0.67 deaths / reference reactor-year (i RRY is 1154 MT emissions in Table S-3). The coefficient of damage Dr. Hamilton used in this comnutation (n.7) is statistically significantly different x from zero by his own statement. The idea that zero "cannot be excluded" fron this number is a nossibility ,

one that likewise applies to radiation health effects considered in the FES/ DES (see FES p. 5-53). l 1

Finally, the FES does not consider the health effects of coal narticulates, in suite of the existence /adnission of contention 8F(1) since 8/18/83, as Staff adnits. How they can crgue that no consideration is an adequate consideration is sinnly beyond me.

The contention was that the FES gave inadequate consideration and insufficient weight to coal narticulate emissions. .

In view of only one sentence I've located being about them,  !

andcoalno weight assigned to them though the evidence discussed above narticulate d

showsA eath estinates by Ann 11 cants' own affiant (I'll call hin as a witness if they don't, seeking a subpoena to do so if necessa*y) that are abovealways, the FES andestimates for deaths above those for due to niant radiation, nuclear transnortj nuclear employment and nuclear fuel cycle in soveral cases.

If Staff wanted to get rid of this content $ or, they could simply have considered and veighed the health effects of coal carticulates in the FES. They didn't, the contention is still true on its face, and fo8fthe above reasone sunmary di snosition must fail, in light of the availbble evidence, e g. . tha t aN' l

1

]()- .

NOTE In addition to the a bove-referenced info to be attached to this Responso, I am supplying the Board with copies of the followinF documents (basis of 8F1, etc) relevant to this issue:

Goldstein, Health Effects of the Gas-Aerosol Comnlex Falk & Jurgelski, Health Fffects of Coal Mining & Combustion:

Carcinogens & Cofactors DPS Natusch, Characterization of Atnoscheric Dollutants from Power Plants Van Hook, Potential Health and Environmental Effects of Trace Elements and Radionuclides from Increased Coal Ut3 lization C. Aranyi et al, Cytotoxicity to Alveolar Macronhages of Trace Elements Adsorbed on Fly Ash (cf. Goldstein, p.193, 2d col bottom)

Cohen, et al, Asthma and Air Pollution from a Coal-Fueled Power Plant King, Mutagenicity of Filtrates fron 9esnirable Coal Fly Ash DFS Natusch, Potentially Carcinogenic Species Emitted to the Atmosphere by Fossil-Fueled Power Plants Fisher & Natusch, Size Denendence of the Dhysical and Chemical Preperties of Fly ash.

Due to extensive size of scme, they nay be mailed Dec. 17 on 19. Tho Staff hasn't requested any documents from me, I'w311 sunnly sane to them upon request.

SHORT LIST OF MATTEFS IN DISPUTE ON 8(F)(1)

1. Applicants and Staff challenge the rules in disnuting the 1154 MT coal particulate emir.sions given in Table S-3
2. It is valid, in light of anibient particulate concentrations (e.g. Exhibit 1, for NC,1981), to compute additional health effects due to earticulates at the 1154 MT level, whether emitted from specific plahts (Hamilton analysis for Aunlicants) or snread over the whole nation (Hanilton 0.67 deaths /yr; my ests nn 6-7 of above resnonse relying on Perera & Ahmed and their references). This is also true if the 1154 MT emissions are localized to the TVA grid.

i 3 The additional deaths resulting from 115k MT emissions range fron 0.1 to 17.8 deaths added rer reference reactor yeat under l

reasonable assumntiens including (at the lower end) analysis by i Dr. Hamilton for Applicants , and (at the unner end) analysis based l

on Perera & Ahned data (p.1 of book & refs on p.1) and Dr. Hamilton's adopted danage function.

h. the Harvard damage function used by Dr. Hamilton, 1.n3 + 0.6 deaths per 100,000 persons ner year ner microgran/m3 of fine particulates ,

is in fact statistically different from zero.

5. The FES contains no enecific analysis of health effects of coal particulates.
6. The FES does go on for pages and nages about radiation health effects, e.g. those from plant radiation nut at 0.008/9RY.
7. The FES analyzes, says Scaff, "significant" effects. B111uns staff affidavit at 5, on page 2.
8. The coal particulate damages from 115h MT of na rticulates calculated by Dr. Hamilton are larger than many innacts analyzed in the FES (e.g. 0.1 death /RRY, his low est, is greater then 0.008 deaths) 9 Neither An licants nor Staff address the non-death health effects of coal pS11ution enough to get disposition on this point.
10. Exposure to c oal long term and continuous. pollution due to enriching uraniun is --

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y 6

9 THE PNluANY A"HIF N T AlH UUALITY STANUAND JS 75 UG/M1 ANNUAL GEOMETHIC MEAN, AND A MAXIMUM OF 260 UG/M3 AVF.HAGED nVFR A 21.HlitJW Ptpluu NOT 70 BE EXCEEDED MORE THAN ONCE PER YEAH. THE SECONDARV STANDAHO IS 150 UG/M3, A 24 HOUR NAA NOT Tn HE h, F E A CEf.DEU "OwF THAN ONCE_Pp YEAR,_A__po UG/M3 AGM " GUIDE" IS USED TO ASSESS VjubATIQNS OF THE 24=110UN.SFCONDARY STANDAND_,,_,, A i

f [ ' g} & 6 & S cfSes fy $~S chu t -/

8F1-5(a)The accuracy of the Table S-3 values is irrelevant to the contention. These values are established by rule, and 10 CFR 2.758 no contention is allowed to challenge an NFC rule (excent via : 0 metitio-petition. Therefore ,I do not " contend" anything about the accuracy of the release values given in Table S-3 re coal pollutants, which is the subject of this contention.

(b),(c) Not Applicable. See 5(a) above.

8F1-6: Cancer, intestinal disorders, increased incidences and severity of respiratory diseases of most types, premature deaths

~~

d dua to respiratory disease and worsened effects or reseiretory diseases (as well as due to cancer and other causes); irritation of eyes, mucous

  • e tsabranes; see documents listed in 8F1; see also the book Reseirable Particles by Perera and Ahmed (Ballinger,1979) e.g. at 31-kh (esu 40-kh),

50-53,55-56,56-57,57-59,59-63,66-69,71,71 -74; see also 84 (food chain I

offects); see also Health Effects of Air Pollution, report of the Anarican Thoracic Society, Medical Section of American Lung Assn, f C2r11 Shy, _M.D. , Chair,1978, particularly at 13-22,27-29, and30-h0.

Sao also references cited in the above-cited or listed works.

The indices of the above-cited works detail what is covered l

, Intestinal absoretion where; the above pages discuss health effects.

effects are included in EHP Vol 33 (1979); data on existence / transport ,

of various harmful substances identified in documents listed / cited above is in the Atmosphere-Bionsphere Interactions (Nat'l Research Council, 1981, David W. Schindler, Chair -- see author list, p. iii). I 8F1-7(a): See listing in contention 8F1, 6-20-83; I OBJECT to making an extensive search of what I may possess that isn't filed under coal pollution cases, but from that, the information and sourcers

T 4 \orn Caroina Jeaar~merr o"

% sources &Communi~y Jeveoamen~

Jarnes B. Hunt, Jr., Governor DIVISION OF ENVIRONMENTAL MANAGEMENT Air Quality Section

\ aura Joseph W. Grimsley, Secretary October 25, 1982 Mr. Wells Eddleman 718-A Iredell Street Durham, NC 27705

Dear Mr. Eddleman:

Thank you for your interest and questions regarding air pollution. In response to your questions we provide the following:

(1) What is DNRCD doing about sulfate pollution in the air? North Carolina has both emission standards and ambient air standards for sulfur dioxide.

Most ambient air sulfates are believed to be the reaction product of sulfur dioxide and other substances in the air.

(2a) How many air quality samples does the State take monthly in North Carolina 7 In excess of 25,000 samples / month are collected by State and local agencies. The State and local agencies operated both manual and continuous ambient air samplers. Manual samplers have been operated for total sus-pended particulate, sulfur dioxide, nitrogen dioxide, and lead. These samplers operate every 6th day. As of Second Quarter 1982 there were 93 TSP, 25 SO2, 27 NO and 3 Pb samplers. Currently the manual network size is being reduced Continuous monitors operate continuously. Data are normally reported on an hourly average basis. Each of the 34 continuous monitors can produce 720 hourly averages per month.

Attached for your information is a summary of the 1981 data. We are 7 currently adding 14 additional continuous monitors to the sampling network.

b) How many are taken by industry? Not all industries are required to report data that is collected. We are unable to provide a count of those not reporting data they collect for their own use.

l There are seven industries either required or voluntarily reporting ambient air data. Some industries are reporting both "cri teria" and "non-criteria" pollutants. Most industries (of those reporting) are collecting the more costly continuous samples. Currently in excess of 7300 ambient samples per month are collected by industry.

l l

i P. O Box 2767 Raleigh. N C 27611 7687 l

An EqualOpportunity Affirmative Action Employer l

Mr. Walla Eddleman 2 October 25, 1982 In addition to continuous ambient monitoring, there are in excess of 50 industrial facilities conducting continuous emissions monitoring. Opacity and sulfur dioxide are most frequently measured. Many industries also sample and analyze fuel samples in order to determine sulfur dioxide emissions from fuel burning processes. Fuel sample information is not usually reported to the State, unless required by permit.

c) By universities, or researchers? Ambient monitoring has taken place at many universities and technical institutes across the state, but primarily for educational purposes. Research type projects have been conducted at Appalachian State University, North Carolina State University, and Uni-versity of North Carolina at Chapel Hill, among others.

The National Atmospheric Deposition Program collects weekly acid-rain -

samples at seven sites.

Numerous ambient air research projects have been conducted by the Research Triangle Institute, and EPA located in the Research Triangle Park.

-as We encourage you to visit our headquarter's offices and review the data file if more information is needed. If you have questions, please call me at (919)733-6126.

Sincer ly, )

/

  • ; gu ,

Fin Jo son Acting Chief Air Quality Section FJ/GM:dg Attachment

? 2 kos f ( R Ye. Otrkq]e.s bu f&Wc 0lnwtd  % cupieri (SGUnocien (@y .

Introduction:

A Brief Summary

$>p HD- G

' OtJ ft&wg SAco '

+ back uf Q Eight years after the passage of the Clean Air Act Amend-ments of 1970, air pollution continues to take a devas-tating toll. Every year at least 15,000 people die from exposure to pollutants in the air;* millions more suffer from debili-tating illness caused by air pollutants.' In addition to inflicting this severe and costly injury to health, air pollution destroys visibility, l damages property and crops, and seriously threatens the natural environment. Thus air pollution costs many billions of dollars each year.88 Increasing evidence places much of the blame for this on one class of air pollutants that remains virtually unregulated today-atmospheric fine particulates.8

  • Fine particulates are generally defined as particles smaller than 1

] to 2 micrometers in diameter-or roughly one-fiftieth the width of a i

j human hair. Because of their small size, fine particulates pose a serious threat to human health. They are small enough to elude the body's defense system and to be breathed deep into the lower lung, i

' where they can remain for long periods before being cleared.5 Fine particulates are generally man-made and result from com-

'bustion, industrial, and transportation processes.' They are either directly emitted or, more often are formed in the atmosphere from gaseous precursors (SO 2 , NO,, hydrocarbons, etc.) that are gen-

' erated by these same processes.* Fine particulates reach very large

" Estimates of air pollution related deaths range as high as 100,000 deaths per year [L.B. Lave, E.P. Seskin, Epidemiology, causality and Public Policy *',

American Scientist, 67, 1979,178) i  !

a e .e.,

40 Respirable Particles General Health Eflects of Fine Particutstes 41 ASSESSMENT OF HUMAN years 1960,1961, and 1969. Once again they found a strong asso-HEALTH EFFECTS OF ciation between suspended particulate and variations in infant mor-AIRBORNE PARTICLES tality and total mortality rate (age-sex-race adjusted). In view of

- these findings, the authors stated that: "Since one of our basic con-A large body of epidemiological evidence indicates a qualitative re. clusions was that suspended particulate levels were significantly lationship between " air pollution" and disease and mortality. The related to the mortality rate . . . it seems likely that if one is willing l

j most obvious evidence of health effects of air pollution comes from a to accept the notion of a national standard as meaningful . . . then i number of tragic episodes that occurred during conditions when air the present primary standard for suspended particulates may not be pollutants including particulate matter were highly concentrated, stringent enough (p. 313)."

These include severe air pollution episodes in Meuse Iliver Valley, A recent attempt to quantify the effects of existing ambient levels j Belgium, in 1930; Donora, Pennsylvania, in 1948; London, in 1952 of air pollution on human mortality has also concluded that total and 1962; New York, in 1953 and 1973; and Osaka, Japan, in particulates were significantly related to mortality.'** The study,

1962.3.2o,73 Many thousands of people died as a result of exposure to based on 1968-1972 data from Allegheny County, Pennsylvania, high concentrations of air pollutants."' Many more were made estimated that a 1 percent reduction in total particulates would lead seriously ill. to between a 0.23 percent and 0.89 percent reduction in pollution-These tragic statistics represent the most obvious damage from air related mortality.'"

in the past twenty years, an increase in the incidence of lung l pollution; long-term chronic effects of air pollutants go unnoticed in far greater numbers of people.' Epidemiological assessment of the cancer in urban nonsmokers as compared with rural nonsmokers has chronic effects of air pollution is hindered by a number of factors come to light through a series of epidemiological studies.8'*"'**

that make interpretation of data difficult. These factors include This difference is often referred to as the " urban factor."',,2o,i4:

j variables such as occupational exposure, socioeconomic status, and in 1967, Buell and Dunn from Berkeley, California, reviewed the j personal habits. Moreover, crude measurements of the pollutants evidence on lung cancer and air pollution and concluded: "The etio-

! themselves and the fact that lifetime exposure might not be reflected logical roles for lung cancer and urban living and cigarette smoking in currently measured levels can also interfere in making meaningful seem to be complete in that the urban factor is evident when viewing l

correlations. nonsmokers exclusively, and the smoking factor is evident when j viewing rural dwellers exclusively (p. 296).'*5 More recently, Carnow a With these caveats in mind, Lave and Seskin at Carnegie-Mellon

University at Pittsburgh reviewed the literature in an attempt to and Meier at the Universities of Illinois and Chicago, respectively,
quantify the relationship between mortality, morbidity, and air also noted "a number of different types of epidemiological studies j pollution at nonacute levels. They described studies from England, leading to fairly consistent estimates of a substantial effect of air pol-the United States, and Japan linking air pollution to mortality from lution on pulmonary cancer death rates." They roughly estimated l that for each unit increaseh of B(a)P in urban pollution, there would

! bronchitis, lung cancer, total respiratory disease, cardiovascular j disease, infant mortality, and deaths from all causes. The authors be a 5 percent increase in the lung cancer death rate."8 A 5 percent concluded that these studies indicated a strong relationship between increase would be equivalent to an additional 4,450 deaths in the United States (1977 estimate).' A recent National Academy of l mortality from bronchitis, total respiratory disease, lung cancer, and a number of indices of air pollution including airbome particulate matter. Two studies were also described by the authors that showed uThe importance of taking into account smoking habits of populations mortality from heart disease to be higher in central city cour. ties studied in areas of high and low pollution (urban versus rural) has been estab-lished particularly in studies examining cancer incidence and mortality.

thin in suburban counties.2e .

Cigarette smoking and air pollution are now widely recognized as mdependent More recently, m. 1977 Lave and Seskm. analyzed atr pollution and factors causing human lung cancer, whic when combined produce an additive mortality data for 117 Standard Metropolitan Statistical areas for the and in some cases a synergistic effect.'*5dg'

{ hA unit increase of U(a)P is here defined as an additional one microgram of i

]

I Chronic effects of air pollution other than respiratory disease and cancer, B(a.)P per 1,000 cubic meters of air.

such as mutagenicity, teratogenicity, behavioral effects, and subtle metabolic 8 Based on Cancer Facts and Figures, American Cancer Society,1977 (NCI changes, are scarcely being looked at. Third National Cancer Survey).

]

~

9

]. g l -

t l

42 RespirableParticles General Healah Effects of Fine Particul:tes 43 1

. Sciences (NAS) report summarized some forty epidemiological bacteria screening system for potential human carcinogenicity.I . i studies linking exposure to polycyclic organic matter (usually B(a)P) Samples taken from a nonurban area gave negative results in the same l with lung cancer mortality and concurred with this estimate by test system."5 More recently, in separate studies filtrates from the j Camow and Meier

  • respirable fraction of flyash from a coal-buming plant and diesel fine l A number of studies have investigated a link with various measures particulate emissions both gave positive results in the Ames test indi-l or indices of air pollution, including airbome particulates, and cancer cating that these emissions contain substances that may be carcino-I of organs other than the lung.'*"A'*h"* Winkelstein and Kantor,in genic in humans."' "'

! analyzing rates of stomach cancer mortality in Buffalo, New York, There is a growing body of knowledge about the role of fine found the rate of mortality due to stomach cancer to be twice as particulates in respiratory disease (in addition to lung cancer) that high in areas of high pollution (based on an index of suspended par- might help explain the observed increase in deaths from chronic ticulates) as in areas of low pollution."' respiratory disease in urban as compared with rural areas. A number Fine particulates are suspected of contributing to this urban of studies showed that certain substances that are generally in the increase in cancer. Possible carcinogenic effects may be attributable form of fine particulates-sulfates and nitrates-are associated with to organic compounds such as polycyclic organic matter (POM) and respiratory disease, chronic bronchitis, aggravation of asthma, and certain metallic substances and fibers that have been occupationally cardiopulmonary disease.'"-

associated with human cancer such as chromates, arsenic, asbestos, Studies on the effect of respirable particulates and other pollu-
nickel, and beryllium.28'"3 "' In addition, organic alkylating agents tants have been conducted by the Community Health and Environ-j such as nitrosamines-a class of highly potent animal carcinogens- mental Surveillance Systa.m (CHESS) of EPA.k These include a j epoxides, and lactones may be associated with atmospheric fine 1971-1972 New York City study that reported an association i

particles.%"' Similarly seven of twenty-two industrial organic vapors between various air pollutants including respirable suspended particu.

emitted in substantial amounts are known or suspected to be car- lates (RSP) and respiratory and cardiac symptoms in the elderly.

j cinogens."2 These organic vapors may be changed to fine particulate Along with suspended nitrates, suspended sulfates, and SO2 , RSP j form by a variety of mechanisms (e.g., ccndensation, adsorption, or appeared to exacerbate symptoms in the well elderly panel. A simi-I chemical reaction).** Finally, several reports have pointed out a lar but weaker pactern of effects was observed in the lung disease

! possible correlation between airbome sulfates and cancer of the res- panel.8'2

piratory and gastrointestinal tracts."5 '" Another 1971-1972 CIIESS study in two southeastern cities l As we have seen, even those inhaled fine particles that may be (Birmingham, Alabama, and Charlotte, North Carolina) showed that j chemically nontoxic by themselves increase the effect of a potential impairment of lung fimetion in schoolchildren was connected with ccrcinogen by acting as carriers and by delaying clearance from the exposure to TSP and to RSP.'" Children in Birmingham, where

-l lung."."* According to Camow and Meier, the importance of the levels of respirable suspended particulates were higher, showed role of fine particles (e.g., carbon) as " adsorbents and carriers of greater impairment of lung function than children in Charlotte, i

POM and irritant gases that, by interfering with and slowing down North Carolina. Until 1969 both cities had had comparable concen-

. pulmonary clearance, may increase the duration of contact between trations of RSP so that only the younger children in the study had

{ carcinogenic materials and bronchial mucous membranes (p. 217)"8" experienced very different levels of these pollutants from early life

must not be overlooked. on. The finding that intercity differences in lung function impair-j While no one air pollutant has been demonstrated experimentally ment were more marked in younger than in older children 'ed the j to cause lung cancer in people (for obvious ethical considerations no

{ one has done such an experiment), the carcinogenicity of the niix- iThe Ames test, which detects mutations in bacteria, is used as a first step in

< ture of substances encountered in urban air has been indicated by screening for human carcinogens because the great majority of,cppounds that

studies in which animals forced to inhale extracts of urban atmo, cause mutations in the test bacteria also cause, cancer in animals.

kin the CHESS studies, samplers were designed to trap no particles above 10

, spheric samples developed tumors.s Samples of polluted a.ir taken in diameter,25 percent of particles of 5 micrometers,50 percent gparticles of i from urban areas have shown positive results in the Ames Salmonella 3.5 in diameter,and all particles of diameters between 0.1 and 2.5.

5 - -

lP _I fe .

44 Respirable Particles authors to state that "it is tempting to hypothesize that these differ-ences were at least partly attributable to differences in exposure to RSP from the earliest years of life (p. 301)."'*8 h Chapter 4 More recently, C.T. Chen at the University of Texas in llouston has reported an association between mortality from respiratory dis-eases and the numerical concentration of respirable particles in the air that was stronger than that for suspended particulate mass con. Substances Found .in the centration. More specifically, mortality from asthma, bronchitis, and Fine Particulate Fraction emphysema was more closely associated with the sir.e distribution of

  • susperided particulate than with total suspended particulate mass. In the study, " respirable" particulate matter consisted largely of parti-cles from 0.3 to 3 micrometers, with particles of 3 to 10 micrometers generally comprising less than 1 to 2 percent of the total number of all particles (ranging from 0.3 to 10 micrometers) measured.

As mentioned earlier, death rates from chronic respiratory disease have been rising steadily in the United States and are considerably higher for people living in urban areas than for the rural popu-lation. Fine particulates, which reach their highest concentrations in urban areas, are undoubtedly an important factor in this observed Fine particulates can be divided into four general cata increase as well as in the urban increase in lung cancer.* gories: inorganic sulfates, nitrates, metallic substances an fibers, and organic particulates. Information is given belo' aTwo recent studies related to the " urban increase" are ofinterest: Aaalysis of 1950-1969 data from the New Jersey region shows that lung cancer is the on the sources, health, and welfare effects of each. Ilowever, leadhg cause of male cancer mortality and that most of the high rate counties should be stressed that at present the extent to which the healt are in the densely developed urban / industrial corridor. (M.R. Greenberg, Cancer effects of each component of fine particulates can be separaten Mortality in the New Jersey Reg on. 1950-1969: High and Low Risk Factors, . . . . . . .

State of New Jersey Department of Environmental Protection, January 1979.) Identified is limited. This is because of the m. teraction between all c A second study of cancer deaths in Texas from 1969-1976 showed an alarm- the components and between fine particulates and gaseous a ing 53% increase in lung cancer over those years with the highest rates found pri- pollutants.no :,32 The environmental effects of these pollutants as marily in the industrialized, heavily populated areas of the state. (Impa:t of Concer on Texas. The Texas Department of Health and the University of Yexas discussed m. Chapter 5.

System Cancer Center, M.D. Anderson Hospital and Tumor Institute,1978.)

While further studies are called for to separate out the contributions of.iccu- AIRBORNE INORGANIC PARTICULATES pation, personal habits such as smoking, ethnic origm, air pollution, etc., r.espir-able pollutants in the atmosphere must be considered an important factor.

Sulfates Backgroumi. Sulfates account for a substantial fraction of th fine particul.ite burden in urban air and are said to constitute up t 60 percent (by mass) of the secondary fine particulate burden i the eastern United States.'" Sulfates in the urban air are generall smaller than 2 micrometers in size and are predominantly in the Oq to 1 micrometer size range.* * They are therefore small enough V aA recent study in California (ACHEX) found the mass median diame '

(aerodynamic diameter) of sulfate particles to be in the range of 0.22 to O micrometer. These findings are in agreement with data from earlier studies Chicago and Cincinnati.ase,s6s 45

[^

146 RespirableParticles N Formaldehyde along with acrolein and PAN is a major product of <

photochemical oxidation as well, Inhalttion of formaldehyde at even low concentrations causes i /

rapid end severe irritation of the eyes, nose, and other portions of 3 g ,

(./

the upper respiratory tract. Eye irritation has been reported at con- t centr:tions as low as 0.01 ppm. Synergism of formaldehyde with References GG. b*"'"td, f].,vSt Q W aerosol has been reported and results in increased toxicity. Bronchi-tis and bronchopneumonia have been reported following exposure to high concentrations of formaldehyde. One report concluded that it O pd NM is likely that at present ambient levels, formaldehyde produces eye and respiratory tract irritation, especially near large production g

f:cilities.3*5

/ 2 -g (,Q

1. Air Quality and Automobile Emission Control. Report by the Coordi nating Committee on Air Quality Studies. National Academy of Sciences, National Academy of Engineering, September 1974; Air Pollution, vol. 2, The Effects of Air Pollution, Arthur C. Stern,ed. New York: Academic Press,1977.
2. LB. Barrett and T.E. Waddell. Cost of Air pol % tion Damages, a Status Report, Publication AC-85. Research Triangle Park, North Carolina, Environ.

mental Protection Agency,1973; Environmental Quality: 'Ihe Ninth Annual Report of the Council on Environmental Quality, Washington, D.C.: U.S.

Government Printing Office (December 1978).

3. P.F. Fennelly. "The Origin and Influence of Airborne Particulates."

American Scientist 64 (1976): 4G.

4. L.J. Shannon; P.G. Gorman; and W. Park. Feasibility of Emissians Sten-dards Based on Particle Size. Report prepared for the Office of Research s.ud Development, U.S. Environmental Protection Agency, Washington, D.C.: 600/

5-74-007, March 1974.

5. D.F.S. Natusch and J.R. Wallace. " Urban Aerosol Toxicity: The influence of Particle Size." Science 186(1974):695.
6. B.J. finlayson and J.ll. Pitts,Jr. " Photochemistry of the Pctluted Tropo.

sphere." Science 192 (1976): 111.

7. K.T. Whitby; R.B. liusar; and P.V.II. Liu. "The Aerosol Size Distribution of Los Angeles Smog." Journal of ColDid andInterface Science 39 (1972): 203.
8. Biologic Effects of A tmospheric Pollutants, Particulate Polycyclic Organic Matter. Washington, D.C.: National Academy of Sciences,1972.
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ence, Villach, Austria,1977. Economic Commission for Europe, December 1977.

7 c - .

148 RespirableParticles References 14 9

~ 11. U. Saffiotti et al. " Experimental Studies of the Conditions of Exposure to 28. J. Trijonis and K. Yu n. " Visibility in the Northeast." Grant No. 802815, Carcinogens for Lung Cancer Induction." Journal of the Air Pollution Control Environmental Sciences Research Laboratory, Office of Research and Develop.

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.  ; "a 150 RespitableParticles R;ferences 151 l

I

! 44. W.L Decker. " Unsettled and Variable Climate-Uncertain Food Supply!" 61. National Energy Plan. President Carter's Energy Message to Congress, industrial Research 16 (1974): 52. April 20,1977; and Report of the Committee on Health and Environmental

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search Council, Committee on Atmospheric Sciences, Washington, D.C.,1973. 10,1978,pp.2229-2240 .

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) Triangle Park, North Carolina, January 1976, NTIS PB-253-942. Passenger Automobile Average Fuel Economy Standards (Docket No. FE-76-1),

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