Document 50J6V3eJeEk5VnD4ZknK7BNwJ

Comments on Proposed Rule for Vinyl Chloride Emissions August 1, 1977 EPA Richard Wilson *<* see Introduction *Xri-a fine statement the EpA administrator, Russell- Train, expounded a policy on health risks of suspected, carcinogens;1 "X believe that it is important to emphasize the two-step : nature of the decision-making process with- regard to the regulation of a potential carcinogen.- Although different EPA statutory authorities have different requirements, in general two decisions must be made with* regard to each po tential carcinogen. The first decision is whether a parti- * cular substance constitutes.a cancer .risk. The. second deci* sion is what regulatory action,- if any,..should b.e. .taken to reduce that risk." It is uncontested that vinyl chloride at high doses is a carcino- - . "geh- The first' step of * the decision making is* clear. Dr. Train- . went ons Xn other regulatory- areas,-for example- -those under the Clean Air Act, the Federal Water Pollution Control Act, or the Safe Drinking Water Act where a large number of suspect carcinogens may exist in the atmosphere o4r. public water supplies, the detailed ris.k.benefit-, assessment will, because of limited Agency resources, necessarily have to be carried out on a priority basis in -terms of which agents appear to be the most important.* * "Once the detailed risk and benefit analyses, are available, I must consider the extent of the r.isX/ .the benefits con ferred by-the substance, the-availability of-substitutes and the costs of control of the substance- "On the" basis- of careful review, I may determine that the risks. areso small . or the benefits so great* that no action or only limited action is warranted. Conversely, I may decide that the risks of some or all uses exceed the benefits and that stronger action is essential. Xt is useful to discuss the proposed changes of the vinyl chloride standard in the light of this policy statement.- / =, A The >Risk^Analysis . ._ . .. . - 36. The -EPA v staff, have .made a .fine risk .'.analysis for vinyl 2 ic chloride.. This gives a. risk of 7_x 10 /year for a concen tration of 1 part per million of vinyl chloride in air. This risk is based on an. assumption of a linear relationship between cancer incidence and dose, and fits the,animal, data for Maltoni, and is 'somewhat, greater.than estimated from ,human data. X have gone over this calculation3 and agree with. JLt.- Were, recent, data of .Maltoni announced in September 1976 agree with the previous data and when plotted on.figure 4 of my paperfit the data we/;'. as shown. These new data, require, therefore, in my view, no change in the risk assessment.. 4 In calculating the community erpsQ^ore the EPA study uses somewhat old vinyl chloride emission data TT* An average PVC plant processing ISO million pounds/year is assumed to emit-4% of the vinyl chloride processed or 800 pounds/hour.5 If the emissions are reduced, so will the concentrations he reduced. Already in my report I had noted the* concentrations measured by EPA^ were 1/10 of those calculated by the diffusion models-- presumably because .of a reduction in emissions between the estinate and the concentration measurement. The present"standard, promulgated in^the Federal Register on October 21, 1976, will reduce these emissions still further to about 36 pounds/hour for a PVC plant according to the EPA, and still less if industry is correct and fugitive emissions are not so great as EPA assume. a. SCL 1563 a linear relationship bebween-'cancer incidence * and, dose do .so ; : on the basis, of a simple theory of cancer incidence, such as that of Axmitage and Doll, without' any repair mechanisms. In herent in the theory is -that the risk is'proportional to the concentrations averaged over a long time--an appreciable fraction of a lifetime-^and - not .-the maximum in -a .'short period or over a small distance,. It Is also important to emphasize that although I use here uie linear relationship between - cancer incidence .and .dose, there may well be'repair mechanisms giving a threshold below which no effect occurs. If a threshold exists, the risk is probably zero at the doses' discussed, here.- I neither accejfc-.nor. reject the idea of a threshold but maintain that it* is unnecessary to accept it to establish an acceptable level of risk. see 2- 156- Approximate :Diffusion'-Calculation V - :.The/standard is written as .if diffusion calculations are' complex. This is not true. and indeed., the EPA has an excellent manual for diffusion, calculations.7 The basis for this calculation is Sutton*s well-known formula. Concentration (c) ~ - 2 "x-y *xplf6 )[.2 exp rJ-_r_w2 + exp ay " ` M2 } y ' where Q is the emission rate Ux-is the wind speed along the x. direction. cr and a `are dispersion constants _in the y and z directions j; * ... respectively (the Gifford coefficients) ve . , 4:' h is the (effective) stack height - afetjqal;height + plume rise For our purposes, we want- an average over a long time and 1 assume all directions of wind, averaged over a year, are equally probable. Then X integrate over the y direction -and average the concentration around* a circle*of radius *x< and center -at the eiaiss* \ source.. Then I find c" x2V *[ exp -(z ~ h) . 2 cl -(z 4- h) + exp 2 a2- I also note that for moderate stack heights, h, c exceeds (h) at small distances and h -- O-for fugitive emissions..anyway. If I assume h < cr^, z = 0 (ground level) then the square bracket equals /2. Then using the relation / exp (-a2* ..2 y) /jr = 2a we find see 1 56! As a rough approximation I take values -for U and. a which X2 are correct about half the time.8 U - 7 raeters/sec, a *= 18 m, X = 500 m, ' EPA estimate for a typical suspension plant under the present standard, Q = 3fc^pounds/hour = 4-5.5 gms/sec-?. 'I' take this although industry believe it to be high.- We then -find c= ------- i----------- 2|.-at 500- rn. (2ir)3./2 7 x 18 x 500 mJ - = 1.15 x 10 ^ gras/in = 1.5 x 10 ^ gins/cm" -vv: .' ^ ' --3 3 . The density of .air is well known to f>6 1.20 x 10 . gm/cia . So the concentration -10--8 or 10 parts/billion at 500 meters. increases less than" linearly with X, so the concentration * . 18' .. -falls at about 1/X * as already noted in' the .EPA._risk asse.s.smenl Taking this meterological air condition alone gives a low result; according to Rogers and Gamertsfelder; 8% of the time ve can expect Pasguill G conditions, a steady wind at 1 meter/se and o 2* = 5.5 m and the concentration is 18, /5.5 x 7/1 - 20 times greater. I average over the', weather classes in* Rogers and Gamertsfelder's paper tabulated here (Table 1) and find that 36 lbs/hr corresponds to an average concentration at 500 m of about 40 parts.per billion, about/what X took in August 1976, ai '2 1/10. of the EPA 1975 risk assessment. see 2-136./ Table 1- Heteorological Data, for Atmospheric Release Calculations* Keather type Probability of weather condition Kind velocity. (m/sec) A' - B C 0.019 2 0.081 3 0.136 .5 0 1 iAt D E` F G 0.121 0.122 6.08 73 2 - ifc Distance, .x Cm) 200 500 100O 2000 -5000 .10,000 20,000 50,000 100,000 z Cm) 28.8 100 470 3000 -- '-- * -- - 2b.3 51 110 350 1900 -- -- -- -- . 14 32 59 111 230 400 ; 650 1200 1800 '8.4 VC 18: 51 90 140 200 310 420 6.3 13 21.5 34 57 80 110 ISO 180 ` 4.05 8.4 14 21.5 35 47 58 75 90 2.63 5.5 9.2 13.7 23 31 37 48 55 Table adapted fron 8. !' ... We should note that this simple calculation should be fairly ^rgood^for: a rlong rterm average, andiprobablv Joverstates ;the . ground . level" concentrations at -500 n and more because we expect the air to be broken up in a populated area more than suggested by the -diffusion constant o of--1-8-meters.. The number is twice that "*'*'"*' 0 given by the more, precise diffusion calculations in the epa risk study- adjusted downwards-by the ratio. 36..bls/hx^Zfi00 Ibs/hr. X also note as have others# that most of the assumed emissions . -come/ and always have convertftpm;-PVCplants. ../which ar more, numer ous) and not VCM plants. Therefore, using the adjustment for PVC plants alone is accurate enough.*. My calculation is rough and intended solely to give some . -quick idea of how the concentrations vary. .X take - the numbers in the EPA risk study adjusted, downward by -the .factor 1/20 noted above for what follows. The EPA diffusion calculation when so normalized leads to a concentration averaged over all persons within 5 miles of a PVC plant and averaged, over a year's-time is less-.than 1 part inX billion given an average risk,, on'the EPA*s linear basis of S x 10--8 /year averaged over the 5 million people who reside within % 5 miles of PVC plants in.the U.S. Multiplying the 5 x 10 ^ by 5 million gives 1 hypothetical cancer case every 4 years out of 300,000 cancer cases/year from all causes in the whole U.S. population or 20,000 cancer cases/year from all causes within S miles of the.plants. -> see 2-1568 Meaning of '-the Risk The risk appears to be 5 x 10 ,/year averaged -over.; all persons within 5 miles of the source. This., is__a_ low number-.and its. mean ing can only be grasped by .a-comparison with other risks;* prefer- - ably risks similarly calculated. paper on vinyl chloride.3 X listed some of these in my ... --8 Xn Table 2 Ilist some risks of 5 x 10 --which corresponds to a- year's exposure to winyl chloride-with- the October 21 , 1-976 --8 standard--and some risks, of 10 which correspond- to the maximum, -change that could be caused by the proposed June- 22., 1977 stand- vi axd.^ To -explain cne entry in this .-table: the proposed- standard wiU reduce the average risk for one year *-by no. more than reducing cigarette smoking by 1/75' of a cigarette, or alternatively, smoking one cigarette is worse than 'living near a PVC plant for 75 years* . . The.data came from many sources including a paper (attached) by Six Edward Pochin.14 1. Cigarette smoking is a well measured ..jand certain hazard.. Boll's study of the smoking habits of British physicians show that the risk is proportional to the number of cigarettes, at least over the range 4-40/day. The estimate of the pollution from other smokers is based on the relative cigarette smoke con centrations. I note that even nonsmokers are subjected to a hazard far greater than from.vinyl chloride. 2. This comes from a WHO3-5 study comparing incidence of- cirrhosis-of the liver in various countries and relating it to see 2-1^69 .v ' /-.'--.v,- > T3ble -2;e^.'y^:vir=^^7^w;r:^?. Maxiimmi Effect of the: Prooosed '-Standard''- -8 Risk of 5 x 10 Oct- 21, 1976 Standard Kiik (or ... _g change in risk) of 10 June 22, 1977 Standard a) 1/15 1/75 of a cigarette (cance heart disease) - 50 hours 10 hours of being in a reem wi - cigarette siokers' C2) ~l/3 or- '* 1/15 oz* wine (cirrhosis of th liver) (3) ` 1/2 tablespoon .. 1/10 tablespoon peanut butter (aflotc in Hold causes cance (4)--375 pint " (5) 1.5 1/25 pint 1/3 - -> . heavily chlorinated c . ing water (chlorofoi water causes cancer; Orleans or Miami fic - diet sodas (sacchar: causes cancer) - (6) 30 nnles 6 miles flying in ccnmerical aircraft (7) 1 hour 15 minutes air pollution (Bosta Washington) C8) 3 days 15 hours inside brick or ston building (radioacti causes cancer) (9) 3 days 15 hours visit to Denver, 00 cosnic radiation c cancer) (10) 1.5 days ` 8 hours fraction of average diagnostic radiat-ic `causing cancer (11) 150 miles 30 miles jet flying at 30,00 cosmic rays causir. (12) 1 year 1 year average exposure wi 5 miles of FVC pla see J. ^ 7 o the^ alcohol consumption. ; The ;incidence, of cirrhosis ."is propor- . tional to the alcoholscqhsnmptipn'1'-:; v-' - ..V' 3-' This cones 'primarily from the FDA report in the FederalRegister,^ and I assume that the cancer hazard for man is re lated to that for..-animals, for_.the same ing/kg intake. I take the average concentration of aflotoxin in the U.S. peanut butter to be about 1-5 parts per billion and the total consumption of peanuts fxcm the Statistical Abstract of the XJ.S-. 4. For this X'take the report by the* NationcCl Academy of Science on health effects of drinking water^ and note that Miami and Kev Orleans have 100-parts per billion of chloroform-in-their vater.- I have confirmed this by my own calculation using data * 17 18 on cancer induction by chloroform in mice and rats ' and relating to human exposure for* the same mg/kg-'intake as for the vinyl chloride-* * 5- . 1 take the procedure as outlined by FDA for saccharin in April 15, 1977 Federal- Register. X take the linear extra polation and this is equivalent to . the proceduxeviin *jC4L) above-. 6. This comes from average of accidents over the-last several years- Accidents happen mostly at take-off and landing and this number is clearly low for a long flight. Also recent improvements Cl-ast five years) in air traffic control reduces this markedly in the U.S.19 7. Air pollution is controversial. There seems little doubt that it is serious, but the active agent is uncertain. Ten years ago sulphur dioxide was blamed; three years ago sulphate particu lates; not it is thought that any cation*may be harmful. The /^ see 2~ie7i nur^]^r.T_liere^ xs jny own-average of ; sevcral ;data " sources and, assign-- ing ^ the-problem all- to sulphate concentrations with a linear plot of health effect versus concentration. There are many press - reports in July 1977 that a recent -National Academy of Science report has similar numbers. . 23 Fmklea may have found a threshold for. the effect, but even if true, it is below the present Boston and -Washington concentra tions. The risk calculated here is much* more reliable^than its. attribution to any particular chemical or source.of. air pollution ,;ince S02, sox' NOx an,a Pa?rt?tcuPL.?'tes;.all tend to vary, together. 8, 9, 10, 11- For all. cases involving radiation I refer to the risk calculations using the report; of the national .Academy ,of Sciences/Kational Research Council Committee on. Biological Effects of Ionizing Radiation, relevant pages enclosed'.**' The four cases cited are for. different sources of radiation. The first is from uranium and .other radioactive ores in the brick. It is largely due to breathing the released radon gas, and can be, but-isn't, reduced by at.some expense of painting with an expoxy paint sealer.^ -- The risk of a visit to Denver, Colorado is taken here as the increased cosmic ray risk at the increased altitude, although in Colorado there is also an increased' radioactivity in the ground and in drinking water which I here neglect. The increased acti vity is taken from the report of the UN Subcommittee for Effects 12 of Atomic Radiation and the relevant pages are attached. it j.s relevant that half this increase is-due to cosmic ray neutrons where there is less likely to be a threshold effect. // 5LL '''^:^:-,'Fiiballyl; ' the average whole body diagnostic x-ray .'dose is:.' 'taken' "from a Public Health^Service report -listed -in *BEIR.- Hany ideas of carcinogenesis Have come from, studying radia tion effects- The International." Committee on Radio-logical Pro tection (ICRP):--set up in 1926--espoused the linear concept for ' priideht public policy decisions*-and -proposed- that 'ito unnecessary risk be taken, and no risk, unaccompanied by a corresponding bene. fiti This is-very relevant to a-dxscussiLan -of .vinyl chloride... The idea of linearity of cancer incidence and dose has its origins in the behavior of -a- single cell-- It-seems much more v ? likely to hold for radiation--than-for chemical insults. For. chemi cal insults/ there are -metabolic.-.processes., and repair .processes before the cell is reached." NonethelessT^-^nimal experiments in volving millions of mice suggest a non-lihear (quadratic) term in the dose response curve at'low dose rates. These data are reviewed and used in the reactor safety study24 to .show the risk is less than 1/5 of the linear curve at low dose rates. At-a recent conference^ Sir Edward Pochin, summarizing^ said: *It is very important, therefore, that the- evidence is strengthening for the presence of a quadratic term * (thres hold effect)*! in-the dose-effect relationship and hence for the increasing likelihood that, for protection purposes, the purely linear extrapolation from the frequency of effects, at high doses will maximize the estimate of risk at very low doses." This may apply with more force to chemical effects, but may not apply to the second and* third of my chosen radiation effects. Neutrons present in the cosmic rays and responsible for half the dose may not show this non-linearity and diagnostic x-rays taken see 2-1573 ^^5^&ae1Jsudae'n'-:e?cpasure*'will: not..^Therefore / the comparison here shows that the "natural* or non-industrial radiation, effects are core serious than vinyl chloride by, a large factor; 12, I note.that this figure uses EPA numbers in HPA calcu lations and-is*probably pessimistic, particularly.since it uses a linear, .non--threshold, -.theory. It is dominated by fugitive emissions from PVC plants, and EPA .assume, that any vinyl chloride - not accounted for in the^ss. balance is.a^fugitive gasepus_-emis- sion, vhereas a. proportion--maybe half--'is probably solid* Also, it takes little or no account of the plume ri.se f.or- ordinary emissions; the reducible emissions are at.-SO feet {h = 16 ra) with air at 150F- If preliminary industry measurements-, are correct, the risk is one-fifth of that discussed here- /5 see 2-1574 The Reduction'by . the Proposed Standard ' - -r; ' . : v' r - ....... . - 1 " ." Vi';/-- . ' In one and`only one- respect the.proposed.,standard, is ;well' ' presented; it is not-to apply immediately to all plants, but is to-be-introduced on new plants only to avoid, excessive pertur bation of the industry. -But there are many other - problems. ' - the Federal Register -of .June . 2.,. 1977 gives-_little..,data .or references to data on how these emission standards can reduce . concentrations land none. at-_all .`about. the effect on.-.public health in spite of the claim that the whole purpose is' to improve health (Federal Register A2, 106, page-281-54 r column 21 .^"the '.standards be set at the level which in . the judgment of the adminstrator provides an ample margin of .safety to protect-^the-public' health from such hazardous .air pollutants. "} * - ^^ ' Accordingly we must rely on industry sources, memos of EPA -staff,25 and transcript of a meeting between EPA staff and indus try. The reduction in emissions from 10 ppm to 5 ppm at a PVC plant wild, change less than--0.1 lb/hr or 3/10% of-.all emissions.. The `increased 'stripping of-resins can only-reduce by 6 lbs/hr or 20% of emissions and it is not.always possible. :Those from a vinyl chloride plant are already low. Thus the effect of the proposed standard will be to reduce the hypothetical cancer hazard from 1 in 4 years>by 20%, or to save 1 hypothetical cancer every 20 years at a maximum. Fugitive emissions are not controlled by this standard. If they are not as great as EPA claims (and there is disagreement on this point, since at a PVC plant a lot of the losses (fugitive .emissions) ebrce out as solids and not as gas) or they can be / see 2-1*57? ed;risk, can be reduced. But rthafc is nothing _ to`; do.wiith .'the L proposed new .standard. . KC, see 2-1576 Cost of Proposed - Standard ; ^ ,, - This is hard to identify'since there is 'a-certain nebulous ~ nature to the standard- It appears " 1.` that'the production of some resins will not be able to be done at some locations 2. plant, expansions will be curtailed 3* where-possible to manufacture PVC will be. more expensive; Industry reckon that the cost of a new.plant with these extra requirements'will. be greater by 2.1 cents per pound of PVC. The total industry output is 6 billion Ibs/year, so that if the whole - industry were to convert, the cost will rise to $120 million per year, which corresponds to. a-cost of. $.4 .bi.l.lip.n for each hypothe tical cancer case. It is true that the industry-is only being asked to install new equipment for new-plants. ' is -also true that the reduction in vinyl chloride emissions will only arise as these plants come in. The ratio--over $4 bill'ion for each hypothetical cancer case--remains correct. /- see 2-l?77 indirect Risks -V* -' - ;: The/list of ; risks above are direct- (first order) . effects: of the pollutant or action concerned. It is, however* clear ^that when the risk is small, as--in-t-his case, indirect (second order) risks may be more important. The number of these indirect risks is huge and I can only outline a procedure-bere,,. There are ignored in the document for the proposed standard. -This is clearly incorrect. There-is* a rdskXo-,iife:..for every action involving capital expense. The classic, oft-quoted, case is thatr three people died building- Brooklyn Bridge.-.* One person died- in building the Cambridge Electron Accelerator ($12 million capital" cost)At the present, time,-about .one person dies .in ah accident for every $30 million spent (average--over industries) . Thus to implement the proposed standard, industry would have to cuase 4 deaths by accident every year to save one hypothetical cancer case every twenty years. The accident risk is well defined and not merely an upper * limit. Moreover, these -liv.es lost indirect!: by accident will be in the prime of life whereas cancer cases arise later in life. ' Thus the proposed standard will by this means alone be a cost to human life Sd times what it can possible save. It is therefore clear that the indirect risks introduced by the proposed standard could well outweigh the minute, hypothetical, reduction. // see 2-1579 Sow Has -the EPA Gotten Into This Administrative Mess? : The gocTd^vintentibris -.expressed .in- the FederalRegister^ on 25^; 1976 and October 21, 1976 have not been followed., .In the 'preamble to: the - proposed standard there are several, state ments that lead to-confusion: "..it has .not been possible to determine if there is a threshold level of effects. for vinyl chloride and it'is not certain-that such a threshold may be determined in . ' the near^future... In. the absence of strong evidence to ' the contrary, , then, :the only* level of vinyl chloride -which would appear 'to be absolutely protective, of-health-is zero, which* may be'achievable only by banning--vinyl -chloride* emissions completely. That, in turn, would-require closing the entire industry. As explained in the earlier rulemaking it is not.-clear that Congj:e?s would., h.ave^ intended this result, so instead EPA required the. lowest level achievable using technological means." The"*!firs't sentence is correct: but only correct.-in the ^sense. that a strict threshold effect qannot be determined -for anything. l?o human- cancer has been attributed to vinyl chloride at levels below 100 parts per million {10,000 times those discussed here) and for animals at levels. below 10 parts per million lifetime dose. J>oes this mean that there, is a threshold at JL0_ ppm?.. Some might -argue that there is. -It^iis-.a matter of. definition. .. Is .there zero* cancer incidence at 10 ppm because we -haven' t-found any can^ cexs at this level/.or is there a finite (but small) incidence because we haven't proved it to be. identically zero? If we cal culate assuming no thresholds in any effect (from alcohol to vita- \ nin' C or peanut butter) we must also assume there is a small but finite risk. It is not consistent to assume that- there is no threshold in cancer incidence from vinyl chloride exposure merely because it is intrinsically unprovable in a rigorous- way and to allow for. a threshold in other matters equally unprovable--such as '/ see z-i "pollution ^_pf rthe air by /everyone .in a -hearing.- room .breathing out. Then/ as-.so well stated in the May 25, 1976 Federal, Register, there must be a comparison of risks and benefits. Such a comparisou ls not made in the preamble., to ..the proposed .standard. There is a second cause for the present -confusion. The state ment -that -an aim is **to .-enoourage .technology" , tCL.r.educe. .emissions xs not addressing the issue. The logical procedure in protecting ^public-health-is to. minimize -the.Tprpduct ;of i.the_1cojicentra.tipn .of the pollutant and the population density at that concentration (ICP irr units-of parts per -billion-X-persons)*.. This* on a .linear theory,* minimizes the adverse effect, oh public .health. . In any case-ho'one can -change the..dose effect relationship'-whatever it is (except for possible synergistic effects)- . It is just as reason able, and I contend that it is more reasonable/ to provide incentives to reduce population density around a plant, to place the plant in a low population zone, or downwind- If the population density is uniform--we rcould. minimize the cpn cenfctfa'tion by reducing emissions. Since emissions--come..from sevexa places, including fugitive emissions, tank car accidents, etc., "the best way of reducing emissions may be complex. In such a task, it is clear that industry, given the incentive, can better decide how to reduce emissions .than.the EPA- If the regulations are set to minimize the product of concentration and population density the aim is well achieved. The distinction between emissi/on controls and concentration controls was made in the legislative discussion of the Clean Air see 2-1580 Act-.. In. particular, Senator Muskie made a very^clear distinction-in the T3.S, Senate. "When concentrations can be .measured, and assigned to a parti cular source, control-of concentrations is preferred. In control of sulphur emissions, pollution from many sources overlaps and it is impossible, merely by measuring a concentration, to identify the polluter and take remedial action., Therefore emission controls are necessary- For radiation from nuclear power plants, concentra tions are not easily separable from the large natural background, and emission controls are again used, but they are related by.dif fusion- calculations to concentrations. In the -case of vinyl chloride concentrations have been, and be, measured up tp the site boundary ari&'.eyen beyond where sites are availabc, and diffusion calculations used beyond that. (The variation with distance is roughly vs. < ----- > AV or x UX2 18 x1 1/x * .) . If not actually used for regulation, this procedure must be used in discussion of the effects of .the regulation. It might be possible to provide an incentive for an. individual plant operator by demanding that the quantity (ICP in parts per billion x persons) be reduced if it can be done for a reasonable price, perhaps 50 cents per unit. It should be open to each plant operator to-decide the best way to reduce this. This has been suggested in the radiation context by the Nuclear Regulatory Com mission ^ 'who asked that power plant operators reduce radiation dose if it can be done for less than $l,000/man rem, corresponding see 2-1581 'xbughly ;tor $10,000,000 per cancer^projected on a -linear theory. X 7 suggested2^ that' a . charge be,-made of this amount' to simplify . regulation- .... This (or a similar) incentive procedure would 'encourage ' industry tot o reduce emissions--including fugitive emissions.as much : ' *. as they can . - s- .... o place plants in low population zones o operate plants well 'y * The proposed standard is too indirectly related to the pro blem (protection of public health) to give' any incentive to indus try. cr- SCC 2-1582 1- Federal Register, 41 102/Tuesday, May 25, 1976. :; -2. A-.M.-.-Kuzmack and R.E. McGaughy, "Quantitative Risk Assessment. for Community Exposure to Vinyl Chloride," EPA Report-, -Dec. S, 1975. .3 Richard-Wilson "Risk Analysis for Toxic Chemicals: Vinyl Chloride," presented to a meeting of the American Chemical Society, 'Sept. 1, 1976. .4 In a memo to Jack R. Farmer, . 20 December 1976, Drs.' Kuzmack and McGaughy seem to agree.-. 5. Reference 2, page A-4, 3rd paragraph. .6 "Scientific and Technical Assessment Report on Vinyl Chloride and Polyvinyl Chloride," EP.A. 600/6-75-QQ4 - _ . .7 J. Turner, Handbook for Atmospheric. Dispersion Estimates, EPA Gaany editions). . 8. T. Rogers and C.C. Garaertsfelder ,* Proceedings of-the Conference on Environmental Effects of Nuclear Power Stations, IAEA, Vienna _____ :1 " 9. .10 Federal Register, 42^ 106, p. 28156, Column 3,-2nd paragraph. - "The Effects on Populations of Exposure to Low Levels of Ionizing Radiation," Report of the Advisory Committee on the ' Biological Effects of Ionizing Radiations, Div. -of Medical Sciences, National Academy of Sciences/^atiouSl Research Council, Washington, DC,;November 1972i 11. "Final Report on Study of the Effects of Building Materials on Population Dose Equivalents," Prepared under-the direction of Dade Moeller and Dwight Underhill, Harvard School of Public Health, December 1976 prepared for EPA- 12. "Report of the United Nations Scientific Committee on the Effects of Atomic Radiation," General Assembly, Official Records: Seventeenth Session, Supplement No. 16 (A/5216), United Nations, New York,. 1962. 13. Sir Edward* Pochin in Proceedings of a Symposium on Biological and Environmental Effects of Low Level Radiation, Vol. II, Chicago, November 3--7, 197 5, IAEA and WHO, Vienna (May 1976) , p. 422. 14. E.E. Pochin, "Acceptance of Risk," Brit'. Med. Bull., 31_, 184 (1975). see 7-1 59-. 15. WHO Chronicle, 1975. 16. 39 Federal Register, .42743., ..December .19.74. 17. "Health Effects of Drinking-Water," National Academy of Sciences 18. "Report on Carcinogenesis Bioassay of Chloroform," Report by HEW,- 1976. 19. .'See Statistical Abstract of the U.S. Table No.^855 from.FAA . Statistical Handbook of Aviation* 20. W. Lindberg, "General Air Pollution in-Norway, Smoke Damage Council, Oslo (1968) (death rate vs. SO;, concentration). :.i. IT. ;Nishiwaki', et. al. , "Atmospheric, Contamination-of Indus trial Areas Including Fossil Fuel .Stations, and. xthe, Method of Evaluating Possible.Effects on Inhabitants," Report to * Conference on Environmental.' Effects. of..Nuclear. Power-. Stations.'/ LAEA-SF5-146/16,--International Atomic* Energy- Agency Vienna'* (Relates bronchitis incidence to sulphate levels in Japanese cities) - ^ ..... 22. L- Lave and E. Seskin, "Air Pollution and. Human Health," Science, 169, 723 (1971) (relates death rate-to sulphate levels in U.S. for 1960). 23. J. Finklea, et. al., "Health Consequences .of Sulphur Oxides," Human Studies Laboratory, -EPA, August 15, 1973. .^4. U.S. Nuclear Regulatory* Commission. "Reactor Safety Study." USNRC Report (NUREG-75/014) , WASIi-1400., October 19.75. . Appen dix VI, Section G1.4. A complete set of references is con tained therein. ......... ... 25. Primarily Susan R. Wyatt to J.R. Farmer, 1977. 26. Rulemaking Hearing Docket No. RM--50--2, Opinion of the Com missioners (Nuclear Regulatory Commission, Washington, DC. 27. Richard Wilson, "Charging for Radioactive Emissions," Science, 190, October 31, 1975. o*. -j see 2-i234