Document Ne23N0arnBkgDGkDRmLyOGp2Q

'jc. 3 3 * Prevention of significant deterioration Dear Sir. While I found Myron Liman and John Middleton's article "Implementing the PSD Program" (ES&T, Vo). 15, No. 9, 1981, pp. 1000-1005) generally accurate and useful, there is one statement I believe is false. The authors state "using any of these statistical measure:? of com pliance need not lead to a change in the level ofprotection afforded by the ex isting system since knowledge of the statistical behavior of the atmosphere will suggest what new number (that may be exceeded more frequently) corresponds to the same level of air quality as the current number (which may be exceeded only once)." While this statement is true for any single facility and associated receptors, there is no single number in the form of a revised increment that can provide air quality protection for a variety of source-receptor configurations. I am a participant in the Los Ala mos National Laboratory's Four Corners Regional Study, performed for the National Commission on Air Quality, and we calculated annual average concentrations, highest fifth percentile, highest, and second highest concentrations. The ratio of the second highest to either the fifth percentile or the annual average was quite variable. For Class II areas the ratio of the highest, second highest 24-hour aver age to the highest fifth percentile var ied between 1.15 and 4.2. The ratio of the highest, second highest 24-hour average for Class I areas to the highest fifth percentile ranged from 2.3 to 14,5. The ratio oF the higntet, second highest 24-hour average to tm^annual average ranged from 12 to 85\Furthermore, as one would expect, its mhre sources were added to a region thw ratio of the highest, second highest to* the highest fifth percentile or annual average decreased. For example, for one Class I area the ratio went from 7 to 2,3 as more sources were added. It is also not evident to me that with the current collection of models the highest fifth percentile or annual av erage can be predicted with greater fractional accuracy than the highest, second highest. For isolated point sources it is rarely possible to test an nual average predictions because concentrations are below instrument thresholds most ofthe time. What little data I have seen does not suggest that the highest fifth percentile can be predicted with an error as low as the 10-40% found for a highest, second highest. Model results tend to show relatively steep slopes near the fifth and 10th highest percentile levels but somewhat flatter slopes near the highest, second highest. It seems to me that a great deal more study would be required to justify deleting the short. term increments in favor of those de fined on another basis. It is also evident that a change to a more frequent cri terion will not result in equivalent protection for roost source receptor configurations. MichaelWilliams Los Alamos National Laboratory Los Alamos, N.M. 87545 Inhalable particulate matter Dear Sir: Thank you for sending me a copy of the ES&T article on partic ulate matter by Bette Hileman (ES&T, Vol. 15, No. 9, 1981, pp. 983). I had previously read it and found it impressive. It has good bal ance between science and news and is very well written in terms of readabil ity and presentation of data. While there are some areas in which my in terpretation would differ from that of the author, it is in general a superb example of how one should present issues ofthis type to your readers. I look forward to more articles of this type in ES&T. Bernard D. Goldstein, M.D. Chairman College of Medicine and Dentistry of Ngw Jersey Rutgers Medical School Piscataway, NJ, 08854 The lead debate: a response Dear Sir: Dr. Hammond's concern (ES&T, Vol. 16, No. 3, 1982, p. 145A) that I believe his research is tainted because he accepts industry support would be eased if he rereads my letter (ES&T, Vol. 15, No. II, 1981, p. 1250) with greater care. Nothing can be found there that would allow him to draw such a conclusion. In my letter I pointed out quite clearly that Dr. Jerome Cole of the 208A Enviroa Sci. Techno!.. Vol. 16. No,4.1982 International Lead-Zinc Research Organization (ILZRO) quoted an ILZRO-supported literature review in Support of an ILZRO-supported in vestigation that found no lead-related health effects, but that Cole omitted mention that both authors were the beneficiaries of lead industry spon sorship. I also suggested that Dr. Cole's comments would be taken more seriously ifhe were able to supply other studies or commentaries than those underwritten by his organization in support of his position. Nowhere did I mention Hammond's name or research, and his spirited--if misplaced--defense puzzles me. 1 do believe that the subject of scientific quality and objectivity in relation to the source of sponsorship is one which needs thorough and objective study and discussion, rather than anecdotal assertions. Such a systematic inquiry should be welcomed by all scientists, including Dr. Hammond and me. Dr. Hammond presumes to know what I think. If so, I am at a disad vantage, There is nothing in my pedi atric or psychiatric training that has prepared me to read minds. If his ed ucation as a toxicologist has supplied that gift, I would be grateful for the name of the course. Herbert L. Needleman, M.D. Associate Professor of Child Psychiatry and Pediatrics University of Pittsburgh School of Medicine The lead debate continues Dear Sir; I do not wish to enter the specific debate raised by Mr. Budiansky's report regarding the scientific validity of the several studies on the effect of low-level lead exposure on children (ES&T, Vol. 15, No. 3,1981, p. 243). I wish, however, to react strongly against a suggestion made by Professor Needleman that studies supported by ILZRO are invalid (ES&T, Vol, 15, No. 11, 1981, p. 1250), This is an insult to many sci"entists who have worked with industry funds. As the head of a laboratory who has received financial support from ILZRO, I can categorically state that ILZRO has never attempted to influ ence directly or indirectly the design of a study and the interpretation of the collected data even when the conclu- TEH 0531862 N33777 vit slops might be detrimental to the nonfcrrous metal industry. As proofof my' statement, I advise Professor Needlcman to examine critically sev eral papers published by my laboratory. I think that a scientist does disser vice to the scientific community by having recourse to nonscientific alle gations to refute the conclusions of studies performed by others. Robert R. Lauwerys, M.D., Sc .D. Professor of Occupational Medicine University of Louvain Brussels 1200-Belgiuin Dear Sir: Dr. H. L. Needleman's letter (ES&T, Vol. 15, No. 11,1981, p. 1250) about effects oflead seems to imply that industry-sponsored studies and reviews are not dependable. This was disturbing since I am currently working on a review of metals in ma-. rine organisms, to be published by the International Lead-Zinc Research Organization, Inc. It would be dismaying if I thought that this review would be automatically considered biased. I expect to make interpreta tions and draw conclusions freely. In deed, the only requests from the in dustrial organization were to write a thorough critical review of world lit erature, and to base it on a reading of original articles, not second-hand quotations of them. Similarly, in a two-year research project sponsored by oil companies, I found little evidence of "industry bias." The sponsors were committed at the beginning to publish the results on sublethal toxicity ofrefinery effluents, which could have been damaging to their interests. We had a lot of fun doing the research, and found the sponsors open and easy to work with. On the other hand, I have experienced government suppression of results that might not be "reassuring to the public." Haying worked on problems ofwa ter pollution for 28 years in govern ment and university, I doubt that I am completely naive in this matter. Of course, there are strongly differing points of view and some sorry tales. However, the bulk of my experience is that Industry generally wants to get on with things in an effective and straightforward manner. Dr. Needleman's inference may not be entirely fair. John B. Sprague Professor of Zoology University of Guelph Guelph, Ontario, Canada NIG 2W1 TOX Plus TRIHALOMETHANES The New Model 610 -- a screening machine. The New Model 610 TOX Analyzer is a rapidfire screening analyzer for organic halogens -- plusj it can be equipped to perform the EPA's specified procedure for analysis oftrihalomethanes.1 The screening approach can save the cost (hundreds of dollars) ofdetailed specific ana- lyses on every single sample. Surrogate tests. Purgeable Organic Halogen (POX) tests may be regarded as a surro gate for certain highly specific measurements, including those for trihalo- ? methanes. Non-purgeable Organic Halogens (NPOX) can be used as a t ; ' surrogate test for pesticides, PCBs, and certain other pollutants In water. Both POX and NPOX comprise TOX, and are separately measured by > the Model 610. A surrogate test can be used to determine whether more specific testing is warranted. In ruling out those samples where contami nants of interest are clearly not present; the Model 610 can save a tremen dous amount of money. And where trihaiomethanes are not ruled out -- the 610 has the capability for this key specific analysis. The combination, TOX plus trihaiomethanes, makes excellent sense. Those *'`Other" Contaminants. Chlorine may react with natural organic compounds present in water to form chloiinated hurnics ofunknown structure. These com pounds can be detected as a group by the Model 610. This feature is especially useful in making before-and-after evaluations offiltration and - other purification techniques. - s> ' Buy one. There's nothing like it for speed. Sample goes in, result comes out. Period. Write for a detailed brochure, or call (713) 693-1711. ```The analysis oftrihaiomethanes in finished water by the purge trap methods/* U.S--Environmental ; Protection Agertcy, Environmental Monitoring and Support Laboratory,Cincinnati,Ohio. September<M977. OTCORPORATION P.O. Box 2980 College Station, Texas 77840 (713) 693-1711 CIRCLE 3 ON READER SERVICE CARD Environ. Sci. Technol., Vol. 16, No. 4,1982 209A TEH 0531863 DUP050032359