The Science and Law of Air Quality

• • Fundamental problem : Science is inexact, with a continuum of limits, errors and uncertainties – Environmental science is more uncertain than many other disciplines because it addresses biological problems in both natural and human modified situations, including human health Law tends to require a “bright line” demarcation between good and bad, legal and illegal. – Environmental law is all the more demanding because questions of risk and safety , cost and benefit, life and death are addressed

The Science and Law of Air Quality

• • • • Air Quality – Science of air quality • gasses • Particles Risk and Safety Historical impacts of air pollution • • European and eastern US concerns California problems Example: Lead and CA freeways Clean Air Act – 6 (7) criteria pollutant CO (HC), SO • 2 , NO 2 , , ozone, lead, and TSP mass – Amendments and key modified regulations 1977 (visibility in Class 1 areas), Example: Grand Canyon • • • 1987 TSP to PM 10 1991 (regional haze and eastern sulfur reduction), 1997 PM 10 to PM 2.5

(fine particles) Example: vf/uf, diesel, WTC

Global Perspective

• • • Despite using 1/5 of the world’s energy and about 1/3 of the worlds VMT, the US has much better air quality than most of the developed or developing countries • Air quality in major international cities outside of Western Europe is usually appalling!

California leads the nation • in cleaning up smog In 1965, Los Angeles was worse than Mexico City in 1995 The Central Valley lags but still is not bad by global standards • There is no way that Fresno is really the 4 th most polluted urbanized area in the US (Sacramento is listed the 7 th ) since most forms of “pollution” are not considered in the ranking.

• Blue skies and good visibility in the Sacramento Valley each Fall (rice stubble burning suppressed); Bakersfield (oil improvement)

Health Impacts of Air Pollution

• • • • 1890 – onward - Industrial Impacts – “black lung”, “brown lung”, silicosis, toxics, ….. 1930s - Meuse Valley (FR) and Donamora, PA – 100s of excess deaths – Essentially ignored – The Great Depression London “killer” smog of 1952 – First serious studies; doubled death rate Los Angeles becomes a national joke – – stinging eyes, brown haze

Health Impacts of Air Pollution

• • • • • 1970s – onward – Major work of health effects of ozone in California – Health and welfare, including crops and forests 1980s – major EPA epidemiological studies – Harvard “6 cities study” over 10 years; Utah valley, others – Soon becomes the “Gold Standard”; – introduction of PM 2.5

“fine particle” standard 1997 1990s – major international efforts at long term “epi” studies aided greatly by the decline in cigarette smoking 1990s - some gaseous pollutants de-emphasized 2000 – better animal models, etc, isolate the heart as the target of fine particles – Very fine/ultra fine particles arise as causal factors

2.5

Health and Aerosols in the Central Valley of California Data Relative to Shasta and Butte counties Ischemic Heart Mortality Annual PM10 Childhhod Asthma 2 1.5

1 0.5

0 Sh as ta B ut te Su tte r Pl ac er Yo Sa lo cr am en Sa to n Jo aq ui St n an is la us M ad er a Fr es no K in gs Tu la re K er n

PM10 mass and Ischemic Heart Disease

California Central Valley 200 r2 = 0.56

150 100 50 0 70 80 90 100 110 120 Ischemic Heart Disease (% of state average) 130 140

Ozone and Ischemic Heart Disease

California Central Valley 0.15

r2 = 0.18

0.1

0.05

0 70 80 90 100 110 120 Ischemic Heart Disease (% of state average) 130 140

Welfare Impacts of Air Pollution

• • • • 1970s – onward – Major work in California – Bimodal particle size distribution and visibility reduction – Effects of gaseous pollutants (ozone, PAN) on vegetation 1977 – National visibility studies (viz CAA 1977) – Airport visibility nationwide – First aerosol measurements Class 1 areas 1980s – start of national effort at aerosols and visibility (NPS, 1981; IMPROVE 1987) – First actions under CAA 1977 “plume blight” – control of haze at Grand Canyon NP 1991 Kuwaiti oil fires rekindle global climate /aerosol connection – Major international studies ongoing – Aerosols now 80% of the uncertainty in global climate forcing models

Calculation of Risk

NRC Redbook 1983 1.

2.

3.

4.

Hazard identification a. Qualitative evaluation of adverse effects a.

Exposure assessment “Maximally exposed individual” MEI versus b. Population at large Dose response a. Animal models, scaled b. Linear extrapolation to zero Risk characterization a. Reduction of lifespan b. Tumors, leukemia cases per 100,000 people in specific regions

Problems with Risk Assessment

• • • • • Maximally exposed individual is not realistic for the person with maximum exposure Repeated use of conservative assumptions (The EPA “Precautionary Principle”) propagates error No assessment of the fate of the pollutant under transport Failure to validate and test assumptions Entire process often happens within the EPA setting, with major political conflicts of interest – science, evaluation, assessment, and standard

Factors in

Safety

Judgments

• • • Risk assumed voluntarily x 1000!

Effect immediate No alternatives available • • Risk known with certainty Exposure is essential • Encountered occupationally • • Common hazard Affects average people • Will be used as intended • Consequences reversible Risk assumed involuntarily Effect delayed Many alternatives available Risk not known Exposure is a luxury Encountered non occupationally Dread hazard Affects especially sensitive people Likely to be mis used Consequences irreversible

Protection by Criteria and Standards

• • • Criteria and standards Personal exposure standards Ambient composition standards Product design standards • Product performance standards • Work practice standards • Promotional claims standards • Packaging standards Example radiation, (air?) air, water seat belts, cars, gasoline car exhaust, flammability of clothes air traffic controller hours truth in advertising?

Childproof pill bottles

Clean Air Act 109 b.1

• National primary ambient air quality standards, prescribed, under subsection (a) shall be ambient air quality standards the attainment and maintenance of which in the judgment of the Administrator, based on such criteria and allowing an adequate margin of safety, are requisite to protect the public health . Such primary standards may be revised in the same manner as promulgated. – Question: Does “Requisite to protect public health” mean no harm to anyone?

If not, which “anyones” don’t we protect?

– Question: How does “Adequate margin of safety” handle pollutants in which any amount produces some harm?

– Question: What should California's position be to this federal mandate?

PM 2.5

PM 10 TSP

Particulate Matter in the Atmospheric – the Atmospheric Aerosol

• • • • Total Suspended Particulate mass

TSP

– < 35 μm Inhalable Aerosols

PM 10

– < 10 μm

0.25 μm

• • Fine Aerosols

PM 2.5

– < 2.5 μm • Very fine aerosols, ultra fine aerosols, < 0.25 < 0.10 μm, μm 35 to 10 μm, mostly natural – Dust, sea salt, pollen , … • 10 to 2.5 μm, largely natural – Dust, sea spray, some nitrates

2.5 μm

2.5 to 0.25 μm, mostly man made – Fine dust, nitrates, sulfates, organics, smoke 0.25 to circa 0.01 μm, almost entirely man made; – high temperature combustion, heavy organics, soot, metals Journal of Inhalation Research (1995).

This figure shows the relationship between particle size and what percent is deposited in different parts of the respiratory tract.

Particulate Matter in the Atmospheric – the Atmospheric Aerosol

• Total Suspended Particulate mass

TSP

– < 35 μm • Inhalable Aerosols

PM 10

– < 10 μm • Fine Aerosols

PM 2.5

– < 2.5 μm • Very fine aerosols, < 0.25 μm, ultra fine aerosols, < 0.10 μm • 35 to 10 μm, mostly natural – Dust, sea salt, pollen , … • 10 to 2.5 μm, largely natural – Dust, sea spray, some nitrates • • 2.5 to 0.25 μm, mostly man made – Fine dust, nitrates, sulfates, organics, smoke 0.25 to circa 0.01 μm, almost entirely man made; – high temperature combustion, heavy organics, soot, metals

Making of the EPA Fine Particle Standard

• • • • • “Those who like law or sausage should never watch either one being made” CAASAC – 8 of the scientists said average standard was justified no new PM 2.5

annual Of the 13 who wanted a standard, not support a numerical standard 6 said science could Of the 7 who supported a numerical standard, choices ranged from 15 to 30 μg/m 3 the (average 22 μg/m 3 ) The EPA staff recommended a standard in the range from 20 μg/m 3 to 12.5 μg/m 3 The EPA Administrator (in a room with 11 others, none of whom were scientists) chose 15 μg/m 3

Fine particles –

age the lung and heart Statistically, excellent connection between fine particles and health, including mortality Causally, most of fine particle mass is totally harmless even in massive doses….

• EPA’s current thinking: health effects caused by 1. Biological agents (fungi, bacteria, viruses, spores..) 2. Acidic aerosols 3. Fine metals such as iron in the lung 4. Insoluble very fine and ultra fine particles 5. High temperature organic matter

Visibility reduction is mostly caused by fine particles, < 1



m; sulfates, organics (smoke), soil, nitrates, soot, and sea salt

25 Typical Sacramento/San Joaquin Valley Particle Sizes Deep lung deposition Typical Haze Particles 20 Soils 15 PM 2.5

Sulfates 10 PM 10 5 0 12 to 5 5 to 2.5

2.5 to 1.15

0.75 to 0.56

1.15 to 0.75

0.34 to 0.24

0.56 to 0.34

0.24 to 0.09

< 0.09

Coarse Fine Particle Diameter (microns) Very fine Ultra-fine Soils Sulfates

Example #1: Lead and the California freeways

• • Data on human health effects of lead cause the California ARB to pass a standard - < 2.5 μg/m 3 – These levels were thought to be violated near freeways in LA, many in low income areas Research on ozone shows ARB that radical technology was needed to correct LA’s problem – the catalytic converter – on all new cars – But the catalytic converter, which makes CO into CO 2 and HC into H 2 O and CO 2 , needs lead free gasoline – However, the catalytic converter also changes SO 2 from the sulfur in gasoline into sulfuric acid

Fine Particulate Profiles from Los Angeles Freeways San Diego at Harbor, August, 1972 5 Wind 4 3 2 1 0 0

Freeway

150 300 450 Distance (feet) from upwind site Lead Bromine Br/Pb ratio x 5000 550 Sulfur

Effect of roadway distance and configuration on downwind concentrations of lead 1 . Roadway At grade At grade Distance Calculated 27 m 4.0

* * not scaled!

Measured 4.0

40 m 3.4

3.1

Depressed Measured 4.5

1.7

Elevated Measured (2 sites)

1 - per 10,000 v/hr

4.8

2.3

100 m 1.4

1.4

0.26

3.1

160 m 0.41

0.35

(3.5) (one site)

2500 2000 1500 1000 500 0 Reduction in ozone precursors in LA roughly tracks ozone decline

Trends of ozone Precursors in Los Angeles

NOx ROG (reactive organoc gasses) 1980 1985 1990

Year

1995 2000 2005

Los Angeles 1 hr Ozone Maximum

Global background

Los Angeles Ozone 8 hr 4

th

Highest 3 yr Average

Global background

Alameda County Ozone 8 hr 4

th

Highest 3 yr Average

Global background

Fresno Ozone 8 hr 4

th

Highest 3 yr Average

Global background

2.5

Health and Aerosols in the Central Valley of California Data Relative to Shasta and Butte counties Ischemic Heart Mortality Annual PM10 Childhhod Asthma 2 1.5

1 0.5

0 Sh as ta B ut te Su tte r Pl ac er Yo Sa lo cr am en Sa to n Jo aq ui St n an is la us M ad er a Fr es no K in gs Tu la re K er n

Particulate Matter in the Atmospheric – the Atmospheric Aerosol

• Total Suspended Particulate mass

TSP

– < 35 μm • Inhalable Aerosols

PM 10

– < 10 μm • Fine Aerosols

PM 2.5

– < 2.5 μm • Very fine aerosols, < 0.25 μm, ultra fine aerosols, < 0.10 μm • 35 to 10 μm, mostly natural – Dust, sea salt, pollen , … • 10 to 2.5 μm, largely natural – Dust, sea spray, some nitrates • • 2.5 to 0.25 μm, mostly man made – Fine dust, nitrates, sulfates, organics, smoke 0.25 to circa 0.01 μm, almost entirely man made; – high temperature combustion, heavy organics, soot, metals

PM 10 PM 2.5

PM 0.25 ?

Aerosols at the Fresno 1st Street Supersite PM2.5 Mass, 2001 120 100 80 60 40 20 0 EPA 24 hr standard EPA annual standard 1 1 1 1 2 2 2 2 3 3 3 3 4 4 4 4 4 5 5 5 5 6 6 6 6 7 7 7 7 7 8 8 8 8 9 9 9 9 9 10 10 10 10 11 11 11 11 12 12 12 12 12

Month of the year, 2002

Strontium Aerosols at Fresno during the FACES Study DRUM Impactor, S-XRF Analysis Data, 6 hr resolution PM10 PM2.5

30 20 10 0 10 14 19 23 27 31 4 8 12 16 20 24 29 3 7 11 15 19 23 27 1 5 9 13 17 21 25 29 3 March April May June July, 2001 7 11 DRUM Impactor, S-XRF Analysis Data, 3 hr resolution PM10 PM2.5

35 30 25 20 15 10 5 0 12 16 20 24 28 1 5 9 13 17 21 25 29 2 6 10 14 18 22 26 30 4 8 12 16 20 24 28 1 5 9 13 17 21 24 28 2 6 10 14 18 July August September October November December, 2001

Very fine aerosols characteristic of diesels/smoking cars

Aerosols at the Fresno First Street Super-site Very fine (0.26 > Dp > 0.09 micron) elemental concentrations for FACES, CARB S-XRF analyses via DELTA Group, UC Davis 300 250 200 150 100 50 0 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21

November December

Phosphorus x 10 Sulfur Potassium Zinc x 10

So what if Fresno in winter is Impacted by diesels and smoking cars ?

“It is important to note that the estimated health risk from diesel particulate matter is higher than the risk from all other toxic air contaminants combined ….

“In fact, the ARB estimates that 70 percent of the known statewide cancer risk from outdoor air toxics is attributable to diesel particulate matter”.

“The ARB does not routinely monitor diesel particulate matter concentrations”. ARB Almanac 2001, pg. 346

Example #2: Yosemite NP, Navajo Power Station and Grand Canyon NP

• • • • CAA amendments of 1977 identified Grand Canyon NP as a “Class 1” area in which visibility had to be protected (to “close” to natural background) from human impact If an anthropogenic plume were identified as impacting the park, NPS could request EPA for hearings on mandated mitigation Navajo Power station in Page, AZ, was a large coal fired power plant with no SO 2 controls located 18 miles from the east end of the park.

The NPS wanted this cleaned up! I was in charge of the aerosol science

Visibility reduction is mostly caused by fine particles, < 1



m; sulfates, organics (smoke), soil, nitrates, soot, and sea salt

25 Typical Sacramento/San Joaquin Valley Particle Sizes Deep lung deposition Typical Haze Particles 20 Soils Sulfates 15 10 5 0 12 to 5 5 to 2.5

2.5 to 1.15

0.75 to 0.56

1.15 to 0.75

0.34 to 0.24

0.56 to 0.34

0.24 to 0.09

< 0.09

Coarse Fine Particle Diameter (microns) Very fine Ultra-fine Soils Sulfates

Informational Resources for this Talk

• • • • • • San Joaquin Valley Unified Air Quality Management District – http://www.valleyair.org

California Air Resources Board http://www.arb.ca.gov/html/aqe&m.htm

– Routine monitoring – ADAM Almanac of Emissions and Air Quality and http://www.arb.ca.gov/adam – Special Studies - CRAPAQS, FACES, ….

US Environmental Protection Agency – Routine monitoring – AIRS data base – Special studies – Fresno Super-site, US Interagency Monitoring for Protected Visual Environments (IMPROVE) – Yosemite and Sequoia NP – Routine monitoring – http://vista.cira.colostate.edu/improve/ – Special studies – Yosemite Study, summer, 2002 Research Projects – – Universities – UC Davis http://delta.ucdavis.edu

(I’ll post this talk) FACES, UN Reno Desert Research Inst., CORE http://nurseweb.ucsf.edu/iha/core.htm

– Non Governmental Organizations – ALASET HETF, Valley Health Study and Sacramento/I-5 Transect Study; HEI www.healtheffects.org

Federal resources NOAA HYSPLIT http://www.arl.noaa.gov/ready/hysplit4.html