The Science and Law of Air Quality

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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

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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), SO2, NO2,,ozone, lead, and TSP mass
• Amendments and key modified regulations
• 1977 (visibility in Class 1 areas), Example
  Grand Canyon
• 1987 TSP to PM10
• 1991 (regional haze and eastern sulfur
  reduction),
• 1997 PM10 to PM2.5 (fine particles) Example
  vf/uf, diesel, WTC

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Global Perspective

• Despite using 1/5 of the worlds 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 4th
  most polluted urbanized area in the US
  (Sacramento is listed the 7th) 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)

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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

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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 PM2.5 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

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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

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Calculation of Risk NRC Redbook 1983

• Hazard identification
• Qualitative evaluation of adverse effects
• Exposure assessment
• Maximally exposed individual MEI versus
• Population at large
• Dose response
• Animal models, scaled
• Linear extrapolation to zero
• Risk characterization
• Reduction of lifespan
• Tumors, leukemia cases per 100,000 people in
  specific regions

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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
  science, evaluation, assessment, and standard
  setting, with major political conflicts of
  interest

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Factors in Safety Judgments

• Risk assumed voluntarily Risk assumed x
  1000! involuntarily
• Effect immediate Effect delayed
• No alternatives available Many alternatives
  available
• Risk known with certainty Risk not known
• Exposure is essential Exposure is a
  luxury
• Encountered occupationally Encountered
  non- occupationally
• Common hazard Dread hazard
• Affects average people Affects especially
  sensitive people
• Will be used as intended Likely to be
  mis- used
• Consequences reversible Consequences
  irreversible

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Protection by Criteria and Standards

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

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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 dont 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?

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PM 10
PM 2.5
TSP
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c
Particulate Matter in the Atmospheric the
Atmospheric Aerosol

• Total Suspended Particulate mass TSP
• lt 35 µm
• Inhalable Aerosols PM10
• lt 10 µm
• Fine Aerosols PM2.5
• lt 2.5 µm
• Very fine aerosols, lt 0.25 µm, ultra fine
  aerosols, lt 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

0.25 µm
2.5 µm
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Particulate Matter in the Atmospheric the
Atmospheric Aerosol

• Total Suspended Particulate mass TSP
• lt 35 µm
• Inhalable Aerosols PM10
• lt 10 µm
• Fine Aerosols PM2.5
• lt 2.5 µm
• Very fine aerosols, lt 0.25 µm, ultra fine
  aerosols, lt 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

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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 no new PM2.5
  annual average standard was justified
• Of the 13 who wanted a standard, 6 said science
  could not support a numerical standard
• Of the 7 who supported a numerical standard, the
  choices ranged from 15 to 30 µg/m3 (average 22
  µg/m3)
• The EPA staff recommended a standard in the range
  from 20 µg/m3 to 12.5 µg/m3
• The EPA Administrator (in a room with 11 others,
  none of whom were scientists) chose 15 µg/m3

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• 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.
• EPAs current thinking health effects caused by
• Biological agents (fungi, bacteria, viruses,
  spores..)
• Acidic aerosols
• Fine metals such as iron in the lung
• Insoluble very fine and ultra fine particles
• High temperature organic matter

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Visibility reduction is mostly caused by fine
particles, lt 1 ?m sulfates, organics (smoke),
soil, nitrates, soot, and sea salt
PM 2.5
PM 10
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Example 1 Lead and the California freeways

• Data on human health effects of lead cause the
  California ARB to pass a standard - lt 2.5 µg/m3
• 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 LAs problem
  the catalytic converter on all new cars
• But the catalytic converter, which makes CO into
  CO2 and HC into H2O and CO2, needs lead free
  gasoline
• However, the catalytic converter also changes SO2
  from the sulfur in gasoline into sulfuric acid

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Wind
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Effect of roadway distance and configuration on
downwind concentrations of lead 1.
1 - per 10,000 v/hr
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Reduction in ozone precursors in LA roughly
tracks ozone decline
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Los Angeles 1 hr Ozone Maximum
Global background
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Los Angeles Ozone 8 hr 4th Highest 3 yr Average
Global background
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Alameda County Ozone 8 hr 4th Highest 3 yr Average
Global background
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Fresno Ozone 8 hr 4th Highest 3 yr Average
Global background
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Particulate Matter in the Atmospheric the
Atmospheric Aerosol

• Total Suspended Particulate mass TSP
• lt 35 µm
• Inhalable Aerosols PM10
• lt 10 µm
• Fine Aerosols PM2.5
• lt 2.5 µm
• Very fine aerosols, lt 0.25 µm, ultra fine
  aerosols, lt 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

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PM 0.25 ?
PM 10
PM 2.5
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Very fine aerosols characteristic of
diesels/smoking cars
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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

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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 SO2 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

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Visibility reduction is mostly caused by fine
particles, lt 1 ?m sulfates, organics (smoke),
soil, nitrates, soot, and sea salt
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Informational Resources for this Talk

• San Joaquin Valley Unified Air Quality Management
  District
• http//www.valleyair.org
• California Air Resources Board - Almanac of
  Emissions and Air Quality and
  http//www.arb.ca.gov/html/aqem.htm
• Routine monitoring ADAM http//www.arb.ca.go
  v/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.e
  du/improve/
• Special studies Yosemite Study, summer, 2002
• Research Projects
• Universities UC Davis http//delta.ucdavis.edu
  (Ill 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