ENVIRONMENT REPORTER 1600 control of individual! plants. The problem arises because the use of “high” and “low” risk subcategories, as discussed by EPA retains a forma) separation of the consideration of public exposure and health risk information from the determination of the level of contro} constituting BAT. In our view, this information ought to be considered jointly by weighing both the public health gains and the costs of a further control of these plants. This approach would lead, we believe, to more sensible regulatory decisions than th several approaches outlined by EPA. are The problems with each of the alternative approaches considered by EPA can be illustrated by considering the cost-effectiveness in terms of expected public health gains of the required further control for individual plants. Under EPA’s proposed rule, the average cost of the expected reduction in population risk for the “low” arsenic copper smelters is roughly $100 million per cancer avoided and the cost-effectiveness of the required control for individual somewhat reduced and the range in cost-effectiveness across copper smelters is generally narrowed. (See Table V3.) However, the average cost of the expected reduction in population risk under these alternative approaches remains extremely large — the average cost is roughly $70 milliog per cancer avoided under the population cutoff approach and $85 million per cancer avoided under the risk-exposure cutoff approach. Risk-reduction investments in this range would go far beyond those customarily required by EPA and other public health agencies, and far beyond those customar. ily assumed by individuals in private decisions involving health risks." Moreover, cost-effectiveness under EPA's risk-exposure approach still ranges from $7.0 million to $312 million per cancer avoided, while EPA's population density approach does not reduce the variation in cosw:A; effectiveness in the proposed rule at all — it continues to =‘ range from $7.0 million to $1.3 billion per cancer avoided. ee ro sources varies from $7 million per cancer avoided to $1.3 billion per cancer avoided. (See Tables V and VIL.) The wide variation in the effectiveness of the contro] of these emissions occurs because of the variation across individual smelters in the amount of pollutant discharged to the air at current levels of operation, the size and location of the exposed population, and the costs of achieving further re- ductionsinemissions. .. .2) --. 3. we, Under the alternative approaches outlined by EPA, the average cost of the expected reduction in population risk is ~ ‘ o -o - ee ort ‘ 7 . - geo a oe 4 “For example, these costs are substantially above current esti- mates of the willingness-to-pay for small reductions in the risk of death. These estimates yield a willingness-to-pay for a reduction in the aggregate risk of cancer incidence ranging from roughly $500 thousand to §7 million per death avoided. For a summary of this literature see: U.S. Environmental Protection Agency, Valuing Reductions in Risks: A Review of the Empirical Estimates, Washington, D.C., 1983, Martin J. Bailey, Measuring the Benefits of Life-Savings, Washington, D.C.: American Enterprise Institute, 1979. e ST Te oe a7 Ah ee If EPA relies on technology-based criteria in making this decision, it is likely to require “too much” or “too little” TAHLE V Acsenic Fmission Control Systems for Converter Operations Fatal Cancers 307 16,200 0.043 7,000,000 ASARCO - Rayden a/ 403 16,400 0.019 - 21,090,000 64,800 6.019 Kennecott - McGill a/ 2,696 mT _ : 140,000,000 7 #70,000,000 Kennecott - Garfield a/ 1,300. - oO 185,400 o.0015 ©” Phelps Dodge = Morencl a/ 1,308 302,900 0.0027 710,000,000 Kennecott = Hayden a/ 1,982 335,900 0.004 500,000,000 2943 - 710,800 @.003 . $80,000,090 679,100 - 6.005 - 910,400,000 Phelps Dodge Douglas Phelps Dodge Ajo >, S62. - 2,943 1,777,000 0.011 Phelps Dodge - tidsigo 1,745 1,586,000 0.000001 Tennessee - Copperhi ti 1,278 2,130,000 0.0015 Hegea - San Manuel- 3,979 6,642,000 0.00066 6,000,000,900 Kennecott - furley 2,296 5,861,000 0.0008 $,700,000,000 White Pine 1,278 4,733,000 0.000% 12,800,000,000 Insapication - Mi anh | a/ Regulated under EPA's cule, b/ Greater than a trillion dollars per cancer avoided. Source: 0.8. Environmental Protection Agency. 1-13-84 cee ee eae Published by THE BUREAU OF NAZ:ONAL AFFAIRS, INC., Washington, D.C. 20037 ne eee o AO Neth are = meee mee a et BSARCO - Bl Paso a/ oe ($/Cancer) Mae (Cancers/year) a? ($/Mq As) ($1000) Coet Per Unit Reduction of Fatal Cancer et bee eT Unit Emission Reduction . Costs Change in Annual Incidence of Cost Per rt . Control 270,500,000 b/ 850,000,000 mae we Annualized