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
~
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o
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-
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