The Environmental Protection Agency's research program with primary emphasis on the Community Health and Environmental S...


Material Information

The Environmental Protection Agency's research program with primary emphasis on the Community Health and Environmental Surveillance System (CHESS), an investigative report report
Series Title:
Serial - House, Committee on Science and Technology ; no. 94-SS
Physical Description:
viii, 110 p. : ; 24 cm.
Dillaway, R. B
Byerly, Radford ( jt. auth )
United States -- Congress. -- House. -- Committee on Science and Technology. -- Subcommittee on Special Studies, Investigations, and Oversight
United States -- Congress. -- House. -- Committee on Science and Technology. -- Subcommittee on the Environment and Atmosphere
U.S. Govt. Print. Off.
Place of Publication:
Publication Date:


Subjects / Keywords:
Public health -- United States   ( lcsh )
Environmental monitoring -- United States   ( lcsh )
Air -- Pollution -- Physiological effect -- United States   ( lcsh )
federal government publication   ( marcgt )
non-fiction   ( marcgt )


Includes bibliographical references.
General Note:
At head of title: Committee print.
Statement of Responsibility:
prepared by R. B. Dillaway and Radford Byerly, Jr. for the Subcommittee on the Environment and the Atomsphere of the Committee on Science and Technology, U. S. House of Representatives, Ninety-fourth Congress, second session.

Record Information

Source Institution:
University of Florida
Rights Management:
All applicable rights reserved by the source institution and holding location.
Resource Identifier:
aleph - 025959496
oclc - 03627577
System ID:

Table of Contents
    Front Cover
        Page i
        Page ii
    Table of Contents
        Page iii
        Page iv
        Page v
        Page vi
    Letter of transmittal
        Page vii
        Page viii
    I. Executive summary
        Page 1
        Page 2
        Page 3
        Page 4
    II. Introduction
        Page 5
        Page 6
    II. Introduction
        Page 7
        Page 8
        Page 9
        Page 10
    III. Findings, conclusions, and recommendations
        Page 11
        Page 12
        Page 13
        Page 14
        Page 15
        Page 16
        Page 17
        Page 18
        Page 19
        Page 20
        Page 21
        Page 22
        Page 23
        Page 24
    IV. CHESS aerometric measurements
        Page 25
        Page 26
        Page 27
        Page 28
        Page 29
        Page 30
        Page 31
        Page 32
        Page 33
        Page 34
        Page 35
        Page 36
        Page 37
        Page 38
        Page 39
        Page 40
        Page 41
        Page 42
        Page 43
        Page 44
    V. Review of CHESS air quality analysis procedures and results
        Page 45
        Page 46
        Page 47
        Page 48
        Page 49
        Page 50
        Page 51
        Page 52
        Page 53
        Page 54
        Page 55
        Page 56
    VI. An analysis of the CHESS health effects studies
        Page 57
        Page 58
        Page 59
        Page 60
        Page 61
        Page 62
        Page 63
        Page 64
        Page 65
        Page 66
        Page 67
        Page 68
        Page 69
        Page 70
        Page 71
        Page 72
        Page 73
        Page 74
        Page 75
        Page 76
        Page 77
        Page 78
        Page 79
        Page 80
    VII. Current CHESS status and future programs
        Page 81
        Page 82
        Page 83
        Page 84
    Appendix A. Recapitulation of the aerometric and meteorological findings of the investigation as they relate to specific sections of the CHESS monograph
        Page 85
        Page 86
        Page 87
        Page 88
        Page 89
        Page 90
        Page 91
        Page 92
        Page 93
        Page 94
        Page 95
        Page 96
        Page 97
        Page 98
        Page 99
        Page 100
        Page 101
        Page 102
    Appendix B. Legislative history of the CHESS program
        Page 103
        Page 104
        Page 105
        Page 106
        Page 107
        Page 108
        Page 109
        Page 110
    Back Cover
        Page 111
        Page 112
Full Text

iL &A



Seri SS


Frined or he se f te kmmittee on Science and Technology


VorWe w te Spernteden ofDocuments U.S. Government Printing Ose
Washinton,).C 20402 Price $1.85

OLIN E. TEAGU E, Teas, Chairmas
THOMAS N. DOWN ING,-Virginia ALPHONZO BELL, California, DON FUQUA, Florida JOHN JARMAN, Oklahoma
ROBERT A. ROE,1 Now Jersey LOUIS FREY, Ja., Florida
MIKE McCO RMACK, Washington BARRY M. GOLDWATER, JR., Califra GEORGE E. BROWN, J&, California MARVIN L.-ESCK, Michigan DALE MILFO RD, Teas JOHN B. CONLAN, Arizona RAY THORNTON, Arkansas GARY A. MYERS, Pennsylvania.
JIM LLO YD, California
TIM L. HALL, Illinois


OLIN E. TEAGUE, Texas, Chairman
DON FUQUA, Florida JOHN W. WYDLER,: New York,
MIKE McCORMACK, Washington

GEO RGE E. B ROWN, Jat., California, Chairman MIKE McCORMACK, Washington MARVIN L. ESCH, Michigan

C O N T E N T Si iiiiiiiiiiiiiiiiiiiiiiiiiii~ iiiii
| :teiiiiiiiiiiiiofiiipageiii
I.~~~~~~ ~ ~ ~ Exeuiiiisumary-------------------------------- V1
.................oni-- -- -- ---- ---- ---- -- ------ -- ---- -- ---- -- ---- ----~iiiii
A. B c g o nd- - -- - - -- - - -- - -
B. History ofiair pollutionihealthistudies pleading ........
i ii-- ------------ i 7ii ii
Findingiiiii co cu io sinirc m eian --- -- - -- - 1
.A .iiii G e e aifn i gi-- - -- -i-- - -- - -- - 1
B............ S p ecifi c '== C H E S S........... fi n d in g s:::::::::an d:::::::::::: ....n! iiiiiiiiiiiiiiiiiiiiiiiii ....iiiiiiiii
iCi R &i.r la eiiiig -- - -- - -- - -- - 1
D .... ............... .............................
E Closing.rema ks.----------- -------------- ------------ 2
TV. C ESS erom tricmeasuemens -- --------------------- -- i2
A I tro ucti ni----- --- --- ---- --- ---- --- ---- --- -i2
B .. R eview~i of........ chemica iiiiiiiiidi ................. m ethods---iiiiiiiiiiiiii iiii 27 ii
I Th Weiiiiiiiiethodforimesuremntiof mbien
................. - - - - - - - - - - - - - - - - - - - - -ii
2. Tota suspe ded paticulaesi------------------- 2
3 Suspendedisulfate------- 28
4 Dwfal buket tae si caia iii an
cyclone sa per- -- -- - -- -- - -- 2
................................................ n g a n d.............................................t a r e d u c -i
ti n - - -- - - - - - - -- - - -3

...................................................-- - - - - - - -iiiiii3 1
a. S illag of reaget duringiiiiiiii ii3 b. K e deay of te reagetiiiiiiomplexi-----i3
m ethod ------- -------- ------- -----i3
d.iiiiiowiiflowiii ii34
e.Bbbe ran3
2. General assessmnt.iofiCESSii02idtai-----------i3
3 .~i T 3
4.Ttl upndd3
D.- TheCHAMP ar monitringiprgram- 4


VI. An analysis of the CHESS health effects 57
A. General problems of epidemiologic investigations of pollution
effects ---------------------------------------------- 57
B. Introduction and 58
C. Specific health effects 60
1. Chronic respiratory disease (CRD) prevalence ------- 60
2. Retrospective surveys for acute lower respiratory
disease (LRD) in 63
3. Acute respiratory disease (ARD) 'in volunteer families 65 4. Asthma panel studies ------------------------------ 68
5. Cardiopulmonary symptoms in adult panels 71
6. Ventilatory function in schoolchildren-- -.73
7. Other CHESS studies---- 75
D. Summary assessment of the population studies 75
E. CHESS current status ------------------------------- 77
1. 77
2. Status of analysis- 18
3. Recent planning directions of Population Studies
Division -------- ----------------------------- 80
VII. Current CHESS status and future 81
A. Retrospection ------------------------------------- 1 81
B. 82
C. 83
APPENDIX A-Recapitulation of the aerometric and meteorological.
findings of the investigation as they relate to specific sections of'the
CHESS Monograph ----------------------- ------------ 85
A. Introduction ----------------------------------------------- 85
B. Critique- 85
1. Prevalence of chronic res oratory
1970 survey of Salt LaTe Basin communities- 85
2. Frequency of acute lower respiratory disease in children:
retrospective survey of Salt Lake Basin communities,
1967-70 ---------------------------------------------- 87
3. Aggravation of asthma by air pollutants: 1971 Salt Lake B "
studies---- 87
4. Human exposure to air pollutants in five Rocky Mountain
communities, 189
5. Prevalence of chronic respiratory disease symptoms in adults:
1970 survey of five Rocky Mountain communities--------- 90
6. Frequency of acute lower respiratory disease in children:
retrospective survey of five I ocky Mountain communities,
7. Prevalence of chronic respiratory disease symptoms in military
recruits: Chicago indu&Uou 92
8. Prospective surveys of acute respiratory disease in volunteer
families: Chicago nursery school study, 1969-70___________ 93
9. Human exposure to air pollution in selected New York metropolitan communities, 1944-71 --------------------------10. Prevalence of chronic respiratory disease symptoms in adults:
1970 survey of New York communities- 94
11. Prospective surveys of acute respiratory disease in volunteer
families: 1970-71 New York studies --------------------- 94
12. Aggravation of asthma by air pollutants: 1970-71 New York
I studies ----------------------------------------------- 95
13. Frequency and severity of cardiopulmonary symptoms in
adult panels: 1970-71 New York studies ----------------- 96
14. Ventilatory function in schoolchildren: 1970-71 New York
studies ----------------------------------------------- 97
15. Ventilatory function in schoolchildren: 1967-68 testing in
Cincinnati neighborhoods ------------------------------ 98
C. Superficial and perfunctory treatment of meteorological informa. tion ----------------------------------------------------- 99
D. Insufficient exploration of possible relationships between meteorological conditions. and asthma attack 99
E. Failure to consider peak and episode concentrations------------- 100


-- ~- ~a~ a apage F. seof snge mniorig taiontodetrmnetheexosue fcommin 10


H o v s===ior===iiiiiwiiiiiiiiiiiiii

Commrrrz ON SIENCE ND Tizwoioiy
Washngtn, DC.,Nawber 9j 976
Chairm, Cmmitt on ciaw nd Tthnolgy, .S. Hwe o
Dz4 MR Cm~mA: amtrasmitin hrewth reorteni......
"TheEnvronmnta Prtecton genc's eserchrogam ih

Cr~nv~ eznhams on he Commuity Healt and Envronmenta
ce ste (CESS: A Inestgatve epot."TIisrpt
P"Wdestheconluson an reommndaios rsulingfro a intnsie ealatin o th sienifi ad tchncaladquay o ti
imporant ar polutionhealt effcts srveilanceiystemandirlate reserchProgum. Th reprt ndictestha thee ae a umbr o
servi. iuo in]E~s esarc pogrmswhih equreresluioni

order toiachieveimoreieffective results
Theiriportiwisipiepared.b.....mittee.s.aff.m.mbers, .D.... B.ii iiiiiiiiiiiiiiiii
Dilliiiiiiiiienceiiiisultantiindiiirector, EPA CHESSiInvestigatonan OvrsihtSubom ieeiiiiiioniiiSpeciiiialSuis Investi
tin akTa edr n r afr yry rSineCn

emmite tort aentigbtpas o h rfsinlmne In closing, howeeIwudlk omk nadtoa bevto that oes beyond this

exaeof ite dosa nstanoid whcahllau feviomna

ra n o te
ad wt
reprt asmuc sgniicncewih rgad t rseachmangeenta4
executiidosntpoiealteasestth ocyaewo

is oligd t ac in he aceof ess hancerainproo, Te pjj4

oriented question of "acceptabl is"adbu enoprf"cne
assited bu neer fllyansere by ettr rseach. wold opetha

those,~ wh edti eotwl.ntuei oudrietem1mJ

Tbe.a$a of the Subcommittee on Special Studies, Investigations
.im Dvsight and the Subcommittee on the Environment and the Ak~aoshre have completed an evaluation of the Environmental Ploocton Agency's research program related to the health effects .o irol tion, with primary emphasis on the community Health andF i..:.ta Surveilla...nce. Sem- (CHESS) This iny igtion wsgtoad elier in the report aon joint hearings held by the Ruse bsta~tat and Foreign Comme.r** Conaisteei and the H Ouse Science m"'Tciboly Cnomnittee, April 9, 1976,0: While the joint hearings, heldAo etemn whether there had been deliberate distortion of dka ring the writing of the 1974 CHESSMonograph? produced
7......+ that no basi existed to question the integrity or
s~auff Adnesty of the project leader for the first CHESS Monoa hearings did not resolvemany questions and supported h
eedora corn whensiwa ealahation of the scientifi and technial P~pd t he WE grm and related Environmental Protection
A40nW (EA) re e ffeorts..
I.OThkines ito reported herein was conducted by a team compoedofme of the staff of the House Science and Technology
Committe with the support of consulting specialists in serometry and naltical chemistry, meteorology, epidennology, medicine, and r eranimonmntal halth, Conferenese were held on site, in the
X~withindividuals in EPA and in State and local government,
,ad private institutions who had detailed knowledge of the
wndctofthe CHE88pogas A number of findings and recomead latins are prvie in the report including those highlighted in th lance ofthis summary.
1o some the findings may appear overly critical since CHEAR iwlemd in a diioult research area. However, in part thd report is meant retroatively to complement the CHESS Monograph which dfis. to fally appraise the reader of the errors, deficiencies, and other abortmmngs in the information presented in the Monograph. The intent-al -the, report is to aid in assessing the validity of the. conclus presented in the Monograph and to assist researchers performing similar studies in avoiding similar problems. The endeavor was greatly assisted by hindsight and by the splendid, cooperation and selfexamWination by investigators both inside and outside of the Environmtental Protection Agency. The, report also notes where problems Mimilar to those found in CHESS research still exist in the EPA program.
I U.S. Congress. House Interstate and Foreign Commerce and House Science and Technology Committee. Alth ~ Cnrs,2d Besin Repor on Joint Hearings on the Conduct of the Environmental Protection Agne'"ComunlitHelthn Environmental 8arveillance system"l (CHEB8) Studies Washington, U.S. WOO Aprril 9, 1976.
2 U.S Envionmenal rtetonAecy. Health Consequences of Sulfur Oxides: A Reprt from CHEB8,


The report identifies the need to reemine the wisdom of legislative and executive pressures for rapid development of informatin W pollution control standards, and the adverse impact of these reqik*, ments on the performance of research. Also identified were the ptel lems which are occurring because of the Office of Mlaymeuent. asi Budget (OMB) assuming operational control over. details in the* research rams.
The prga has historical value as al Brat atteaps
broad based defintive study relating air quality :to health aeuthli precise, quantitative manner. The program: -is a contribution *d general field of air pollution epidemfiologicalstudies. However problems critical to obtaining useful.. quantitive: result wft*n solved in the conduct of this research. This faure'to. Solve Preiavt problems became obvious whe the stade were examined T"e
were too many inconsitecies in the data and too many problems that resulted in large data qncertainties or arn A'NI with the aerometries for the results of this -rogramf to provide quia tative support for policy decisions.-!The 25 #gfma loeI limit of the method used for most 8O2 measurements icopaoob the overall large error band on a meaurements- (possiblyexld 100%Y) and the apparent bias of SO, concentration data -on' ttM@ side,' make most of the numbers. presented in the CIIESS graph maneak.,In Topaicula, :the, dlata evfam rsoA knpwmasoQk&mAd accurate in the range of the SO2 standard (8 0 a tiila
"hockey--stick" curves have no apparent badls iid the dat4&l
Further, there are inadequate date in the Monagraph for interests researchers to evaluate skily, the many envenaftrequired for intew pretation of the'conclusions. For his reason it in recommend
usage of the (Twimit Monograh InadAdition, BI% shouldprp an addendum to the Monograph painting eni e7edti, lhmitations of the Monogrph. This ad~indum abould: (1 dtai
at least the material presented in Chaptes If ,V V,7n V, A ppendlix A of this report; (2 B e made ar part of any f uture prmi zn of the Monograph; and (3) Bemade 'available to, the pulic aml d scribed in the formal notice mentioned. above. 151% should: notuw data in the 1974 CHES8 Monograph as, supp orthav justiication fo policy decisions without exlii qua.lifi.ati:n.and.shud Avi r.... .....:.

vestigators should obtain all available data am. tab studies _Ibea continuing investigations-of the same or simil v henomenamiUt critical that EPA establish with high priority an adequately saVW ported program to corret rapidly-the da of deficiencies in teadsa execution which are reported in this document. Only when tepe capabilities are established should major air qualityhelhAe programs be renewed. .. .
To recapitulate-the overall.:CESS experience, a~s e...e... plift...
in the Mono a Lh, teaches two outstang lessons: .
First, CHS corroborates the notion that elevated a~i olf levels cause adverse health effects.:

Sqq*pd, CHESS points out the many difficult problems involved in carrying out air plution/health effects research.
Of course the first lesson had been learned long ago, but failures in ,CHJW ,Planning an execution precluded the development of new
v Wormation on the relationship of air quality to health.
WOMES8 cannot be called a major advance, only a confirmation of previous advances. With respect to the second lesson, the value of
Terience lies mainly in the use to be made of it in
and improving operational procedures and research tools
-tation, questionnaires) and in pI ture health
466i*0 studiesil Finall it seems that both these lessons could have bun lewmed at much iess cost in funds, elapsed time, EPA credibility, and staff morale.
XPA has. only recently been reorganized to modify the National lKnwonmental Research Center concepf. This reorganization waa exammed in more detail in a previous report.3
The reault : of this present investigation suzzest that the changes MaAelast year. axe less effective than anticiliiied. The issue of research management should be continuously monitored to build the 4viroqmenW: Research Center, Research Trian le Park capabilit and raplutatWm, At theend of the 1977 fiscal year tTe situation shouli beexuWnod to determine further need for reorgant ation. Perhaps
*maider an, should -be given now to some structure which provide. for a single point of review ai both the Research Triangle Park and Head carter in Ord
mut z r to alleviate the obvious lack of coordination of
Plnaxy projects, without attempting a major reorg.-.1-LUZ ation.
There is considerable evidence from this investigation that some critical disciplines, such as quality control, monitoring and sampling, and statistical analysis continue to be inadequately addressed in preproject planning of health effects studies.
In the area of reseaxch management, the investigative team's recommendations axe critical of the control of research programs within EPA. There is also concern with the fact that research is being conducted by other EPA offices involving little coordination with the Office of Research and Development. This functional overlap is begminmig to produce problems within the laboratories and needs to be effectively resolved before these programs continue much further. Related to this overlap and the need for the solution of the problem of poor communication between the offices and laboratories, are the needs to provide for a more effective input from the Science Advisory Board, to establish a permanent peer review s stem to insure coordination among laboratories, and to expedite tKe timely publication of research results.
Although the Administrator of EPA had indicated during the joint hearings that there was a five year plan for research on suffates, the *investigative team found that only draft plans of this program were available and that the development of this plan was being poorly coordinated. Accordingly, no specific recommendations with regard to this plan can be provJded. However, the need for better information on the species of chemicals, including sulfates, which are of primary
3 U.S. Congress, House Committee on Scienee and Technology. Organization and Management of EPA's Offlee of Research and Development, 94th Congress, 2nd Session. June 1976. U.S. GPO. Washington, D.C. Serial LL 40 pp.

Importance in health effects is .emphasized, and this: r4bomakt o has direct relevance to',the proposed, sulfAtA iirigranE : *
A number of other recommendations are :made wiith .e zmre need for improvements in the air monitring Iad'8 'ProgDrams, the need for additional strength: in met~ippy a
number of specific suggestions about im~proy mhents' fti: epidemiological studies reported in the OHESS doetithent. 9*
It should be noted that the investigative teft reeive0411 cooperation throughout the entire investigation afft'sppre this help is acknowledged. A number of the l'eebbithedait 'change evolved from the suggsin an thS1y'e1teot
EPA personnel for the improvement of their reiselith rgti.
report be ars on the condition of a research area which is the- i many forces and restrai:4ts. There is no intent oimug's theo or ability of any individual researcher,. ally4f, 'wmwere-, exhibit professionalism and: dedication toi their spogam- 'I 0 I Finally, a most. important point must beo mhade ieh Agr6*'sA but 'goes beyond -the study. This -repyort -' doestnents' manyI '*W deficiencies in- EPA research both past and !Cesnt. It dds:s-not many of the fine research efforts ongoing. Th# this report then is to point the way to i.mptvwifig a'nd Ott
EPA research. program, not 'to undermine the 'poga. regulate wisely only if its decisions are based ont itformationerkw in a sound and comprehensive research p~ia.*o s

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............... i.
it 4

Pi~*:nvi*ronmental Protection Agency, in partial response to bhe viiidat, b Congress under the Olean Air Act, conducts research to stud theadverse health effects of air pollution. A series of major &i.
Pk~itbn~eath effects studies were carried out between 1967 and im ad 'ere considered by many experts to be the most compre houive bftheir kind. This program attempted to implement a comdimed18stem of serometric measurements, including measurement of ulfm dide (S02), particulates, total sulfate, carbon monoxide ") I ouho, hydrocarbons, nitrogen dioxide (N02), and' nitrate.
In artg here these measurements were made, the EPA initiated cdnwjmntspidendological studies embracing sate and chronic respiratwy i;% ventilatory function of children, and the aggravation of ia~msymptoms. A portion of these studies eventedlly was given tbe, oraltitle. of ,"Community Health andL Enviroxnmental SurveilaceSytem" (CHESS).
k&Oughdata were gathered. over the entire 1967-1976 period the
160', He #4 Consequences of Bulfur Dxee, A Weport frobm CIZ~e978-71, (EPA 650/1-74-0)04, 1May 1974), treats. only somiq at thee tAwSome controversy exists in the professional community Mardnelthe technical correctness of the results and conclusions as presntein that monograph. The controversy was intensified followwgw tas of newspaper articles starting with a Februitry 29, 1976
bcd the Los Anzeles Times. In this article, scientise both within, and antside of EPA 'were reported to have alleged that the data and. As analpin were manipulated to more strongly support ertain regulatory;post'tions taken by EPA.
FR owing these allegations, the House Science and Technology 006nitee and the House Interstate and Foreign commerce .Commhta on April 9, 1976 held a joint hearing on the alleged mishandling of te -CHEISS program.'
htle. the hearing generally negated the idea of a planned manipulti on of the data, many questions were raised as to the reliability of t1e8d t, the technical soundness of its analysis, and theimubsequent v~dt of the conclusions reached.
Furter, the EPA Administrator, Russell Train, testified that there da fed a five-year program plan for sulfate air pollutionr and health effects R&D which would assure a sound data base for promulgating air quality. standards in the future. However, the plan itself was not
As a result of the questions raised by the April 9 hearings and other addrees, the staff of- the House Science andf Technology Oversight
I U.S. Congress House. House Interstate and Foreign Commerce Committee and the House Science sad Techoloy Comitee.94th Congress. 2d sesson. Report on Joint Hearings on the Conduct of the En=iom n11al P rom tection% Agec "Cmunt mealth and Environmental Burveilance, System" (O.RESS) Stadies. WashingtonTUS. Govt. Prin. Oft.April 9, 1976. 25 pp.

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Sum mteanthSucmiteothEniomn dte
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CHESS Monograph. Theinvestigation also looediinto the follow-o

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hi i s ............... was la nc ed due..... to t e m ora ce o
researchiii~ toth .N paper~ii icles.ii i impyta eogiinoih iprao, eiromna eerha ai o euainhsadwl:"
to fosteri evi ew of theiiHiiiiiiiiiiiiiiiiiiiiiiii EPAi iiiiiiog am W e-wou iiii-t onto.....
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p e t in n iiiiiiiiiliiiiiiiiiiiiii ...ns.wer....e...o....f....t.e.specific
findfitigs and are given at the end of Chapter 111, Findings, Cond u sio m s a n d R e c o m m e n d a tio n s .
T6iii~i~i invesitigative team consisted of at least one person with tech- iiiiiiiiiiiii
iialnolege*i ec ........ the == scientific disciplines expressly involved
in, (H ESS i e., epidemiology, aerometric measuiement, meteorology,
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Vale n egim Frkt rcune ta svea hnresweo
ickeedbysudeny pparig esirtor smpom, cmp tted
in lrg nmbr y rvecicuatryfalue H nte tat,."@r
thnsxyde nte4had5h fDcme fe nyafwhu
oicns.Aszalnubrolietchatob sluhed"
Haviiiiiiing caclae.......iyrae wr enadonhlft
avra urn hs eid ire ometdta, huda,|gfa
fogii ....................................................................... @
mourn~~..... wod ee rpeic. Four thousand ecess deaths. wea ti b u................................................................................
added!i! hi..m rt.lity.igure.......-....
"Th inidn

a e as et ae tandalvl hthsbe xedd py
rrly~ii~iiiiiii duigtepathnrdyer-o xmpe ttehegto h


years? To answer such questions, epidemiologists began to measure sublethal effects of pollution such as eye irritation, seseptibility to chest colds, subtle changes in pulmonary function, and asthnna attack frequency (see references n1 and 12.) The Community Health and Environmental Surveillance System (CHES8) represented a natural
el ofefforts to ahrcnurnadnorbdity and air pollution
The keystone of the CHESS program is the couling of senaltive health indl* Cators to cmrh lve environmental monitoring . . . EP A health research needs are prcial ad arbe rented. CHESS reearch is thus pragmatic and our gasetreod (1) to eva1luata exitn environmental standards: (2) to quantitae pouatburdens in exposed popula'tions; and (3) to quantitatehecalth benef of poluaotrol

measurements and monitoring methods which in some instances had aot been adequately field-tested. Municipal regulation of industrial ail. pomer combustion, space heating, and incimeration resulted in diiisie decreases in sulfur dioxide and total suspended particulates in Newr York City, Chicago, and elashere. 4 Themn favorable pollution
more already evident in 1967 Thus, by 1970, it was urgent that
poku stin dies begin immediately if crepnigimprovements naet indices were to be dcmne. CESdata was gathered in Now York City, Salt Lake Citynh Charlotte, and in Chatanonga from 1970 thog 95and Los eles between 1972
an 195. The analysis of the daaand compln of conclusions was
began ag r iely as data became available. Te factsralating to this pca m history are diseassed in h following chapters.

n1 Nemson w Amenelethn.,tnlish T.m 14Trp, RI. an, ~pl a a o.. a9varnment Protecdon Agncy ealt Consequenes aome onfu Odse AReport ruom OROAr@-MAL M17.EP-5/74W
.'awm n M athem=U."atel Static and Pmhbabilty (14f0).


.:Th# findings resulting from the CHESS program review have extended into EPA's evolving task of developing sulfate standard ss: well as a general perspective on EPA's entire air poll ution-health effwts research program.
The EPA five year plan for sulfates research cannot be commen d onat this time because the plan is still' in the formative stage. Thus, the recommendations deal primarily with what it is believed can be accomplished to prevent repetition of the problems produced by or related to -the CHESS program.
The EPA CHESS program intended, as one of its prime goals,
to provide a sound basis for relating human health effects to precise quantities of S02 and other oiddes of sulfur in air and to rovide a raUable record of the improvement of the health of the Ul populatioii as Air pollution was controlled and reduced. The program, spanEm9p 6 to 7 years, was to achieve these objectives by measuring and analyzing 6 health indicators together with S02, NO2, suspended sulfates, total articulates, and oxidants in the air in 6 representative areas throughout the country. Only the 1969-1971 data were analyzed, earrelatiad and published by 1974 in the CHESS Monograph. Most of the remainder of the data are in various states of analysis.
A critical review of the epidemiological and air monitoring programs with conclusions for each subprogram is presented in the body of the report. The results present a picture of a program pressured by EPA management-finposed time constraints to meet legislated mandates for promulgating new standards, hampered by inadequate mechanisms to detect and correct technical problems, and handicapped by budgetary' and management restrictions placed on the program after it was weHunderway.
: In the drive for results, the program did not adhere to standards of quality control, validation of methods, cross-checking of data, and calibration of instruments required in such research. The decision ncit to submit all results of on-going research for publication in protessional journals deprived the CHESS program of an important source of peer review and evaluation at various stages, although the Monograph was sent to many reviewers for comments. The simultaneous publication of a large number of complex studies in a single roport-the 1974 CHESS Monograph-rather than as individual ongoing research reports may have been an administratively expedient method of publishing and collatmg results, but it undoubtedly reduced ttw effectiveness of peer review. Ae complesity of the doiAiment also unpeded the public from acquiring an understanding of the results of the studies associated with,,polides of national importance.

Avidnced of advers ealth Vffet of etgtv ea ssa
mili ties supral enera fnep chrael~~ndwe
in snsseatin wit wn haeer level aHS oh.rfdr foste itinwre prese inetel ofad i~px~uat-r''rsn health paaels weretivless OheSCS alorphpeenssm eidncte ofiars m aeffso air pollutiensnipatclr

in the Western World. It is important orcr s rne~rO lesons learned for future undertaking AS pointed out in Chapter VII,thfidns]W"mg l
epidemiological work corroborate theisusrse *pkvxn au8. This report .collects the issues andgositdeh b:cg f errors, etc., and suggested corrective ein In addition, this review documentserosrosan ma ww the aerometric data and analysis meerlg.aiefteaie important specific findings and relatdrcmeaimrltdt the CESS8 program are presented Ieofloe Y T eW

set forth atrthe beginning of the invesato '0-4It should vbe noted that these findig ontcnrdc h B. Spincinetenan FNI.9AnwRCMEDMN
1. The data and analysis in the 197 HS wga d
provide a reliable, quantitative basisforeaig8:'r f, ftlk in the air to adverse health effects. The mnethods and instruments usedhdascaew errors (mnaccuracies) such that the trsodcre 'DjWcurves") presented in the MonographaeWtotyi n at i
indicated thresholds occurred at levlatwihhp- jem
methods (as used) were not reliable.Seicalintecso0 measurements the method used had hehl fI2pn,"Oli
cumulative errors found in hindsigti if~,-R
reading the instruments made SO, rinbewn,5 d.5oW
unuseable. There were similar probleswtbte nesrn~ j pointed out in Chapters IV and VI.
2. The CHESS program did appeart essrt' ~e effects in association with local air p~to f udfie ee.4 pollutant mix. Studies of chronic resprtydsaereaji LW provided the most consistent results hs eut *nttatl latable to commu-nitie other, than thoemmrd(nojcie.o the research) because the error uncertittaM h eaerc a made it impossible to arrive at reliabeqatttvhrltosis
3. The CHESS monograph has .beenrfre oete ietyo indirectly as a document supportiveofrgltyansadrsa- @difid bxamples were found stich: as its. use to support EPA fJi ah, air pd11ution health Ifleets in the follow ing excerpt frozi
at 6%rtors 6port, to Obigro8 I or 1974.i
The* 8 ntstudies have deonstrated feimphasis. aged} the 'benefits from improvdar quality with respect to the chrozi .6 respiratory disease experience of submt wo have moved to communities having cleaner air; Alsdfpthe studies
A ov ampt added] that children, living, for 34 :or knore years in comPr4de bvisfig bigh level of air pollutin, JiAve more aoute respiratory disease eods ta recent immigrants to the community. .. .Data obtained from the FIM prgam indicate that advperae'health: effects ate. consistently.lemphasis iA". i "e "ih"xosr to aispetided attlfates, indeed, mn*re s than to
P D~ort proesses and control techniques tor avapended sulfates.'
Vh6 illSS study results were cited in 'an EPA document dated MWa., 96. The preface of that document states "The report's objective 1,1 t- iew, results of research, bjr and 'Under, the sponsorships of E xW/TP 'Prelated to criteria and hazardous pollutantsme publication'It toriteria and background documents." CHESS; studies are *ilrn'K PAge 0 hog 386em to describe thte OCHESS studies
Phe. d in .the OHESS Monograph, although no reference to a docOrh a gives. 'Curiously,- reference numbers 244 through, 252 are
not -o~ in "the body of the text where they would be expected (bety n pgsi 301 and 308). Inspection, of the references list at the 'end 94 t tinent chapter hw that the "mi'ssing" references, numbers .244 tiogli242, efr to the CRESS Monograpli.Thus, it'appears that
ON rsubsaeused without attribution, adthus without caveat.
'- W.m enddions
-a) EPA: should immediately publish and distribute a formal
anouncement to the effect that the 1974 CHESS Monograph4 is
4est a prgliminary document reporting' research ,of varying
d es. of liabilityy and. a .s such shoulI d be c onsidered only as a ueining study of larger, problems. The notice should further
nt out: (1) That many of the problems leadigt h ne
utility of te research a re ..not Ireported in the Monograph; (2) -hat no interpretations should be made based eoily on tlie data in he Monorkiph; And (3) thtother data atvax ble at EPA, finding data taken since th publibktion of-the, Mohograpli,
casetherie& fr tentthiatide of the ceictAsions in the
a~ ~ rao. h notice sliatld also announce the availability d
anddecribe'how to acqire, the addendum reconrdended below.
()EPA, should inot utilize -the, 1974 OP 1988 Monograph as a
I~t ~ibefr specific quantitative date' su ro a of standards or
rglatory decisions without explicit qu dcation.
,,()EPA should publish an addendum to the CHESS Monoh dentaii gat; least the mnstrialh in Chapters IV, V and VI
ApeixA of thid report. EPA'should take'the iiitv
tinak e sure this addendum is available. to the: public and
mcuded in all'future issues of the Monograph.
4. Ithe EPA had drawn adequate attention to the many difficulties
ti countered in the CHESS4 progrm (which was under pressure to pde data as fast possible to support air quality standards
V'. ifronmenta Protecton Agencdy. Report to Congres. Progress in the Prevention and Control of Air in

iiiiii~i='" iiiii2 iiii1 4
une cniiosse yth ogrs, n n hc OBsusqeity plcdrstitos st healctono oitosad u(s i si blihaihipora oldhvibeieteitrintd:i"t
coideal aigso etite cp o emtamrestsatr
resarh rogamtobe omleed Reomndtos
(a egsato afctn tereerc esmbiiie f h EP hol b eeaindtoisuethtunelitc rceue and sceue r o asge....
(b eerhpormsol e eindt anifra,
an nwr usins o o upr pstos
(c I ubicpliy euiesepeitos esach
should........ be maeioinsre thtiheiiiaiosil funding... andipersonnel.
(d n h vn ha ugtr etitin vlewi!w
hae n mpctonte omleio o mjr roect h.wB? Administrato shudbirqieioidieth gesO

potentiiiiiiiiiiiiiiii i alfr sc m at o sdeain so l eO w e reuiin th Adiitao toii prvd ananul nays O C congress which est m ats.he.rob bl..m actof...o ............................................
chanes n mjorproeei suhia th CRSS rogam,
5.Atth pesnttieO-B asth pwe t cntolth m! dtaiii le aspect inarserhpiga.ioiia peiadl i h

aprvlb AE fhat fet usinarssbitdb
EPA present o signiicantlidelayitheicntinuaioniofiiiiii

i iimiiioil suisasoitd ihteiialsmeto rqilt sandads ThsEAhstersosblt o t isobti thi eesr uhriyt ar tot Reomedtin Th M hudb se odeeo rcdrsb hc
qusionirsad iilrdouetsrqurd o esachpo

(c)Th reuls o lxgeorcople pojet3sholdnotbepu

RAW plely n monographform..If.EA.decide..t.... h suc
risuts n mnogaph as ellas ourals the EP shuldtak

'dft.tat wthn heliit o rasnaUpetienidtaar

Projects sould.................. assuranc
Ai h dt oeeem uc rp cnb roel ne
aw.19orts prepxiiiin
sidraio I pliy onsdeaton ditae tm rmte
-b comlshdi tealotd ie
1 While CRAMP loksimoreipromiingiforiprovidigireliableirea
1*: ~sreens f irquliy aboltepoluan lves) te ys
.tow f~abilty andpreciion fr SOilsulfaesiadiiiiiiiiyeitoib
% (a)Theaeroetrc ad qulit cotrolproramin EA soul
bei fuiiiii strengtheiiidiandiimproved.

1 1'-th6 errrs n mistruentiiio andcollctio ma beiorreted
(c) he raciceof eploingdevlopent tag intruent

in:fi~ 'oeraios bfor quliicaiontesin issatsfatoiiiiiii
Oo~plted souldbeistpped

Theiiiii ]EAHat fet rga a ela nV;Hlz,
i oniiiiiii o f.........................l................. r eH"oHre m M theH
halth efet rashudbixmie ihte be so
.... ificatl aceeaigiierhiti r
10ii ..... iiiiiiiill im si on l f wiiiiiiiiiiiiii i thitiiiiiiiiiiiiiiiiia'illu
awrns fmn ftepoI w fon eteZiqaiyhat
effectsiiiiiiiii reserchareabutan aath to ealy drve o corwtthe q i c k ly~iiiiiiiiiiiii................., ... ........!!iiiii
R e c o m m eniiii...............a t '' i o n s:i= ............................
(a rl nedsilnr akfreldb ne!m
sciiiiiiiiiiiiiiieist should drawiiN upaprga pa frEA odeeo
a oi d
................................. and measuremeiiiiiilI n tsiiimeteorologyiiifield t4W

bei ailabl fo uuergas
(b) At heeryleatCATshudbiuhe ovrf
presnt istruentsand rotcolsso tat rliabe daaia
poltn ocnrtoswti isrmn aafiiscnb
ahievd Ne tir gneaio mtnnet uc a te ule
fl o e s e c d vi c e ........................................................................................................................o r fi ediiiiiiiiiiiiii
usageiiiiisoiiitiiaitiirel i l .............. wi i th uncertaintiii ofiless than + 2i
c a n ..................... b eiiii d e t c t e f o r ..........................................w
current standards.iiiiiiiiiii

(C)Th epiiii i deilgclietonipnlslcinciei an te tmsciiieii hsrpr solbwokdotad
aprvdb ergopss htEAwl eirprdfrtenx
round ofi isieriiiiiiiiii i aloreisdsinesiitosiihieial tos n
p n Secfclliiesin sc sih oloig utb
reole foriiiiiipdemolgiiliiides
(1 Howdoii *qiiiiiiiiiesonesiin~ o
p a t t e r n s .? iiiiiiiiiiiiii~iiiiiiiiiiiiiii iiliiiiiiiii ii

-h all Alang with correcting epidemiological program deficiencies 9l T ntsed out in Chapter VT ot the report, the following idas were
Mmdin team interview with IPA personmel arsA others and are
lawoth of review in such a prgrm as outlined above.
(1) Even though OHS was stolD ed artially due to the
m.. eet of such masave programs, the O concept of health
s..weillmane shmuld ke wrevatd befra decnision is mae not to undertake similar programs in the future. Documents> IR.1),11 :tion of improving. pubhic health with pollution abatement; 0 a. l; niffication of new pollutants becoming threats; and
baseline serial heath date are important.
(2) The appropriateness of the CHESS endpoints (i.e.,
doe ndent variables) such as chronic respiratory disease
)should be evaluated with respect to utilizing more
objective and more easily quantified health measurements, .:,suh as mortality rates, amissions to emergency wards,
oor blood or pulmonary function* tests as bemng easier to
l ocument and more reliable.
(3) -Surveillance in small rural towns may yield valuable:
control data on serial health measurements.
(4) Epidemiologic3al program planners should consider
(IJI )m Shnation of local physicians to help develop and screen
paels and gather data in localities where there is an interest.
()Additional consideration should be gven to the study .f hig risk groups 9teek as those in nursmg homes, those f recent admitted to be intensive care unit for myocardial Sdanation, and premature infants.
(6) .Resources should be available for opportunistic
a',pidemiology to study interesting events, such as the Januy1976 episode of high SO2 in Magna, Utah. Such events
jI, s this may allow one to disenteagle the acute effects of
particular pollutants.
(7) Alternative populations should be considered, and
cahort studies of particular occupational or medical risk
graup may prove valuable.
(8) More, attention might be given the need for individualised desimetry.
(9) Under what circumstances, if any, can epidemiologic
studies, alone provide unambiguu dose-response data?
(10) More exotic studies r, "yh be considered. The health
effects of a new event could g observed, such as the construction of a coal gasification plant. Changes in a town
whc i nontopanslctive modifications in the regulation of, specific pollutant could be studied. Studymng vacationers from small towns who spend a week in a polluted urban center mgt be considered. Longer term migrant
studies might also be useful.
During the course of this. investigation the extensive interviews

EAealth b etbs esc Laaory. ldM atQlabotwes ivisins, apea tob is%111 rit&ad
fro pon moae Manaemtof mer ff6.Jcuigfe

hernel folsevderalhifi foidinporydf*.Anrng 11.ea th e abratoris rbem nof eoriatoln Ko (ietae) disrpion T asoiaedl asa ed4ty, W~nt Oganiztion fd thenOffien of IP'sOfie ftrdhc ad e

vopmetinte repershoudhe cmiteo h nion n moe itshut further Hos sinfontee onSineziTcnlg iscalunea 1977ihlpsib h
12There ilws evena pfc fianedi ogadretdrcomntis. t1e forhesa laboratories at t mlteyrcoeeifo Rietle isrtiulalybtwen soitdihthe fleb 195rer anztoo the nviro etal MesitrchyadDvlpet
Shige oftablty i an coorintinredet-naygo.rsfw laoraiesio, adteen EPAl beale untin rsn
Aod sitcift exmfurthsisnifiatk oga~mi nn of Howaler even7 aferthlpisblerning ProTe i Agenc s stl ne ot ell k~ I criit ewe
thorratinlchagares a eiee tniomna esa etr When mutiicliary proeec ts Halh faRsrc-Lbaoy ang ah snineacla doisciplid tp a
needratorbes craed morwen Effecotive r, 4.Fdea aortre ivl e. S ain sician r as an qua l y o n d q i o .: : Aroleii explain of tsuc pocodntosi se nCES communrcation sfeem thaisle arn .gperonethi nirr' ofc Researcplan Develdopets org i fccrti hercn orniial atres reortlieedt3a x~r~edtiirbm Wn PA Headquiars Thisecis eporgaie AAfnb tf haor g sulfates o rtexam l where in e hotat lei poristinctsemte at RTv bu fccn tteto O~cie nteRT to ine coadordtion. Asureet a7 roe nte evlopedn o citn premt.Polm~dco to n comucton Hosee omteon Briene and T-ect~vl eas fteOfc hfemspear, Oranaond Managepment o gn PA'i wic

tr 2nd Ssinsue 97.USc o er nmeint Psrin thfu esac e ~
ar o eeoe ncnitn rmss

3 ..Cnges 1os o mtteo cinead ehooySlo aibda'
th topee raiainadMngmn fEAsOfc fRsac n e7eo|h*dr,9t n grs,2dSsin ue17.US oenetPinigOfcWsigoDC eilL,4 p

OQD Maidation:
a) Inaccordance with the recommendation under 11, ahove,
i~fipo e ordination should be so htst this time without formal w~uhitenal changes. This couldug achieved through establishaiiw Oan authoritative peer review panel to monitor all on-going
Projctsand ensure appropriate interfas between the various dis
4pliopp 4hea review panel should, represent the highest level of r"WOalh9U and should assist not anlr in program planam and *VWWforscientific-obj ectivity, but in peer reiew of major sceiic Impo ith ,- Policy imp eens. Such review abshouse that A Wm sports, are released in a timely fashion after complete scientific
1, Ui nee for coordination cannot be satisfactorily achie ved by angmens alone. Nevertheless, the formation of ad hoe woringgroups, under the oversight of the continuing pear review pau4,mptioned above, could be a useful mechanism for attacking
problems, suc ainnig a coherent sulfate research program.
Addition, the following additional steps might be taken without
affctngthe stability of the Isboratory:
(b) A stron eao .s on management at the Environmental Research
C16terI APwould aid in interfacing with the four Deputy Assistant
Offic, NPA"%es at Washington to prevent separate taking on
emnl~a4.identical problems.
1j. Cider ation should be given to creation of a systems anal sis/ op atons research program review group at Headquarters of EGA andperaps at each techncal center. Tis activity could 'insure that
oirattention is addressed to all scientific disciplines in progam
Adbudgets, irsetive of which scientific discipline initiates
.pTrogropamgh act as staff to the peer review ynl
(d)TheScience Advisory Board's (8AB) charter should bereex ed to improve the assistance rendered to the Health Effects gemare Laboratory and to Washington project directors. The SAB 4111&have direct informal access to the research programs and
ortuityto review and recommend actions relative to planamE
c~orinaton of projects involving several divisions. The SAB
*piddhave scientific review responsabilityv for programs, and its partiption should not be limited to public evaluations after somethig oes wrong.
U..The EPA research programs in many cases were found to be Anwat isolated. The research staff -does not seem to avail itself A..m imal technical exchange with scientific peers. It seems that ajrge extent outside contracts go to the same groups again and

Rewnendations:{)EPA should actively seek cooperative research programs with a variety of universities, other laboratories, other agencies. NOTE: This is Xnot -a recommendation that more task-limited contracts be given, but. that truly cooperative Programns be implemented in which the, outside laboratory can contribute its own ideas. 9(b) EPA should. arrange for research staff t n six t eighteen

i i. .. .. . . ........ ... .. .......... .... .. .. ............. ..... ............ ... ...... . . Qi i

ping suhourac.rorms... .
14ihr r xmpe ficesngoelp'ogt
R e s e a r ch = == = ................................................................ ..................... ........ ...................................... ....................... .
th Ofice ofT-iiusacs(T) t ahntn i sin'n
toteEvrnetlRsac etr T .Isacswf oei

whr botWi hH OR n T aease h T ete o eerh
onte sm ubtne adwer twa vdntta..nihe'te
divisions at the R T P C enter nor the O ffi ces at M rashiiiiii~iii~iiiiiiii~iiiiiiiiiii!iii~ ................. I I ii iii i I I iitoiiiiiiit'iiiii~iiaiii
coordii i n a e th e in p u ts......... to th e........................................
a ssig n m en o f~ iiiiiiiiiiiiiii~iiiiiiiiiiii p o e t ...........................................
Inadto tapasthtrsac sbigcareotM fI&
other than ORD. "=

laboraoi esincaryn it o....... 15.] Th va iu EP....atR Paenw ctee~gotpi
ii ally~ii ,i i n suc ...................a tio.n ur.Pr pe
cri nain n ecageo iesispyscly ifiut
R eco m m en d a tion:.......................................
Whteerfia mnaemn cncpt eove tisspas ii4
fiitiiii i e must......... bei ............ in an ex ed tou......i .th F
program a RTP is epected tofunction ith anyiiiieeof co

2 1iiiii
,(ER onet a peeredt teforRT-iisiii/ifour W -on-mnaerstucurewhchcuretl e is. Aiimajori
th lc o asngemaagr ficea h etr insurei
.itrdvsonlrviwo mlidicpinaiipojetsanitoseur
from~ ~ ~ i all diiin nsc rjcs
"wf su c s in recruiting........ keyii ..................... and iiiii
t iiiiiiii piiiriililgramiiii

,=cautioniiiiiiiiiiiiii cannot===- iii be= =HHH~ shown,... even more undam n sepsiiiiib iiii ii,".. . !iiid.iii

portancesof cnten asebcueteei tM3'i i
(5) WHEreo the edeioogidalenopdivdaxpsrtb&&bet The fuaindinghs, ae doubSS serther intko hs-nw t n selection. c

(6 Ieer the u nlt maesterifmicnt toass ra4d~~cnrtog

Again, the findings disblosed inanyiii wih ilhestaesmt the hoteth meraldoiers us)eefu f w valida ed e ttuetse. rceue nrou4"
(7) Ipregama they dat e redveiabl and arvn carrsem otheitoutofnwtcnqe a lwa e.J~
There wetroued ntnce sly ofe errorste inertad t fn

thporcecne of co mputery i an rjcsukp HS, u hs a %
(5) Dide the healtiademooin dopltinadqtey8eot conetratins ofispee doltats haliiyo eti fte1 b adv er e althe elt m endpoints'miaiiiuiiuliand: iiii"i

Thein fefidi n arlyse o.sotomnsi hi ra.
(10) Ife sro do the uaties-remetol av enmr refu or hveairmed epcalbss
(1) Were the conclrustion and from i curtlyadc clarid u? bgoss a ofr
Again, the inswercis nfro. s HES dosdtedcinadnlss progra ofhaltohvet research h nlssadrprigo h
(12)S doesthenwHMpor
provea mecito pernovd herometrmpranappvtQ tocomplemechntguue ofeompuetr monituor otacos
The CHAM syseatendmoistlerlyg data sals nmiumy:A polluttions easureent, olughaits ir sscaewihmm is fn ig clearly efned weloaretd program tfsoo ake u iatv ofe-epos CHAMPte at thiCE epdtaemioog mi asisHAP?
Fr(13) h aditionalstei any, s4 clou nd ec mbil oast om on basis will beur available
Forin the answer tois qu CESio n iit refee o arg r

iThe sCtion ste s an ocerd with oeetin4rmt plionmaueenatog i sitye!ul aidtd hi
]isnclaldeiewltagtdcoriae pdmeo I
.................. to m ak u seii of C H A M at th i tim e.i T h er axeiiii ii iiiin o iii iiiiiiiiiiiiiiiiiii iiiii iiiiiiiiiiiiiiiiiiiiiiiiiiiii
ieiolg maigus fCAM aa
(13)==~iiiiiiiii W hat add===ii i ti onal st ps if............. any, shouldH E P take........... to=== insure........................... tha a.........

........................... tehh a bai i vi befrf tr ,a nq dciio sprinigtoO1Wfts
in h eton n cnendwthpormimrvmns


The investigative team is awaxe that this is a very critical report. The Environmental Protection Agency is a relatively new agency which has been confronted with the need to grow rapidly and to assume a laxge burden of responsibility. The enforcement of these responsibilities has increased in political significance with the growth in *intensity of the overall energy problem. All EPA personnel consulted in this study were generally cooperative and hopeful of being able to provide constructive suggestions. Indeed, the recommendations presented here are, in many instances, suggestions and comments made by EPA personnel. It was not difficult to identify many deficiencies within the CHESS program or to relate these difficulties to the need for changes in organization and management within EPA. The difficult task will be to resolve these issues and construct a more effective organization to meet the very real problems of our society which have been mandated to the Environmental Protection Agency for resolution.


G ope.out in the introduction, the ttlmnsof precise, rolla e rer, cible, and real time air quality measurements in the field
SOarticulates) was a cri"i element of the CBESS proVon,.Thi X ter provide a iariis review of the aerometria
mesummntaspects of CHESS.
41owverbefore reporting on this review two faots about CHESS acrmetysholdbe mentioned. First, the methods used in CHES8,
yin 1970 71, were probal as good as any available. Second, qgaiyentrol procedures werepslw introduced into: the CBESS ik.EPA cannot be criticiaed, is not criticised in thief "sport, uthe best avaable met oda However, EPA can be criticized
aotpusmng a vigorous progravp of qaiycontrol hohut
8The review. reported lhee' showed.'ta CHESS d2not
*Ploy established quality control measures. The quality control
described in Appendir Anof the Monograph was not carried
gut4,ahrough quality control program weald have discovered, for
oe the temperature effects on the method used to measure SO2
below). It would aso have placed bounds on the validity
a dtaandpracluded overinterpretations.
te design and implementation of any measurement system the rost important consideration is the end user of the data pro4ped~y ths4 meaurement -s~ters. In the .simplest of i4*vj~da nvlved has at his disposal all of the information detained
especially that conerned with the. limitations of the~dats:
a~d~*- opatraints under which they should be used. In this type Q4 itutiq, ew formal qualifications of the recorded data,- are, neces-snqahose!,qualificatrona are implicit in- the mind of the scientist.
lax programs howewer,- the measurement process and the
process are quite often a mpattmentalised such that one
WP eo sesetists is responsible for the ocolleation,- q a eement s~u sormeof. the measurement data. and o second, ualynear elated, VWientists is responsible for tbe syatheisis -of ap.rtent
tiinto a final set, ofa conclusons.: In: this typ of systemic
determination of the ftamental quality of the measure
out aanand transmittance of that quAty assessment are the single most important quAlifer in the proem of going: from observation to
Gk CHESS program, as designed and implemented by the Eurizonmenta Protecti*on Agny sacacexmpl of4 Ith mlrg systems appraht eerh The eidemiological measurements
were designed, conducted, and stored by one, group of scientists,; the

ii~~iiiiiiiiiii iii! iii iiii 2 6
aerometrici measurments ere dsigned conduted ad stord by .............. groupiii ofl scieist. h d sre ndp od ct crelton o
helt efetithamshrcioltoiasteieiedfo hs

toindpndn ...... ofdt cuuae na agaasoaent

program iii @ii isi iniiiin uothmarentpsneo....nmi to th aaueralo h infraincnandi h eutn aa

standi~iiiii the,,, problem enonee in a agerserh rgrmsuha CHESSiiiiii i tiiiil i s neesrt n esadt6tpso esrne-L fa wereimade
T heiiiiiii~iiiiii~!!iiiii assessm entiiiii iiiiieic-p lu iiex o u e ci vediiiiiiiiiiii


mloe theiica complex of 80s. If enrefully carried out, the procedua
= Aftin ecorate value for the SO2 concentration. The procedure ib
in, detail later in this Offspter.
'11,1 sutitetssuch as the: eVst-Gacke procedure, which are
md quntitative' can be used to compare: atmospheric nt rdens across diverse geographic areas and though long
ab* pri~ ., They can also be used to assess short-term variationsin dfiatat:eis provided that sufieienit sensitivity exists in the th~khodto sbam maningftil signal for the short tune period used.
taking program such as CHBESS, where an attempt is made
W rekte ealhefects to pollution burdens, only those measurements thlt,111'iithe. second class, specific and quantitative, can properly Wlise&Oassess the relation between health effects and pollutant
rA e th shpter, an attempt will be made to evaluate: the method01d& used to measure serometric parameters and to assess the val~ity of the resultant data. The review wi1 encompass procedures
ujid i-ta field situation, the quality control exercised over the proce'siad tho data storage and retrieval network. Conclusions will '&awh 6 1ite adequacy of -the measured pollution levels to assess
eli~g~sreceived by specific CBES8 population groups.
a1e West-Gaeke colorimetric procedure for SO2 determination is th dsignated Reference Method (Federal Register, 86, No. 84, 6168,
Aoffl StIt9 ).* Atmospheric SO, is collected by bubbling air through a nilui of potassium tetrachlorozaercurate (TOM). The product of -reona between SO2 and TOM is the nonvolatile dichlorosvo tearcetl that is then determined quantitatively by resetion a th inrmadehyde and pararosanitine hydrochloride, followed by
dau~his.measurement of the resulting intensely colored parar at kathyl sulfonic acid.
b. Do ptfy of the Field Apparatus and Sample Colleetion
Outaida. air is drawn through a sample line at the rate of 200 mnl
W7then through &. 6-inch lon glass bubbler stem (tip dliamnetor of ) 0602 in.) immersed in 35 ml(50 ml after January, 1974) of 0. 1 M TOM solution contained in 32 mm diameter by 164 mm long
polprpyene sample container. The exaust air passed through a
wolmaist trap, then though a hypodermic needle used as a
drfce to control the flow, through another moisture trap, and tis t hrough a vacuum pump. A simple consisted of a 24-hear dblection. Collected samples were stoppered, and mailed to EPA/ ETPW for analysis.
c.-V alidity as a Laboratory Procedure 'A collaborative study by McKee et al. (H1. C. McKee, R. E. Chiders, and O. Saenz, Southwest Research Institute, SWRI Project 21-2811, EPA contract CPA 70-40) indicates that "the method can*Alternately see CPR Title 40, Part 50. Appendix A.

prooie aviue f 8 masa pacio
'n lesstadifrne mle than thi noren is patofbs~ trumbyte entatinals for th' ag f0t 00A 43 A~ mf2 renton, lwencmae eetdaoe30gi-,adadf~n sidermgs than the epen a edtcted aoeI IO"I tanlte ambict ay irfrn u ltytre o hsm j~?4 %& betreard asvaldtc aiftermnc toflsthn2pect ;; tins, rpand osweans he analialoaoisi helrm~f0 ri0 gorously A by exerened oalysta. 37a ifeec o es

Ttalt Suspndd prt ils: (TSP w4hu vrg,35 ~/.Fta

Beferenceii iii Meldasseiie nt Totrale s0 g.Tuspne priulthe stadr Tsmt41s ausb trough ar pewig 8 10 nor ha nailb bveM :,O Voueample.n the edi of dtin the 24br~ctd heoairoflowe rat as aox gIm3ael 60 fratilfiue"Asnl notn less than 4fthin- vat isth en fr tly ifrn rmable. Thearge iBfowratley wabomptoisMac192, l in nterorio etwden thatginningl analssi fltte <;cA Thde Natoa Priar Ambitdonentrain ofS(wl sayb

rior2 our avexeren60c/ annts
TlSuspe~ded ulf cuate s wasP anlzedrin esrduin hrN pofrinse ofthd Ts saplfe. Fro tFeraRgitr(6(8) Septmbr1971 thei 3, th turbidiei metoduwas drop e esrdb jwn blues med whichrats used frthprohouewstetn" Thlue tulrbiteen fte 4hu imeti method, conist of ty sulfate on the TSP ilterted dton th,< i f oa i a-M ntns toa 0fmn1a the extract, and measurement to.ofMlin Alteroati on se bFRTten bPrt ginnni R. ,Odn l wrts Th Ntinl riar mben ArQuliy tndrd -o IIs
Foriiiiiiii 24hu vrg,@0g/ .Franulgo ercma,7ig il.
Suspended suft ainlzd uin h HS.rga m

po tin ...f the TSP samples. From the beginning Wiiiiiiiii~iii~i ......................
Setme 91tetriierimehdo nlsswsue; h.

theiiiiiiiiiiiiii t idiier metho wasiiii~iiiii dro pe iniiiiiithiiit yfhy w

tftft"Ani of insotablebarium sulfate) with a-specto hotomete r .or oioiftler Aeourac of the method, is affee8 by the a4ci arid 68fi 4 eftftonat other -ions present, a well as pH, conductance, tersperaw
66W 4adam concentration in the test solution.
N e metglthymol blue method also utilizes the water extraction' of s~uhl~a~fteefrom the TSP. The filter extract is then passed through h s iouacange bed to remove interfering ions, and barium etloride ig *ed uder slightly aid conditions, forming barium sulfate. Thetn ihe4m4 m tore io made alkaline and methythymol blue is added, Whi frmsas chelate with the excess barium. The uncomplixed mk~ythymI blue is equivalent to the amount of sulfate present "and ioriiaiedspectrophotometrically. The methylthymol blue proce are *i~domned (Technicon Autoanalyzer) in all steps following water
Wacto of the TSP, and this part of the procedure is reprduil
1. *", arange of 2 preent. Error in the determination of sulfate occurs
atln the steps preceding the methylthymol blue method.
diWtin to TSP measurement using -the Hi-Vol sampler, four:
athromana of esimatmg particulate concentrations were used at V*XXtheek. Abty .are the Rustfall bucket, the tape sampler, the
e~~icae~i~ctor, and the eyclone sampler.
(a he name "dustfall bucket" is adequately descriptive. It is
6"cllyan open-topped cylinder, with some protection against wind &,a riAleoe, that is left Out in the opens, close to the ground or on a oofopfor a month. At the end of the 45kne the dry matter collected is wpirhdand sometimes analyzed for trace metals. The dustf all-bucket Wethoa iivery entde and misses almost completely the very significant partof te aerosol, including the respirable aerosol, that does not settle r~pdly.Itmusthe considered here, however, because dustrall measurex~ets ere, extrapolated to obtaim estimates of suspended sulfates
%adsulurdioxide in New York City during the. period 199
itS 5,2 CHESS Monograph), and intermittently in Chicago
.11.3, OE8' Monograph) Dustfall measurements were
ai,.s the bais for these extrapolations because there was no other baiwfr such estimates, but it must be remembered that the relationa between- suspended sulfates and dustfall is unknown, and that
betas ediatur dioide and dustfall is another step removed from
(C oeaftalent of Haze (008) is determined by the Automatically
operating tape sampler. It is determined by measuring the optical (Ma 1 tut n aerosol deposited on a filter tape. The aerosol deposit
iM Maltaked by drawing air at a given flew rate through white Ailter Cpaprtp o a known period of time.: If one could assume that the
composition and physical characteristics of the aerosol in a given l4.oation did not change with time-that only atmospheric loadings would change--then the COH would give a fairly good approximation
of the vrariations of particulate loadn n visibility.
1However, thsasumption is seldom justified, and even at a given
lation the COH only roughly, approxiates. the true particulate
16ad* B.The FT/11 Io ___ _i __Atles _orn l soT o oprsn

collected at the Utah skito" are. mpruarily, Ab -k-slo allicate dust, whereas aeros pollecteda the. large cities has a predommantl1y, noty chpacte;or ticulate loading the Utah aerosol, will pftenasl ....itt the optical density of the urban aerosol,.
(c) The cascade impactor operates on the cipp*, tJg in an air stream will tend to folow a straightln when ft is deflected, and thus can be impacted on a (acem inA The cascade impactor consists of a -series of p"el plakpt by precisely determined spaces. Alternate platcontaiwra number of holes of a size that is decre~s~ase --n oes ( series of plates from -entrance to exit. Alta-~g Wg with th containing the calibrated holes are. plates, without holes be coated with a medium for the trapping of impgedl is drawn through the apparatus at a know rat, ad the collected in decreaing size fractons related to the dcuh the holes i the plates.
(d) The cyclone sampler is a device for the "sp ties, of-ttipp rable size fraction of an atmospheric particae loading. It0 on the principle that the inertia of individual articles will tea' keep the particles moving in a straight line wo the. air srg which they are carried is, deflected. Ry. this nste'. I e particles are removed by impaction and settlirg while the. particles are carried along with the air stream. ad are sub8 seq collected on a filter. '
C. Fri-Dies'AxoEvAxnome or Mams--OM mer ma

It is important to preface this evaintion of the CHE ak toring program with a statement of the fo~oe g facts..The4 tigative team looked backward at the progra- ChroughA, wildW time with all of the subsequent knowledge bul up during th* IAt More than ten years have passed since the 101al panine: 0(at k CHESS program and more than six yer a pse iqq h
data were collected. During that.,time -there a een a vast; ment in the understanding of the methods, ued for.p::l toring. Many of the procedures used in (B t have Is' been found to contain serious errors& Thiem--olm:wr lt
uncovered as a direct result of research and quliy com#rd pr0pgroINP
ongingwithin EPA. It would thus be unjusife to la criici T the principals in the CHESS prograin foT r., s"9at1me urement technology. 410
On the other hand, some serious oversights ien fij
did occur. In the area of pollutant monitoring,. thse oPversight have been completely -avoided had. proper attenton been paid to oR
rudmenaryquality control procedures. Throuhout: the 101put much more emphsis was placed on the un- -cupted ctetise data than was placed on the systematic evaluaton of Aske qu "w The field investigation stage Of thi view id Te nearme .
lems that resulted in thepa gaio of une iy I"gdere4
the: aerometric data. These unvlutdro rsist eyest-todasa
the: ata as it isr stedi...A: the ICT1000 ------W My--..fLB A
haebenaodeiiiisl.dicvrdi=iiaffe AWi,::wW


44sgfi~dquaiy control procedure been, applied to obee OBESS aeroO~fio P%6it~nngprogram. This stee tat is contrary to the state6ft,,abte qual : control procedures in appendix: of the 1974 C14SSMonogra Appni A was not a manual provided to
OHESdta gaters, bt was written long after the dats in the
1974Wtioraphwere collected. However, ring :the field investit'O Of te CESS, monitoring contractors; it was found that the
qukityen tr61 procedures as described in Appendix A of the ORES korf~raphweret routinely disregarded. In fact, for the Airst two years Of hoptgrag virtually no, EPA-diretted quality, control program
impiente at any of the New York, 8tilt Lake Oity or Los
A.0 es, HSS monitoring sites. Problems that were 'found in this tieperiod were observed ad -documented -by' contractor: personnel inditwas mainly through their person.professionpi condut that anyofthe field problems were corrected. Reasons for thi rather
ove rsight on proper data management can o ly 1e conjecture,
itdd appear that inadeque4p staffing Of the monitoring ro
P,1 edwith the intense pressure to get th patorin~g stations on
L Udproducing data, led 40 the: situ atili hO~ribed.
aess (regarding th time pesetive intiestd earlier) the
ltof inadequate qttality control on jhany large EPA programs
Ov~ntulywas recognized Internally and in 1974 a Quality Control Oram~hwas established in thes Quality Asurance and E environmental *onLabratory Ti( branch yd give n Ithe authesityl tuniWmef proper quality control proc84ures on all large atmospheric
nitrgrms Sinc e die formation of this goup there hoL
Tf 6 sinpiant and steady 'ifiprovement in' qunhty assurance as
_Aj~ eto air monitoring methods and data.
t8 Matcion, major emphasis will be placed on review. and evaluof 'the 'analytical methodology use4 in the CHESS'programn to
t es ppulation exposures to suflur hiludes and total suspended Dartcustes. Conclusions will be general to aill adsi takeit, at "o cial"l 'ESSmonitoring sites, regardlss of location. Where'loealdifer' ps.'inprcedures or resultant dlata did'oediu r, these wil be described ewitfy.Health studies, as desebried irfll1 974 CHESS 1Mono,rph tat used serometric data derived froin non-CHESS monitorsites. will be. reviewed apparately,
,"tfospiteric levels of SO2 were deters bred inigthe EPA Refer rince' Method, better known as the, West-Gacke or Pararosanaline method. The specific details of this method are described in the
(JIures. section 'of this chapter (Part BAl.). However, a few im.0tant aspects, of this method will be reiterated-. This reference %thod- is basically a laboratory method adap'tqdfor field use,. It is iCo "wet chemical" procedure( relying on a gas-liquid, phase chemical reaction between SO2 and sodium tetrachloremercurate (TOM). To
ecomlishthis reaction, the SO, as a gas phaselpollutant, niust, be qantitatively 'absorbed into the liquid readtant sblutidn.::This is tomnilished -by bubbling athabient air, throughW the solution at at

In an., attemPt -to a the..=ethodolooy and'.
problems assooiated-with* inteirlaboratfty C AV*%'
matituted whereby,.AA air, equipment,
tested- at the central: Rjk rese laboropty, Wkdl the contract" for. fiel& use. Also,, bubble 1 tulmw the appropnstoabsorber solutim shipped to the, co*trA4QtA* daily monitoring use,: and shipped back, to,44oemtrid, I chemical anedyis. R was this long distanceahipment Outbp solutions that led to:,the first of a series of fieW4sw.,pr,-,@W procedure. These problem, weas WiR -be surdins.iiak' AIV attempt to evaluAtetheir neveffea on the resultant CM Followilig this summary of individual prablerviavwm ,_*o .of the overall 802 data quality will. 1* &em. ivv A 41"
The fiist field. 4ita, -were o tainad in NeWYork Citj Lake-are's (Utahj in Nov embor, 1010. By n*'d-j07'1', fil, at the Utah site reported to eir -0 Qi UESS field ep &ee
spi l ge was 6pcurfif4 diiring shiOaent. Many b4Wor amvmg axtiall falea W'ith're. i and P me wore e MD10
agen, so pow
At the Xyt tl area 8'n attempt was, made to reAll 'Wi
.. I.: 1 11 *it '
from extra tubes. those tubes that were, %owe*er, uo
.Inj 6m 'This'
cient reagent thims was ..Q' S megs
not officials d drae
y. recog=e un c _er7 1972 at which
ou. I
corrective action'. Wp magniituke 4 t r' caii bq teA,
by quoting1r6is the mej p. "Th: e t"'' ent vu
yesonf reag U03
X02 leak dunng sbi'ment 'ISO Jeakage iw 4
be) 18% of the tot fvohime, ihe-iim It
fore, that thexesu'14t t, pollupi6on q4t4.; arf jt nrlq it tions were inade in this'm 'possible 66kkoifve M'*
(910:01'as to
recommendations ii*t4t4"u-nti1 M AN 197
gth juent Years, many'Wemp wero14eld
hi pro, lem." U, O*Over noiie were w -oily suO -00,
late as jaji6ary 1975, 944h6r memo, desalibO
in S02 bubblers Auiv Wp4ent, d ugg"t g irg, Ovproo
The effects of the reagent spfll 46 ala 4
be only grossly estimated., Qqrta.inly,"M -samples were t Otany 'loot. These lost samples were n.ot the" majdr problem.. Of mom was the. undetermi.Dedamwunt,,.Qf,44y t1we",
due to the lo g of samo spfflnq n y*inq o4d Anin
Lot 'd
If.,therea w U t
gent, *s putially,
I Mag
site and, used as ropel*4.' 'j complex. would:, 06 4. -'r' t 0, norm SaMA lin This, P A,
Dositiv 4 me c A
'e Diss wo ld; C j';1WT
Pag A,6 CEIE$S, .. I
_k t 4' al'
tory,, the s I &6u t bac 4 44.jorwm volum,
of distilled gh ens
water'+to co= ate Or -woter, Was 4w
If however W"--nt $pMw .qPr=ec1 after
addition wstekxpuld. reswt,, kn, Wor a ia'4 Mt
portion t o the amount spille'd relAtive to the total voTlume...

A,&brd*g to the EPA, Mimo of: Oaidlmr 1472ft one hW'.*f &U SOj
66tween.,November,,19M and Maw* 1q7&:M&*)hkOlr to =Iwm Nased low by- an AVeM#O:o( 17%. T1 w',problem was: corsoft MC 14tw:.
Aprii 1073.
Roagfnv- ,
aerence Metb6d 16 QY S.: M the F dekal
0 1 as a known eit&
waA. to be cojidu OA
ed.associated tli= del& y* 1 between sqwpling smd
,9 a &pendent on tepaperatures. Tf4s. wgr was'derived from
Wniineous d6c6maposidej; q comp ex
WAP o the TOWs%,
po function of t6mpeiftiture. magnAtude of the 'errbr and ita
A de endence on temperature was not knovvn Ut wbrief stud "I= Oted to determine.: ite tists of t1w CHES
*W$*4)1M9. group In November,1971L. a: rMes. of thislatudy, a
factor Of + 1.5% per. de6jr was *0'811Y applied to oR
i &ta to compensate fek the time delay betwe sampling
uw6reqent, and coanprehensi*e study has been: darriedoutvithin 4L '16nt uviro M lAboratory
4hw M"tvy C ro1BrAnch,1.E onitoking
ZRI on the effect of tempenture: ow "The Stability of-SOz Sampleis,.the:Federal. RefeitmeMeitho&" -M&istudy ', 'cated,&
14lb-mftweevereproblem then -wag esti by the C ML5$
#xK1Mf,,Th& o0aluation vs carried out, ov4kn the: jmug5odoi 35 to 278 Thfr Wowing fiAdis&: were Present6d:in
*be ,mpdrtt
- f I 't o Over anornma, range,. of Umpdr&ture'. the..: rate,'Of decay of the I ,;4,)TMOrSiOt pomplek inm"M five-fold I for: evipry,: IOPC crease flof Aw-temperaturei res timely, i) .',Tba.rate of de my-Is itide d t of: S02 concentration. j 1;-, 4 !Ak2Ot 30,40p wid 509-1C r0 CO;;;.S()*.losMS were, Observed. jw: Ak%:59:25P. and 74% low per day, respectively,
*oMfiwatudy makes abundantly &ear a second-' and. even moresevere fwrbo!a&ed&ted, with Ow S% emurements conducted by CHESS. baking ithd super montlig, ; vrhen the S" absorber solutions were iiAwe i Ao: high and: unimown tempemteres between field sa-M-Eing
*a+, hibiwatory analy m*i ficaint: degradation-of the Sam occur. Eatimatow of time: d -'ay between sampling and- a range
TAo 44. ds' Estitnlt w ot summ"UM emture expo sures. ran
.40? 0 bmW most sevem for, husffe
0, IheUtg CBMS 94 sites
CHESS S1% data can be estimaUd to be: negatively: biasi ,. mainly during the summer mouths. It would norm A-V-Lediffiiault orunpo *
ips tq the magnitude of the bW except, to my. that: it' is Pro
Ao sifnuitat eous qc -inieasuremiihtsvere ti&en Wy the
Nork Oty of Air Resources and. by th6 Utah 8tAW
rekA were bwl ed, 6y. an 64ependent 4jaA bf Realth. These ts
not suseeptable4o the' telnperatui M t6d emo A c6n-sistent
ti tml eiJaemed W C b id WA 46 b6wpared. V xn May to
h ji side: si
the CHESS S02datavoe foir with the larimst emr occurring
middle three surnm idonths.,.M of the error varied
month... to M.6nth and year to Year, but the C data
gently 16*Ajad represented bnl 'a portip 'of tho U-6q ak6bient Sc

The S02 -refeence -method was, subjected to olbreie.swy program in 1973. Four palrticipatmng laboratoriestse h abo version of the Federal Reference Method. A preiusyunnwndu of error was documented that applies to the-CIDSS2daa tM found that the 24-hur sampling method does haeacnIe4 o
dependent ihs whjh becomes sgnificant at th ig cn(tr4 tion levrels (200,g/). Observed 'Values tend tobelwrtate expected (kn ownS0concentration levels. This ero luei i
a negative bias on the daily CHESS SO2 data whe hyece 0 jag/m' and on a11 knonthly and yearly average data d. Jewfloevcorrection
The determination of atm 6gheric SO conicentrainwsseedn on, among other faotors, the accurate measuremnt fartapsc through the TOM solutions. This flowr was cointrolldba rtcLfW orifice mn the form of a standard hypodermic nel.I rt6,A air flow through the sampling system was measued ttesatin end of each 24-hour sampling periodd* This was An odtc o flow due t6 needle blockage. The Federhli~egistethed(eoui Method) calls for an air flow of 200 20.ant/min. In il prto A CHESS procedure subitakatialljo'broadoeied thesetoeacs phm inent needles were installed if the initial air flow a raeln 220 ml/min which is consistent; with the Referene Mto;hvvr needles were not replaeditior were sarpides vaided ni hmaue flow dropped below 100 ml..min. Integrated flows wr aclWb assunung a linelir decrease indlow between the str n-edonh 24-hour sampling period. If, however, theaneedl waprill lce near either the begmmnng or the end of thesamln eid h
linear flow, correction would be in errar Using theRfrneMto flow tolerance, only simillerrors would be hadtkduedbthscreio (less than 10%). Using the CHESS procedur-e, hwvr rosa
large as 50% coud be introduced ad not detetdlheeat would be random (either positiveaor negative) depednlnshmur ing the sampling period the ndedle blockage occure.Tu l~ random error component was added to the:B S0 al The modification. of flow tolerance by. the CESarmti group is a procedure that would not have withstoodteciicl The West-Gaeke method, as described in the eea ei i
employs a vacuum bubbler train. That is, the samldari rt through the bubbler train, by a vacuum pump rtekta'bu pushed through by a positive pressure pump.-hr '] an'd
vantages to the vacuum procedure, most importni'thttear does not come in contact with any internal pump mehns.Hwvr there is a modest pressure differential between the amshr n h, internal bubbler; thus all fittings and joints mustbgatih.T6 bubbler train used in the CHESS program had twoponsweefqki air leak problems were' encountered. One wasarudteubo stoppers for the bubbler tube and moisture trap nd thotew te

Mftb* tubing used to hold the glass ssembly pieces together. Field
*a...*,pote . 4stn p,,71,. wit *leaag i. th *ou1in* fie11 1..fh bubbhlhir tr.** In severe leak situation, the samples were vbided,,due to, out, of tolerance, (Low) flow -rates. There were many maes Ambwrever, where small leaked occurred but the final, flow was soths.. if.aina so the sample was included as valid. In cases dbae the', leaks, f.amed around the rubber stoppers, no significt6at mren ashnd- be introduced except due to the linear flow correction as
adhiets- instantaneonely developing, leaks. This error is similar in naue to that discussed in the -flow section. In .the case of leaks upaaf'tie bubbler train, room air instead of antside air is drawn
throgh raget. In normal situations, it has been observed that room
Ai~i icatly less polluted -than outside air. (See page 6-6,
unmnph--omparison of cok air to outside air).. This
nfeiay note as large for the small buildings used to house OKESS
staiosbut a somewhat decreased pollutant level would undoubtedly U~ap led. The absolute magntude of this error cannot be adequately sadessdd but it can: be state that- the error would be in a negative
4iretin;hat is, again to underestimate SO, levels.
data, accumulated at "official" CHESS sites, followed a
rer.Artay; :aiform trend as the program progressed. The method w~a v*te EPA, Reference Method which is specific for the chemical
4 ~SO2. Thus, regional changes in pollutant mix, i.e., the proportion 6f other pollutant species relative to SO2, had minimal effect on the SQ, Aa.- However, the sum affeot of the errors detailed in this seekindid1have-a profound aeffet on both the accuracy and the precipiew4 othe. data. 1
i-Xlades normal circumstances, a retrospective evaluation of a supp brmng, effort that occurred a number of years in the past, and which had been tarimiated, could yield only the broadest of estimate of cdst gwality. Fortunately for this review, two geographical different locations with six different monitors sites were involved in,.the p1lies~tion of simultaneous SO. data. Further, the groups reWa be for the two data sets were managed independently and the wthod oegyused was also independent. This fortunate circumstance ashld: ah reviewers to acquire a4 quantitative understanding of alibte diffeences among data sets as well as correlations with respect to time.
The. locations where side by side -data existed were the New York City sites at Bronx and Queens and the Salt Lake Basin sites at Ogden, ,Salt. Lake. City, Kearns, and Magna. Ju these locations, the local environmental monitoring agencies had sites located within 50 meters of the CHESS sites and at similar elevations. At these sites, the local
ncie collected daily SO, and TSP data for the entire life of the program. The SO, methodologies used by both State agencies were variations of the peroxide bubbler method in which twenty-four 1-hour samples were. integrated to form a single 244hour SO, measurement. In New York the samples were measured acidimetricly and in Salt Lake City they were quantified conductiomietrically. Neither method is as specific for SC2 a,3 is the, Reference Method, that is.

pollutants that T-in a sigaificant con centratione, rltveld and that also esidiseto rm an e6 ic compound Wbri inepep as 802. For EPA memo dated November 3, 19t1 described a limited studyintedibe Reference Method. The conclusion reached was "On kth Assin this study) . f eel therb isno sound basis for discard <@ EES (Environmental Exposure System) methodology.t! i:r~ *:6 to
No further attemptwas made'to uncover the catisefof, thb A** ancy in 8S data. Had the CIIESSIBEStea -obtained iandre the Salt Lake Basin~data, especially thiat fro Magna site, a;t s similarity would have been immediately apparen. Thisdat in detail the discrepanates obsek-ked-in New York. It is, important, (A the.Magna site data w ere cotifirniatory since "it was in alre"A*4ta single source pollution that. from the ne arby 'copper smgftkindi site very low levels of -other pollutants existed talaive to,,Swhe the peroxide method was capable of giving rsoably' relidds dutle mates of the SO2 concentration. Of equal impo .rtance th general polhitant mix was ver different between this rural smelter site, and the urban area of New York City. Despite these differences the l son of side by side Fede 8atedaa indicaite the satheh d' in both trends and absoli concentrations.'The folovn bdt
as to SO2data vdty ca ths e rsonably drwIrom the fekiet
of methodologital errors ad the ddiparishn .,of exiting sidfe 4sid data.e .From Novemnber 1970 tintil I eeniber 1971 theSOdteo ad
from CHESS. sites using the modified: Refef-nce meUthod were bideq& low by 50 to 100 percent in the Tigh Exposure sites when obttigit with existing State 802 data. Thus the 1971 an-nd live '80
exposure estimates of 60yg/m3 asreported for Mapa in, the monograph (page 2-24) are mefU6 ely in the vcicaty of tf Also, the same phenomenon occurred in New York Aad Ih values are also in similar eiror. Tit
A confirming taet is that during col months afte 1971 B a correlated well -both in trenddithd absolute contentrtionsi State and Federal analyses. It thus eems liey htthe km were reasonably accurate thrdughout that time peid Hoee;ei consideration must be applied here: -namely; that d&e to Ahd deferefdl between the independent methods, an error bar-'of at least one;9 percent must be applied to the data'and explicitly corfect daftikwo drawn'from these observations. Ini other words, where .two to@1 independent observations are in disagreement by a signifidaftit ob it cannot be said by inference alone that. ond'daft set is 14'ote~bord04t th64 the -other. It is reasonable to assure, howvr rty-a'hre of .all S tate: and Federal datit in the time periodd 001970) thliugh ITO! that the Federal, 80.. data as collected in the-C CHICSS9 peogtai-wp substantially low and went-through an brupt pward trassitio-hWI concentration in December 1971 at fill CHESS sites Ond P1'derat Ad ia

November 1971, the CHESS monthly mean SOg data underwent at-vAoruat chanape hi the positive direction. The cause of this change is imt apparent. Iffowever, the result was profound. From that time until the conclusion of the CHESS program in July of 1975, the fall-winter "mere in: very good aggreement with other existing data and very
Ir ga : r ia tim
vt el' ble es ates of S02 exposures.
N:WZghout the entire program, the CHESS S02 data had 'an ated negative bias during the summer months, b most
assom coming
sevem..,during the hottest periods of July and August. This error
reached a maximum of to 80 percent underestimation of
exposures and was variable. As a result, even though wintertime monthly S02averages appear valid from 1972-1975, annual a-yerages of.-Mm Bame data are biased low due to the inclusion of the summer amrs. The best estimate of error in the annual average dat&-19721975 is approximately minus 15-20 percent relative.
The individual dalIVS02 levels, when compared to city or State 4ta or:lto replicate CHESS measurements taken after 1973 had so Uize a, iand.oin error component that they are not useful to aseas digi SO exposure (as attempted in the asthma panels). The random ikr6rs, Associated with the daily values were much larger than the "erencesobserved over time.
Dud to 'inherent methodological errors, the following may be coAsidered- as ininimunidifferences between High and Low S02 exposures v&ehl'm'&Y, be considered "real.'" These are based on EPA's collab6rative study of the reference method and used a 95 percent confidence mterval.
Below 100 Ag/M' S02Y a difference of at least 50 ;sg/ml is
necessary to be statistically significant.
B.btween 100 and 300,Ug/M3 S02, a difference of at least 60 AgIms
ii neemary to be significant.
Below 25 pg/m a single determination is not significantly
different from zero.
The Reference Method for the determination of total suspended, p"culate matter (TSP) is probably the simplest and most reliuble method uged by CHESS. It has been well studied and most error sources are known. However, it is a method that measures an arbitrary and poorly defined portion of the total atmospheric particulate burden and the portion measured has unknown relevance to the human respir" portion. The size fraction measured is somewhat dependent on the &6e of the shelter used for Hi-Volume sampler. The de and di.,nQ of the Reference Method shelter are gDecified insifen
Rogwiter, thus the portion of TSP that is collected by the method 18.,Werillv uniform. Best estimates of particle size range included i& ihe. Reference Method are from 0.05 to 60 jam. diameter. Above 60 gm diameter, the particle fall velocity is too great to navigate the b&nd around the roof of the shelter., Below 0.05 pm, the collection WtWency of the glass fiber filter used in the'method diminish s.
A collaborative study was conducted on the Reference Method usdqr 12 different groups sampling ambient air at a common location. The results of this study indicate the-method is capable of reproducible

i- H ''''H~ .... ........ .......... ....

m measurement~i ifi w........................... [ i th less ..... 5_!! percent........... er o at .... 9 ......9&
~iidec lee.Astemnm mdeetbeaonofTPi pm&mately 2 jug/ for a 24-hor sampling priod. This sesidyity jff iiiiii e thaniiiiiiiiiiiiiiiiiiiiiii~i suff==i~iiiiiiiiien foiotiih uP m a u em n s 4
TheiI TSP measuremen met od asiiii used................. in............ ota l
Rdifrnefo thlaoaoypoeuewihwsclaotiey
s t u i e d T hig i n... ...............t o.................................................
EPA/RTP laboator noti iiiii theCH SScotrctrson...-hi
neesttdtesimn fidviulfle ape hog: h
m a i l a n d t h e .. ......................................................................................

elpe ewe culfedsmln n aoaoyaays ,r 1
Th olwn i u mr o niiul rosadanaesnm
ofiiiiiiiiiiiiiiiiiiii overalliiiiSP idataii uai ty.i Los of particulate matter beforeiiiwiii ngiiiiiii .......

:::::!Iniii~iii~i'''i~iiillii iiiiiiiiiii ................ ................................... m eth od ology... ............ w ere fi eld -related p roced u m -th .

gtat Ue edieste that this managementt is reasonable. These lk dicate that the 089 d ata were -by, f ar the ;beet' quality
dat tke. ii h&CHESS monitdring pro Differeaces.,measured
-*toon 'Hgh:and, Low site'- Ate prdbybly reasondble d Mhiate of Oledife~llas of TSP exposfureer as received by populations within
.Samleeoal searce& variations undoubtedly did occur, laut
*Mer~olneel 9 sposure wee reasonable.
In Y. veralt asesement -of the CHESS TBB- dats it should be .notod taRl of the sources'of errors anentioned previously related A~ost elusively to the loss of large paticulate. matte and most 11el'tatmatter is asseeiated with oMustal weathering. This material isM~deof the normal human respirable ese fraction and by comlo itWould be unlikely to be asseskthtd with aggravated heawth aos of that portion of the total material may not have, diOib~flite quality of data for health effects studies. It may in foot hav~, eered that data a. closerr elminate of the respirable TSP dodsue which the CHESS population groups were subjected.
~~ Jtha ben"uggested by some environmental scientists that when.ever io measurements are made for health related suditgsp theVtdr d shoatS~be "shaken ot"f much like a: housewife does wifen
Mkw crmbs Ifrom a used' tableeth., Me segUltant TSP et sow Ma-fii tegtserived frorn such "& procediro *on 4 tl n more closely' .reat t te hiuman resparble one fra ton:o I' the total atmospherto ..."6 1ate frA Although never-kAusall implemented, this 0=1---o i ndi6ates the Eneda level 8Of dissatisthection' with the fl'P
measurement method.
The: s deemnation of:.: smoaspheric. .mlalte amonentrs.... a.s datid ou in the CHES8 programs, was a methodological, tension of~h HiVol TSP method. Thus, all, errr associated with the, USP h~~ha'das affect the: sulfate method.: Subsamples wesatu anilba the expoed i-Vol Stters and were analyzed for total waternsolubledlf ate. A14h nd viahle for sulfate analysis, at the timne of CHESS determhid sllwater-solble sulfates as a class rather than distingu Lish-ing th~i bt hemical, species. Two different methods were avadab lador totl lfto and both were used, in CHESS.: From November 1970 itfti Sptembe 1971, the mnanna: -turbidimetficniethod Iwaaghkeye.-Fron September 1971:0 until July 1os7, the methpithymol lu (MB)'method was used. frain atds.arn: anmewhat similar mdatdescribed in detail Aove. ^n. .(f6 Warbidimetrie methed is sbj*ect to interfereaes, messy of them bigother common pollutants. In areas like the Saltr Lake Basin
*hr!the pollutants are dominated by a, single source, the procedure 1yber adequate.:However, in urban areas like Cincinnati or New YokCity, where the pollutant niix is derived from many independent s;u a~ and is -variable even within the city, the method is capable of qt~ he crudest estimates of sulfate levels. It should not be thought dasan accurate measurement of atmospheric sulfate. Especially, saldifferences between. High and Low exposure: communities, such aee reported in the Cinc=int Study. mn the CHESS Monograph (poge \ 6-,5 be. Aidetfe.a rim difer1 When---2 TIL a reas12-2 m

ence becomes statistically insignificant. Any comrelation oef health effct th sbrultate levels where the sulfate dateveAsb using the tarbidiagatric method must be carefully qulfe,. ,The MTB method is basically a better measurement methdtipl most of the aememetric ihterferences have been Mig Q+A
revised methodology. The two remaining interferents, ph barium, are not normally found in atmospheric consentirkin enough to eause inordinate problems. However, problems with the sampling aspect of the method have been docmetf, do impact on the general CHESS sulfate data quality.
First, publese associated with sulfate blank (the level91*f" on the filer pad as manufactured) were reported to be.............
variable. In the 1971-1973 time period, problems pl v.' b,1 within theoEPA NASN program were documented. The, atre blank level was equivalent to an atmospheric sulfate concent~ra of -1-2pug/ait However, the major problem was variability ofW blank among maufaetured lots of the liters. The Meak'I varied by" more than, 100 percent among. lots so 4hat I me~no O continuous blank assessment should have been 9ltoyt. rNo evidences ot routine sulfate blank, determination was fud 1 the CHIESS monitoring program until 1974. Ergy* $tatiee on, adequate blank assessment and earrectionwereapplied to h From 1971 until 1974 however, the blank contributtin to the sulfate data was net adequately assessed, and conequesly "a f4V and highbly variable bias of unknown magnitude Was ineled4'data.
Second, adsorption of atmospheric SO2 onfo the fitierglew material followed by spontaneous oxidation of the SO2 to sulfatha been well documented. A 1966 publication by R. E. Lee n
J. Wagman providedlresuts of their, investigation of the probnMha conversion was ce~arly documented with seven eets deontme on four-hourr samples. The conversion did appear to be an selv" catalytic conversion that decreased in magnitude 4 her ans satuiatiorn of, sies Thus, 24-hour samples were -mnuch, 14ss by this p releni than were those taken for shorter time in= Even so, the paper by Lee and Wagman presented data, M"-t U' routinely 0.65 to4 I /m' of the measured sulfate- was derived'fo 802 canversionou c ts. The maximum nression prese a
2.14g/a derve from 8SO; this constituted a 10 percent postd" bias of th suolfate data., A more realistic average biae is likelyikW
5 penaent ne. However, tee is clas evidence tat in re ....In high levels of 8SO, relative to sulfate, the positive mesasementbis becomes amuch more severe. This is probably the- case in the M Lake Basin area.
The third and most devastating problem associated with. h CHESS sulfate data occurred when the laboratory analysis of sulfa was contracted to an outside firm. During this time period (Octoei 1972--June 1974) the reported sulfate data underWent a sudden nd sustained decrease in apparent atmospheric sulfate level. Upo investigation it was determined that the laboratory analysis ofan sulfate data from all CHESS sites were biased low by approxima 50 percent. The reason for this. -negative bias was and still. is nt
completelyii clar bu h otne ieinion fpordtv
clal u oiaeut ult:cnrl. n nei P eo


11 Tetrospective quality assurance evaluation of CHESS Sulf ate .41ta st*tes;
A queNty control protocol was designed for CHESS chemical analysis but has Act been implemented as per the contract:. The quality control protocol
F4 be implemented immediately.
Jua series of follo studies the magnitude of the affected data
ankof. the error were doegumented and an attempt was made to correct ud-therefore recover the data. This type of procedure is difficult at hflet. o4d. impossible in most cases. The validity of this data correction: vra# 4gain assessed by the EPA Quality Assurance Branch. Their
The basic question is-How does one make b data good? Whatever is tA@d will be attacked for a multitude of (justifiable) reasons. Using the existing 41i set for relative pollution level assessment will be acceptable, but statements obnoeming absolute levels will not be, It would not be wise to submit these data to the NADBl but rather answer all requests for these data internally.
Their statement gives a reasonable assessmeiat of the CHESS walfate data between 1972 and 1974. The assessment of other year QJW&S8 sulfate data is more difficult. No comparative sulfate data eW#ts.4 pm the local agencies as it did for S02 and TSP. Based on
-trinsic capabilities of the methods, and the error assessment of QWfielduse procedures, it can generally be stated that: .46 From 1970 to September 1971 the sulfate data were obtained 11amff the:turbidimetrie method. It should be used only as a sulfate lWiAdicator. Due:to interference, there will be severe problems if a^*#mpt is made to correlate sulf ate levels in one part of the country whh: sulfate levels in another.
Yrozn October 1971 until October 1972, the data are subject to Qwfollowing considerations:
a. The data are likely biased in the positive direction from
1-2. pg/ml. This bias may be more severe in axess of high S02
c acentration relative to sulfate.
b. The random error component of the measurement is probably
in: the order of 25% at an atmospheric concentration of
10 #g/ml.
i .JYom. October 1972 until June 1974, all CHESS sulfate data were Waxed negatively by approximately 50% on an annual average basis 4 je to improper laboratory analysis by the contractor. These data shmid be used only on an adjusted annual average basis to establish lipod: tmmds wigiin site locations. The unknown cause of the bias prohibits use of the data mi shorter time structure (i.e., day, week, ]Uftth) incremen ts.
4. From July 1974 until July 197 5, CHESS: sulfate data underwent 9,. uwked improvement and was somewhat better than that collected iA the 1971-1972 era. The positive bias of the data is probably similar to that of the earlier period but the random error component was improved due to unproved sulfate blanks on the TSP filters.
.Jj rly in the execution of the CIIESS program in 1969, a number of st .,memmbers in the air quality measurements organization of EPA
AeromeWc DoLta Bank.


decided it: big bi 6Atlfe,
and accuracy of short-term air :: quality data *mooft EPA coined the: twm CIIAMP: (=Uty R*W"* Program) for this concept of a se6bvid air monitoring stations. Seven protot
California ftola:jin ... A..
uaM 972 tby
ceiUmg placed on EPA resulted.: in a &646a -w 1 V j swit olmient,;installatioA, and opemtion- 6f- the OEUW tract for the development of, thti'CHAMP February, 1973. Th6dairgopmont4l n46Wtorij19 vstvft**W tw the newest technology in monitoring instniimentation; measurement of &U.ciltical. Aw-and fiq0i MAO*,
incorporated to enhance the acemmey of the aya, TU n_-"4L
continued. to mid 1974 when the first Aktion qobftba, W"Um inthe.1.Aos-Aj*ejAs

The CHAMP air quA
able discrete pollutant ineasiiremefit deviem. logical imtruments intw: a complete 1gy-Ati*W -jA 1 portable building. EPA ifiO& tho Pautfints;V6L66, selected the, instrmentwivith &e tW Ofluo"
I Ot
All data are recorded viftii
systemThe dataare chftked: An& site for transmUUI to the EPA/RTPK1AboftU" at Camlina. 9% and N02, and TSP measureftwats am, odicafly -using older CUFAW-Aype instruments described previously for backup Aind, *44idAW ir CHAMY instrunva". These: Wbblee::-And the contractor's themicaL laboratorylm r4 34
All the CHAMP systems meamm "kOmej tow, NO/NO2, TSPJR8P eombixi l paMuft,
velocity, and humidity, Beketed xyatam4js o Ooi
drocarbon sampling. The CHAMP systein while automatic requires peri,( dic ciii aiid 1 AW liy an-1: a high: duty factor and., an acceptable 4uality- of 1yeaw-ertor band). The operator ndadjusUint4aimoftwW
checim for failures,, and 'does periodic: ei"rwtionsr-,Aad' tiong- A quality. asmirfined ft
CHAMP sites c qtAgtyj& t 1rWWUWN4
It should be noted that the insbruxnentxtioni W tb&j StAtions is not bs*cq
pressure instruraeaita;, not: all: have 00 and hydrb ft-rho *td**WW
The: manner ia whiah metemlogimd da-arbmthe PRAhWAWO1WW is: being analyzed and wied his not been,%vestigateiL ',A mi ik of inte6st pleadingg an U* faWke, of, the CHAMP* sow
CHAMP stations were visited. in 10a arni&,,,=W
qvs*ud Oaks
Salt Lake Ci y;:.Magji&7: jiid KA% p Uiah.'The k&&Q nikftlrologiftl t
instruments in use appeared to be mpria A and: th w twbe
well-located and prop rly m I I lems., have pmr
OMT 004 1
nemr dew-point m&mnrink e4ti*Pment "t IS WOW haA & do, with humidity me&""iiitnL Rtft*ff i:-, =1UniWQkLV
of the sensing element of the dew-point, ap W
logical data from the CHAMP stations should be routim -:t* -,

ii T hwe are, at present 18 CHAMP stations on line at locations se ledtad b PA; six in the Los Angeles Basin, dine in Birmingham,
". 901W W W W ur in the Solt Lake Valley, and
four in Now York City, fo
one at the EPA Health Effects Research Laboratory at Ftesearch Ttitagie Park, North Caxolina.
CHESS program, all the instruments ated in the
1A "th Incorpor
CILAMA; station were developed by the manufacture for taboratoQ?
)(h fact,, some non-commercial instruments were selected Erl A-tw t9 use the Most advanced technology. The CHESSexpmence
dej onstrated the need for validation in field use and the con41 ttor Appears to be attempting to do this.
There was apparently some attempt to standardize on one instruInent manufacturer for ease of maintenance, etc. Bendix ozone and NO. instruments were employed. Flame photometric measurement
sdected for S02 EPA was iinterested Ised
as a parently M a puts
flov. remmee device but the eq
remmeed vicebutthee uipment cost was too high forth budget. The present instrument actua measures total Faseous sulphur and itiis asmimed that this is 80 The ont oth likel er y gaseous sulfur
compound U26, does not seem to be gad,,ly present.) The rest of the raeasurements appear to be well-validated. Ile backup measurement with... bubble methods have validated' N02, to the extent Possible. The SP/Iii-vol measurements were apparently validated at the
the CHAMP program. However,
bn&ning of because of the non*bration character of the flame
linear Cali photometric instrument in
the low concentration ranges of interest from 0 to 50 JAg/M3, calibration and range setting by the operator still results in 5% to 15% r ange of uncertainty in the total sulphur readin S Further, while the We7st-Gaeke bubbles used to check CHAMP962 are stored at 70* F at the sites, they are shipped to the contractor's facilities for analysis without temperature control and axe subject to the unpredictable temperature dependent decay of solutions prior to analysis. Thus, the S02validation in the CHAMP system may be in greater error than EPA expects.
The execution of the CHAMP program has yielded validation and quality control of field measurements better than CHESS. However, there are clearly numerous unresolved problems with the operation which have led to delays in validam% the data bank and which require high level attention for resolution efore reliable quantitative aerometric data can be obtained.
The data processing was 2,900 data-days behind at the time of this vestigation and no date agreed on for total backlog elimination. Drift of zero setting and data span of instruments have invalidated part of the eaxlier analyses. The data are only about 60 percent machine validated. Field operator problems bave arisen possibly due, in part, to a lack of standardized operating procedures. Successful operation of the CHAMP system requires well-trained instrument technicians, and people of this high level of skill have not been employed in the past. Because of such circum tan the S02 data
obtained through 1975 have been lost and apparently are not recoverable.


Some-months ago EPA-:found:AhS'-,s yffieftt.dowi
transinitting 'over, letwed lines -.4o,'the. qp ilabm t i source iwtbe dataAap": from-the CHAaff which an mailed teATF. 74
The CHAMP contract is up for renewa1i NovmbOr.
bids are being solicited competitively. It is believed that at competitive biddi tgcouldbs wde 0m,
could delay the achievement of reliablq routine data ;9A a year. On the other hand theremv bb riousAdttkita p6tifive bidding. When system &tblopme't is -mot6 1kar
6uld tertal-nly h6 -appropriate for oompbfitive -Ud adopted. Thecompetition shouild-in6lude tions. Unfortunately, the EPk *iality asgtiran & &Mlp" consulted on the renewal request for)propostd, th*, participate in evaluating proposeNjokeived.
11 twe
4. SUMMAM'r ai-.0Z
I ift haw
CHAMR, appears'to be
ment -,of air pollutants :'in com]paxison with CHESS, H system is, still. not 'Completely valAited *ad nxs r nat hw"**- I routine use for- 6 to, 12 months.,,Data shmAd Aw"e, stbta i"Al 0 un 1 v
*ble, data bank til -it is, vaUate& W, g )r'
The, present best estimate bf exp4,ctod. wouraqyU, +15144 the CHAMP measurements. However tWs ,wil be 9, provement oveaf, MR nVan
previouss CHESS.:a-eroaWdj ,, iuk*ork systems when. and if -it is.realized..

Jf 04M$J.,: oi

J CA) J,*j
"F.. MA Y."C4,6100
1- kk w
ii:..' 0 41 vAx!:,x.#;,AP4


.. ... .. .. ..

.T 1j:.

This chapter presents the results of the investigative team's critical review of the utilization of aerometric data in the analysis and data modeling presented in the CHESS Monograph. The citations to pages, figures and paragraph numbers are to the 1974 CHESS Monopoh. The findings aie highlighted in terms of examples wherein I eaIrs that estimates have been extended beyond the range of
Z! odels have been misused, or miscellaneous errors of
'Oarious "es have occurred which lead to misinterpretation or overinterpretation of data or results of analyses.
A serious weakness in the CHESS study was acknowledged in the 1.4st paragraph on page 7-9, which refers to the Salt Lake Basin study and the Rocky Mountain study. It is in part:
Se factors should be remembered When interpreting the results of the lbower: respiratory disease studies . a majority of the pollution exposure data in both studies were estimated from emissions data.
This statement applies to one of the most important and controversial paragraphs in the CHESS report, also on page 7-9, which follows:
It is interesting to note that larger increases in total lower respiratory disease itad two of its components were observed in the High pollution community of .the Salt Lake Basin study than in the corresponding communities in the Rocky Moumrtain study. Also, the mean annual suspended sulfate concentration was higher in the High pollution community in the Salt Lake Basin study than in the Rocky Mountain study; the opposite was true for sulfur dioxide. This suggests that increases in lower respiratory disease frequency are probably associated with suspended sulfates rather than sulfur dioxide.
The paragraph summarizes the'axgument that. exp9sure to suspended sulfates over a period of years. pmdi ces significant adverse health effects.
Analysis of the background material leading to the conclusion shows that it is derived from an interpretation of the relationship of four numbers all of which are estimated values. The sulfur dioxide 'values are estimated from smelter emissions and the sulfate values we estimated from estimates of sulfur dioxide in one case and estim ates of suspended pqticulate based on smelter emissions in the other, assuming no difference in the ratio of sulfate to suspended particulate in the communities, KeHoggL Idaho; Helena-East 11elens and:Anaconda, Montana; and Magna, Utah. The "High pollution communi of the Salt Lake Basin" is Magna, Utah. It isless clear what is meant by the words "than in the Rocky

iiiiiiiiiiiii~ i~~iiiiiiiii~i4 6ii

Fro iiiiiiiiiiii itcnb .cnldd.h trfeec...en ad ocn
cetain fslae nAaodMnaa
A'~ii co p rsn i en a e hrfrb t of :'g'slu
iidecnetatosadaeiaeslat ocnrtin nM
....... ................... ....... ................... .................... ......
yeas 96 -170

F roiiiii !,iiiiiiii~m t he...... ...............................................................................
otined Tey reasfolow:
[T e on e trtinvaue regie i .................e cubitmet,== .........o 4
),),))))S piiir .ii
iiiiiii))))iiiiiiii~iiiiiiiilliiiiiiilili i ii~ i i! l i li i ii i ii i iiid io x id ei~ i M agnaiii~iiiiiiiiiii i( ---------- --------- --------- ---------- --------- --------- ------- 9
A n co d a - -- - -- - -- -- -- - - -- - - -- - -- -- - --17i
Because~) oftemtosue oain siaeteaslt
values of these concentrations axe questionable. The next four s......ections i scu ss th ese............................. es i at s
1 .! i~ iii~) E S I A E S U L F U R.........................................
Th ocnrto au 2u/l o an a eotiAfv
T a l ...... ......... A.... ........................................................................................................................................................................................................ ..................... .. ............................. i i i ... . .
valuesii" Hiiiiiiii for the yers
Y ea r : iii ii ........i
1 9 70iiiii~~~~iiiiiiiiiiiiiiiiiii~ - - - - - - - - - - - - - - - - I - - - - - - - - - - - - - ;-:::::::
1 9 6 9-i-iI iN ......................

1 9 6 8 - - - - - - - - - - - - - - - - - - - - - - - - - - - - r o
h ,, = ,,,,==,,,:: ''- - - - - - - - - - - - - - --...

Tere, was no pentation in the: Monograph of the use of
0-'s cal data- to shoSw11 that 19 71 was simiar. to. the other m
arorg, orageeally representative yE Even i h
teor~icilconlitions for, all four years had been identical, there fi paibl'et because the year 1971, on which the estimates are
1 not .a normal year for smelter operations. Emissions were
ao, practically zero for two weeks during July,.and nearly zero ,F4rsi eek~s in July and Aust Therefpre, the enusaxon/concentra141ratfio is deficient in showing the effcts of the 'summer season,
id- direction frequencies from thesinelter to Maplea it
leaeness than during the remainder 'af the year. Ths suggets
t~ea, arbr concentration of sulfur dioxide in 1Magna is likely t
,A~e Den ~igtlyover-estimated, but it supportsxrather than changes
ibecoclnpthat average, concentrations of sulfur dioxide are less
8?la I~ian in Anaconda.: Tiimarilly this estimate is criticized
lbauset is not supported by climatological information.
Trs4*oit should be realized that the method used for estimating the p4average concentration can. result in an incorrect estimate if 141" Ka sigmifcant background of sulfur dioxide from a source or WuresoQ- than the smeter. Multiplying the emission rate of the a factor assumes tat all individual observational values
aske~~~~~~ _pteanalaepeca emllied by this same f actor,
ally onily those vake~s totally. reading from the smelter
WIQUSwould lb effectedl. The Salt Lake City airport wind rose
2.1:2) is'probably' not representative for estimating the
ATe f tiieta Magna. is downwind from the smelter because ,me,= erstack iat, the, base of the Oquirrh mountain rage,
1ever, the fp incy of wes t,northwest and northwest winds art
or suggest that Magns is only downwind about 5%
e6 tie. Allowing for the effect. of calm and variable winds, it
W m likely that Magna would be under the iixfluencee of the sinlitrmore than 10% of the time. It follows then, sulfur dioxide a~ie for only these hours would be affected. On the other hand, i'tesmelter is the onl significant source of sulfur dioxide, as may 468,ih case, then mailt 1m individual observation values of zero fto wou d Y only einand the procedure for estimating
a ktrue result, .assuming no change in meteorological or emisson
codtionis'. Since the sulfur dioxide backgron ex. MYagna is not
-kRW 1.the error that could be produced by backgound epmpatraY pmeit be determined. ..Prabably most of te sulfor 'dixide orb om~e from the smelter, so this source of error is not signifiant.
A4i, paragraph in the right hand column of page 3-12 explains how the attrage concentration of 177 pug/m' for sulfur dioxide was estimated
Anaond fo th peiod196-70 usin sulfation plate data. and Ossion rates. However, the explanation is incomplete, because it reires the 1971 emission rate of the smelter, which has been omitted hojm the Monograph. Thus, the validity of the entire procedure is impossible to verify. Table 3.1.2., which lists the emission rates by year
begns iththe year 1970. The ratio of 0.343.253 (pg/m')/(tonijday) w= band by a, very dubious procedure.. To begin with, sulfation plate data: an of somewhat uncertain nature. The documenAr

duiox id eri". ufrOie" .. eateto elhEa

1965. thet sulfation "cnls" an ates) ofite 1ra eveomhaenta onctherato" Itwaso eportuls e reence: wn Hu eey, N a d he mdiy Pernd' eht"telad Dioxde ProllutsinteJ.lirc Polltie ontrozale sufrcm t
pleatsernue wih Asacldomin 9 dietl65.*e x s.1u
plTe anES eMrical h eationsh ps beer su.pltdt-o
1972) The sulfation vaues wer ton ted te slea eoiecn meensofmna ko the relatioasdhi :r1eagi8theero100weng
toeene 0.035 ppm80 nThe istor ofterouse of iato lfalfi ther has611 not. een. generlsgeenuent at s tolkel wha ulsedale rev nAailsntat tion cand. coerie to. thatin sulfur dioxide ronca entadprie aUo pte loatn ofirca theationhi or uston sed Fon thh2e-, tHelato ata weobta inAed.Eniordet Study (EAOfc sufuAr diogride dat arh workangeed tako rt eolft dona 19 the ainnualue avere concetraton aufrdoid ausb
with the oresptonig m conten rato of0 c86 pe aaisq*& th 197103 emSIn te histlso o the ule f ledpid0 ei there sees nto beeto gnrat agdfrente beto tratosb centratin, and. th t 286 furdgomd concentration Cesoetme han idhe, ag nied -12.)oeinomtini nee cn~ the atio 0.343+.253tasin ar ltargeror fnteacond n .090 sftio 97. Ifet e obvaued Is mulipled by vaiaete1nc
year 196859 the fonullowinage concentrationfsulu aredd
the 19 7 emissionrate is o itdfos thper or itcaay]eopae w!it the......spon in..c..centr tion .of.28..u.&

1961L ii ... .

NOE-h ri o tthe 1971 emission rate mis alt imphnrdrof60-0ihisdyc. te

mentatines the misio rates liteoenation. meltere lagahrih .090l to 9 .................................missona~ i th
Y e r 1 9 6 8 1 9 7 0 ................. ............................................
::iMons W day]
TWA~~i U. NO i0
Yeari~ i8iion R
-- - - - - - - - - - o it e
i~i~iiiiiiii ii5

; I N&i~i -- - - - - - - - - - - - - - - - - --......
: i i......................................................................................................
Narx. -Tbe omisdon of the I n th
ne alefo 91 nth sd ae m i ii iiiii
*The= == = =-- = = = ........... reaeffe-iin i= for ......... D tu I t e .... '
tirerdin to inomtonrenl rme amteIfutmSae eatet tWhkdRvrn m e t Si e n mi th e== = e m iseb ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: ................................................... iUs ted k r th e A n o w n d a imn iiiid ter m e lowi~ii~ii~~iiii~iiiiiiiiiiiii.........

.. .... ............... .. .. .635 57

-Th- aerage of these values is 46 ;tg/m'. This concentration is oo~dttbflesg than the 92pug/m' value at Magna. However, inreJwelved from a representative of the Montana State
Voi~ent of Health and Enmvironimental Services, suggests that
In' value and the 286 Ag/ms value we&e measured in two 3;-A 1oMca'tohsU in Anaconda, anid that the 80 ufg/m'l value is too low Ths:indicates that'the estimated values of sulfr dioxide in the t",roparing Anaconda and Maga values are somewhat too low.
-h esimnates are further weakened by the fact that an assumption is iaethat meteorological conditions durma all of the year is identical
--i in irs. No supporting, climatological information is Presented.
-Alo note that ,the Table 3.1.7 lists a sulfur dioxide concentration 1f7hgl for 1971 instead of the 286 ;&g/ma value obtained "from
Motana State Department of Health.
-IMrecedure for estimating sulfur dioxide 'concentrations in
em rinnnj Wecessarily crude, makn the average concentra*W *hi6for the 'years 1968-1970 uncertain. However, since the
971 values for Anaconda and Magna are 286 4u/m' and Al, and these values are the basis for estimates, it would 4p"Ie thrat it was fairly certain that there was more sulfur dioxide pii4-- h Anaconda, than at Magna during the '68 to '70 period of the CHSS studies.
Te15 Ag/m* estimate is a double estimate since the sulfur dioxide cnetration data on which it is based is also estimated. The sulfate tueseems to be an average for the years 1968-1970. It is obtained uig the following regression equation, which is found on page
'egadioisbased es' 1971 cndition.
1fis of interest to note that with a zero concentration of sulfur %d~a there would'still be:6.66 #g/m* of sulfate, or approximately average annual Value reported on 1971, which was 12.4 atg/m' Furrt 44% of the. 15 g/'of iterest f or te yars 1968-1970 is
-iito sulur. dioxide concentrations. The igues 2.4.2 and
s ugest some lack of complete correlation between sulfur dioxide
hufate concentrations.
Drino the strike with, zeo sulfur dioxide concentrations, there
is on.:pprecie amut of ,suspended sulfate. Also, a peak of sulfae occurred during the tird week that does not .corre: it sulfur: dioxide vilue behavor during the same eid
-ythe very. largp in sulfur dioxide thtieke n the

sulfate values is not understood. -What 'is the A 464& Sulfates?
Since the sultuf7dioxide concentrations used in the tion are themselves estimated, uncertainties m, estimates arw Compounded in the s uVate os*%tiU* source of a considerable amount of the sulfate ated with the sulfur 4dioxide- it is not cleax what eibc
has on the estimates.
The CEIESS rp listg ihe' su p' ded
_,Ug/M3 in..1071 an
12.4 d this' the _b f or
for tY6 1.68A97 8, 11servat
subsequent.. support e t, th "AN
centraiions are in the neighborhood ofj5,;qj' nificantly higher than reported foit'Uac.04da,
Onpage2-79 inTable,,.itmayt ll 'te4l' -114VPIT
value.4 "for the community, ,no't
centrations,. partic jarly .. for the, Sp o4d,: question ab t, sulfur dio ide as wu in c T
done.,wi session eq OPIPW"
th the regr nationn
th ni h are: Sulfur dia.
q ; g CommulutT
for suspended sulfate they are 8, aad 77 iiv
Wind blow*Qag,.. from the' 'ter sta"a, cross a portion of V:he' Gieai: P L. t Lak' more moisturq,-;t ereby factta tt, OnX
to sulfate. Perhaps this meel.-- 4,)s
s lfat e coitemtratipns'obse" -d in Magna,
The 7.2 jug/m suspended sulfate vallp can tbe o
Table :3. 1.71 page,3 '12,.Iby: iikint, "an av&ho, of Qh% three yeap-, as follow$ '-.
1969--Average---These sulfate values are esUmatesl boil4 ended ipaxtici4late and tua e9ii
tra d &Q 4i &:Tqjioa
concern tion to. uspon 0 P a; e, a 4tr#
I d H 1 A i nq
results from East He qwkan e en
Tfie saweproeedure'vr ,4' used for
PO a tem
gO 3- 1, M I t ILPt e
IS $Aa +1 'a
Magnfi.durtiftg the period JaAiuary ratio of suspended sulfate conoantmtiop' fic'ulate:of J0.1, FO thig is r
f Wational, Air 6 IJ n
P-41 "Cbairacter t 3 Otp
T'pp publicatioft *PMgwt su d,
tiops for v es oypr a t.
M the

iptJ~oisatherefore,, it nzaust be canetteded- that the reference is an
nr N~arbus reference for.this paper would have been the paper by Ma~ri Hertz, et al., "Human Exposure to Air Pollution an Salt
".4w the reference intended. Even so, the ratio: 0.150 cannot b
&h 0 frorn the Hertz paper.
*Hertz paper, page 2--11 Table 2 1.2, which gives 0CHESS
i67. nnual Averages for Magna., the suspended sulfate concentra0.R. g/m' and the total suspended partione coenrtn
J*A4*-hich gives a ratio of 0.178:. In Tables 2.1.5 and 2.1.A.16, the *Aow ouocentrations are given: 088, 66 aug/m', S8, 12A4 pg~m3.
o-'theratio is:0.188. Other- reatios can he determined for various
fimeperads from Tables 2.1.A and 2.1.A.5, but non& of these is
Not.:page 3-11) that the nexplained ratio 0.160 for Magna is
im. Z iththe 0.063 ratio for East Helena to obtain the ratio 0.111
Io inus 0.067 that is used to estimate suspended sulfate con9,wzatonsfor Kellogg, and the: 0.11 plus or amus 0.06 ratio for
Asp~ad^ page 3-13).
(P~es3-8 and 3-9) Particulate emiseian for Enst: Helens are given
"Wwin Tahle 3.1A should be' "Emissions, Tons/year," not "Emis,
0 ,onsday.".
dC4-pgo 3-71it is stated that estimates of stack emissions for both p~tee and sulfur dioxide for East Helena for the yeas:1941-1970 *m~provded by Asarea. Presuabsly the data in Table 3.1.3 are Asaro dae. The source of the'data in Table 3.1A4 is not stated.
..Te Offce ,of ,Air Programs Publication No. AP-et1, Helena Valley, uu p;, Area Environmental Pollution Study, gives more inforatig:, out the industrial complex at. East Helena. This shady was aftuotd -during the period June 1969 through .June 1970. The
tbabelow is from this study. .
.. ....ITeas per day]
pCopar and ips ties, S* roductiom ParticulaW tde dt
Reduced Normal Maalum Reduced Nor"na awlua

ag..n ----------------- 184 6 St 1 355.1I 0. 8 0. 5 0.5+
ing ------------------ 4t2&2
sebttal ------- ---- 19&.0 330.2 37483 .8 .5 .5+

SubtoaL ... 13.0 13.0 13.0LOO10 A agrican Chemet: Pigment Production. ))0)(9))
Toa.. __.... 206.0 343. 2 39L 3 LS1 LS6 1.5+
aTh outside storage of concetrates contributs a significant but undetermined amount ofpatcles 2Ewmissionesalsonoccur druring the eleB PharW'n MD/ad FtW co mill btR I asl@af 11 '

]i iEI ili~ii~i~il iii ii

lat sore oih atH ln ra u ig iPr

,'ighe rateiii thaniiii is ive nT bei...(ie,16:22 osdi

1 9 70iiiiiiiiiiii~iii :ii''iiiiii 2 3 9 ,,, t on s / d a y)' 'i ']ii...i iiiiiiii~iiii ii ii iiiii! iii i ......................"............... .. .... ii

.................. p ag e 3 ri h h andiiiii sidiiiiiiiiiiiiiveiniiaiiiiiiiiiiin aiiiiiiiiiiiihiiiiiiiii
dai n al .. eeue ooti ai fttlsip6
p artii culate....o.c.nt.atio.n.t..t..n..of.par.t.cula.te...i....................
........ H elena............................... H oweve = ter g iing thiiiiiii is ex l n to th ii
of~iiiiiiiii!iiiiiiii= ... ....... in Table 3.1.5, that wereiuseito m............. dedsolfa
ei matesiii were notii obtainedii= by= = === meansii of ............ ratio They s f.....

PA The from statioas I and 3, the stations neet the ssck were
ar raio range (0.037, paces &'#8), hot for someouis
Aa~aleratios from the Rdlena, Vallay study were not
.1".1 Awarage ratio for stations 1 and 8 is 0.051.
a~ mki 9. on for, Eas Helena.., 0 #.0 plu or miu 0.2 d (dga & 91 (p/O, is not significantly different I m that which might have been oad had more use been made of the Helena Valley study, but Omhe no ass for he anwsmpto that the matio of rsusned suwlfaes to suspended particulate is similar in Magna, East Helena, Helena,

Tb-debiou~s nature of using suspended particulate concentrations
to ~ .Wmt wrend slat ca beee by comparing Figures 2.4.8 an.94-4. In the Low Exposure Community, the sulfate level remains i*m& nearly constant wile the suspended particulate concentratm-lantats
aith High Exposure Community, the highest concentration of mm~en..1 pawriculat occurred on the fourth week whereas the peak alooccurred on the third week. Oa the tout-h week, sulfate adde& Ampped. A corresponding drop in the sulfate levels does not oceur until the fifth week. Only during the last seven or eight weeks do suspended particulate and suspended sulfate concentrations fltuate together. There may be some situations where suspended partiulte and suspended slate concentrations are well correlated.
Mth fo **ssurnin correlation in the Salt Lake Basin and the
RokyMdutatdn communities is inadeqttl supported by scientific
6vno presented in the CHESS% Moorp.
Frher, -the 7.2 gg/ms suspended slaeestimate for Anaconda is
beon si estimate that comes from another estimate of suspended
pwt~iate values based on rates of emission from the smelter. During &0 jod1061-1962, the anntal total suspended particulate concentft*2:wasfound to be 84.5 pig/uit Ini 1971, the average suspended pardeua level was observed to be 62 ug/mW. By comparing the Asevedtotal suspended' particulate concentration with, the part)8 late dentted from the Anaconds plant, a ratio of 9.1+:--2.3 (pg/m')/I
(d day) was determined. This ratio was multiplied by the padtianInte emission for Anaconda shown in Table 3.1.3 to estimate the total Ottspended particulate concentrations for the years 1940-1970. This raho camnot 1e actually obtained from the data presented in the report ,.eauseo particulate emissions for the year 1971 are not given, i.e., they are not listed in Table 3.1-.
The basis for tis ratio is unfounded' since there are sources for the suspended particulate other than the smelter emissions. KI.Although there are no actual sulfate observations from the Anarconda area' included in the CESreport there are some actual observations of suspended sulfate versus total suspended particulate available for the Year 1971, that were obtained from the Montana State Department of IHealth and Environmental Scie nees. These sugest that annual average suspended sulfate levels in Anaconda are iiCi nheighborhooLad of 4 or 4 .. elmemn less than the estimaedA


There are also pronounced seasonal effects, with, Met Vnite in winter than in summer. Tho: monthsi ot Aeue g
values of 7 ad 9 pgym* whaeas the months of Jul -heA values of less than 1 ug/m'.Loed heating emissionaL dd
ity may be significant factors -deteraming theacocdls tism as well as the smelter emaissions-: -a
On page 2-23 it is stated that "the number of sulfric. asidahits utilizing sulfur recovered from emissions have increased?,froim din 1940 to seven in 1971, and that air pollution control. deviceSjh the form, of baghouses, scrubbers, cyclones, -and, aist eliminAtes (a we been installed. Such changes in tha-ssnelter operations: weald'go* effect the ratio of suspended particulate to tons of cop .per-prodn"4 Theretore, aside from the fact that there would- be diflefnem iWm year to, year because of meteorology, the procedure.dsrbdl<* first paragraph, right hand column, page 2--24, for estip~a pended particulate from copper production in tonmfor 1971,ilihy questionable. *
*In th Chicago and New York studies suspended sulf0,te concA+, trations were einimated froM, suspended. particulate. conentrationas In Chicago, the estimates were used to fill in data for some years teR no data were available. In the New York suymeasured vaue (ork suspended sulfates for 1956-1.970 were available fronimthe M 121st Strelet station, and these values were used as cityide o The bserved annual ratios of' suspended sulfate: to' dusfall~for.t York City were used to estimate the suspended sulfate levels Is4 and Bronxs. In Table 5.3.1 suspended sulfate levels for the 1w mattity (Riverhead) 'are listed as about, 10 pg/ni? for the y easrsM though 1970. The basis for this estimate is not give wa probably determined from the' 1971 concetrAtion, wich wqi0
In anmmary, it appears that some values, onR which are
important conclusions that sulfates may be harmful to heath, we estimated values. ....
C. USE OF MATHEMATICAL DISPERSION:. MODXELSThe dispersion model shown in Figure 2.1.16 is ince' tl pplie
It was used in the Salt Lake Basin study to determiig sulfurPdoxide, contoutrs around the smelter source and to show that-anual exposure. estimates obtained from the ratio of, 1971 observed ai quality' to: 1971 emissions were not unreasonably high or low. Vist the cAoxuW irst, t iL1 iq

are incorrect because the model used does *not take *into account t14 elevation of the terrain and the wind direction -frequeniesl for the: Salt Lake City airport, which were'used are different-N frIhosO affecting the smelter plume, which originates at the basse of the Oquirrh Mountains. Second, a dispersion model is based on numerous assumptions and applied in this way might be off by a factor of two, or more. It does not make sense to use a model to check observations.


Mtn ufffiW application i's to applY observational data to calibrate, w n model. A model -such -as the one used migbthave been appfied to:. show some sort of relative distribution, of concentration's across the Salt Lake Valley, however, it should not have been used
jwt4 :estimates of concentrations: over the period 1940-1970.
sbka 2. I.A. 14 and 2 i -A. 16). Further, Aurin; thisreview of the CHU9 report it was diwovered that, smelter emissions used for the
i'd liklim tes -were tons of sulfur, not tons of sulfur dia dde. TherehdPIK -model estimate is only half what it should have been. Dou&ling the emission rate and reducing the wind direction frequency somewhat with respect to Magna might result in an estimated concentration near that measured, which was 61 Ag/m3.
ApDarelltly the dispersion model was run only once and then the ratio Between the emission at the smelter for 1971 and the calculated concentration was ap 1i d to emission values for the other years in order to obtain the Meer listed concentrations in the column headed Diffusion Model". No account is taken of the fact that meteorological conditions, c r perhaps stack conditions, were not the same for all ears. More information should have been included in this report on etxactly what meteorological data were used in the model. The model requh the use of the STAR program, which is obtained from the National Climate Center. Frequently the results of running this program are based on data for the year 1964, which is the only year
*h n wind directions were punched on data cards to the nearest 10 degrees each hour rather than each 3-hours. Therefore, the model is IB ely to have incorporated meteorological data for some year other th 1971, the year of the emission
an. data. No attempts is made to
show that the year (or =d) of the meteorological data is average, good or bad. Similarly is no attempt to show that 1971 was an
average eW7, yet all of the estimates are based on this assumption.
Zering how the model estimates for the years 1940-1970 were obtained it is misleading to include them in the table, and they serve littlepurpose since the ratio for the year 1970 is repeated throughout.
On page 2-43, bottom of right hand column, the following statements appear: "Estimates of sulfur dioxide, total susg2n d d particulates, and suspended sulfate concentrations in the Igh exposure community for 1940-1970 and the Intermediate 11 exposure community for 1950-1970 were obtained by a mathematical dis"erslon modeJ, which utilized emissions from the industrial source an7;;iWaive local meteorolo I d ta, and by observed relationships am su ej
pollutants. Observe aded particulate, suspended sulfate, an
Wfur dioxide concentrations for 1970-1971 were used to calibrate the models used to estimate exposure levels for previous years." This is an ov erstatement. The estimates were obtained from simple ratios and the ap lication of a regression equation. See 2 39. The model W&A oNy applied once to demonstrate that annua ext osure estimates bbtained from a ratio were not unreasonably high or ow.
In the Chicago study, another attempt was made to apply a disersion model (Figure 4.1.10). This model gives a false picture of 001 ution conditions that prevailed in the study area because it is based only on Pollution sources within the city limits of Chic;W, ofnitfing effects of adjo nin large industrial sourm M* 1ndiana and of some suburban communities to the southwest of the Loop area, which have considerable air pollution.

il i

thei ode ii cates.i Oni iigei 4-8, it iii iiiiiiii Mesrdt a rmte'iy*

from w ich the epsr estimates wer

by the Mit i s n cla w a iiie use wa no 4a4& i'
the:::::::::::: av ailab le.................................. ac u a m easu re m en ts....................... initii iii th o e
Alsoiiiiiil isiotsifi ietliierihythimdeiapeniiiii~r.*
y e ariiiiiiiiiiiiiiii~ 1 i9l 6 8.iiii iiiiiiiiiiiiili .... iiliiiiiiiiiiiiiiiii==iiiiiiil~ii~iiiiiiiilI iiiiiiiiiiiiiiiiiil

iiii ii i ""= .... .. ...

Before discussing health effects problems specific to CHESS, some discussion of general difficulties inherent to pollution epidemiology ,ioa% be helpful.
Xposure to suspect pollutants is not controlled in population aWdies. Indeed with current technolo 'e itis not possible to be sure that, the correct is &I
pollutant even being measured. Combinations of.p6llutants may be more harmful than any singlepollutant, and the munber of studies needed to investigate such synergisms (interactions) kaenams rapidly with the number of pollutants under consideration. The. analysis of synergismsis often impractical since sites with the n*eded tonfigwations of pollutants axe seldom at hand.
Not only is exposure uncontrolled, it is often: difficult to measure. Even when aerometric measurements are valid, special meteorologic conditions or personal habits may cause a given subject to experience pollution levels very different from those measured at a nearby fixed monitoring station. These problems are exacerbated in long term studies dur=* ich the quality of serometric, data has been variable and individuils have change d jobs and residences. Aerometric methods for weasurkikg hourly or y pollution levels axe often less reliable
than. required for studies associating pollution levels with short term health iffects.
The health measurements axe often subjective responses to a questionnaire or interview. An individual may give one answer on a selfadministered questionnaire and another to a friendly Miterviewer. Other factors, such as the public announcement of a pollution alert, can also influence subjective health measurements. Some health messurements, such as pulmonary function tests orblood anaJyses, are Jess influenced by poorly defined conditions surrounding the meaurements and axe said to be objective. However, even objective endpo.n.its respond to uncontrolled events like an undetected influenza 61idemic or high pollen count.
Whether the health measurement is subjective or objective, the response is often &ffected -by factors (covariates) associated with the subject studied and unrelated to pollutant exposure. Whether the individual smokes or is subjected to e gazette smoke at home or work is a covaxiate of dominant importance in pollution studies. Educational attainment may affect responses to questions about phlegm orpneuMonia. Occupation, age, sex, race., immunity to influenza, anergy, access to air-conditioning and countless other covariates complicate 'the interpretation of ppidemiologic data. Epidemiologists treat t6variates in two ways..Th try to choose study populations which



have similar covariate characteristics so that health....d between such populations can be ascribed to pollute" ternatively, they make mathematical adjutet to_. effects of corariate imbalances. Both strategies hav and neither works if the investigator is unaware of an, corariate or has failedto measure it 3 The epidemiologist has little conro 'over he subjecgisr cannot assign them at random: to residei in pollutedcon intere.t Thus, a clean town. may. contain many asfMGo asthmatics have wisely chosen to live there rather Ithalf: polntel community. This funda mental problem. of self-selection meet qualify any conclusions obtained, from. non4-1rMazidoiise studies: it may be possible to deon traetparal or tions between health and pollution measurements, byV tionship, cannot -be -inferred on -the basis of aksingle epim,
Students of pollution counter these weaknesss i sevpret
strategy is to replicate an epidemiol ogic study in W redetYMAg sumstances and seriay in time. I f a. cosset asitis pollution and health measurement is observed, it is beh4t ainee covarite, imbalances and prwoblems of: self.oidiem '*: = to affect all sites antd to per sist overtmeClnclsdi, healthy volunteers are subjected. to controlled pqltni lIstI and toxicological studies$ in which animals are Aujc. & erag combinations asd doses of pollutants, complement ieaegg tained from eidemiologic studies. 'This.1body.o, eomaefg clintical and toxicological studies and: from several ek studies may substantiate an interesting association health and pollution measurements, of c ge;' "t In addition to these general issues, eme quesipesnrw
-nent to the CHESS_ heathm mesueet wMr exaned ta
(1) W a h healt mesrmn0a eibe t
indicator of public, heath? ,dIo
(2) Was the sttsiclaaysis sound andimpr" A T
(3) Were the methods used to~ earbe sp'iA helt a&ld
speicpollutants and to esabihdo-rpas
logcaly coelig adO
The sources of information used in thi sesmn icuesa s
(.1) The CESS Moogra citedpeiul Mikmi
data gathered in, 197D-1971 as well assmearirbialsl
(2 Pelimiary internal EPAfaof 91Af2dpia
(3) External peer review domans ..q Iv, 3
(4) Interviews and progress reporty4CQt* >q ts)
personnel who gathered healt and serometrio., Id
(5) Intervie:ws wt EPA persone awin h ern
the data. J. resdu
Time liittions. prohibited a coplpete reanalysis of.I." ga health andserometric data..,n aa B.~~~ I.aDCIN.N .E..Iri.H .18

Whtfollows is a det~ale<' dUssnoe. ,p
the HES Monograh. EAh hath measuroping is together With special Problm associated with priua Sites. Comparisons across CHESSsites and comparing with sub-

OquftCHE88 studie, are. made (when possible). A relatively nontohnif to mary follows the discuesion of each health masurement, Unfotuntely, much of the -terminology is specialized. A shortgleseary (t kai sial terms is given -below for those who wish to, read the d ld afa sment. as glossary is intended to convey theapups
a",weofcertain 'statistical terms rather than to give precise def'nta~ns:wieh are available from standard statistics texts. The definition Ar particularized to pollution applications.
dieves Procedure.-Tjhis is a mathematical method, based on
aa~isured model, to compare populations exposed to various pollution.lel when other factors which might affect health measurements,
s~oho ap,.sex, or race also differ among ommunities.
praevmlation.-This term describes the way in which the asthma,
to ona artcaar day depends on the attackraeoote
AYS eglation levels, which are also time series, also have autosreltian structure, since a polutanat which is elevated above usual
be4on one day is: likely to be elevated on the next day also.
role, dton.-Correlation is a measure of the strength of the linear i-" nabip between two quantities. Positively correlated quantities bM.,j rise and fall together, whereas negatively correlated quantities
t4W4,W.,rbe and- fall out of phase.
-o geef-Fit Statiatic.-This quantity is used to gauge how well m athematical model fits a set of data. eat Squaree Method.-This is a method of estimating the parameters of a mathematical model so that the final estimates brmng the model into, osest possible ongrence with the data.
Linear Model for Categorca Data.-Linear models are models in viih.she, average Value of the observations (dependent variable) is ass adbd to ber linear function of independent vriables, -such as
olton category, age or sex. If the expected frequency of a tell in a is assumed to be a linear function of such indeem deiale, one has a linear model for categorical data. The
VAl of such a model, if it fits the data, is that it enables one to mfirth the relative contributions of the various independent voabes.
fe*.,Altiple Regression Analysis.-Multiple regression analysis is a nietk d- for relating an observation (dependent variable) such as Authoura, attack. rate to several independent o variables, .enuch as suav pleaded sulfate levels, sulfur dioxide and perhaps other polutant&. atu~ applications require that the expected value of the oberation is:a Jner function of the independent variables, and that observa,tim a ae'statistically independent with constant, variability about the expea ted value. A multiple re 'on model can be used to describe a glami-set of data and to pre 'at the outoome of future observations for. iown values of the independent variables. However, the fact that a: multiple regression model fits a given data set well or yields good predictions of future observations need not imply that the independent variahies determine the observations or hear any causal relationship -to the observations.
holed -Pooled-data is data obtained by combnung& data from two. or md~re samples and then ignoring the fact that the combined data& came from various sources.
Besiduals.-Residuals, are differences between observed data and values expected under a mathematical model. Residuals are helpful in assessing the annronriateness of the model.

estinate how bte set of atuar 18ndpen en talbo n meensdtht thrae ane retly inhance ywa te ind100 onntmercouls ae oclned i the ypothei we rgeso n sance leves is ato oft takrmiin ts a imnertnur: of th In patuarinth ehpenhesin th aiblltere smce ofohras 6

mre idepneagnt thehi hpthsbing t rbbeset dtai udr that two populationThhs chreloi reprabty discede hsignfcae llnd a 1nu0P' :<0 men htthechneare iss noa dif5ns f in vie0o thet dat6 this-v otoe highl haroabled fth is poheslower p re.Th.
mre ie ne ejeitsth hthehyoesis. ofose nor differear beptens poplints)tad asms nst epouatin tha e th esmbr crkobonic respiratory disease betwscalea4nul" t yoo--hi I.

threisn dffr1.. f CHONHSin ief tIeAS (ORD) thshPoteilf CHSS b e sthyimpate ult hr oniav respratry .d ili menace ofe aesecndnstred quotesionnaiffrenc hic is-o
btee prvoulaios y ar. Th ssudies intare thtOr g 4iiri jacentf chomnitirespithr dieerbetween teralo plaih

"Hih, "INteREIRAOR Yow' DI'hAS MbatighsAF. gHEi eNiew Yoronicrespiratiryiiidiseiiiiiiiiiiiiy aBl

and aleiso include es e studies r om e Chiag art~ eo%1U-* gahee iniihe Newiiiiii YoriCit an atLk iy& sii17-17

Mountain: communities, CHESS monitoring stain-wee\a'r present in Chicago or the Rocky. Mountain comliniis, zd'w posure: estimates were, based on .local data sourcsadhovi8 extrapolations, in these areas (see Chapters IVT nV,,, H monitoring, stations only became operational inSatLk-CAyJ December, 1970. Attention .in this investigation wscnie~~h four surveys, which were reviewed by Chapman e l adt e York City CHESS follow-up data 2 from. 1971-197.
The CHESS CRD questionnaire was adapted frtl-diita
Medical, Research Council?, Although a similar u~tani a
been valilated for self-administration in a 1971 Jaaee.1uy'h
1Chapman, R. S., Shy. C. M., Finkle, J. F. House D. E, Goldbey, xpsE ~ f Respiratory D~isease in Military Inductees and Parents oi Schoo~lchildren.' Arhk zrb V61umne 27,1Number t (1973), pp. 138-142.
3 Galke W. A. House D41 Prevalence of C0hronic Respiratory Disease gyp m Eflv r.A Adults, 16n2." EM0A 1-10fe Teekshical lepr (Ji7 1976).1
*"Standards for Epidemniologic SurveysvinChronic Respiratory Disease.11XtoL1T M~s1 0 Respiratory Disease Associatin 16)
g unretosi, Y., Shimiza, T., 'fakshshi, Af., Ichinieswf, A., Ueda, Mq., ilat -9 1 h( "Epidemooia Study of Chton'o Bronchitis. with Special Reference toEfeto
Arh rbeitsmd. Voume 29 (1971). pp. 1-21
I "0iiiiii1iiiii~iiiil c a l .................. = iiiiiii i iiii = =iii iiiiii!i~iiiiiiiii=iii iiiii"i~ iiiiii i =

]a-es aot contain vdidating data for U.S. aurveys. AA PA apport *1 dated 1973 abowed that the self-admbus.*tered
M P~rsdetected only three of aineases of chronic bronchitis Wtmgh interview. Surv uerirsoted that the werd
enot understood some subjects, suggesting that
-A sio;WAttainment affects G D response. However, even if the QEM$ qustionnaire, underestimates ORD. prevalence in a given
ibmy give a reliable indication of the difference in ORD
pevaaum hetwe two, communities of: similar educational
T~oBrax, Queens and, RIverize4 o Island represented two
Weme~wto and one Low level et urban adlution in the New. York C~t ora4The latermediate Negious I eeieed Riverhead in total
$F Dpticulate (TSP), sidfur dioxide (S), suspended sulfate
@S), p suivended aitrate (SN). Genera y, questionnaires were glv() shool children -who gave tuom to teir parents to fill'out.
'*"is.,0*sample is not representative of adults in general but only
vvmtsof school children. Only 73% of Riverhead parents re.pqdodto he questionnaire which Drbably reflects the fact that a IST0"ni=' brof Riverhead questionnaires were mailed to the parents
distributed through. the -children. Only white respondents
dh'ced suicide uetionsire 4a and who had stable
iwideca I histories were included in -thie analysis. Queens was shown IAythe highapt income and educational level and unpublished
owed neen to -have a larger proportion of Jews than Bronx.
Tl~qtAc may amount for the lugher ORD prevalence rates reOoredor the QueenRs than .Broom. 1No formal adjustments were vplid-,or these -socio-economie, coveriates. While smokers.-and non, r~iokeivwere. temted separately, nos covariate adjustments were Wa~~fgenpogepous exposure to eigisretteo smoke at home or work or OD q stional exposure (which affected less9, than::1% of respond.4 "4 .1e statistical methods were soun. 0e-sdsoigseii pr-ekyl ce rates were consistently lower in. Riverhead tha-i Queens 04 ,ax the difference being 5% typically., For comparison, smokers pevalence rates nearly 10% above naon-smokers: in the same oomm-uity. A linear model for eategorical data was used to make = @9,. age,, and sex-,adjusted tests for community differences in roaendsa rates, anad the differences were statistically. sig~niont.
X aallel &AmlYsis .Using severity seeoe for ORD confirmed the aaris of Prevalence. While the statisticalmethods were appropriate, neitoal ifonation would be: helpful In particular, confidence intwala on the prevalence rates in'l able 5.2.7. (unless otherwise i d, figure, page:.and Table eitations refer to the CMESS
*Pogrnp) and observand ,e ma sxetdateas uage the liueer model
bl&e 5.2.8. would- allow the reader-to make. specific prevalence .Mamna and to veriY that the-4linear model-held for al
Nnmunities in the Salt Lake region provided an opportunity to.
"ythe effects of sulfur oide (%sul2) elter equeos Other ur pollutants including 5N and TS, were modgrate or low.
awse,.posed to interw iLttl erf igtosf80an
IHmD., "Relibiltyof the CHESS Schooland FamnilHeath Questonnaire." EPA Human Studies
.=oatr itrsnalm Depom+ V[ A l1(171


had the highest average S02 and SS levels of these polltitantg441i(I Ogden was desianated Low. Aerometric copper data was not &v_1dl',&bJe4' The questionnaire was distributed through elementary school. childjren and mailed to parents of high school students. Response :rates ;ot 85% and 35% were found for child-carried and mailed qubstioph respectivel3:. Although the 65% nonresponse rate to mailed' question-6 naires admits the possibility of serious reporting bias, the autho6 assure the reader that inter-community CRD differences (presuinitbly similar) were observed for both sets of -parents. Respondents'we", excluded.for incomplete questionnaires, for a residential change wl,'thin the previous two years, and for occupational exposurelo irritants such as coal dust, cutting oils, asbestos, mine dust, smelter ftlim&' cotton dust and foundry dust. Subsequent analysis showed that, 6 occupational exclusion gives a conservative estimate' of effe.c.4 attributable to pollution. All races were included, but the proportioii of black respondents was trivial. No covariate measurements w&b made to assess religion, exposure to exogenous cigarette smoke. A home or work, or racial composition, although Salt Lake City hi proportionately fewer Mormons, and Magna more Spanish Americaho,,, Educational attainment was comparable in the four communities.6, CRD prevalence rates reflected pollution levels faithfully, and rateg in Magna (High) exceeded those in Ogden (Low) by 2-7%, dependiiii on sex and smoking status. These differences were, found to 'be statistically sipificant using the sex, smoking and age adjuit6d. linear model. I For comparison, differences in CRD pre.valenoo' attributable to smoking and to occupational exposure were 10-'20,0/6 and 2-8% respectively. Thus, air pollution and occupational exposure. were associated with comparable increases in CRD prevalence, aM personal smoking habits seemed to be a more important determinant.
The exposure data from the Rocky Mountain communities' Were least adequate. Two smelter communities, Kellogg and Anaconda,, had relatively high levels of SO,. East Helena and two non-8melter communities, Bozeman and Helena, were classified as Low. Afn'bjoht zinc, copper and lead were not measured. Nearly 85% of the qu&tionnaires distributed by elementary school children were returned.: Respondents were excluded for occupa-Cional exposure, but n6 residence duration requirement is mentioned. Over 97% of respakidentg were white. Low communities were better educated than High
and most occupational exclusions were from the att "I communities, I er I
but these factors tend to reduce the apparent pollution vffecC Conversely, the increased residential crowding in High Oommunilties might increase apparent pollution effects. Sex-, education-, smoki.nwand age-adjusted prevalence rates were: statistically significanirx higher in High than Low communities (Table 3.2.6). High communities had CRD prevalence rates 1-3%'higher ;&n found in Low communities (Table 3.2.5). Co- rresponding differ. eitces. msocihtted with smoking and occupational exposure were 10-16% andd.l- 3.6% respectively.
The Chicago studies compa ed urban (High), suburban (Inter-' mediate) and clean surrounding areas of Illinois and Indiana, (Low)-.Local S02, SS and TSP measurements were used, and othtr urban pollutants were not measured. Gary, Indiana was includedin -urban
2 GZIZZle N. E., et %L, op. cit.


U~yrepreent aspecil i dstria polltion azard A CR
& e~~~~tiorma Hiiiiiiieii dei ne......Glbeg wa d i se d t

recuf~q eprtig o te 1hiag inucionceter Tis oplainiiiiiii obviouslyl differsfrom theirevious hree and contain nly youn Ma~e ai~ts Somewith eriou resprator problem my hav bee
exemped pror toinducion. o be nalyzd, th quesionnare ha
i6 te dequaely flled ut an the esponent hd to ave lved a
hisresntaddessfo atlest hre yars Satiticll siniicantiiiiii
race-,smokig-, ad eduationadjused comunit diffrence
#i prvalene rats wee foud forblacksmokrs an whit non m~krs Tabe 42.8. Hwevr, he ig~ficncelevls or lackiiii smokes andthe adjust rats *i Tabl 4.2. aresuspet sine th linea mode doe not it th dat wellfor back nd whte smkers
(Thi6"adjuted"-ratesin Tale 42.7 ae realy exectedrate ndr te inex mde, wic isa ueae ufamlix t e ideii~~iii ologits.) ace ad smoing secifc prealenc rate tendto b

b,.4-.6 pecent ighe amon urba thanLow.ommuntieswhil

smokig effcts re 0.-3.5 ercet forblack and12.4-5.1 prcen

fol wites

tionnaires. Children less than one year old, those ith questionnaires, and sthinatics were excluded from:i anoyi last exclusion tended to miiieestimates of pallationifms Table 2.3.4). The sample is not a random selection froine ~ di aged 1-12, but represents only schoolchildren and thi 4ll;'A Because toe data is, retrospective, validation is crnial examined medical receirds to document LRD ( ,bo
or pneumonia) detected by questionnaire. In.7 of questionnaire-detected cases were confirmed, w ras 7 0wm documented in Kearns (Intermediate) and Magma (5A T "
differences would tend to reduce -estimates of piollutineet. b
coresonin figue were 88% and 75% for pooled Lown 910
High Rok ountain communities, which weild tend onr4
estunates pollution effects.
Parents smoked less in Magna than in other Salt Lake noti (Table 2.3.3), which would miiie pollution effects. T. A

adjustment is needed.
The monograph does not specify how age-, sex-, and society onu.1 "adjusted" rates are comsputed. Since the epidemiologic int-rrtto is predicated ot these adjusted rates, some clarification, obtandfu EPA interviews,, is gven........
A linear model agaionin'mg community, age, sex, ad..QW
economic main effects ad no interactions was fitted seo t the three residence designations in Table 2.3.12. The "tadji'ta in each column tof this table are simply the sumi of the. svm overall mean and community *effect. Differences of jratesihn 1,1 such column are estimated community effects under tel These comments majr expain the anomaly that 4'juted rat e unadjusted rates in every community, both for Salt Lake #dRe Mountain studies. A more 'reasonable "adjusted" rate oW,6 obtained by applyinglie total estimated linear inedel, Lels4, .i main qeets, to the social corariate composition ofe 4 Un1 The "adjusted" rates i the li til pvie
estimates of comn teets, prvde line mode asd'i
the data well. Th atLake atuie pve no goodpme-of-i t
or analysis of residues and the model is nt even.spcfe vyTa
2.3.9. Thus tlhe Salt Lake adjusted" rates and 'gnfcUC C4 W
be regarded as provisinal. Tough RockyMonansuis' no analysis of residuals, the goodness-of-fit statistics sugges t.te 9v model is valid.
If one assumes the validity of the linear model used,. the *tlk
studies demonstrated statistically significant community dfere ew in three-year croup, bronchiti s, and LRD incidence rate afteadjut ment for sex, age, and socioeconomic status (actusay eduatma attainment of the mother). Mapna residents of three Yom had LRD, croup and bronchitis rates which: exceed ox o, mio
rates in Ogden by 10.9 percent, 9.5 percent, and 7.1 perc- tresp ively. However, these rates did not increase in strict accord. ie w ......... ....................d- z z l % Tii i i i ii ii ii iiiii 1iii 9 a t a l o p e ft.i i ii iiiiii~i~ii iiiiiiiiii~iiil iii iii ~! iiiiiii~~~~!!!! !! !!!~~iiiii !! !!!! !~iii iiiii~~~~~~~~i!!! !!!!!! ii!!!!!~~iiii~!i! !!!!!!!! ii!!!! !!!! -

d~uied evels and Magna residents of fewer than three years actas fpedePed the lowest aroup, bronchitis, and LRD rates. No ' an nanmnity differences were found for pneumonia or hospitaliz..
RihRocky Mountain immunities had significantly higher
sAjRt eroup rates than pooled Low -communities. No significant diftmes(at p<.05) were found for LRD, bronehitis, pneumonia, pu1i' talization. Those residents in pooled Low communities for fwr thn three years experienced higher adjusted croup, bronchitis, 4ad.RD rates than corresponding inhabitants of pooledHg p u nities.
Theaic observation that children of families resident in smelterexpeedcommunities for three years or more experience higher croup raW tan those in nearby communities may be valid. However, these Woas ¬ increase consistently with increasing pollution (Tables 3.812 2.3.8, and 2.3.A.2), and recent migrants to'High areas have lower croup rates than migrants to Low areas (Tables 2.3.8, 2.3.A.2, &.2 and 3.3.8). These inconsistencies deserve further elucidation.
undocumented insnsitivity of the LRD questionaire reminds us ta.this endpoint is no better than a mother's ability to recall a ,,tre-yar illness history for each of her children and to remember poifediagnoses, such as croup and bronchitis. Finally, the conclusion a h Monograph (.7-9) that "increases in lower respirtory disease freqencyare prob ably associated with suspended sulfate rather, than
afrdioxide" is tenuous at best, since no formal methods of relatmg
Wtheffects to a spenific pollutant are described and since suspended sw~temeasurements are not available in Salt Lake and Rocky Mountain communities for the years 1967-1970 surveyed by the questionnaires.
The Monograph contains New York ARD studies from 1970-1971. Telephone interviewers made biweekly calls to mothers of families
B~yed in the study to inquire whether any family member had ,deeloedUpper or lower respiratory illness in the preceding two weeks, an ) isi, whether a doctor had been consulted and how many days of refifite activity had eventuated. If an individual was re!ported to uPer and lower resirtory symptoms, his illness was fi as Twer respiratory dHIsease. Thus, the least ambiguous sIc ctegory is "fall respiratory illness." A10 percent subsample
amiis who had cooperated on the CRD questionnaire was reerited for the ARD study. An eligible family had to have resided at leas .t the past year within 1.5 miles of a CESS monitoring. site, to be white, to have one or more children age 12 or less, and to have a working phone. Priority was given to famiilies with many preschool ibling, and in a subsequent protocol, such "Priorities" were specified iAn writing. These priority schedules introduce ambiguity into the eligibility requirements. The major response variables were the numbier of respiratory illnesses per hundred person-weeks exposure (the arac rate) and the severity score, which reflected. physician visits, fever, anid. restricted activity. The severity score scale has been critioiael as arhitrary, and inversions for scores II and III in the upper

iiii"' "=== iii= 6 6

r e sp ir a to ry c o lu mn........f.T..b.l...........................................................
(whii c has.bviu..msprn.sfor.ron.dat).sows.hat.o...
ofiiiii :ii 1,36fmiisiniiered ariip tdiorte ul 2 ekso studyiiiii,
iew eerpae e asatr h nta aladcl'oi
resuiiiiiiiii~ltsIiiiiii weeo tie no e 0pret ftoepeiul eoti
ARDl and 98 pecetofths.peiosl.enin.....i: li
t!i~iiiishwh i nerv i ew weerpodcbe uti osid"*r
theeica cotet
Theii!!i~i autor pon u htth oldB oxQuesc. ln
h a igh e p r ori on of ad lt s m k e s n d o ................................. ..............................
smokeiii at........ver a..........g w0
haga a l 9d i
B r o n x -Q u e e n s.ii"' B ut......f....a..........m.......................................
vaits h ecn fcoddfaiisws1 ecn nR Vrec
andiiiii 17.........................ceth au ho s~ude U h
inconsquenial.(Tabe 5..14)
Th nlss fteepae tdesiiopictdb hefcta
iwekyatc ae r ttsial eednsne-h,-sm
pepeaerpael uvyd h sm omn ple o ,"elt

scrs.Sgnfcac lvlso cnidne iit ano b:esiati ithutanaalsiif uciepndncwhchteiongapide
no poid. npatiuarth ongrp desnt peiy hemthd
usd o cmptngsgnfiacelees nTale .35,53., ad ..1. an te uoe sgnfianeleel ae upet.Th fralsttitia prpetesof"ttckrte" n "eltvenik"'ar nsffcenl
deie oalwu ocluae ofdneitrasad!io
iificacetst, vn hog tes uatiis ayb "se
!citv ttsis
Fiiiiii gr 5......ta iehedatc rtsaeus n
tn ithe Quen orBrox ate. t i inonistntwitithplluio

values. The lowest 10, were designated as Thtetmediate, the next five
Iand the five with highest TSP values as Highest. Such #Qns did not correspond to SO, ranking(Tabl 4.3.1) and SS t measured for these sites. Families with 2-5. year old children eare centers located near monitoring stations, were recruited.
*was assignedteepsr clsafication of a monitrn
*k tesame census tract, if anbut the Monograph is. unclear
teposure designations for fmhsin Unmonitored census tracts. F.'r 500 of the fanudlies initially enrolled participated throughout the gldy. Bi weekly telephone interviews were used to gather data for deak rates and severity scores as in New: York. Review of doctors' terpds documented 95.3 %of telephone-ourveym-detected ARD.
The Higest 'exposure category contains more smokers and More oeasionals than the two other categois The Monograph gives
o~m-sdusted relative attack rates (able 4.3.15) which show couriate does-not alter conclsions, but the method of adjustOOtis not presented. Although fmles of pofessionals appear a
rrisk than those of non -p rofessionals (Table 4.3.3,ajsmn
tscovariatwasido produce little change. The rewssadlaacal comfinof the aosure categories is not given.
q.4.3.1 7ows that Intermediate familPS experienced 'the
-attack rates during 20 of 25 biweekly surveys, but the largest eces were evident- during the three m6iith anfluena season.
Wonders why the first three surveys were omitted in Chicago, but
t eri York. Severity score rankings show inversons in days of
'oted activity (Table 4.3.7).as in the New York study, which es against this scoring system. The :,relative, risk data mn Table shows higher ARD attack rates in Hug'hest'than in Intermediate
siv families, for fathers, mothers, older siblings, nurser schoo
,ad younger siblings. This result holds both for mobile atid (he. year residency) families (Table 4.3.11), in contrast to the
6*York study. The Monograph does not dfine Table 4.3.12 quntely. If the analyses were performed on attack rates, the
cance levels quoted are untrustworthy. If by "frequency" the
o4rs mean the proportion of families ever experiencing AD durthe study period, then use of the, linear model is Justified, but more iesPiction is needed.
nee two ARD studies have the advantage that health data werq kifierd prospectively by telephone interview, so the recall of the mother was not: taxed as in the LRD studies. The. quality: of the byath'data are probably adequate, and descrip tive statistics, such -as "attack rates" and "relative risks" are no. dob .ueulgids.Hw
ever'some mathematical statistical investigations to compute confimethodology,. especially since these problems are non-trivial. It is y. true that families exposed, to high levl ofuba ollution
erience higher ARD attac rates tan thohso A 't lessexpose, owever, N6r surprising findings:rqjefrhrsuy aey (1) Why do
residentially stable fathers and 'mothers 6erence' lower attack
atesin Boux eens than inRvread? (2) Why. do: *crowded
imiiesin New rk and less educate faiisihcg pera
Summery sk? eeigl se i wt
excesses ~ in weARL-CikO ND atakrtsmslevee ihcso a. can

,1# IhM. ...
The 1970-197tsat Ut is pa
late the daj y ProportiOA o panetks kufferwg. v,
with dally pollutait ie,04 The st-WIROO wore m4p W M rejeV&Ut
and theoretical problem, :ally W'"A
.4 VVIIM;+-Wr
tion (steroids), exere1602 ail JOAP04o
niRrogen dioxide 1 .00 er 10VIOS =7
Fp I
home or. wo4 !ronQt eva Uated, 4 d the stu to
%2t S1q (OlaPellded MIT
nitmtes), and' temp'er 44rf meats mav be too unreliable foir ml _anipgfiil 13MPnt
and whil; to Rdda Ut (184 asthin rA* werq
:MIQW.W.. ples w6ro 9 tiZed 00.
ring sam _#q4i. 10.; .1 *
A.M. the next, introduemig.
PotentisA panelists, reemi'ted froi* f .9,
the CRD questionnaire, or suggested. doctors or UPOW4,40
were interviewed to obtain.. cov"i* 44d
gible, the asthmatic had: to havebeen rmq
lDhysician.and'had to givea. histprYQf twg or Rlpro
nd shortness-of-bre2CthdiFm' th *ear.
.1.3 0.. g e previous
to Jive within two mues of a, m9m toft 4-tog" TOS1610
inent was violated ft9m.time to time and' 97
Panehsts resided: outside a 2.5::mjle r4diutOk
Since a Phy Man was not available to make th qi.jiap
for ProspecuVO candidates certain ludivi" W Ua
histories (such aselderly smokes Withasufta Wt
were eliminated While this, '*6oAd levoll of panelist W, ijumber of filoo -thJW*f4Ot it i4trCd axe -as
reduced i; Q#w*
as to what the bud eli ilit' Wreincl t's OPp$tates O jy: "Highest prior y Lx s tion w4k; to
teen years of
ever six ge." ...In 1474P 9
unproved initial i teryiew.-44e, Opanpjre wasu
asthma from othei 11jut'' thosid
were not implemented. As" ar. a4ellost RIW :
tionnaires and asked.0-Itecord t!7 IlaY
Otalok, or more',tjiam one atta4. 1 Ocomdv;, W04
diaries, and some filledAhem out"Iflor th V&O
sisteatV faA WT:elpoua the*
ed tarottga djaxios w%-9.
; tt A I
were 696P who never reppitod a4, 4, ..: V x T i
Aaattaokever da
Th 1970 1971 ttw CHP88
., -al T I .
asthma panel 444, M-Mcalw Qu t mWIe4'4- e,
i ies at
Du4ng week ei6t,.j3 ;Iiaxias were MAU0 L 0 Me'tA
rot=ed additiojiO d4w-w'O' wBrI re,
telephone promp';.' T64 balJs wer 4 to '0 or
e reqiwe 0%
tholl $3 dirks, sfmt 01 'DrO t t mat
date, for ypicaj wee, i6l
190M-1974 n
pr tono .... . ....
W gather
Beek, IL X and F. Out DWWWOf IlivuUnM&W x0oftwom il%
MAU 77!"U"
0Mve! to CoWn dm m Col M SW 1 Udf VEM01 h i a u D h; d w.
A 77
900jr 2
.. .. . ....

'The Monograph deemphasizes coveriates since no intercommunity
kpfiosare made. Some community differences inaesx
Mdftion, and smoking habits are noted (Tbe242).
r.Dopen rates varied by community. Magna, Kearns, Salt Lake Ci ad Oden had respective dro out rates of 18/48, 24/55, 20/40 ah 14/46 during 43 weeks of study. 8
The measured response was the daily proportion of panelists repatdng' an asthma attack. The daily composition of the panels (age, sex, severity or illness) changes as panelists drop-out and are replaced. 8thee some panelists contmfue thr-outhout the study, daily asthtna assadk rates are statistically dependent, which complicated the
Figres2.4.1-2.4.4 relate mean weekly attack rates for each panel to~woly minimum. temperature, weekly T8P, weekly 8S, and wleely S. By superimposing these graphs one oan see that OgKden (Lw:often has higher attack rates than Magna (High). The Mones.
mrphiakes -no such comparison. Conspicuously absent are corrow,
A graphs for Salt Lake Oiyand Kearns.
Ss fe correlations for daily attack rate with daily pollutant
lv6are shown in Table 2.4.3. Sultur dioxlide has negligible positive reatoias with daily attack rate. Correlations for TSP are positive ilasites and negative for SN and minimum temperature in all sites.
a.0eded sulfates are negatively correlated with daily attack rate in treof four sites. These correlations indicate that SS, SN, and minimmtemperature are usually low when daily attack rates are high.
W e ,the opposite was observed in New York (Table 5.4.3.) where SO-shows negative correlations in two of three sites, SN is positively carrelated in al sites, and 88 is positively correlated in two of three dts. While these conflicting correlations may have descriptive value, thi gi cancer 16vels in Tables 2.4.3. and 5.4.3. are untrustworthy snbe daily attack rates are statistically dependent.
This remark applies to the multiple regresion analysis (Tables 2.4.4. 61al 5.4.4.). Researchers at EPA and collaborators have recognized that both the daily attack rates and pollution levels are time series lith autocorrelation structure, and they have begun,* to explore shoernative analyses. Stabbings 11 noted that autocordelations affect matiple regassion -parameter -estimates and mnanioneI te need for audbbds which ould detect lagged relationships beten pollutant and attack rate.
13loomfield 17 responded, 1by suogeating an, analysis of spectral 6earetxce to relate attack rwate and pollutant level time eries Hawalkid *, recently suggested methods based an first order Markok structure, and French et. al. "I recently uoed an informal but sensible analysis to relate pollutant combinations to attack rate. ,Even if daily attack rates were staistically independent, so that the significance levels in Table 2.4.4 had meaning, one would need to exercise caution when inferring that particular pollutants are associated with daily attack rate. This is because daily pollutant

A4 Itebings, t. Some Prbles InthDebsign and Analysis of Panel Studiesn idenlo Seminar atrV ne ta' D prtment of Sisticsm. Ogobr 18, 194
ft looId, "Spectrum Analyssof pidem6ioga fata." Updated srn rom atheDeptmnt
d, "Aaytof Panel 8tudies." EPA Interna bra)?00 070),
11 F .ren Trammkin TrI a"..r pe m .*A Sietud Abmhrns nthe LgmdAngelbsthein*

levels are correlated. Table :0.4.3.). -Rid 20
lied to the Salt IAke d aW to stigate "mulfi
aPpollutants show that tempmerature-: adjusted $8,effe Thia-result tends to support the Yypoth*sthat SS may, be
"ments:4 static tieal
but fonnal aro "A
To compute- the relative risks in. Table 2.4.5,.t.(and,
from. all d with minimum, temperAturp.. betwoca.3
mtegrated V02 less than or 6aual to 60*g/M3 were total number of attacks was &vided by i& tottil number tpo"99p days to obtain the rate 16.9 (Tahle,2AA Ratios of .BU,64,Aumb were, termed "relative risks.' The st*tis6qaI;,proW -Pf
relative risks require furtfie study,, Since the days::contxibutq"""-..&tically dependent data. Also'Ao, consideration is.. M*en spec* nations, of Tollutontssiripe.. the same days. are used (except with missing pollutant datw):. for ewh -polltitot. TJw o- y* cre&seg in relative risk occoft on, days wiffi, hi& temperatures, but these relative. risks are, based: on. wim"AWIA few person-days exposure., and 41w corr;espon4ing inm as York (Table'5.4.5.) are IIDJ P-MSKVC4, t X Irl
The "hockey stick" model .' uged to determ''mple threshold ia i 4600A. parameter non-linear model (attack. ratev intercept, tbreshcQJq squa
suprathreshold slope) which. the &vtho". !it jiy JeWA .
fidence limits am not fAot-the estimated, slopes- o#d
nor are these ajnropriate since, the..daAyattack -ratea am aAd possibly h6teroscedastic. (Le.licvvithl.differwt Monograph gi Analysis of rR "dualsi..., the
ives no W, no,.is:.: Or*W. 4 W-1
plotted on the fitted graphs kfts, 24,5. --U,74) Thuat thw,,.o camiot assess whether, the "h mkey $Ack)' wWej: fit*' thovd&t*-g* whether the. data suggest, that:4 tbxesh Q evow- e4W,,)Q scstterplot of SO,.data does not'wpport.the ooncept,.of w. Jjira" AtcK and it is likely that uncritical use of, t1w: hoolgo sOok t -00, W* 0, f
led to estimAte! of non-ei I stent tbteshWds,4w c 1, ..P
The Now York asthma studies;h". similar pr#p "- aOd, tl eo*dir
difficulties as documentedJw the. 1970. B.. ReIPOO-2IFig0mjI" ;. that Report shows 74 of 80 mailed: diaries,:were 'Die a Which *k.
required telephone prompting-, or interviov 'mg. Elevta, of 43, V"rh& panelists dro ed out during the stud,
PP Oc rab* for
head (8/38) awl Queens (11/52) wor. M&W Of A=
nual Report N). Supe positionn of the Figures 54,1. ,6.4A! Ob4WO that Riverhead of ten has lower weekly attack rabes: thAWQtAmw4I;5ut such data is notgiven for Bronx. Prid 435412plio Of
New York asthma. panels using tbo the Monograph suggestthat SN Von bbpr Ort"t, xisk, jw*m..
than SS. The Monograph) giveCawzdativw. risk-c4oulMion, 0' Arl'_$W* and SN was discountedin. corwafion, and innhiple'rV W'634wlr in 1970-1971:SaIt- Lak ajad We* Xorlk, studies ,'," iiW ri*- VAd* from the, 1971-1972,Nevr York study',confitm,4kit,1970 -19 7,1
-A I I 1 1A I A.1111 i lft:
20 Smitb, r..T. 0., "'A Ridp Ptegression Anslyab of the CHESS Studlei; SWt IAke Asthm 11 Undated EPA Intemal Dr9fL
Cresson, J. P., I ebo n,.w. C., m,,RweadPn'u&vHoWex;m* Vti 22 DemIn, Ir- W. P. "To Memorandn-m tifts Resamh Wive, My,
W Pravda, 9% "OMMU14ity _H 81,tb SUAW NOW' Tort- 0_%7]
]H;I to EP.& (Dee=ber IM,

t S. 8wth daily attack rate, but the effects of SN cannot be clirentn since SN is highly correlated with TSP, RSP (respirable suspend edpaticulates), 88, and 8S, in the 1971-1972 stuy Comdrso.hfe conclusions of these two New York studies bu the
difiol f associating a specific pollutant Wit asth a rate, but studies show attack rate is associated with daily urhan fpoluti on."
Thse panel studies suffered from several practical and theoretical iefiecies. Panelists were not examined 'by a physcian and eligibiiyrquirements were somewhat obscured by, a "priority" system ,0,awodaxy selection. Numerous factors known to precipitate asthma %Aswore ignored. The analyses failed to consider autocorrelation iAteasthma attack rate and daily pollution levels, and the authors ew- t 'present spectral or lag, analyses. The apiiance levels preehedare untrustworthy, sine the attack rates are dependent.
Thesttisic used have descriptive value, but the patterns of correlaionbetween polutants and attack rate are strikingly discordant
she~I adNw York. It is disturbing that Ogden (Low) often
hshgher attack rates than Magna (igh),P and tlus observation reqp further investigation. Although 88 may well precipitate asthma 5itak, the hockey stick model used to estimate thresholds was ntsown. to fit the data. Tentative fin diof the 1971-1972 New
asthma study hihih the difficulty of relating asthma attack
rae oa specifle pollutat.
a 1 commentary emphasiman limitations of the analytical methodQtoyand problems in data collection because these topics are scarcely aoilnd in the Monograph. The panel strategy is nonetheless an al~rprat tool for studying the effects of pollution on selected iglh .plations, and the statistical methods used provided considernae.,hsght in exploring Dssible relationships between pollutants and asthma attack rates. eJ fact that time series methods were not umand or that theory could not provide formal inference (without sai as research) for statistics such as the "relative risk" should. not oewseethe descriptive and exploratory merits of the methods used.
Iese 197(0-1971 New York studies attemnpted to associate symptom
asraation in high risk elderly panels. with daily pollutant levels.
Siiethese studies were simillar to the asthma p anel studies, they shrdsimilar practical and methodological p Nbes igr 4o te Biannual Report25 shows that recruitment aried by community. .iverhead contacts came from trailer parks and from recreation and golden age clubs whereas Queens and Bronx participants were concted on park benches or tlu-ough the New York Rlousing Authority. It is hardy surprising, therefore, that Riverhead (Low) participants were generally younger and healthier than those from.. ueens and bronx (Table 5.5.A.1.) Candidates were interviewed an questionAire information was used to classify them as w ell heart, lung, or
herWung panelists. No previous or concurrent phsciandigos was specified in the 1971-1975 protocols althoughg the Mono


be 60 years of age or more. In later studis youngerRW ur accepted and some candidates wer found outside the 1 nw-11toring radius, especially in Riverhead. \
Substantial numbers -of enrollees ouDT&,ft dtu i
many because they wrtosick, hadfiln diary, or just found the'study bothersome 1i
Report A ,'
The Monograph ptates that dropout rate ecede ith 4in and Queens and approached 30% mi Riveprheatd. *
Many panelists failed to return weekly dia ribs F-on 5
Biannual Reposrt2* shows that only 49: eof .80 i itt 9 Glub provided useable diaries for the week: Novemhber 22 --28: 6A& i@ sponding fractions for Bronx and Queens werem' 39/09, J %'tM fraction of useable diaries for there heart, lung And' hear edi was usually even smaller. Thus Brohk; Queensg Ad. ItvleAl respectively 24/47, 18/40 and 10/13 heatrthin diatop and 20/26 lung diaries and, 26/50,: 10/52,' W 27/13W 9 Mailed diaries were replaced by telephone fiterview inth& 3 protocol.
The high dropout rates and poor'weekly diary raper. MAl the generality of these studies since Ithe idat was: genhoer by dBA6 selected population. This fact also complicatescom i
Panehists, were asked -t6 specify dailyr whetfar. qmpOA-4' e
worsese" "(much worse,"I "the same, "better," v"ei Pf
an dily agavation rates were COni' e Ash the. meft ', 1
plus "much worse" divided by all partiblnts'that-day.The W worse" category was eliminated M'in sbqued goftoolps .. .2 9hows that Broax and Queens bggra&Hle raesar 2
than Riverhead rates, but the authors db niot ascribedel :fi qv.1. to pollution since Riverhead is known th' contain: youtrI panelists. a
Figures 5.5.3-5.5.6 relate composite WekY y tn
rates to weekly SO, TSP, 88, and. SN for the R-verhil' heart-lung panels. We aggravation raft sees to Wiwse it m SS levels. No such graphs, are given for Bronx nor for wH hear and lung panels.
Table 5.5.4 shows that SS is positively correlated -wtidy pp tom agvation in the well and heartrl=ng panelsb ae
significance levels are, untrustwvorthy since dal agg.onit and pollution: levels are, each iautocorrelte.Mlh analysi s confirm s that, temperature adjutedSS s 1.
symptom agga'tish,' especially in tehatlna 5.5.6), but these siniicnc leel too eag only bet ive indicators. Be'ause the Iday PoAtaant leti kre lated (Table .5.5.5), specification of a partleolar pollutant foliti concern is speculative. However, it is inpressive that ote-0 have little explanatory .,power irt temperatures ih& 88 whereas SS still explains substantil variqation i didl* atida
iiiiiiiiiiiiiiiiiiiiiiiiii W ,9

rate after adjustment, for temperaor 8N, J TSP Timl
5.5.3 shows that daily 88 was stro, y peatively*'oM~e e.:I2 Shortness of breath aggat"ation in sixpanels and stro gly correlated i'ne.Tese figure ar& deie4f1s 6 .'.
* Thid.........

es that the correlation was strongly positive in all three
panels, in two of three heart panefs and in one lun iane] Temper-ature specific relative risk calculations tabless
al sso suggest that 88 i4 associated with increased symp
t~fi agnavation rates, especially in the heart-lung panel on warm
9 &h i table is no t presented for 8SN. All these me thod s sugges t
&'h*1'4901tky btween SS and symptom aggravation rate in hearthin&ndus. It would be interesinf to know if the SS data indeed ek t~da threshold effect and fit te hockey stick model in Figure
Tft e avre dropout rates and low weekly diary returns (especially
t~i'he eart~ang, heart and luag panels) raise important questions 48'tbth trDe of respondent and the meaning of the response "'worse." Th6 Aitickal methods have the limitations mentioned for asthma
Pai~. 'Mreover, a subsequent New: York 1971-1972 study 28 failed to cnfir the dominant importance of SS but did find that S, SN, :S0, nd"RP'. were associated with symptom aggravation of the well vnl.' (Ts study did not use the same analysis as the Monograph an1,"M-:particular,. did not include temperature adju sted multiple
grpsin or. temperature !specifle. relative ris3k ealcuations.) Noneth 19702-1971 data suggest an association between symptom
otin rates and. various polutants, especially suspended suliates.
1111 fte, hoi4 nneti study of ventilatory function in scho ol children p~d~dd: CESS,. -Children from schools in an industrial -valley at Vkenn~ti were compared with children from schools in a nonir~br~alriver valley on the east side of the metropolitan area. Two a efmdile, white, lower-middle white and lower-middle black 'geh~lswete, selected from each valley. Air monitoring stations within the blocks .of the schools showed that seven month average TSP vwes were from 18 to 32 yg/ma higher in the industrial valley than -in tenon-indutstrial valley, but corresponding differences for 88, SN & 6 ranged from 0. 1 to 1. 1, 0. 1 to. 0. 8 and 0. 6 to 10A4 respectively .,(Pgur0.*1.1). Thus,. the industrial valley had more TSP than the
-nn 4nuetrial valley, but *its levels of SS, SN, and SO2 exceeded thiain the non-industrial valley by, very small margins. Ventilatory Ateion was measured as the forced. expiratory volume at three q rters second (FEV .75), and height, sex, and race were noted to
"-e. adjusted FEV .75 comparisons.
Th@- Udy wag confined to 394 second graders -who participated in
ekymeasurements during November 1967, February 1968 apd
988 Thse tudntsrepresented 93 percent of second rdr
M te classrooms selected. Mother were interviewed to obtain seeiomumic--daa. The educational, attainment of fathers was: similr to
ending, schools in the industrial. and non-industrial walleys

,wAure 6.1.3 shows that -average height adjusted FEV .75 in "clean" sceheels exceeded that in "polluted": schools in all three months for lower-middle whites and in two of three months for upper-middle
n Stebbf 8a, J.R. Hayee -C. O "Panel Stadies of MActe Halth Eeet of Air Polla I. Wa punry ftptom in A~fdt.^ Environmental Research Voltan 11 (19M0,. M Ill1.

coemmsunt differences xit Therlaelus.5 eerogl''.4

illili erd th e s es t i l u (p...........................g........
the high cr eata nss of faine hc allw n ots.1

liss mongwhte secodgxrae in the i those the no omn- t ffcindustrial valleipyu.onid~r~
5com13.nSchoolsferee xsitTe ithi in 1ht.5spned.Iae andrRivehead Btronx nQuee (age 6-)iwereane i i* Atew hceltonc siometer, then amNtheepluaus,~ teibite sis drprt perhaps io6 mitFV.7 s31 c deed byo fidtease ho hradr iffhidut ilvle ta ahs nd wh on- sevral trisltlem The June 1971 Prgess Reort gveniaostd nlddcidr;.Ia' 5te 1Sproleter, sind ted Asithn 1. ilooxCESui on anityertent, Bofx Halth Qepes seerpeeneoytre cpl eiability ote m..enireeine an Atngw Chietoi thsPpideioloaa Clne drhifte fetis dagiteras the resultes)Tispo .PI haece bnielystemcsl swbjecd fiutyerdcn maueo drif (especal if7 rif riedp~ in e ase wi onioifiuteswt through ommties). Evten AsiftatCosioneofteNwYr cornmunite o itiuedalrt equallyd teiuhesrain aoth tions.itly incrhoseeasured ts by rao dinu

cmmnityhieff e (60 miliitersoy ess)."I i~osi drift Then Nytmtial GCjcedt spirometer wash replace< dtpespimeter desribved in the ayh 1h oaino prmt evruhcmuiis.Evnioaino the NG spirometers wasusd hr reormtesdstiue theif Monograph.rabliy fth~be Thosisea 10 n97crotocol iynstrct istiuonf ,sncth

proftoco Thi sirdjment was recdi ae17 ya os Nyeo water pesentbed inteMy17 HS rtocl comarwf Rver head, Queensand Bronx ute theoghu ah 0191suy atantwrepre sai th o dereaeaihth BrnThe Monographprotconainsu in etgtr comddctony i habitsacindthees commnthsirl es; nuches"I this cova797 sti sti cll ysi nif t dif feren e s wredft to.......

"Neo r ity He S p oresse Reor" (Junae 971).f hlde suieji

soaitial Be e.D.L sistfiant omifsioernfor th e fundartrrrole ci~
............................. ...........................) .
20 B f Yor CityiLeter t

mgnr D.L AsitntCmisinrfr h iI i 1 s1
Dr.L. ammrActng hie, pidmioogy]P zit ii192)


re t.6.1 shows that inale hegh a ag adtuste E .75
,Vxfrom Riverhead were untermedito between Queesed Bronx
V~i-q 'or three of four test periods... For femals the Riehad
n eceddBoxadQueens values in oe test period, but
ahe' difeences were usu1-allyF less than 50 millilitedq Table 5.60 shw tha Elverhead height adjusted PEV .75 values wera largest during one. effour test periods for youing males, three of four for older males, onp of four for young females, and three of four for older femaleas.
Tksthese differences were inconstant, and dren fbi dide females, t~l~ Aeage difference between Riverhead and Queens wae only 42 AMises (about 2.4%1/). Table 5.6.6 is puzzling shnee it heludes a & as e.of freedom for "ethnic differences" no-, described i the text. 2 ahps blacks were included in this :ta1%ys.;is. The mulitivariate
aYis. of Variance used in Table 6.1.5 is itbore. appropriste' theti 4veagm., over all test periods as in Table 5.0.6. However, the analyses
individuall test periods in Table 5.6.6 show statistically signi~eant d4V eces for older males and females.
'Te inoinnati study demonstrated small (less than 10%) differences inK. 75 between white children in school located in a nori-ind ustridl v e and those in schools hn an indusial Valley. For New York, SM inconstant differences were found between Riverhead and Quen-Bronx only fo older (9-4 3 years oid) children. Preliminary aa lsis of 1971-1972 New York IHESS writer and spritg data a pam'd with a bellows4# a ffpiotef shows that older Riverhead chidren had statistically sagkhificantl higher FEY .75 values than II on children in winter anit stistically significantly lower value 14 s.Pering?3 In view of these findings, the problems of spiromieter drift, g&Ud the possibility that older chidretn in Bronx ad Queens smoke
mor tha4n in Riverhead one mnust be cautious in linikitng New York pollution effects with ventilatory differences.
CHESS has conducted two types of studies not found in the Monograph. The "Episode Stuidy" measures rates of discomfort (cough, shortness of breath, restricted notivity, and eve, throat and ohest discomfort) during control periods and during air pollution episodes. A 1973 report shows higher rates of cough, chest discomfort and restricted activity durin episodes of high air pollution. "Pollutant Burden" studies are designed to quantitate the levels of metals and other pollutants fouitd iii hthan tissues and to relate these levels to exposure history. Sodlp hair wao collected from families participating in RD studies, maternal hair, blood, cord blood, and placental samples were obtained foin willinggshothers, and various tissues were obtained at autopsy from pathoiogy laboratories.
This assessment is made from the point of view of an epidemiologst. More global judgments, made in consideration of the quality of both epidemiologic and aerometric data, are found in Chapter III.
31 Chapman R. S., Hasselblad, V., Burton, R., Williams, J., "Air Pollution and Ventilatory Function." EPA Droft (1pril 8 1975).
..~n-r,.J., Shy Ck M., Ens T Sharp C.R. Andaman R., Trunni. L. Van Bran J..
i~~~~~ii ij A t .............. ............................................................................................................ ............................. .................................................................................................i. ......
daF a i y u r e s f r it ti n S y p t m a'I"
rouutin Conrol Asociaion, olume 3,iNuberi2(FebraryiI)iiPp

N o ii fo ma m t o s a e u e to ln .............................ifi

helhefet n h D,,D eniaioadA, t&eq1I

de ostae helt...freceb.wen com..tesU...t ~
iiiiii explaned i term, it 1's igineito=
a ci b e t o p l u i o n T==iiii h e R t d e o v n c n l e m o n
s m all iH i i n cre............................len ce o f p rod u ctiv e .........................
................... an smelter. s....i tes' .... The retosp cti e RD tudesiiy av
dmntahighrcruiidbrnhtiiitsincidrniinp~lt smeiiiiiiiiiliiii leii co mu iies n hepop ctv R aerter O

vicn !dmntaiga nraei ct eprtr ies
iiiiiiibnsttns heCninaivnilto tuydmn sallifrneinFV.5bten ht eodgaesatadn scosinidsraan o-nutilubnvles ftea'mee

...... G E N E R A L H==H ==HH ==H .........:::::::::::::::::: ii~iiiiiii ii
th poes f ntrieig P prsnelcncring CHES

iient ideas wer aloiierdiythiiApesnnl
Th HS rormn on fiillyeist wihn P ecp

as~~~~ a itrclrfrnepit dnnsrtrTano p il hcm fikea f hae al dait fom te pogra.anlyze.-b m i,,1977,o
Howeerthe ffot wthintheHealthlffets Rseach Lbortor
diretedat rocesin th seeralyeas o daa reai 197-75
tinsnklzed.fro th CHES sudie isproressng loz.A frce chane ofcompters(seebelw) cusedmajo dely. Iaditin


The team found strong evideneof a continuing lack, of coordina~ft.between field and Headquarters and insufficient coordination~sjmot*,1 renal programs, Envirenmental Research Center Laboratoriepsaoxb. tractors, other Federal agencies studying health effects -of -sit pollutants, and Headquarters, not onyin tota program "'ft mi but also in program coordination of quality cont1;rol, smple or 4000 and analysis, and standardization of health effects- dAta collectic, tools. n
Schedules 33 for analysis of CHESS data. show that CHEWS data were collected from 1970 through, 1975 for astha cardiopulmonary panels, and ventilatory function panels. sureys for acute respiratory disease (ARD), and chronic disease (ORD), and acute episodes took place in 1973, 19741 ami 6 respectively. CHESS surveys were completed for 26 asthma 12 cardiopulmonr panels, 28 ventilatory function. paels, 14 12 ORD, 8 episoes and 8 acute lower respiratory. diseaoo d;: this period. The Monograph reported on only eight Al pe, p conducted in the 1970-197 1- New York and Salt.Lake %tAtis (TeRocky Mountain, Chicago, and Cinci*n.ati studies containal iW the Monograph were not CHESS studies.) Thus, :CHE4SSgertl only a portion of the data analyzed and reported in: the, 1974.
grp, and the Monograph reports on only a small: fraction. jof
0The present analysis of the studies proceeds. in steps; FRE e, survey data is edited far computer processing and subjectedrto timinary statistical analyses. Then an epidemiologist. writes 4 an the basis of the preliminary statistli-al analyses of heal th Amage metric data. Other analyses may be done if judged necessary U, the epidemiologist or statistician. EPA staff have tabulated: thedfrato' of surveys subjected to preliminary statistical analysis and the fate for which a preliminary draft has been written?" Drafts existfq4o
8 episode and 7 of 8 LRD panel studies. Drafts have been writibe Mr 7af 15 ARD and 8 of 12 GRD studies, but no CRD drafts ha,bepps written for survey years 1973 or 1974. By comparisonash ,c pulmonary and ventilatory function analyses are far behind sced Of 28 ventilatory surves, 10 have undergone preliminory ,14 and 8 drafts have been written (as of June. 28, 1976) .: or 25 a
surwys, inehave undergone preliminary analysis and nine
hs een~ written, and of 12 cardiopulnonary panels, two, ha-ve Aqgg analyzed and two drafts written. Thes figures substantiate, the dge to which the CHESS program has falen for behind, in ania "d writing up survey data (61 data sets are yet to be Writtene-up).
The figures quoted above indicate that a maxnjor bottleneck inlh
analysis of survey data has been the preliminary editing mad statistipa processing. It should be noted that EPA had little or no pontro iver two disruptive events which retarded prliinr alyses b y a P~r more. GSA. ordered a change of computer from, ILBM to U-m"vWa An August 1974 as part of a. general: government, policy related to oppipetitive bids. Both hardware and software conversions were dii" t and most programs had: to be completely rewritten. CompoQunAug.
A Unpublished 4Oble giving dates of CRE8 data collection prepaed by Dr. DoohyClm?,%A RTP.
=Unpublished tables showin chronology of survey data analysis and dra!,t rtin preparetby rs. Carl Haves and/or Kathryu Me 'ai (June 28.,1976). E[PAIRTP.

this problem-was the need to rely increasingly on outside data processing contractors, since increases in EPA staff needed to meet the increased data load never materialized even though verbal commitments had been given to the laboratory directors. SA contracting 1 1. r cedt"g. required two changes in data processing contmetors etween 1972 and 1974. Other problems impeded the preliminary s tistical' analyses. The loss of key personnel imposed new scientific and administrative burdens on rem&m'm*g statisticians and epidemi016 W ts. Moreover, responsibilities of the Statistics and Data M anagenient Office were broadened during this period to include ptojectB with the Toxicology and Clinical Studies Divisions as well as special tftsks such as preParing data tapes in rerponse to outside requests for EPA data'. CHESS analyses (Populatioii Studies Divisdon) now accomt for about half the Statistics and Data ManWment Office work load. Rowever, the most important delays in the prelinimiaxy analysis ate attributable to the forced com puter change and to bfems with "tside data processing contractors.
I,%e epidemiologists chakged with writing a draft monograph must ,a*ait receipt of aerometry computer output and biometry out Ut. RpMenindologists interviewed attributed delays to the failure of We'se piefirninfirv analyses to arrive and to subsequent changes in aerometric vifues used in the manuscript. Other problems retard the ep dermologists once preliminary analyses, are in hand. To begin with, the, Population Studies Division has lost many of the important early 'Witb6rs or reseaxchers within CHESS. It is hard for. an epidemiologist, Aot, -famfliar with the background and history of the data collection 'and'faeod with two computer outputs, to assess the quality of the datw and to obtain specific scientific guidance. "; Moiilo is low, and this may be due in part to the loss of key personne1jo investigations of the CHESS program, and to organizational itmtsbility affecting Population Studies. Furthermore, during the p ast y6ar, epidemiologists have been encouraged to pursue competing scientific interests, and they have had to shoulder ministrative btirdens associated with incresised reliance on external contractors 9&d to: nieet special tasking such as the Kepone Task Force.
It was interesting to find that several epidemiologists interviewed .. omplained that the current team structure for analyzing survey data d6os not function well without a strom authority to resolve scientific and scheduling conflicts betweei emiologists and statisticians.
Whil6 these factors and lack of staff have not seriously impeded the drafting of CHESS reports until now, they may become pressmg p robleins as the backlog of preliminary analyses clean the new computer system in the near future.
The continued delays:in analyzing C dat& have had several adverse effects. Contractors &the survey data aind ana" have been embittered and demoralzed by lack of dal a an 6edback from EPA. The failure to provide contractors with timely aerometric and health data summari s stifled local initiative in analvAng the data. Thus, the CHESS program did not benefit fully from locj field level insight as to local pemilaxities of the survey and populations or from comparisons with independent local air pollution measurements and data analysis.


The following comments are largely specuaon based on interviews with EPA staff. ,,
CHESS data acquisition ended in 1974-71975 when O i1 approve, questionnaires needed for. the. study gad 'O I the forms, however, it? is likely that 6 asthma, 6 ventilk
2 LRD and 2, CRD surveys would havetknyaei lustead the Populations Studies DivionW .' 9k 4 Ag
data and made several proposals for non-C S studies,
on cntrct.One- of these is a coho16rt study -of, ventppy in adolescents which uses a CHESS endpoit -magre but does not use a cross-sectional CHESS.. replicate Another uses the CHESS ARD end~point the', peak NO2 Values. One study entitled "A study. .a Det Health Effects Associated with Empissions frm Col and Coal Gasification" uses the CHESS ARD' an7E iep to study the impact of coal combustioxi, andgsiiap populations (Hair, blood, and. uiesmples are- also '4 aSay for poducts of combustion and. gasi iaton). Ohe studies do not use CHESS..endpoints.' These ilud -(1 mortality patterns: in Montana, where excessive..cance has been noted, (2) a general household heal. 4uvy i bers of a community located: near. a..n ew sewage -treato
(3) a study of trace metal burdens found1W inth hai blood of people livig near non-ferrous smelters, and (4 On v4 hyperactivity and cognitive function. in cldre wi lead. burdens. These proposals build ,on CHESS -experienle, do not embody any. continuation. of, CHS uvilne,, ,only one -study plan. and questionnaaire: Was, approved.: by. the -time of this investigation. The continued.rssac approve new study forms .and questionnaires. is a greAt to the researchers. There Was, atrongIR feln vde4tJ sistance stems from a' misguided assessments of siftii a
much as from a Presidential concern -fore," ht ofpvs e4 The Scientific Advisory jBoard (SAB),1has-i short p, expectations. :The staff .members .had hoped :01, work, .SAB to formulate and refine ne prp-lsint provided-only formal criticism, expremed is ,publime ki4 by press and industry.. This Ji timeo whop. thqEPA, etaff, leadership from a Director of Popula;ipr tdqan g
normal working relations --ith. theg SAB7. W
33 Table, of proposed CHESIB studies fr 1975-:.490 peae plIys iiiiiIJ
Ilkiiiiiii' IT W

A. Usaceac'aoN
ialwAys easier to look at the past agd datest mistake than it oto look, forward and avoid them, Thers.'are lessonsi which cam be leared from the research which produced the.CITESS Mon we ph aw wel as from the efforts to process te balance of the CHES Piata which remain unanalyzed and unpublished
inyptigtv report supports mud of the, criOiimo h
SMong, p adeeloped by other earlier. and independeist
exem. For exmla report prepared fox t54 Federal tngg
Mlnstr#' in 1975 describes the use of the invalidated version. Of' tj 14' Medical Resetich Council questionMagire as. limiting the, tefab~ of the health effects analpyis Wo prograxas utilizing tlus~i
hdh in diestor. The Subcommitteeme aio'td thisU sa .e
defeet,. na readn h lssOf therdits 94,asthma attacks
igic 0, ,serious dicrepancies. In the yogeort to F"however, ihe sigiare44 of the errors im the aerometi data which are detaile to te Sucommittee's investigation was not tly recognzed, r
their xquiew of the CHESS Monograph, the EPA Scence Advidry Board. (SAB) identified many of the same problems noted by,.theA investigative. team, agi puarily in the epidespiiological areas. Is the SAB, or so called Wisab R R ort other deficiencies
i= ,Og: limted population sampling control; ltrtoming in' the
lastio sedfor assessment of past arpollution levels; varations i4 swa* populations which-limit comparison of comuies hig
Arp-4traesi st m~aels; iadequate cnsideration of tempra-ture as an unportant variable mn consideration 61 asthaa.*the s; a soan sueern about the, problem :of gainn ifznin o n n
Aaalexosr to pollutn level. All of these points u~kphr are eagrmed by the Subsommittee's investigation.,.
oad in. the legislative history of thispport (AW44ix B q other
14,opnerdat investigators ,also had, offered ncriicsm ptthe C11 Nfpig*Dh during the .brief, period of peer review liph so, pror to publication and this criticism &lW appears. to. be oH foundp.. for the most part. In separate talk with researchippi 9 had
p atedim some phase of CHESS or ha.4rie %flo
rpreasepf the CHESSjprestigati# s d'rve of d ata e 's,
th Sbommittee investistrs ha/cainto p npaaecn
fi atiesv of many of these;sam iocrsapt x f g
qesionsips ha eao s e for. Pooe
ast piethods of autysi, 7

W[GHES Progrm. A BeportelVevietr PPettam.~64 dr Ognltee, March 14, 1975.

77-90-76 6-7


Thus, the conclusions contained within Chapter III of this report #M not exceptional in th ir general tenor. Howe vei, ithe 4i6ous err6n 14 the aerometric data ang the verified s .,In;-Acant effect of the roo r quality control during the early stages of the CHESS air monitorio 'git. measurements and anoyses efforts are identified more the: first time by gh'64Wde mivestigatioji,
3B. ';OURR
Moving -froni thb histo'tal PersP&tA#&-tn
be asked wh ther tht errors sugftsted-m- othit rmfirtmed in greater detail by the hW6Aigatilv4 teard ato b, addressed M : thb.x cuitent dnd Pnned tavironment AgenV's a yollution/hesltji effects prbgraim"
It.was R ifiterest 1 fh4 to determine the'q oi) aW A". ".. al P *f -.A.
C11kSS:' data whil'srew ain una-n yzed kiid theib data will ",44T6r ftomthe imo6 or. other disctlepfl ft
ted in th -197-4 OHE S Mo 2 K
present 0 hograph. As is d
er (V-1),4b disopu sions,',YvW end of th6'last 9hu'pt' In s
anl 'P. stigativete M 4e
Research Tti 'g, 6 ark, the in*e still remains a coniadd7abi6 AMoJ A a trtlysis, to be from th66 ftiterAu*
"pressions gaMO. wa's thab It"I",
least until the di'of 19 77 bef or6 th,6 "final AjjgeM*, T
examinationfoor potentid'an, and publication would b*
owever as note
0,,eailier in'the report Q(,%APkr, VI)
draft studies were completed A the. fina6 -4 tfi A its to' e mple, draft fe e 6 e P.rvj) are r, ports have b & 16 6 ,of-fl e
episode type heattli studies and for sevell Of fli i
reSDirat6*y- dkak 'stu(r Se*en A the renitt acute
disease studies h'al*6 beeh, propar6d,.: And 8 of tho'r6lia respirator disdit4 studies hAhd.'No &Jraft of the" *dstAA& rbspiratory diseage studied p eArs t6 be*i6adk-'f6i*t6 1913 or 1974.AiiAyseg p A number of 6*r effei&
'The ge" er4-" 1r, ig S at -iwtfflj1:: ,1
r6quir6d'for "the., basic transter.of field"& to edmi Are
1nftjysi-" Ulaf ortunately sen ps i6serliEffl Are mvestigatil e, t a t, el- ol'these A 0e: e
'* 6 JjSeL
t. chniqu
cri Icisms a otii the d collg6f' ih6liB
ii fbrmadon in- the C ESS MoTio&aph c6ht mde to,, t4o,4atii'agWip alated after, 1971.'
Ile est9bfish1ne*tLt of-i more igorddsi (taM
to' havo M 4 r otV 4 'the. 611e'dioili of ,-aer6m d k6a, itf A- t Ai
fterQ tri "i6vie* (Ohapie 01A ffi fl 60, as Wed id' the CIIM" di*"WN c
iefifib "JAe rdi jo"6t'th iv V
ile cfaii in t X i6h
SUndaids. Thif91It is, aely %it" bO A not
CHESS data would achieve the desired W6 fi tk- er lk i
41:p74 Wax
adeq"to 1AP 9W *#ed,,F
64114. cVWM 4z 1 4
-inpork 4h"
p0eiv-j- 4-- jaw;q
all reseamh components.

sulfates were identified within the CHESS n onograph as b.eiug a pollutant requiring an immediate increased priori y of mvesti ftd6W' the investigLive team attempted to determine the status of ; rk O'n': 1his pollutant. Mr. Train had indicated during testimony V Pn P I
chite, We joint hearing on A *1 9 1976 that a five year plan for
dy-of stilfates was avii1able. Actually, it was found during the
*est ation. in the summer of 1976 that the sulfate plan was still in drag forr althwigh passing through a second iteration. There was some indication that even now there is not a full appreciation of the
t u=
need for pla i i tput with regard to quality control, air monitoring, instrumen- anning, structuring of health effects data collection
proce ssing of data, analysis and publication scheduling. The requirea level of cooperative preplannm'g does -not seem to be present. In a letter to the chairman of the Subcommittee on the Environment and the. Atmosphere (undated) in, May, 1976, Mr. Train summaiized EP Aps projected research program on sulfates. In measurement and monitoring, the emphasis in the draft plan is
placed upon the development of reliable analytical and sampUn techniques and instrumentation to support laboratory and fiell measurements of sulfates and sulfur compounds; the development of quality assurance programs; data audits, and providing technical support. The ongoing research and near-term research is aimed at increased data collection on sulfates with emnhasis on measurement methodology, instrument development and &1d tests. Emphasis is to be'placed also on the development of reliable models to predict sulfate concentrations and precursor emissions over long distances. The plan indicates a recognition of the need for instrument and field tests.
A continuation of the concept that more data on the health effects, of sulfates axe needed is reflected in an intention to expand emphasis. on the toxicological, epidemiological and clinical studies on ther effects of sulfates. The plan includes a recognition by EPA of the difficulty of conducting epidemiological studies, particularly in correlating ambient pollutant (sulfates) concentrations with health affectg.
With the exception of the paxticular emphasis on sulfates, these o jectives are essentially the same as the objectives cited as necessary upon the initiation of the original CHESS studies. If these objectives are to be achieved in the near future, it will be necessary for EPA to avoid the errors of CHESS. It is not clear either from the proposed program or from discussion with indiyiduals who win be implementing these-programs. that some of the basic errors committed during the CHESS studies will be corrected before such field, air monitoring, and epidemiological studies are continued with different oRutants. Certainly, the manpower problems have not been = ,
lu the aerometric area, the CHAMP aerometric measurement and shalysis is entering a new phase of development. It is essential that the aerometric measurement and analysis errors detected, durmg 0 CHESS time period be eliminated as the CHAMP effort is expanded and greater emph A u on this program. The CRAMP
instruments, when verified may E: canable of
asis IS p ar idenfifyi reliable
differences in absolute air D01111tAntli4ai: but the iwb ta wiH

be pushed to their limits of sensitvity ad wid. require attention by skilled technicians. New intrumne i just1 0 May be. able to. meet the ultimag re* t iear
health effects program. ..g
Sound program of developmentad ig( ripg
naires and other approaches -to epidemiclogcal reo swh oV2 mounted and completed before. another CUEE typW initiated. Completion of both phases ,,of ch aEora topp the tools and techniques for a sound he th eff tc*p; require up to -2 years and 'several mil n. dail# not carried out, progress iathe area is de +tful

0 i
ii~iioI'um'm 'mAiti46jiil

iii~i ......




Aw f t


aj~ section contains citatiens of errote and omissions found in a ft~ulreview of the CIIESB: Monograph which show that the use of Manats~ and meteorologists data in correlation, with health effect& endpgoint measurements can easily mislead the rewder of the CHES& d46itn ad Into inferences which are not whoity or even partially supported by the data in the report. Page, .par srph, and figure ref mances are to the 1974 CHESS Monograph.
SiBee an important application of the serometric data is to determiecorrelations with health effects, any errors or overusage of ass~eMIe data baswd upon estimates or Intprer measurements wiln obviously reduce or negate the value of any health effects correlations. wkiah are attempted. This tadenege or everusage of serometric data wti be particularly damaging as the extension of the conclusions is audWi an stmpt to discover possible thresold effees

&. Pevalence of Gwwmic Respiratory Disame *mnptU in, Adulds:.
.1970 Survey of Salt Lake Basin Communities
Observed concentrations for only one year have been used to enadely estimate concentrations of sulfur dioxide and suspended s~aiswelating to a 4-7 year exposure. The 1911: osedred annual "econcentedtion of sulfur dioride was used lth the 1971
mkskarate from the smelter to obtain a ratio that was. then mulWtigiled by emission rates for other years to estmat cometraion feltAe other yoes. The estimated saulfur dioide concentrations Vag the used mea regressa'n equatien based: on a 1971 reltdonship waghnste suspdaded slate concentratins. Possible ramgm fin: abdesologiest conditions and mode of steater: opwatlans wer adgietd. Acknowledgment is not given in the diseassion add oum]Inry tha the critical concentrations relating to: health effects are nothing more than estimated concentrations. % I is questionable, whether or not long-term exposure should have& been attempted for Magna, based on only one year's record of obAdvationsa that are abnormal: because of the smelte* -strike. .1It would doiny have been appropriate to, have mentioned 'that only es-, tted long -term' data were available and indicate&dthirw degee of usstainty in the disoneionan smmry

Further, we find many errors on Page 2-3 7, Table 2.1.A.14.4 that this table should have never been included in there from the misuse of the diffusion model (discussed in Chaptp table lists suspended sulfate values for Magna for the years 1* that are not the. same as listed in Table 2.1.A.16, on page 2 -3k values are estimated by a simple ratio from the smelter em issidy but this is not explained. On page 2-39 a reg esio quation is9 the same purpose. All of the -sulfate concerrationg, Under, CHESS are estimated observ ations ercept theqe ri fi This has not been properly indicated, e~bthpuse of
On pages 2-37: emission rates are not sulfr dioxide rates a s
but emission rates in tons of sulfur per, day. .This means that the eitt dioxide emissions were twice .the values listed. It also means thAt the dispersion model estimates are incorret. He evertelteetip< concentrations in Magna and Kearnis, which- are basd ons W ratio between observedconcentrations in 1 071 and some m for 1971, whatever it-might-be, are notcha igd.sti
Note that the regression equation: f4. suspended 4 uoeta Lake City, (pages ,2-39) -which is: La y
SS=0.101(TSP):- 8'5 asa
is quite different..than that, which can, be pbbaned e i.e.: .,f eJoi
SS= 0,065 (TSP+ IS M aiW
SO2 eXpOSurg8 WereO derived by multi tyhig the ylq4 lAr emission Of SO2 by the ratio of the 1971 measured annuala SO, concentration to the 1971 SO, emit ion rate (193 tonsk.
Estimates of suspended sulfates were de red from the estims ft' 80s, using the: following regresion equatio' or197M'i i16 ase .
S~m0.09(SO2). A 6 oaEned

'The annual TSP exposuirbs. were derived by mnultiplying tOeW smelter production of copper by-the ratiof lte 1974.masure arithmnetic mean ,TSP concentration to. .l.491' ope rate (260%000 tonyear).. e ac;. eI
Smelter emissions of sulfur dioxide ini-: th edily41940Ys-wa0ri three times greater than ,they. were after 4966 although a ag S duction has remattised moreor lessconstant, Me 404e forW suspended adfate, which. is base& on; sulfur diotid antI nop very high vsaes in: the4 1940's. whereas- the Wtalsuspend64P are estimated laoe in 1940 than in 19714ThasprdeeddroWe very high ratios between SS and:T8P for tl> arlier yeesiats the71940 *ratio (34.6/#3) is 0455. Thib ai is 44ageit f
-questionablei ani.'1'o1 apodou
The audsofty .of tha.essiitnte can beU1in aue.01
lowest value, hich occured in 1971, is ext *W .lwdrgthvyb 1940, reaching unusually annual.. avera go c iombegaticealotM than one part per million., drn bd~oaotiirtt~~ which w oud reult in low concentrtions m ch of .the time because the


average. It ims questionable that.such coneeAtra tions
-If Ow 4ids would be well-remenihered, and livmg
=m agnswould be.differentAtban in 107 L Such unreasonably Jp* i -j"Uthatels should have been furtbermivestigoed before. being
MM of the estimstAs: mad& ovum es other shortcoming
itudy g to exposure that t be- menti(ined. HowOarefidly made estimates would.1mv6 required considerably .1i m*smorki: including obtafiifiw meteorWogical records, an& dotegs... of
-*Wtwoneratiens affecting .07ume bohaviQr over the d of ears
46h a lap effbrt ,znay not have been worthwhile eonsi abig the inewtness of some of the other aspects of the study. Nevertheless ,j&;jA1WY!- cif this nature seems to call t4 ai6iaW -observatione, more ao,curate estimates, or considerably less, ex"UWw in: its conclusions..
N &%6y 0 Am& Lower Rel F*aM Dw'ease. i4 Chadrent Retroin 4,
P&iiw Simp-my of Saft Lake Sann 6iAmvi7iitiei, 196749710
ame comments apply to this study as for the recedig study
pfevalence of dism uit4 tiD
.,on the to aA4 16i;xz1 9TM
4on is given to the fact thiLt 'anly estimated., po ie ntrelion data are
gj sed in the discussion and ary,
J. sipprabaiin, of Aisthma by Air PeUutaaW: 1971 Sak IAU: Basin

U Ost;tidyy dauy enWee, in a- davy- *ere iied to AetierbA&O weekly tiagbmft, ittae]Vratos. A stAtisticali rekfionship. ww then d6termliba betwft4 the attack rates (weekly) and. observedd, ... pollution.concen-**9dni (averaged weekly). Participants lived *ii.ifdh a 2-Ibile radiu's W ab monitoriiag stations'
M. Daily ex*osure of asthm fics in a oommuntty each, ImMAgnit, which
to %e smelter arb poorly charactAdzed bjt a s Acnitozing
tion.'OnAVVen day, one side of theocepimuni I be much more
affected. by. the smelter stack plume than the other,' apd bigh'oon
from looping or funnigatioA mi ht affwt one n e4i!hborhood Wt tot others. The study tnadiquately*s"mos the effects of pftkezP6*r68 itna episodes.
This-report does noVmake clear thatrAhe temperatures
vie&weie from the Salt Lake City, A 11 e asmmption
have been made that. temperature was unifforft over, tK6 ftfire Audy
This i's n6t true because of the differences in, ele 4 n abd the 4966U of : the mountains, and: the lakoa "Perhal" A 0 diffartnebs weAe IA66imporftnt 'but'they shotdd h&vfa;beeA-1toiisidereO' Itis.not clew
*hj**dgys ;-W stratified by rniTiimVtd taflmk'O n, mean teml tur6 'the ifl in rhihg *C n
X temperjturas"66 ur dumiy e '114
i0i ra: Y -indoors and perha VW gen tem
i:tre g_ *%% -9windows are genlitsHy c1666d. Also, lower Wd ... MjJLJUL
I *- templ ftftres
LA* correlated-with other.'m6teorologitAl AefibmenzV that bi. d' a1w V#&t "thbMi! dtaock rategi 0. t andAVVnk W.Urid
-Airthbi'thera'may be a C=h= l dh 6ctidfi. W, tdv** h dn
i Wifto i OM11M tempttatmw J ribbAbIV
min 10'1111 Woodated'4rith 4
146to" temperature inversion I.. which would, % vojiduciveAW
stack. phfte. Weatsw of thp, ihohy questions *kaiatd, ft 116~ pertgnh* t,6 x uimpemtu&baere sugg6at farther W*d y =4
hav6 no general application.

New the m'l df the ile hand coluan,'page 2-0, thm fH
sentene pe "The shut-down of operations by dho obanWms
accmpaie by a prdnounced haprovement in air quality and eade tion in anslhmatackb ratesthat ocurrrnd corner and wemre lhe. seasonal reductions oberved in the more distant study coW gi some 2 weeks Iater." Mfers'themeds a lak ofapprcition of Up a*Wra climatic differences that eidb in the altL1k Basik. Salae eutsft summer weather could eainlly be delayed tee week befeme anahq Ogden. The average date f6r the les hii frost in Ogdet % abati afay 6, whereas the average date of the ant .iln hfee ateeledar (the climatic station nearet to Maga with a long record) ItEB
Ap Pae--78 (near middle oap right hand cooonnatorixu is not "5 miles nortle of Magna."
On pae281 the first graph in Figure. 2.4.1 is incorrectly drfed. After te17th week the broken line should be solid and the soli lin broken. The temperature carve should appear as in the. gr% 'for the high exaposure commfunity.
Figure 2A4.2, page 2-81,showrs a weakness in the argument that the sulfur dioitde concentrations are responsible for the asthma'atd rate. In the High Exposure Geomimunity the attack rite starts~v 4pt the 18th ekas flut salter diexdle cogncerations appoe muse a near zero, and remain veylow for about six weeks. It is: mte fta this sawns grapleshows the hgetSpea aturng& the Ath Week
wich seems to beiobu ay9,Tegah pageZ-1 so#A
.show the peak in Arl 4
.In 1iguro 2.4A, pae -82, with respc to the I iff Community, it may benoted tha the suft caneantashou 1"
particularly 1el-correlated with the ulfmr dioxide. plotted in Figure 2.4.2,4padathepreceding page. The -hb a rcading oceurp in the 3rd week, whereas the sulfar diaxide. .build up to a peak i the 9th wek .On, page 2-871, left had column, it is stated that a tbreshM4 i", .gratien af 1.4 atg/ar was ealqulated for alsndeantsellates higher temperature range. In Fiue2.4.4 all of the plottes ftw tions are greater taeu t.1is vaup, Cosiern the ic 6..;
sauspended sulfatesneal ohserved, this low tdhnesold to have no prcicl-ie
The tidpu pthtappagrs in the right hand soluoup
2-80, probal applies to Alagna, however, this. js not made There is a possibility that the paragraph could feiea interpretations than actually intended since the lastthe ,seem to refer to conditions in urban areas geerlly Uh
poabl should have been divided into two se t
However, the main faut with the paragrap-his &mprateclusions are drawn that are not supported byinomtnprsnd elsewhere in the report. It says "'excess asthma atiutle to dioide might bexcted 5 to 10 percent of summer dy" f 4e pended patcltscould occur on up to 5 percent of sumUman 30 percent of fall and winter days", and "eexcesses due to uifates are likeiv to occur on nioawt of Uan. wins., P- dnal

bbe concentgations and, temyerature, are. trup, the rep9yrt qpeq.
ain hair the percbntager b asys wMir obtained. The etiudr
cov only 26:weeks, but theia conclusions apply td an entire year.
740 dceItghs given seem to be'rough estimateisinmoe they appear to .bef emby -to- the nearest 5 or 1!0 percent The peenae might
been obtained from daily values for the minimum temperature
0*q concentrations ad asthma attack rate; but it is not clar
byr wore obtained.
Af mably daily, average concentration levels! of specific pollutants Voro-used in the construction of the "hockey stick" curves shown on pagow, S-86 and 2-89., The disonesimn imphies: that "24-haar levels"' weused,,4bu the precise nature: of the air "quality data. used in the (Maesdatanalyses is not made clear.
There could be various reasons not explored by the study why the hMS hde for asthma attacks were lower on warmer days. 'One of thAs that there may be more plume labin on warmer days. ThiszhMt absnls in locahmged, short- period, -hi concentrations, but we a ilelfow average concentrations.
a h valdity of sceetife -work own be tested by the repeatability of age to aI- this and the bother: (01188 studies there were factors. afetiag asthma attack rates that were not considered and whose, Meets wemunknwn. Snch factors am* .time spent nutdonrs percentage 1time windows are open, temperature chan relative humidity, etc.' ITb incompleteness of the study and the 1ac of understanding of the sma of the asthma attacks eagges that it might be repeated with R iiantly different results.
IgAII- term exposures to concentrations much higher than average ea ag or, weekly concentrations could have acqurred in the communities studied that were near large sources of 'air pollution such as
sters. There exists the possibility that asthma attacks could be j~ggee197b brief-duration Inhi 'concentrations. Such axpsures, could 44V kawn determined only adequately by the procedures used in 4th tiy. The report does not make clear why more attention was not devoted to peak concentrations.
46 mes' Exposure to Air Pollutests in Five Rocky Monatin Com
moiWes 16to--1970
a.? pages 3-7 through 3-12 beginning with the second columag 1M~aph near middle of page, which begins "Bty caring . .ff.
ai-W is: not, a simple relationship between average dal .pollutant agassions and average annal pollutant concentrations bcuethe, do Aptar area is often now downwind. Also, some consideration should, Rave been given to determining if the years for which data arn available wer representative meteorologically.
o (ag 3-1)Seondpaa"h, left hand side of page. Infr an
obtained during this investigation indicates that the ratio 1.63-60.2 should be 1.42 0.21. (The value 1. 63 is. the upper limtat of thi ratioJ.
(_Pag 3-12) Emission ratios of particulate and sulfur dioxid for; 1971 are omitted from this report. Therefore, it is not posible toredlfy &he ratios given here.
(age3-12) According to information obtained-during thi laves& gation, the two values.:for TSP listed as: 99.5 kor the yeare 1-70sshoul be o8.1 for both vear.------m -------. .

impot7n whrethf erh edoc iy utin ommuiis sour echmunas we r onueie:id Bofan it ea LwA Hes(High)ao, rpap Kellgg. en comnteheaealiio* ofaping ra andorbmecoteorloienedfelingoe uc'moe.tha atuals esre moigt be. ern ar reua 1ta xom
an patisudy omniodwllvr conaieaby ItiApxi~r
opened, sulf as Mare estimaeiasthsie mfiask mgtb, h~&A waos thatl excess broni odiedaotesr without 2-e0efrt.
dIxie coctratilonseidcncnrtos of.17 tofu di74de atgi

concentrations of 7.2 to 10.9 pg/mP (in the~rsneo 0,0a suspended particulates),.*covers siuch a wide rneo ocdrt~& it has hardly any practical significande. rVA
On page 3-3 1, in the Summary is stated '.'Meaf2slatsmy, have accounted for the findings of excess brocis. h-aue :f the sulfates is nowhere mentioned in the, repr.Tesqt -64 p aren tly the source of only some oflhesulfatesanteaurome of the sulfates has been determined.
6. Frequency of Acet Loer Respirafory Dises nCide:Ptb
spective Survey of Five Rocky M1unin Cmmniie, 90 Sulfur dioxide level are crudely etmie rmsla''P (or candle) .data and smelter semisexqn rates.Sseddul#W2 estimated from suspended particilate data.uig ,rai qydm East Helena,,IHalenia and Magna. Iwassueththes't values prevailed throughout the community Thsi nieloae been true considering the topographic effect the u i
Communities. A major shortcoming in this yppri ai~at i clear the inaccuracies that might be associaed ihetmtn h pollution levels.
There is an irregular distribution of annuaavrg ufrdoi concentrations in the vicinity of a smelter. Teedfeecialo concentrations in East Helena and can be conimdb xmntol of a report on the Helena Valley EnvironmetlPluinzuy;1 During 1965-66, 66 measurements of suspeddslaenia an average concentration of 7.9 lpglm'. The Then to determine a ratio range, measurentmaedrith period June through October at, two statio:so h eea ~le study were used. The original information is a olw.
I Helena Valley, Montana, Area Environental Pollution Study, niomna rtcinAec Office of Air Programs, Research Triangle Park, North Carolina, Janur 92

99ha 2Lye ars t rom lvtedk anm a
s 7. /m)inth esne Mi o fo
(65W Wgm". Thi0satmen1rfe
frm .5 /m to 0.9 g/m bec2
Ilerdf~eno rate aloeerto s.3,'s ttd tton vu the n statem teturomtellHelnate all twoEs
..Tl/m' fbevtos th e ri dfte sudy)g ae camrmntso h yearwhe'thre anud seeerve l to pono thate the drsnwcoe possib houl b~gte sunoted hatiulate concnrtosItint sta~d'henthe fiver sampinvsations, whedic he iHStuywr t~~ett it inve, remase in conentrato inm thertofsupne 901ftfto suae obrvuation mhta ed or tEaseeahc
*i1entpl rains of4. r50g22ocuri Thei stimate -Suspended Sulfate Conspide ticlt eemnd forAnaond, wche II] .11 Assn tha miu 5,wsdtrie by:: tak bouta 7 avrgm diocri the Henarao(.6 lso iu

trationblicationgcontasno ioatio peinindgatoclt Maganraiog

tewrecertai henduffctwetere (Parr h -sneo
Eusponesue esits in this stuy aetrmkTes stdtrnigsae mury thoowingplteto atem o th trnent leonadel of suped thlatexposures lastng 12n ynpea or5 mor.t
(7 211e~e 0g#} :arnispdrariclates 'M
suspended:sUldate I(ducg/mo) weer (accomph4) Ereasursiaes in ths fretuedd aohrncrespira6Icue 13&Aa
chrcied eg/m vaed anne average lebano

which rangestfrom 54 to 138 atg/m, whereas the 1,g/ i .
-value for five suburban communities for the~ya,16. ~u a
12 years concenations were much higher. .uigt 16
through 1965, the lowest value was 222, and teewsa f3K
in 1964. For th ive suburban communities hrewadta-nyf, ,one other year. It averaged 183 ;zg/ni. The 14 ;gm qen in% sultates is for a paed of 7 years, niot 12 as sed.1bscytij sents data for the Chicage core area, with somesatrdow tbw from East Chc'o and Hammond, Ind. The aeae ocurtos for the city shul be somewhat less than in th oeae.Ue1fOf core area valne would generally result in anovrsiae .It is diffictult to, characterized exposures lasting1 er o h ni Chicago area. Either this should 'have beendeinvr ges torns, nonquantitatively, or a greater effr shudbreke vae to present more representative. estimate. The assumption is ben made that sulfateobevtnsmd:4:% ,central urban leeation in Cia aeagedwihafwosram from East Chicago and Hamhmond, Ind. are genrlyepsetif.f the entire Chicago area.
(Page 4-8) Referring to the Chicago area thellgSaeet made: "Each sampler location, identified -b a tioi.4vi Fiure 4.1.2, represents. the central businesscmeiadVqkkt that particular area." This statement is not tu.'rcial,' i
-not all the samplers are located on the roofs ofsho located deliberately in business commerce i tit n *a slightly overestimate area-wide concentration ugte. (Page 4-23) In reading this paper about th re1eneo respiratory disease symptoms m military recruitqetos-aie:o the actual locations from which the men came should be 16 micrograms per cubic meter, ut 1,a ttd 0
appears that the concentrations of sulfur dioxiead:sedd,, ticulate are for only the prod 1969-1970 andntfr1tom.s i.% stated. (See Table 4.1.A.6)