State of California AIR RESOURCES BOARD Los Angeles Hilton Golden State Room 930 Wilshire Boulevard Los Angeles, CA 90017 April 27, 1977 10:00 a.m. AGENDA Page 77-8-1 Minutes of the October 4, 1976 Board Meeting. 77-8-2 Public Hearing to Reconsider the California Air 1 Quality Standard for Sulfur Dioxide. 77-8-3 Other Business a. Executive Session - Personnel & Litigation b. Research Proposals ITEM NO.: 77-8-2 Public Hearing to Reconsider the California Air Quality Standard for Sulfur Dioxide. RECOMMENDATION Based on the staff's analysis of the data presented in the accompanying report and the conclusions set forth below, we make the following recommendations: 1. That the Board adopt a 24-hour ambient air quality standard for SO2 at a level of 0.04 ppm; 2. That the Board adopt an additional ambient air quality standard for SO2, based on a 4-hour averaging period, at a level of 0.05 ppm; and 3. That the Board, for the interim, retain the currently accepted measurement methods for SO2 pending the completion of research studies currently in progress. SUMMARY The staff has reviewed a large volume of information pertaining to SO2 and its effects, much of it published within the past 5 years. A portion of this has been summarized in the accompanying staff report. The following conclusions represent the results of our analysis of this information: 1. The federal 24-hour ambient air quality standard for sulfur dioxide, 0.14 ppm, does not provide adequate health protection for the vast majority of Californians. The federal standard does not take into account the known consequences of interactions of sulfur dioxide with ozone and other photochemical oxidants in producing or aggravating disease. It does not adequately consider interactions of sulfur dioxide with other pollutants, such as nitrogen oxides and suspended particulate matter, or the suspected role of SO2 as a cocarcinogen in producing cancer of the lung. Finally, the federal standard was apparently set without incorporating a margin of safety. The staff has concluded that California requires a separate, more stringent 24-hour ambient air quality standard for SO2. 2. As summarized in Section II. A. of the report, the results of recent toxicological and epidemiological studies indicate that simultaneous exposure to sulfur compounds and ozone and other photochemical oxidants leads to consequences that are significantly more serious than exposure to either pollutant alone. This is supported by at least two studies showing effects at 0.06 ppm SO2 (24-hour average) in the presence of oxidant at about 0.15 ppm. Many additional studies show effects in the range of 0.10 to 0.15 ppm SO2 in the presence of suspended particulate matter. Since, in the presence of even moderate amounts of oxidant and suspended particulate matter, effects upon human health are observed with 24-hour SO2 levels in the range of 0.06 to 0.10 ppm, and since a margin of safety is desirable, the staff concludes that a 24-hour SO2 standard of approximately 0.04 ppm will provide adequate protection to the health of essentially all residents in all areas of California. The proposed 24-hour standard assumes the presence of photochemical oxidant at ambient levels in excess of the State 1-hour standard (0.10 ppm) and includes a margin of safety to ensure adequate health protection for sensitive groups within the larger population. 3. There is a substantial body of evidence showing that damage to vegetation occurs at SO2 levels as low as 0.025 to 0.1 ppm (two to eight-hour averages for single and multiple exposures) and in the presence of oxidants at levels as low as 0.05 ppm or possibly lower. Since California's prime agricultural areas frequently experience ambient ozone levels above 0.10 ppm, the board should assume the presence of ozone in considering the need for a standard that will minimize the impact of SO2 on vegetation. It is also clear that protection of vegetation requires that special consideration be given to SO2 levels for averaging periods shorter than 24 hours. Based on the data discussed in Section II.B. of the report, it appears that a 4-hour averaging period would be reasonable. From the brief analysis presented in Section VI of the report, it appears that a 24-hour standard alone cannot be expected to provide adequate protection against expected short-term fluctuations in SO2 levels above levels that are clearly harmful to vegetation. On this basis, the staff has concluded that a separate SO2 standard of 0.05 ppm with an averaging time of 4 hours is desirable to protect vegetation in the presence of photochemical oxidant at levels above 0.10 ppm. Even at the level of the proposed 4-hour standard, some damage to vegetation is expected to occur when moderate oxidant levels coincide with SO2 concentrations at 0.05 ppm. However, achievement of this standard will reduce economically significant damage to an acceptable level and prevent widespread irreversible damage to forests and to sensitive ecosystems. 4. A 24-hour SO2 standard of about 0.04 ppm is consistent with reducing ambient levels of sulfate aerosol to acceptable levels. The following points are made in support of this: a. The 0.04 ppm SO2 standard is expected to yield maximum 24-hour sulfate levels of about 22 ug/m3 in the South Coast Air Basin, consistent with the Board's interim 24-hour sulfate standard of 25 ug/m3. b. Reduction of sulfate aerosol to approximately these levels will be required as a part of the broader effort to meet the State and federal ambient air quality standards for total suspended particulate matter. c. Sulfate aerosol contributes substantially to visibility degradation. No strategy for approaching the visibility standard can fail to require substantial reductions in sulfate aerosol. Even at the levels consistent with the proposed SO2 standard, i.e., sulfate levels of 25 ug/m3, sulfate aerosol alone will account for more than half the total allowable visibility degradation consistent with the visibility standard. 5. Many types of materials are damaged after long-term exposures to ambient levels of SO2. Studies on the exposure of steels and cotton fabrics to gaseous SO2 show that damage is linearly proportional to SO2 concentration. Therefore, the lower the SO2, the less damage incurred. Clearly, a zero level is desirable, but as a practical matter protection of materials must be based on economic consideration. Accordingly, the staff declines to identify a specific level, and suggests that the Board would be justified in relying on the standards needed to protect health and vegetation to provide an acceptable degree of protection against damage to materials. 6. The staff concludes that none of the measurement methods currently in use in California for monitoring ambient levels of SO2 is entirely satisfactory. The ARB staff and EPA scientists are currently evaluating a "new generation" of monitoring instruments that promise improved sensitivity and will be less subject to interferences from other pollutants. this work is still in progress and the staff is not yet able to make a final assessment. For the interim, it seams appropriate to retain the measurement methods currently in use. Within the next year, a recommendation for adoption of a new method or methods will be forthcoming, along with recommendations to establish equivalency with current methods. ATTACHMENTS: Resolution - 77-22 Staff Report 77-8-2 Recommendation from the State of California Department of Health on the Air Quality Standard for Sulfur Dioxide STAFF REPORT Table of Contents Page No. I. Introduction 1 II. Effects of Sulfur Dioxide 4 A. Human Health Effects B. Vegetation Effects 49 C. Effects on Ecosystems 1. Lichens and Bryophytes 128 2. Acid Precipitation 131 D. Effects on Materials 138 III. Sulfate Aerosol Formation 158 IV. Atmospheric Concentrations 173 V. Air Monitoring Measurements 193 VI. Comparability of Air Quality Standards for Different Averaging Periods 204 VII. Conclusions 209 VIII. Recommendations 217