United States
Environmental Protection
Agency
Office of Emergency and
Remedial Response
Washington, DC 20460
EPA/540/1 -89/002
December 1989
PB90-155581
Superfund
Risk Assessment
Guidance for Superfund
Volume I
Human Health
Evaluation Manual
(Part A)
Interim  Final

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                                EPA/540/1 -89/002
                                 December 1989
        Risk Assessment
     Guidance for Superfund
             Volume 1
Human Health Evaluation Manual
              (Part A)
              Interim Final
    Office of Emergency and Remedial Response
      U.S. Environmental Protection Agency
           Washington, DC 20450
                               Printed on Recycled Paper

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Page ii
                                            NOTICE
        The policies and procedures set forth here are intended solely as guidance to EPA and other
government  employees and contractors.  This guidance does not constitute rulemaking by the Agency, and
cannot be relied on to create a substantive or procedural right enforceable by any party in litigation with
the United States. EPA may take action that is at variance with the policies and procedures in this manual
and may change them at any time without public notice.

        This interim final guidance is based on policies in the proposed revisions to the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), which were published on December 21,  1988 (53
Federal Register 51394). The final NCP may adopt policies different than those in this manual and should,
when promulgated, be considered the authoritative source.  A final version of this manual will be published
after the revised NCP is promulgated.

        Following the date of its publication, this manual is intended to be used as guidance for all human
health risk assessments conducted as part of Superfund remedial investigations and feasibility studies.
Issuance of this manual does not invalidate human health risk assessments completed before (or in progress
at) the publication date and based on previously released Agency guidance.

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                                                                                          Page iii
ABOUT THE REVISION . . .
 WHAT IT
IS
WHO IT'S
FOR

 WHAT'S
 NEW
DISTRIBU-
 TION PLAN
 WHERE
 TO SEND
 COMMENTS
EPA's Human Health Evaluation Manual is a   revision of the Superfund Public
Health Evaluation Manual (SPHEM; October 1986); it is Volume I of the two-volume set
called Risk Assessment Guidance for Super fund. This manual has three main parts: the
baseline risk assessment (Part A); refinement of preliminary remediation goals (Part B); and
evaluation of remedial alternatives (Part C). (Only Part A is included in the first
distribution see below.)

Risk assessors, risk assessment reviewers, remedial project managers (RPMs), and risk
managers involved in Superfund site cleanup activities will benefit from this revision.

This revision builds upon the process established in SPHEM and provides more detailed
guidance on many of the procedures used to assess health risk. New information and
techniques are presented that reflect the extensive  Superfund program experience conducting
health risk  assessments at Superfund sites. Policies established and refined over the years
- - especially those resulting from the proposed  National Oil  and Hazardous Substances
Pollution Contingency  Plan (NCP) -- have been updated and clarified. Additionally, the
links between the human health evaluation,  the environmental evaluation, and the remedial
inveatigation/feasibility  study (RI/FS) have  been  strengthened.

In Part A you will find:

        For the risk assessor - Updated procedures and policies, specific equations and
        variable values for estimating exposure, and a hierarchy of toxiciry data sources.

        For the risk assessment  reviewer ~ A baseline risk assessment outline for consistent
        presentation of risk information and format, and a reviewer's checklist to ensure
        appropriate quality and  content of the risk assessment.

        For the RPM ~ A comprehensive overview of the risk assessment process in the
        RI/FS, a checklist for RPM involvement throughout the process, and a complete
        index for quick reference.

        For the risk manager - An expanded chapter on risk  characterization (Chapter 8)
        to help summarize and present risk information for the decision-maker, and more
        detailed descriptions of uncertainties in the assessment.

This manual is being distributed as an interim final document while the proposed NCP  is
being finalized.  After the final NCP is published,  the manual will be updated  and finalized.
Parts B and C — which were not distributed as interim final because they are highly
dependent  on possible revisions to the NCP ~  will be added. Periodically,  updates  of
portions of the manual  will be distributed.

                      Toxics Integration Branch
             Office of Emergency and Remedial Response
                    401 M Street, SW (OS-230)
                      Washington, DC 20460
                        Phone 202-475-9486

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Page iv
                                     WORKGROUP

                                   EPA HEADQUARTERS

Office of Emergency and Remedial Response
Office of Solid Waste

Office of Waste Programs Enforcement:

Office of Solid Waste and Emergency Response:

Office of Policy, Planning, and Evaluation


Office of General Counsel

Office of Research  and Development
Office of Water:
                                  EPA REGIONAL OFFICES
Region I:

Region V:


Region VI:

Region X:
                                    OTHER EPA OFFICES
 Great Lakes National Program Office, IL:

Office of Health and Environmental
  Assessment, OH:

 Office of Air Quality Planning and
  Standards, NC
Marlene  Berg
David Cooper
Linda Cullen
Carla Dempsey
Steve  Golian
Bruce Means
Pat Mundy
Sandra Panetta

Stephanie Irene

Georgia  Valaoras

Larry  Zaragoza

Charlotte White
Craig Zamuda

Joe   Freedman

Rebecca Madison
Sue Norton

Frank Gostomski
Robert Zeller
Sarah Levinson

Dan Bicknell
Pamela Blakley

Fred Reitman

Dana Davoli
David Tetta
Cynthia Fuller


Chris DeRosa


Fred Hauchman

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                                                                         Page v


                           TABLE OF CONTENTS

                                                                         Page

INTRODUCTION

CHAPTER 1 INTRODUCTION                                               1-1

     1.1 OVERVIEW OF THE HUMAN HEALTH EVALUATION PROCESS
         IN THE  RI/FS  	     1-3

         1.1.1  Project  Scoping 	     1-4
         1.1.2 Site  Characterization  (RI)	     1-4
         1.1.3  Feasibility Study	     1-8

     1.2 OVERALL ORGANIZATION OF THE MANUAL	    1-10

CHAPTER 2 STATUTES, REGULATIONS, GUIDANCE, AND STUDIES RELEVANT
           TO T HE HUMAN HEALTH EVALUATION                            2-1

     2.1 STATUTES, REGULATIONS, AND GUIDANCE GOVERNING HUMAN
         HEALTH  EVALUATION  	     2-1

         2.1.1  CERCLAand    SARA  	     2-1
         2.1.2  National Contingency Plan (NCP)	     2-4
         2.1.3 Remedial Investigation/Feasibility Study Guidiance	     2-5
         2.1.4 ARARs Guidance	     2-7
         2.1.5  Superfund Exposure Assessment Manual	     2-8

     2.2 RELATED  SUPERFUND STUDIES	     2-8

         2.2.1  Endangerment  Assessment  	     2-8
         2.2.2  ATSDRHealth  Assessment   	     2-9
         2.2.3  ATSDR Health  Studies 	    2-10

CHAPTER 3 GETTING STARTED PLANNING FOR THE HUMAN HEALTH
            EVALUATION IN THE RI/FS                                 3-1

     3.1 Goa 1 of the RI/FS	     3-1
     3.2 Goal of the RI/FS Human Health Evaluation 	     3-1
     3.3 Operable Units	     3-2
     3.4 RI/FS Scoping	      3-2
     3.5 Level  of Effort/Level of Detail of the Human Health Evaluation	     3-3

PART  A --  BASELINE RISK ASSESSMENT

CHAPTER   4 DATA  COLLECTION                                        4-1

     4.1 BACKGROUND INFORMATION USEFUL FOR DATA COLLECTION	     4-1

         4.1.1 Types of Data	     4-1
         4.1.2 Data Needs and the  RI/FS 	      4-2

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         4.1.3  Early Identification of Data Needs	4-3
         4.1.4 Use of the Data Quality Objectives (DQO) Guidance	4-4
         4.1.5 Other Data  Concerns	 	   4-4

     4.2  REVIEW OF AVAILABLE SITE INFORMATION . 	   4-4

     4.3  ADDRESSING MODELING PARAMETER NEEDS ...  	   4-5

     4.4  DEFINING BACKGROUND SAMPLING NEEDS	   4-5

         4.4.1  Types of Background	   4-5
         4.4.2  Background Sampling  Locations	   4-8
         4.4.3  Background Sample Size	   4-8
         4.4.4  Comparing Background Samples to Site-Related Contamination	4-9

     4.5  PRELIMINARY IDENTIFICATION OF POTENTIAL HUMAN EXPOSURE	4-10

         4.5.1  General Information  	4-10
         4.5.2  Soil	4-11
         4.5.3  Ground Water	4-12
         4.5.4  Surface Water and  Sediment	4-13
         4.5.5  Air	4-14
         4.5.6  Biota	4-15

     4.6  DEVELOPING AN OVERALL STRATEGY FOR SAMPLE COLLECTION	4-16

         4.6.1  Determine  Sample Size	4-17
         4.6.2  Establish Sampling Locations	4-18
         4.6.3  Determine  Types of Samples	4-19
         4.6.4  Consider Temporal and Meteorological Factors	4-19
         4.6.5  Use Field Screening Analyses	4-20
         4.6.6  Consider Time and Cost of Sampling	4-21

     4.7  QA/QC MEASURES  	4-21

         4.7.1  Sampling  Protocol  	4-21
         4.7.2  Sampling   Devices   	4-21
         4.7.3  QC  Samples  	4-22
         4.7.4  Collection   Procedures   	4-22
         4.7.5  Sample Preservation  	4-22

     4.8   SPECIAL ANALYTICAL  SERVICES	4-22

     4.9  TAKING AN ACTIVE ROLE DURING WORKPLAN DEVELOPMENT AND
         DATA  COLLECTION    	  4-22

         4.9.1 Present Risk Assessment Sampling Needs at Scoping Meeting	4-22
         4.9.2 Contribute to Workplan and Review Sampling and Analysis Plan	4-23
         4.9.3  Conduct Interim Reviews of Field Investigation Outputs	4-24

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                                                                              Page vii


CHAPTER  5 DATA EVALUATION                                             5-1

     5.1  COMBINING DATA AVAILABLE FROM SITE INVESTIGATIONS                5-2

     5.2  EVALUATION OF ANALYTICAL METHODS	   5-5

     5.3  EVALUATION OF QUANTITATION LIMITS	   5-7

          5.3.1 Sample Quantitation Limits (SQLs) That Are Greater Than
               Reference Concentrations	    5-7
          5.3.2 Unusually High SQLs	   5-10
          5.3.3 When Only Some Samples in a Medium TestPositive for a Chemical	  5-10
          5.3.4 When SQLs Are Not Available	5-11
          5.3.5 When Chemicals Are Not Detected in Any Samples in aMedium	5-11

     5.4   EVALUATION OF  QUALIFIED AND CODED DATA	  5-11

          5.4.1 Types of Qualifiers 	   5-11
          5.4.2 Using the Appropriate  Qualifiers  	  5-16

     5.5  COMPARISON OF  CONCENTRATIONS DETECTED IN BLANKS WITH
          CONCENTRATIONS DETECTED IN SAMPLES	  5-16

     56   EVALUATION OF TENTATIVELY IDENTIFIED COMPOUNDS	  5-17

          5.6.1 When Few TICs Are Present 	  5-18
          5.6.2 When Many TICs  Are Present	   5-18

      5.7  COMPARISON OF SAMPLES WITH BACKGROUND	   5-18

          5.7.1 Use  Appropriate  Background Data  	   5-19
          5.7.2 Identify Statistical  Methods  	   5-19
          5.7.3 Compare Chemical Concentrations with Naturally Occurring Levels	   5-19
          5.7.4 Compare Chemical Concentrations with Anthropogenic Levels	   5-19

      5.8  DEVELOPMENT OF A SET OF CHEMICAL DATA AND INFORMATION
          FOR USE IN THE RISK ASSESSMENT  	   5-20

      5.9  FURTHER REDUCTION IN THE NUMBER OF CHEMICALS (OPTIONAL)      5-20

          5.9.1  Conduct Initial Activities	  5-20
          5.9.2 Group  Chemicals    by  Class   	 5-22
          5.9.3 Evaluate Frequency of Detection 	 5-22
          5.9.4 Evaluate  Essential Nutrients  	 5-23
          5.9.5 Use  a Concentration-Toxitity   Screen	 5-23

      5.10 SUMMARY AND  PRESENTATION OF DATA	  5-24

          5.10.1 Summarize Data tillection and Evaluation Results in Text	 5-27
          5.10.2 Summarize Data Collection and Evaluation Results in Tables and Graphics . . 5-27

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Page viii

CHAPTER 6  EXPOSURE ASSESSMENT                                         6-1

     6.1   BACKGROUND   	6-1

          6.1.1  Components of an Exposure Assessment	6-1
          6.1.2  Reasonable Maximum Exposure	6-4

     6.2   STEP 1: CHARACTERIZATION OF EXPOSURE SETTING	6-5

          6.2.1  Characterize Physical  Setting	6-5
          6.2.2  Characterize Potentially Exposed Populations	6-6

     6.3   STEP 2: IDENTIFICATION OF EXPOSURE PATHWAYS	6-8

          6.3.1  Identify Sources and Receiving  Media	6-8
          6.3.2  Evaluate Fate and Transport in Release Media	6-11
          6.3.3  Identify Exposure Points and Exposure Routes	6-11
          6.3.4  Integrate Information on Sources, Releases, Fate and Transport, Exposure
               Points, and Exposure Routes Into Exposure Pathways	6-17
          6.3.5  Summarize Information on All Complete Exposure Pathways	6-17

     6.4   STEP 3: QUANTIFICATION OF EXOSURE: GENERAL
          CONSIDERATIONS    	6-19

          6.4.1 Quantifying the Reasonable Maximum Exposure	6-19
          6.4.2 Timing Considerations	6-23

     6.5   QUANTIFICATION OF EXPOSURE: DETERMINATION OF EXPOSURE
          CONCENTRATIONS   	 6-24

          6.5.1  General Considerations for Estimating Exposure Concentrations	6-24
          6.5.2  Estimate Exposure Concentrations in Ground Water	6-26
          6.5.3  Estimate Exposure Concentrations in Soil	6-27
          6.5.4  Estimate Exposure Concentrations in Air	6-28
          6.5.5  Estimate Exposure Concentrations in Surface Water	6-29
          6.5.6  Estimate Exposure Concentrations in Sediments	6-30
          6.5.7  Estimate Chemical Concentrations in Food	6-31
          6.5.8  Summarize Exposure Concentrations  for Each Pathway	6-32

     6.6   QUANTIFICATION OF EXPOSURE: ESTIMATION OF CHEMICAL
          INTAKE	6-32

          6.6.1 Calculate Ground-water and Surface Water Intakes	6-34
          6.6.2 Calculate Soil,  Sediment, or Dust Intakes	6-39
          6.6.3 Calculate Air Intakes	6-43
          6.6.4 Calculate Food Intakes	6-43

     6.7   COMBINING CHEMICAL INTAKES ACROSS PATHWAYS	6-47

     6.8   EVALUATING  UNCERTAINTY 	6-47

     6.9   SUMMARIZING AND PRESENTING THE EXPOSURE ASSESSMENT
          RESULTS	 6-50

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                                                                               Page is


CHAPTER 7 TOXICITY ASSESSMENT                                         7-1

     7.1   TYPES OF TOXICOLOGICAL INFORMATION CONSIDERED IN
          TOXICITY  ASSESSMENT  	
          7.1.1  Human Data	7-3
          7.1.2  Animal Data	7-5
          7.1.3  Supporting  Data	7-5

     7.2   TOXICITY ASSESSMENT FORNONCARCINOGENIC EFFECTS	7-5

          7.2.1  Concept of Threshold	    7-6
          7.2.2  Derivation of an Oral RfD(RfD0)	    7-6
          7.2.3  Derivation of an Inhalation RfD (RfD,)	    7-8
          7.2.4  Derivation of a Subchronic RfD (RfDs) 	    7-8
          7.2.5  Derivation of a Developmental Toxicant RfD (RfDdt)	   7-9
          7.2.6  One-day and  Ten-day Health Advisories	    7-9
          7.2.7  Verification of Reds	   7-10

     7.3   TOXICITY ASSESSMENT FOR CARCINOGENIC EFFECTS	  7-10

          7.3.1  Concept of Nonthreshold  Effects	  7-10
          7.3.2  Assigning a Weight of Evidence	  7-11
          7.3.3  Generating  a Slope Factor	  7-11
          7.3.4  Verification  of Slope  Factors  	  7-13

     7.4   IDENTIFYING APPROPRIATE TOXICITY VALUES FOR
          SITE RISK ASSESSMENT 	7-13

          7.4.1  Gather Toxicity Information for Chemicals Being Evaluated	7-13
          7.4.2  Determine Toxicity Values for NonCarcinogenic Effects (RfDs)	7-15
          7.4.3  Determine Toxicity Values for Carcinogenic Effects (Slope Factors)	7-16

     7.5   EVALUATING CHEMICALS FOR WHICH NO TOXICITY VALUES ARE
          AVAILABLE	7-16

          7.5.1  Route-to-Route Extrapolation  	7-16
          7.5.2  Dermal Exposure 	7-16
          7.5.3  Generation  of Toxicity Values	7-16

     7.6   UNCERTAINTIES RELATED TO TOXICITY INFORMATION	7-19

     7.7   SUMMARIZATION AND PRESENTATION OF THE TOXICITY INFORMATION 7-20

          7.7.1  Toxicity Information for the Main Body of the Text	7-20
          7.7.2  Toxicity Information for Inclusion in an Appendix	7-20

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Pagcx

CHAPTER 8 RISK CHARACTERIZATION                                     8-1

     8.1 REVIEW OF OUTPUTS FROM THE TOXICITY AND EXPOSURE
         ASSESSMENTS  	8-1

         8.1.1 Gather  and Organize Information 	8-4
         8.1.2 Make Final Consistency and Validity Check	8-4

     8.2 QUANTIFYING  RISKS 	8-6

         8.2.1 Calculate Risks for Individual Substances	8-6
         8.2.2 Aggregate Risks for Multiple Substances	8-11

     8.3 COMBINING RISKS ACROSS EXPOSURE PATHWAYS	8-15

         8.3.1 Identify Reasonable Exposure Pathway Combinations	8-15
         8.3.2 Sum Cancer  Risks	8-16
         8.3.3 Sum Noncancer  Hazard Indices	8-16

     8.4 ASSESSMENT AND PRESENTATION OF UNCERTAINTY	8-17

         8.4.1 Identify and Evaluate Important Site-Specific Uncertainty Factors	8-17
         8.4.2 Identify and Evaluate Toxicity Assessment Uncertainty Factors	8-22

     8.5 CONSIDERATION OF SITE-SPECIFIC HUMAN STUDIES	8-22

         8.5.1 Compare with ATSDR Health Assessment	8-24
         8.5.2 Compare with Other Available Site-Specific Epidemiological or Health Studies 8-24

     8.6 SUMMARIZATION AND PRESENTATION OF THE BASELINE RISK
         CHARACTERIZATION RESULTS	8-25

         8.6.1 Summarize Risk Information in Text	8-25
         8.6.2 Summarize Risk Information in Tables	8-26

CHAPTER 9 DOCUMENTATION, REVIEW, AND MANAGEMENT TOOLS FOR THE RISK
             ASSESSOR, REVIEWER AND MANAGER                        9-1

     9.1  DOCUMENTATION   TOOLS 	9-1

         9.1.1 Basic  Principles  	9-1
         9.1.2 Baseline Risk Assessment  Report	9-2
         9.1.3 Other Key Reports  	9-3

     9.2  REVIEW  TOOLS  	9-3

     9.3  MANAGEMENT  TOOLS	9-14

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                                                                                   Page xi


CHAPTER 10 RADIATION RISK ASSESSMENT GUIDANCE                         10-1

      10.1  RADIATION PROTECTION PRINCIPLES AND CONCEPTS	10-3

      10.2 REGULATION OF RADIO ACTIVELY CONTAMINATED SITES	10-8

      10.3 DATA COLLECTION  	 10-10

          10.3.1   Radiation Detection Methods	10-10
          10.3.2   Reviewing Available Site Information	10-14
          10.3.3   Addressing Modeling Parameter Needs	10-14
          10.3.4   Defining Background Radiation Sampling Needs	10-14
          10.3.5   Preliminary Identification of Potential Exposure	10-15
          10.3.6   Developing a Strategy for Sample Collection	10-15
          10.3.7   Quality Assurance and Quality Control (QA/QC) Measures	10-16

      10.4 DATA EVALUATION  	10-16

          10.4.1   Combining Data from Available Site Investigations	  10-17
          10.4.2   Evaluating Analytical Methods	10-17
          10.4.3   Evaluating Quantitation  Limits	  10-17
          10.4.4   Evaluating Qualified and Coded Data	  10-20
          10.4.5   Comparing Concentrations  Detected in Blanks with Concentrations
                 Detected  in  samples 	10-20
          10.4.6   Evaluating Tentatively Identified Radionuclides	10-21
          10.4.7   Comparing Samples with Background	10-21
          10.4.8   Developing a Set of Radionuclide Data and Information for
                 Use in a Risk Assessment  	10-21
          10.4.9   Grouping Radionuclides bv Class	10-21
          10.4.10 Further Reduction in the Number of Radionuclides	  10-21
          10.4.11 Summarizing and Presenting Data	  10-22

      10.5 EXPOSURE AND  DOSE ASSESSMENT  	10-22

          10.5.1   Characterizing  the Exposure  Setting	10-23
          10.5.2   Identifying Exposure Pathways	10-23
          10.5.3   Quantifying Exposure General Considerations	10-24
          10.5.4   Quantifying Exposure Determining Exposure Point Concentrations	10-25
          10.5.5   Quantizing Exposure  Estimating Intake and Dose Equivalent	10-26
          10.5.6   Combining Intakes and Doses Across Pathways	10-27
          10.5.7   Evaluating Uncertainty   	10-27
          10.5.8   Summarizing and Presenting Exposure Assessment Results	10-27

      10.6 TOXICITY  ASSESSMENT 	10-27

          10.6.1 Hazard Identification  	10-28
          10.6.2 Dose-Response Relationships  	10-30

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      10.7  RISK CHARACTERIZATION   	 10-32

          10.7.1 Reviewing Outputs from the Toxicity and Exposure Assessments	 10-32
          10.7.2 Quantifying Risks	10-32
          10.7.3 Combining Radionuclide and Chemical Cancer Risks	 10-33
          10.7.4 Assessing and Presenting Uncertainties	 10-33
          10.7.5 Summarizing and Presenting the Baseline Risk Characterization Results . .  . 10-34

      10.8  DOCUMENTATION, REVIEW, AND MANAGEMENT TOOLS FOR THE RISK
          ASSESSOR, REVIWER, AND MANAGER	 10-34


PART B  --REFINEMENT OF PRELIMINARY REMEDIATION  GOALS
            [Reserved]


PART C  --RISK EVALUATION OF REMEDIAL  ALTERNATIVES
            [Reserved]


APPENDICES

APPENDIX A ADJUSTMENTS FOR ABSORPTION EFFICIENCY	  A-l

     A. 1 ADJUSTMENTS OF TOXICITY VALUE FROM ADMINISTERED TO
          ABSORBED  DOSE	  A-l

     A.2 ADJUSTMENT OF EXPOSURE ESTIMATE TO AN ABSORBED DOSE	  A-3

     A.3 ADJUSTMENT FOR MEDIUM OF EXPOSURE	  A-3

APPENDIX  B INDEX                                                      B-l

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                                                                                     Page xiii
Exhibit
                                  LIST OF EXHIBITS
  1-1       Risk Information Activities in the RI/FS Process	    1-5
  1-2       Part A: Baseline Risk Assessment	    1-7

 2-1       Relationship of Documents Govening Human Health Evaluation	    2-2
  2-2       Role of the Human Health Evaluation in the Superfund Remedial Process	    2-6

  4-1       Elements of a Conceptual Evaluation Model	    4-6
  4-2       Examples of Modeling Parameters for Which Information May Need To Be
           Obtained During a Site Sampling Investigation	    4-7

 5-1       Data Evaluation	    5-3
 5-2       Example of Output Format for Validated Data	    5-4
  5-3       Examples of the Types of Data Potentially Unsuitable for a Quantitative
           Risk Assessment	    5-6
  5-4       CLP Laboratory Data Qualfiers and Their Potential Use in Quantitative
           Risk Assessment	    5-12
 5-5       Validation Data Qualifers and Their Potential Use in Quantitative
           Risk Assessment	    5-14
 5-6       Example of Table Format for Presenting Chemicals Sampled in
           Specific Media	    5-26
 5-7       Example of Table Format for Summarizing Chemicals of Potential
           Concern in All Media Sampled	    5-26

 6-1       The Exposure Assessment Process	    6-3
 6-2       Illustration of Exposure Pathways	    6-9
 6-3       Common  Chemical Release Sources at Sites in the Absence of
           Remedial Action	    6-10
 6-4       Important Physical/Chemical and Environmenal Fate Parameters	    6-12
 6-5       Important Considerations for  Determining the Environmental Fate and
           Transport of the Chemicals of Potential  Concern at a Superfund Site	    6-13
 6-6       Flow Chart for Fate and Transport Assessments	    6-14
 6-7       Matrix of Potential Exposure Routes	    6-18
 6-8       Example of Table Format for Summarizing Complete Exposure Pathways at a Site . .    6-20
 6-9       Generic Equation for Calculating Chemical Intakes	    6-21
 6-10      Example  of Table Format for Summarizing Exposure Concentrations	    6-33
 6-11      Residential Exposure Ingestion of Chemicals in Drinking Water
           (and Beverages Made Using Drinking Water)	    6-35
  6-12      Residential Exposure:  Ingestion of Chemicals in Surface Water While Swimming ...    6-36
 6-13      Residential Exposure:  Dermal Contact with Chemicals in Water	    6-37
 6-14      Residential Exposure:  ingestion of Chemicals in Soil	
 6-15      Residential Exposure:  Dermal Contact with Chemicals in Soil	    6-41
  6-16      Residential Exposure:  Inhalation of Airborne (Vapor Phase) Chemicals	    6-44
  6-17      Residential  Exposure:  Food Pathway ~ Ingestion of Contaminated Fish
           and Shellfish	    6-45
  6-18      Residential Exposure:  Food Pathway ~ Ingestion of Contaminated
           Fruits and Vegetables	    6-46

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Page xiv


  6-19      Residential Exposure: Food Pathway -- Ingestion of Contaminated
           Meats, Eggs, and Dairy Products	    6-48
  6-20      Example of Table Format for Summarizing Values Used to Estimate
           Exposure	    6-49
  6-21      Example of Uncertainty Table for Exposure Assessment	    6-51
  6-22      Example of Table Format for Summarizing the Results of the
           Exposure Assessment —  Current Land Use	    6-52

  7-1       Steps in Toxicity Assessment	     7-4
  7-2       Example of Table Format for Toxicity Values: Potential Noncarcinogenic Effects . .    7-17
  7-3       Example of Table Format for Toxicity Values: Potential Carcinogenic Effects ....    7-18

  8-1       Steps in Risk Characterization	     8-3
  8-2       Example of Table Format for Cancer Risk Estimates	     8-7
  8-3       Example of Table Format for Chronic Hazard Index Estimates .	     8-8
  8-4       Example of Table Format for Subchronic Hazard Index Estimates  	     8-9
  8-5       Example of Presentation of Impact of Exposure Assumptions on
           Cancer Risk Estimate	    8-21
  8-6       Example of Presentation of Impact of Exposure Assumptions on
           Hazard Index Estimate	    8-23
  8-7       Example of Presentation of Relative Contribution of Individual
           Chemicals to Exposure Pathway and Total Cancer Risk Estimates  	    8-27
  8-8       Example of Presentation of Relative Contribution of Individual
           Chemicals to Exposure Pathway and Total Hazard Index Estimates	    8-28

  9-1       Suggested  Outline for a Baseline Risk Assessment Report	     9-4
  9-2       Reviewer Checklist	     9-9
  9-3       Checklist for Manager Involvement	    9-15

 10-1       Radiological Characteristics of Selected  Radionuclides Found at Superfund Sites . .    10-5
 10-2       Typesof Field Radiation Detection Instruments	    10-11
 10-3       Types of Laboratory Radiation Detection Instruments	    10-13
 10-4       Examples of Lower Limits of Detection (LLD) For Selected Radionuclides
           Using Standard Analytical Methods	    10-18
 10-5       Summary of EPA's Radiation Risk Factors	    10-31

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                                                                                        Page xv
                                         PREFACE
     The Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA)
requires that actions selected to remedy hazardous
waste sites be protective of human health and the
environment. CERCLA also mandates that when
a remedial action results in residual  contamination
at a site, future reviews must be planned and
conducted to assure that human health and the
environment continue to be protected. As part of
its effort to meet these and other CERCLA
requirements, EPA has  developed  a  set of
manuals, together  entitled Risk Assessment
Guidance for Superfund.  The Human Health
Evaluation Manual (Volume I) provides guidance
for  developing  health  risk information at
Superfund sites, while the  Environmental
Evaluation Manual (Volume II) provides guidance
for environmental assessment at Superfund sites.
Guidance in both human health evaluation and
environmental assessment is needed so that EPA
can fulfill CERCLA'S requirement to protect
human health and the environment.

     The Rirk Assessment Guidance for Superfund
manuals  were developed to be used  in the
remedial investigation/feasibility study (RI/FS)
process  at Superfund sites, although the  analytical
framework and specific methods described in the
manuals  may also be  applicable to other
assessments of hazardous wastes and hazardous
materials.     These manuals are companion
documents to EPA's Guidance for Conducting
Remedial  Investigations and Feasibility Studies
Under CERCLA (October 1988), and users should
be familiar  with that guidance.     The  two
Superfund risk assessment manuals were  developed
with extensive input from EPA workgroups
comprised of both regional and headquarters staff.
These manuals are interim final guidance, final
guidance will be issued  when the revisions
proposed  in December  1988 to the National Oil
and Harzardous Substances  Pollution Contingency
Plan (NCP) become  final.

     Although human health risk assessment and
environmental assessment are  different processes,
they share certain  common  information needs and
generally can use some of the same chemical
sampling and environmental setting data for a site.
Planning for both assessments should begin during
the scoping stage of the RI/FS, and site sampling
and other data collection activities to support the
two assessments should  be  coordinated. An
example of this type of coordination is the
sampling and analysis of fish or other aquatic
organism,  if done properly, data from such
sampling can be used in the assessment of human
health risks from ingestion and in the assessment
of damages to and potential effects on the aquatic
ecosystem.

     The two manuals in this set target somewhat
different audiences. The Environmental Evaluation
Manual is addressed primarily to remedial project
managers (RPMs) and on-scene coordinators
(OSCs), who are responsible for ensuring a
thorough evaluation  of potential environmental
effects at sites. The Environmental Evaluation
Manual is not a  detailed "how-to" type of
guidance, and it does not provide "cookbook"
approaches for evaluation. Instead, it identifies
the kinds of help that RPMs/OSCs are likely to
need and where they may find that help. The
manual also provides an overall framework to be
used in considering  environmental effects. An
environmental evaluation methods compendium
published by EPA's Office of Research and
Development, Ecological Assessments of Hazardous
Waste Sites: A Field and Laboratory Reference
Document (EPA/600/3-89/013),  is an important
reference to be used with the manual.

     The Human Health Evaluation Manual is
addressed primarily  to the individuals actually
conducting healh risk assessments for sites, who
frequently are contractors to EPA other federal
agencies, states, or potentially responsible parties.
It also is targeted to  EPA staff, including those
responsible for  review and oversight of risk
assessments (e.g., technical staff in the regions)
and those  responsible for ensuring adequate
evaluation  of human health risks (i.e., RPMs).
The Human Health Evaluation Manual replaces a
previous EPA guidance document, The Superfund
Public Health  Evaluation Manual (October 1986),
which should no longer be used. The new manual

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Page xvi
incorporates lessons learned from application of
the earlier manual and addresses a number of
issues raised since the earlier manual's publication.
Issuance of the new manual does not invalidate
human health risk assessments completed before
(or in progress at) the publication date.

     The Human Health Evaluation Manual
provides  a basic framework for health risk
assessment   at   Superfund   sites,  as   the
Environental Evaluation  Manual does  for
environmental assessment. The Human Health
Evaluation Manual differs, however, by providing
more detailed guidance on many of the procedures
used to assess health risk. This additional level
of detail is possible because of the relatively large
body  of information, techniques, and guidance
available on human health risk assessment and the
extensive   Superfund    program    experience
conducting such  assessments for sites,    Even
though the Human Health Evaluation Manual is
considerably more specific than the Environmental
Evaluation Manual, it also is not a "cookbook,"
and proper application  of the guidance requires
substantial expertise and professional judgment.

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                                                                                         Page xvii
                                 ACKNOWLEDGEMENTS
     This manual was developed by the Toxics Integration Branch (TIB) of EPA's Office of Emergency
 and Remedial Response, Hazardous Site Evaluation Division.   Linda Cullen provided overall project
management, contract supervision, and technical coordination for the project under the direction of Bruce
 Means, Chief of TIB's Health Effects Program.

     The EPA Workgroup (comprised of members listed on page iv) provided valuable input regarding the
 organization, content, and policy implications of the  manual throughout its development. The project
 manager especially wishes to acknowledge the assistance of the Workgroup Subcommittee Chairpersons:
 Rebecca Madison, Bruce Means, Sue Norton, Georgia Valaoras, Craig Zamuda, and Larry Zaragoza.

     Other significant contributors to the manual included Joan Fisk, Michael Hurd, and Angelo Carasea
 of the Analytical Operations Branch (Office of Emergency and Remedial Response); Paul White, Anne
 Sergeant,  and Jacqueline Moya of the Exposure Assessment Group  (Office of Research and Development);
 and Barnes Johnson of the Statistical Policy Branch  (Office of  Policy,  Planning, and Evaluation). In
 addition,  many thanks are offered to the more than 60 technical and policy reviewers who provided
 constructive comments on the document in its final stages of development.

     ICF Incorporated provided technical assistance to EPA in support of the development of this manual,
 under Contract No.  68-01-7389.

     Robert Dyer, Chief of the Environmental Studies and Statistics Branch, Office of Radiation Programs,
 served as  project manager for Chapter 10 (Radiation Risk Assessment Guidance), with assistance from staff
 in the Bioeffects Analysis Branch and the regional Radiation Program Managers. Chapter 10 was prepared
 by S. Cohen and Associates, Incorporated (SC&A), under Contract No. 68-02-4375.

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                                   CHAPTER  1
                              INTRODUCTION
     The Comprehensive Environmental Response,
 Compensation, and Liability Act of 1980, as
 amended (CERCLA, or "Superfund"), establishes
 a national program for responding to releases of
 hazardous substances into the environment.1 The
 National Oil and Hazardous Substances Pollution
 Contingency Plan (NCP) is the regulation that
 implements  CERCLA.2 Among other things, the
 NCP establishes the  overall approach for
 determining appropriate remedial actions at
 Superfund sites. The overarching mandate of the
 Superfund program is to protect human health
 and the  environment from current and potential
 threats posed by uncontrolled hazardous substance
 releases, and the NCP echoes this mandate.

     To  help meet this Superfund mandate, EPA's
 Office of Emergency and Remedial Response has
 developed a human health evaluation process as
 part of its remedial response program.  The
 process  of gathering and assessing human health
 risk information described in this manual is
 adapted   from well-established chemical risk
 assessment principles and procedures (NAS 1983;
 CRS 1983;  OSTP 1985). It is designed to be
 consistent with EPA's published risk assessment
 guidelines (EPA 1984 EPA 1986a-e; EPA 1988a;
 EPA 1989a)  and   other Agency-wide  risk
 assessment policy. The Human Health Evaluation
Manual  revises and replaces the Superfund Public
Health  Evaluation Manual (EPA 1986f).3It
 incorporates new information and builds on
 several years of Superfund program experience
 conducting risk assessments at hazardous waste
 sites. In addition, the Human Health Evaluation
Manual    together    with    the    companion
Envtionmental Evaluation Manual (EPA 1989b)
 replaces EPA's 1985 Endangerment Assessment
Handbook, which should no longer be used (see
 Section 2.2.1).
    The goal of the Superfund human health
evaluation process is to provide a framework for
developing the risk information necessary to assist
decision-making at remedial sites.    Specific
objectives of the process are to:

    •    provide an analysis  of baseline risks4
         and help determine the need for action
         at sites;

    •    provide a basis for determining levels
         of chemicals that can remain onsite and
         still be adequately protective of public
         health;

    •    provide a basis for comparing potential
         health  impacts of various remedial
         alternatives; and

    •    provide  a  consistent process   for
         evacuating and documenting public health
         threats at sites.

    The human  health  evaluation process
described in this manual is an integral part of the
remedial response process defined by CERCLA
and the NCP. The risk information generated by
the human health evaluation process is designed
to be used in the remedial investigation/feasibility
study (RI/FS) at Superfund sites. Although risk
information is fundamental to the RI/FS and to
the remedial response program in general,
Superfund site experience has led EPA to balance
the need for information with the need to take
action at sites quickly and to streamline the
remedial process. Revisions proposed to the NCP
in 1988 reflect  EPA program management
principles intended to promote the efficiency and
effectiveness of the remedial response process.
Chief among these principles is a bias for action.
EPA's Guidance for  Conducting Remedial

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 Page 1-2
 Investigations and Feasibility Studies  Under
 CERCLA (EPA 1988b) also was revised in 1988
 to  incorporate  management initiatives designed to
 streamline  the RI/FS  process  and  to make
 information collection activities during  the RI
 more efficient. The Risk Assessment Guidance for
 Super fund, of which this Human Health Evaluation
 Manual is Volume I,5 has been developed to
 reflect the emphasis on streamlining the remedial
 process. The Human Health Evaluation Manual
 is a companion document to the RI/FS guidance.
 It provides a  basic framework for developing
 health risk information at  Superfund sites and also
 gives  specific guidance on appropriate methods
 and data to use.  Users of the Human Health
 Evaluation Manual should be  familiar with the
 RI/FS guidance, as well as with other  guidances
 referenced  throughout  later chapters of this
 manual.

     The Human  Health Evaluation Manual is
 addressed primarily to the individuals actually
 conducting human  health evaluations  for sites
 (frequently contractors  to EPA, other federal
 agencies, states, or potentially responsible parties).
 It also is targeted to EPA staff responsible for
 review and  oversight of risk assessments (e.g.,
 technical  staff  in the  regions) and  those
 responsible for ensuring an adequate evaluation  of
 human  health risks  (i.e.,  remedial project
 managers, or RPMs). Although the terms risk
 assessor and risk assessment reviewer are used  in
 this manual, it is emphasized that they generally
 refer to teams of  individuals in appropriate
 disciplines (e.g.,  toxicologists,  chemists,
 hydrologists, engineers). It is recommended that
 an appropriate  team of scientists and engineers be
 assembled for the human health evaluation  at
 each specific site.   It is the responsibility of
 RPMs, along with the leaders  of human  health
 evaluation teams,  to match the scientific support
 they deem appropriate with the resources at their
 disposal.

     Individuals having different levels of scientific
 training and experience  are likely to use the
 manual in designing, conducting,  and reviewing
human health evaluations. Because assumptions
 and judgments are required in many parts of the
 analysis,  the  individuals conducting the evaluation
 are key elements  in the process. The  manual is
 not intended to instruct non-technical personnel
 how to perform technical evaluations, nor to allow
 professionals trained in one discipline to perform
 the work of another.
        KEY PLAYERS IN SUPERFUND
           SITE KIS3K ASSESSMENT/
             fflSK MANAGEMENT

   Risk Assessor. The individual or team of individuals
   who actually organizes and analyzes site data, develops
   exposure and risk calculations, and prepares hwnan
   health evaluation (ie,, risk assessment) reports. Risk
   assessors for Superfund sites frequently are contractors
   to EPA, otfcer federal agencies, states, or potentially
   responsible parties.

   Risfc Assessment Reviewer. The individual or team of.
   individuals within aa EPA region who provides technical
   oversight and quality assurance review of human health
   evaluation activities.

   Remedial Project Manager fRPM). The individual who
   manages and oversees all RI/FS activities, including the
   human  health evaluation,  for a site.   The  RPM is
   responsible for ensuring adequate evaluation of human
   health risks and for determining the level of resources
   to be committed to the human health evaluation-
              . The fadwdaal or group of individuals
   who serves as primary decision-maker for a site,
   generally  regional  Superfund  management   in
   consultation with the RPM  and members of the
   technical staff. The identity of the risk manager may
   differ from region to region and for sites of varying
   complexity.
     The Human Health Evaluation Manual
admittedly cannot address all site circumstances.
Users of the manual must exercise technical and
management judgment, and should consult with
EPA regional  risk  assessment  contacts and
appropriate headquarter staff when encountering
unusual or particularly complex technical issues.

     The first three chapters of  this manual
provide background information to help place the
human health evaluation process in the context of
the Superfund remedial process.   This chapter
(Chapter  1)  summarizes  the human  health
evaluation process during the  RI/FS.  The three
main parts of this  process  — baseline risk
assessment, refinement of  preliminary remediation
goals, and remedial alternatives risk evaluation
- are described  in detail in subsequent chapters.
Chapter  2  discusses in a  more general way the
role of risk information in the overall Superfund

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                                                                                         Page 1-3
remedial program by focusing on the statutes,
regulations, and guidance relevant to the human
health evaluation. Chapter 2 also identifies and
contrasts Superfund studies related to the human
health evaluation.   Chapter 3 discusses issues
related to planning for the human health
evaluation.
1.1  OVERVIEW OF  THE HUMAN
     HEALTH EVALUATION
     PROCESS  IN THE RI/FS

     Section 300.430 of the proposed revised NCP
reiterates that the purpose of the remedial process
is to implement remedies that reduce, control, or
eliminate  risks  to human health  and  the
environment.   The remedial investigation and
feasibility study (RI/FS) is the methodology that
the  Superfund program  has established for
characterizing the nature and extent of risks posed
by uncontrolled hazardous waste sites and for
developing and evaluating remedial options. The
1986 amendments to CERCLA reemphasized the
original statutory mandate that remedies meet a
threshold requirement to protect human health
and  the  environment and that they  be cost-
effective, while adding new emphasis to the
permanence of remedies. Because the RI/FS is an
analytical process   designed to  support  risk
management decision-making  for Superfund  sites,
the assessment of health and environmental risk
plays an  essential role in the RI/FS.

     This manual provides guidance on the human
health  evaluation activities that are conducted
during the RI/FS.  The three basic parts of the
RI/FS human health evaluation are:

     (1) baseline risk assessment (described in
         Part A of this manual);

     (2) refinement of preliminary remediation
         goals (Part B); and

     (3) remedial alternatives risk evaluation
         (Part C).

Because these risk information activities are
intertwined with the RI/FS, this section describes
those activities in the context of the RI/FS
process.  It  relates the three parts of the human
health evaluation to the stages of the RI/FS,
which are

     •    project scoping (before the RI);

     •    site characterization (RI);

     •    establishment of remedial action
         objectives (FS);

     •    development and screening of
         alternatives (FS); and

     •    detailed analysis of alternatives (FS).

     Although the RI/FS process and related risk
information activities are presented in a fashion
that makes the steps appear sequential and
distinct, in practice  the  process  is highly
interactive. In fact, the RI and FS are conducted
concurrently. Data collected in the RI influences
the development of remedial alternatives in the
FS, which in turn affects the data needs and scope
of  treatability studies and  additional  field
investigations.  The RI/FS should be viewed as a
flexible process that can and should be tailored to
specific circumstances and information needs of
individual sites, not as a rigid approach that must
be conducted identically at every site. Likewise,
the human health evaluation process described
here should be  viewed the same way.

     Two concepts are essential to the phased
RI/FS approach.   First, initial data collection
efforts develop a general understanding of the site.
Subsequent data collection effort focuses on filling
previously unidentified gaps  in the understanding
of site characteristics and gathering information
necessary to evaluate remedial alternatives.
Second, key data needs should be identified as
early in the process  as possible to ensure, that
data collection is always directed toward providing
information relevant to selection of a remedial
action.      In  this  way,  the overall  site
characterization effort can be continually scoped
to minimize the collection of unnecessary data and
maximize data quality.

     The RI/FS provides decision-makers with a
technical evaluation of the threats posed at a site,
a characterization  of the potential routes  of
exposure,  an assessment of remedial alternatives
(including their relative  advantages  and

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Page 1-4
disadvantages), and an analysis of the trade-offs in
selecting one alternative over another.   EPA's
interim final Guidance for Conducting Remedial
Investigations and Feasibility Studies  under
CERCLA  (EPA 1988b) provides a detailed
structure for the RI/FS.  The RI/FS guidance
provides further background that is  helpful in
understanding the place of the human health
evaluation in the RI/FS process. The role that
risk information plays in these stages of the RI/FS
is described below, additional background can be
found in  the RI/FS guidance  and  in a summary of
the guidance found in Chapter 2.  Exhibit 1-1
illustrates the RI/FS process, showing where in the
process risk information is gathered and analyzed.

1.1.1     PROJECT  SCOPING

     The purpose of project scoping is to  define
more specifically the appropriate type and extent
of investigation and analysis  that should be
undertaken for a given site. During scoping, to
assist in evaluating the possible impacts of releases
from  the   site on human  health  and  the
environment, a conceptual model of the site
should be established, considering in a qualitative
manner the sources  of contamination, potential
pathways of exposure,  and potential receptors.
(Scoping is also the starting point for the risk
assessment, during which exposure pathways are
identified  in the conceptual model for further
investigation and quantification.)
          PROJECT  SCOPING

     Program experience has shown that scoping is a very
   important step for the human health evaluation process,
   and both the health and environmental evaluation teams
   need to get involved in the RI/FS during the scoping
   stage. Planning for site data collection activities is
   necessary to focus the human health evaluation (and
   environmental evaluation) on the minimum amount of
   sampling information in order to meet time and budget
   constraints, while at the same time ensuring that enough
   information is gathered to assess risks adequately. (See
   Chapter 3 for information on planning the human health
   evaluation.)
     The preliminary characterization during
project seeping is initially developed with readily
available information and is refined as additional
data are collected. The main objectives of scoping
are to identify the types of decisions that need to
be  made,  to  determine the types  (including
quantity and  quality) of data needed, and to
design efficient studies to collect these data.
Potential site-specific modeling activities should
be discussed at initial scoping meetings to ensure
that modeling results will supplement the sampling
data and effectively support risk assessment
activities.

1.1.2     SITE  CHARACTERIZATION (RI)

     During site characterization, the sampling and
analysis plan developed  during project scoping is
implemented and field data are collected and
analyzed to determine the nature and extent of
threats to human health and the environment
posed by a site. The major  components of site
characterization are

     •    collection and analysis of field data to
         characterize the site

     •    development of  a  baseline  risk
         assessment  for both potential human
         health    effects    and    potential
         environmental  effects; and

     •    treatability studies, as appropriate.

     Part of the human health evaluation, the
baseline risk assessment (Part A of this manual)
is an analysis of the potential  adverse health
effects (current or future) caused by hazardous
substance releases from a site in the absence of
any actions to control or mitigate these releases
(i.e., under an assumption of no action). The
baseline risk assessment contributes to the site
characterization and  subsequent  development,
evaluation, and selection of appropriate response
alternatives.    The results of the baseline risk
assessment are used to:

     •    help determine  whether additional
         response action is necessary at the site;
                                                             modify preliminary remediation goals

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                                                                 Page 1-5
                           EXHIBIT 1-1

     RISK INFORMATION ACTIVITIES IN THE RI/FS PROCESS
RI/FS
STAGES
RISK
INFORMATION
ACTIVITIES
Project
Scoping

Review data
collected
in site
inspection
Review
sampling/
data
collection
plans


Formulate
preliminary
remediation
goals (PRGs)
Determine
level of
effort for
baseline risk
assessment


RI/FS:
Site Establishment of Development & Detailed
Characterization Remedial Action Screening of Analysis of
(RI) Objectives (FS) Alternatives (FS) Alternatives (FS)

_.








1 ' Iff





Conduct Refine Conduct risk

risk on risk remedial
assessment assessment and alternatives
ARARs


%


'


-------
 Page 1-6
     •   help support selection of the "no-action"
         remedial alternative, where appropriate;
         and

     •   document the magnitude of risk at a
         site, and the primary causes of that risk.

     Baseline risk assessments are site-specific and
 therefore may vary in both detail and the extent
 to which qualitative and quantitative analyses are
 used, depending on the  complexity and particular
 circumstances  of the site, as well as the availability
 of applicable  or   relevant  and  appropriate
 requirements  (ARARs)  and  other  criteria,
 advisories,  and guidance. After  an initial planning
 stage (described more fully in Chapter 3), there
 are four steps in the baseline risk assessment
 process: data collection and analysis; exposure
 assessment   toxicity   assessment;   and   risk
 characterization. Each  step is  described briefly
 below and  presented in Exhibit 1-2.

     Data  collection and  evaluation involves
 gathering and analyzing the site data relevant to
 the human health evacuation and identifying the
 substances present at the site that are the focus
 of the risk assessment process. (Chapters 4 and
 5 address data collection and evaluation.)

     An exposure assessment is conducted  to
 estimate the magnitude  of actual and/or potential
 human exposures, the frequency  and duration of
 these  exposures, and the  pathways by which
 humans  are potentially  exposed. In the exposure
 assessment, reasonable maximum estimates  of
 exposure are developed for both current and
 future land-use assumptions. Current exposure
 estimates are used to determine whether a threat
 exists based on existing exposure conditions at the
 site.    Future exposure estimates are used  to
provide decision-makers with  an understanding  of
potential future exposures and threats and include
 a qualitative estimate of the likelihood of such
exposures occurring.    Conducting an exposure
assessment    involves    analyzing   contaminant
releases;    identifying    exposed    populations;
identifying all potential pathways of exposure;
estimating exposure point concentrations for
specific pathways, based both on environmental
monitoring  data and  predictive chemical modeling
results; and estimating contaminant intakes for
specific pathways. The results of this assessment
are pathway-specific intakes  for current and future
 exposures to individual substances. (Chapter 6
 addresses exposure assessment.)

     The toxicitv  assessment component of the
 Superfund baseline risk assessment considers: (1)
 the types of adverse health effects associated with
 chemical exposures; (2) the relationship between
 magnitude  of exposure and adverse effects; and (3)
 related  uncertainties  such as the weight of
 evidence of a particular chemical's carcinogenicity
 in humans.   Typically, the Superfund site risk
 assessments rely heavily on existing toxicity
 information developed on specific chemicals.
 Toxicity assessment for contaminants found at
 Superfund  sites is  generally  accomplished in two
 steps:   hazard identification and dose-response
 assessment. The first step, hazard identification,
 is the process of determining whether exposure to
 an agent can cause an increase  in the incidence of
 an adverse  health effect (e.g., cancer, birth defect).
 Hazard identification also involves characterizing
 the  nature and strength  of the evidence of
 causation.    The  second step, dose-response
 evaluation,  is the  process  of quantitatively
 evaluating    the    toxicity    information    and
 characterizing the  relationship between the dose
 of the contaminant administered or received and
 the incidence of adverse health effects in the
 exposed  population. From this quantitative dose-
 response relationship, toxicity values  are derived
 that can be used to estimate the incidence of
 adverse effects occurring in humans  at different
 exposure levels.    (Chapter  7 addresses toxicity
 assessment.)

     The risk characterization summarizes and
 combines outputs  of the exposure and toxicity
 assessments to characterize baseline risk, both in
 quantitative expressions  and  qualitative statements.
 During risk characterization, chemical-specific
 toxicity  information is compared against  both
 measured contaminant exposure levels and those
 levels predicted  through  fate and transport
 modeling to determine whether current or future
 levels at or near the site are of potential concern.
 (Chapter 8 addresses risk characterization.)

     The level of effort required to conduct a
baseline risk assessment depends largely on the
complexity of the site.   In situations where the
results of the baseline risk assessment indicate
that  the site poses  little or no threat to human
health or the environment and that no further (or

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                                                                                           Page 1-7
                                      EXHIBIT  1-2

                   PART A  BASELINE  RISK ASSESSMENT
                                 Data Collection and
                                      Evaluation
                             •  Gather and analyze relevant
                                site data

                             •  Identify potential chemicals of
                                concern
Exposure Assessment
 Analyze contaminant releases

 Identify exposed populations

 Identify potential exposure
 pathways

 Estimate exposure
 concentrations for pathways

 Estimate contaminant intakes for
 pathways
                                                                               i
 Toxicity Assessment
Collect qualitative and
quantitative toxicity information

Determine appropriate toxiciry
values
                               Risk Characterization
                             Characterize potential for adverse
                             health effects to occur

                             —  Estimate cancer risks

                             —  Estimate noncancer hazard
                                 quotients

                             Evaluate uncertainty

                             Summarize risk information

-------
 Page 1-8
 limited) action will be necessary, the FS should be
 scaled-down as appropriate.

     The documents developed  during  site
 characterization include a brief preliminary site
 characterization summary and the draft RI report,
 which includes either the complete baseline risk
 assessment report  or a summary of it.  The
 preliminary  site characterization summary may be
 used to assist in identification of ARARs and may
 provide the Agency for Toxic  Substances and
 Disease Registry (ATSDR) with the data necessary
 to prepare its health assessment (different from
 baseline risk assessment or other EPA human
 health evaluation activities; see Chapter 2). The
 draft RI report is prepared after the completion
 of the baseline risk assessment, often along with
 the  draft FS report.
 1.1.3
FEASIBILITY  STUDY
     The purpose of the feasibility study is to
 provide the decision-maker  with an assessment of
 remedial alternatives, including their relative
 strengths and weaknesses, and the trade-offs in
 selecting one alternative over another. The FS
 process involves developing a reasonable range of
 alternatives and analyzing these alternatives in
 detail using nine evaluation criteria. Because the
 RI and FS are cortducted concurrently,  this
 development  and analysis of alternatives is an
 interactive process in which potential alternatives
 and remediation goals are  continually refined as
 additional information from the RI  becomes
 available.

     Establishing  protective remedial action
 objectives.   The  first step  in the FS process
 involves developing remedial action objectives that
 address contaminants and media of concern,
 potential exposure  pathways, and preliminary
 remediation goals.   Under the proposed revised
 NCP and the interim RI/FS guidance, preliminary
 remediation goals typically are formulated  first
 during project scoping or concurrent with initial
 RI activities (i.e.,  prior to completion of the
 baseline risk assessment).    The preliminary
remediation goals are therefore based initially on
 readily available chemical-specific ARARs (e.g.,
 maximum contaminant levels (MCLS) for drinking
 water).     Preliminary remediation goals for
 individual substances are refined or confirmed at
 the conclusion of the baseline  risk assessment
(Part B of this manual addresses the refinement
of preliminary remediation goals). These refined
preliminary remediation goals are based both on
risk assessment and on chemical-specific ARARs.
Thus, they are intended to be protective and to
comply with ARARs.  The analytical approach
used to develop these refined goals involves:

     •    identifying chemical-specific ARARs;

     •    identifying    levels  based  on  risk
         assessment    where   chemical-specific
         ARARs are not available or situations
         where multiple contaminants or multiple
         exposure pathways make ARARs not
         protective

     •    identifying  non-substance-specific goals
         for exposure pathways (if necessary); and

     •    determining a  refined preliminary
         remediation goal that is protective of
         human  health for all substance/exposure
         pathway combinations  being addressed.

     Development and screening of alternatives.
Once  remedial action objectives have been
developed, general  response actions, such  as
treatment, containment, excavation, pumping, or
other actions that may be taken to satisfy those
objectives should be  developed. In the process of
developing alternatives for remedial action at a
site, two important activities take place. First,
volumes or areas of waste or environmental media
that need to be addressed by the remedial action
are determined by information on the nature and
extent of contamination, ARARs, chemical-specific
environmental fate and toxicity information, and
engineering analyses.  Second, the remedial  action
alternatives and associated technologies are
screened to identify those that would be effective
for the contaminants  and media of interest at the
site. The information developed in these two
activities is used in assembling technologies into
alternatives for the  site  as a whole  or for a
specific operable unit.

     The Superfund program has long permitted
remedial actions to  be staged through multiple
operable units.   Operable units are discrete
actions that comprise  incremental steps toward the
final remedy. Operable units may be actions that
completely address a geographical portion of a site

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                                                                                           Page 1-9
or a specific site problem (e.g., drums and tanks,
contaminated ground water) or the entire site.
Operable units include interim actions (e.g.,
pumping and treating of ground water to retard
plume migration)  that must be  followed by
subsequent actions to fully address the scope of
the problem (e.g., final ground-water operable
unit that defines the remediation goals and
restoration timeframe). Such operable units may
be taken in response to a pressing problem that
will worsen if unaddressed, or because there is an
opportunity to undertake a limited action that will
achieve significant risk reduction quickly. The
appropriateness of dividing remedial actions into
operable units is determined by considering the
interrelationship of site problems and the need or
desire to initiate actions quickly. To the degree
that site problems are interrelated, it may be most
appropriate to address the problems together.
However, where  problems   are reasonably
separable, phased responses implemented through
a sequence of operable units may promote more
rapid risk reduction.

     In  situations where numerous potential
remedial alternatives are initially developed, it may
be necessary to screen the alternatives to narrow
the list to be evaluated in detail. Such screening
aids in  streamlining the feasibility study while
ensuring that the most promising alternatives are
being considered.

     Detailed analysis of alternatives. During the
detailed analysis,  each alternative is assessed
against specific evaluation criteria and the results
of this assessment arrayed such that comparisons
between alternatives can be made and key trade-
offs identified. Nine evaluation criteria,  some of
which are related to human health evaluation and
risk, have been developed to address statutory
requirements as well as additional technical and
policy considerations that have proven to  be
important   for   selecting   among   remedial
alternatives. These evaluation criteria, which are
identified and discussed in the interim final RI/FS
guidance, serve as the basis for conducting the
detailed  analyses  during  the  FS  and for
subsequently selecting an appropriate remedial
action.    The nine evaluation criteria are  as
follows:

     (1) overall protection of human health and
         the environment;
    (2) compliance with ARARs (unless waiver
         applicable);

    (3) long-term effectiveness  and permanence;

    (4) reduction of toxicity, mobility, or volume
         through the use of treatment;

    (5) short-term effectiveness;

    (6) implementability

    (7)  cost;

    (8) state acceptance; and

    (9) community acceptance.

Risk  information is required at  the detailed
analysis stage of the  RI/FS so that each alternative
can be evaluated in  relation to the relevant NCP
remedy  selection criteria.

    The detailed analysis must, according to the
proposed NCP, include an evaluation of each
alternative against the nine criteria. The first two
criteria (i.e., overall protectiveness and compliance
with ARARs) are threshold determinations and
must  be met before a remedy can be selected.
Evaluation of the overall protectiveness of an
alternative during the RI/FS should focus on how
a specific alternative achieves protection over time
and how site risks are reduced.

    The next five criteria (numbers 3 through 7)
are primary balancing criteria.    The last two
(numbers 8 and 9) are considered modifying
criteria, and risk information does not play a
direct role in the analysis of them. Of the five
primary balancing criteria, risk information is of
particular   importance  in   the  analysis  of
effectiveness and permanence. Analysis of long-
term effectiveness  and permanence involves an
evaluation of the results of a remedial action in
terms of residual risk at the site after response
objectives have been met. A primary focus of this
evaluation is the effectiveness of the controls that
will be applied to manage risk posed by treatment
residuals and/or any  untreated wastes that may be
left on the site, as well as the volume and nature
of that  material.   It should also  consider  the
potential impacts  on human  health and  the
environment should  the  remedy fail.  An

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    1-10
evaluation of short-term effectiveness addresses
the impacts of  the  alternative during  the
construction and implementation phase until
remedial response objectives will be met.  Under
this criterion, alternatives should be evaluated with
respect to  the potential effects on human  health
and the environment during implementation of the
remedial  action and the length of time until
protection  is achieved.
1.2 OVERALL ORGANIZATION OF
    THE MANUAL

    The next two chapters present additional
background  material  for the  human health
evaluation process.  Chapter 2 discusses statutes,
regulations, guidance, and studies relevant to the
Superfund human health evaluation. Chapter 3
discusses issues related to planning for the human
health evaluation. The remainder of the manual
is organized by the three parts of the human
health evaluation process:

     •   the baseline risk assessment is covered
         in Part A of the manual (Chapters 4
         through 10);

     •   refinement of preliminary remediation
         goals is covered in Part B of the manual
        (not included as part of this interim final
        version); and

    •   the   risk   evaluation   of remedial
        alternatives is covered in Part C of the
        manual (not included as part of this
        interim final version).

    Chapters  4 through  8 provide detailed
technical guidance for conducting the steps of a
baseline risk assessment, and Chapter 9 provides
documentation and review guidelines. Chapter 10
contains additional guidance specific to baseline
risk assessment for sites contaminated  with
radionuclides. Sample calculations, sample  table
formats, and references to other guidance are
provided throughout the manual. All material is
presented both in technical terms and in  simpler
text. It should be stressed that the manual is
intended to be comprehensive and to provide
guidance for more situations than usually are
relevant to any single site. Risk assessors  need
not use those  parts of the manual that do not
apply to their site.

    Each chapter in Part A includes a glossary of
acronyms and definitions of commonly used terms.
The manual also includes two  appendices:
Appendix A provides technical guidance  for
making absorption adjustments and Appendix B
is an index.

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                                                                                                           Page 1-11

                                   ENDNOTES FOR CHAPTER 1
1. References made to CERCLA throughout this document should be interpreted as meaning "CERCLA, as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA)."

2. 40 CFR Part 300. Proposed revisions to the NCP were published on December 21, 1988 (53 Federal Register 51394).

3. The term "public health evaluation" was introduced in the previous risk assessment guidance (EPA 1986f) to describe the assessment
of chemical releases from a site and the analysis of public health threats resulting from those releases, and Superfund site risk assessment
studies often are referred to as public health evaluations, or PHEs. The term "PHE" should be replaced by whichever of the three parts
of the revised human health evaluation process is appropriate "baseline risk assessment," "documentation of preliminary remediation
goals," or "risk evaluation of remedial alternatives."

4. Baseline risks are risks that might exist if no remediation or institutional controls were applied at a site.

5. Volume II of the Risk Assessment Guidance for  Superfund is the Environmental Evaluation Manual  (EPA 1989b), which  provides
guidance for the analysis of potential environmental (i.e., not human health) effects at sites.

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Page 1-12


                                REFERENCES  FOR  CHAPTER  1


Congressional Research Service (CRS), Library of Congress. 1983. A Review of Risk Assessment Methodologies. Washington, D.C.

Environmental Protection Agency (EPA). 1984. Risk Assessment and Management: Framework for Decisionmaking. EPA/600/9-
     85/002.

Environmental Protection Agency (EPA).  1986a. Guidelines for Carcinogen Risk Assessment.  51 Federal Register 33992 (September
     24, 1986).

Environmental Protection Agency (EPA). 1986b. Guidelines for Exposure Assessment. 51 Federal Register 34042 (September 24,
Environmental Protection Agency (EPA). 1986c. Guidelines for Mutagenicitv Risk Assessment. 51 Federal Register 34006 (September
     24, 1986).

Environmental Protection Agency (EPA). 1986d. Guidelines for the Health Assessment of Suspect Developmental Toxicants. 51
     Federal Register 34028 (September 24, 1986).

Environmental Protection Agency (EPA). 1986e. Guidelines for the Health Risk Assessment of Chemical Mixtures. 51 Federal
     Register 34014 (September 24.  1986).

Environmental Protection Agency (EPA). 1986f. Superfund Public Health Evaluation Manual. Office of Emergency and Remedial
     Response. EPA/540/1-86/060. (OSWER Directive 9285.4-1).

Environmental Protection Agency (EPA).  1988a. Proposed Guidelines for Exposure-related Measurements. 53 Federal Register 48830
     (December 2, 1988).

Environmental Protection Agency (EPA). 1988b. Guidance for ConductingRemedial Investigations and Feasibility Studies Under
     CERCLA. Interim Final. Office of Emergency and Remedial Response. (OSWER Directive 9355.3-01).

Environmental Protection Agency (EPA). 1989a. Proposed Amendments to the Guidelines for the Health Assessment of Suspect
     Developmental  Toxicants. 54 Federal Register 9386  (March  6, 1989).

Environmental Protection Agency (EPA). 1989b. Risk Assessment Guidance for Superfund: Environmental Evaluation Manual.
     Interim Final. Office of Emergency and Remedial Response. EPA/540/1-89/001A. (OSWER Directive 9285.7-01).

National Academy of Sciences  (NAS). 1983. Risk Assessment in the Federal Government: Managing the Process. National Academy
     Press. Washington, D.C.

Office of Science and Technology Policy (OSTP). 1985.  Chemical Carcinogens A Review of the Science and Its Associated Principles.
     50 Federal Register 10372 (March 14, 1985).

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                            CHAPTER  2

               STATUTES,  REGULATIONS,
                        GUIDANCE, AND
                  STUDIES RELEVANT TO
                   THE  HUMAN HEALTH
                           EVALUATION
   This chapter briefly describes the statutes,
regulations, guidance, and studies related to the
human  health evaluation process.  The
descriptions focus on aspects of these documents
most relevant to human health evaluations and
show how recent revisions to the documents bear
upon  the human health evaluation process.
Section 2.1 describes the following documents that
govern the human health evaluation

   •   the  Comprehensive  Environmental
       Response, Compensation, and Liability
       Act of 1980 (CERCLA or Superfund)
       and the Superfund Amendments and
       Reauthorization Act of 1986 (SARA);

   •   the National  Oil  and Hazardous
       Substances Pollution Contingency Plan
       (National Contingency Plan, or NCP);

   •   Guidance for Conducting Remedial
      Investigations and Feasibility Studies Under
       CERCLA (RI/FS guidance);

   •   CERCLA Compliance with Other Laws
      Manual (ARARs guidance); and

   •   Superfund Exposure Assessment Manual
       (SEAM).

Exhibit 2-1 shows  the  relationship of these
statutes,  regulations, and guidances governing
human health evaluation.  In addition, Section
2.2 identifies and briefly describes other Superfund
studies related to, and sometimes confused with,
the RI/FS human health evaluation. The types of
studies discussed are:

    •   endangerment assessment,
    •   ATSDR health assessments; and
    •   ATSDR health studies.
2.1  STATUTES, REGULATIONS,
    AND GUIDANCE  GOVERNING
    HUMAN HEALTH
    EVALUATION

    This section describes the major Superfund
laws and program documents relevant to the
human health evaluation process.

2.1.1 CERCLA AND SARA

    In 1980, Congress enacted the Comprehensive
Environmental Response, Compensation,  and
Liability Act (CERCLA) (42  U.S.C 9601 et seq.),
commonly called Superfund, in response to the
dangers  posed  by  sudden or otherwise
uncontrolled releases of hazardous substances,
pollutants, or contaminants into the environment.
CERCLA authorized $1.6 billion over five years
for a comprehensive  program to cleanup the

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                     EXHIBIT  2-1

RELATIONSHIP  OF DOCUMENTS GOVERNING
          HUMAN  HEALTH EVALUATION
                      Statutes
           Comprehensive Environmental Response,
           Compensation, and Liability Act of 1980
                 (CERCLA or Superfund)

                Superfund Amendments and
             Reauthorization Act of 1986 (SARA)
             Regulation ("Blueprint" for
             Implementing the Statutes)
            National Oil and Hazardous Substances
              Pollution Contingency Plan (NCP)
                     Guidance
                    RI/FS Guidance
        Risk Assessment Guidance for Superfund (RAGS)
        « Human Health Evaluation Manual (HHEM)
        • Environmental Evaluation Manual (EEM)
                   ARARs Guidance
        Superfund Exposure Assessment Manual (SEAM)

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                                                                                         Page 2-3
worst abandoned,  or inactive waste sites in the
nation. CERCLA funds used to establish and
administer the cleanup program are derived
primarily from taxes on crude oil and 42 different
commercial  chemicals.

     The reauthorization of CERCLA is known
as   the   Superfund    Amendments    and
Reauthorization Act (SARA), and was signed by
the President  on October  17, 1986. (All further
references to CERCLA in this appendix should be
interpreted as "CERCLA as amended by SARA")
These amendments provided $8.5 billion for the
cleanup program and an additional $500 million
for cleanup of leaks from underground storage
tanks.    Under SARA, Congress strengthened
EPA's mandate to focus on permanent cleanups
at Superfund sites, involve the public in decision
processes  at  sites, and encourage states and
federally recognized Indian tribes to actively
participate  as partners with EPA to address these
sites.      SARA  expanded EPA's  research,
development (especially in the area of alternative
technologies),  and training  responsibilities.  SARA
also strengthened EPA's enforcement  authority.
The changes to CERCLA sections  104 (Response
Authorities) and 121 (Cleanup  Standards) have
the greatest impact on the  RI/FS process.

     Cleanup  standards. Section 121 (Cleanup
Standards)  states a strong preference for remedies
that are highly reliable and provide long-term
protection. In addition to the requirement for
remedies to be both protective of human health
and the environment and cost-effective,   other
remedy selection considerations in  section  121 (b)
include:

     •    a preference for  remedial actions that
         employ (as a principal element of the
         action) treatment that permanently and
         significantly reduces the volume, toxicity,
         or mobility of hazardous substances,
         pollutants, and contaminants;

     •    offsite transport  and disposal without
         treatment as the least favored alternative
         where practicable  treatment technologies
         are available; and

     •    the need to assess the use of alternative
         treatment technologies  or  resource
         recovery technologies and use them to
         the maximum extent practicable.

     Section 121(c) of CERCLA  requires  a
periodic review of remedial actions, at least every
five years after initiation, for as long as hazardous
substances, pollutants, or contaminants that may
pose a threat to human health or the environment
remain at the site. If during a five-year review  it
is determined that the action no longer protects
human health and the environment, further
remedial actions will need to be considered.

     Section    121(d)(2)(A)   of  CERCLA
incorporates into law the CERCLA Compliance
Policy, which specifies that Superfund remedial
actions meet any federal standards, requirements,
criteria, or limitations that are determined to be
legally applicable  or  relevant and appropriate
requirements (i.e., ARARs). Also included is the
new provision that state ARARs must be met  if
they  are more stringent than federal requirements.
(Section 2.1.4 provides more detail on ARARs.)

    Health-related authorities. Under CERCLA
section 104(i)(6), the Agency for Toxic Substances
and Disease Registry (ATSDR) is required to
conduct a health assessment for every site included
or proposed for inclusion  on the National
Priorities List. The ATSDR health assessment,
which is fairly qualitative  in  nature, should be
distinguished   from the EPA  human health
evaluation, which is  more quantitative. CERCLA
section 104(i)(5)(F) states that:

    the term "health assessments" shall include
    preliminary assessments of the potential risk
    to human health posed by individual sites and
    facilities, based  on  such factors as the nature
    and extent of contamination, the existence of
    potential  pathways  of human exposure
    (including ground  or surface water
    contamination, air emissions, and food chain
    contamination),   the  size  and  potential
    susceptibility of the community within the
    likely pathways  of  exposure, the  comparison
    of expected human exposure levels to the
    short-term and long-term health effects
    associated    with    identified    hazardous
    substances and any available recommended
    exposure or tolerance  limits  for  such
    hazardous  substances, and the comparison of
    existing morbidity and mortality data on

-------
Page 24
    diseases that may be associated with the
    observed levels   of exposure.      The
    Administrator   of ATSDR  shall   use
    appropriate data, risk  assessments, risk
    evaluations and studies  available from the
    Administrator of EPA.

    There are purposeful differences between an
ATSDR health assessment and traditional risk
assessment.    The health  assessment is usually
qualitative,  site-specific, and focuses on medical
and public health perspectives. Exposures to site
contaminants are discussed in terms of especially
sensitive populations,  mechanisms  of toxic
chemical action, and possible disease outcomes.
Risk assessment, the framework of the EPA
human health evaluation, is a characterization of
the probability of adverse effects from human
exposures to environmental  hazards.    In this
context,  risk assessments differ from  health
assessments in that they are quantitative, chemical-
oriented characterizations  that use statistical and
biological models to  calculate  numerical estimates
of  risk to  health.    However, both  health
assessments and risk assessments use data from
human epidemiological  investigations, when
available, and when human toxicological data are
unavailable, rely  on  the results of animal
toxicology  studies.

2.1.2    NATIONAL CONTINGENCY  PLAN
         (NCP)

    The National Contingency Plan provides the
organizational structure  and procedures  for
preparing for and responding to discharges of oil
and releases of hazardous  substances, pollutants,
and contaminants.   The NCP is required by
section 105 of CERCLA and by section 311 of the
Clean Water Act. The current NCP  (EPA  1985)
was published on November 20, 1985, and a
significantly revised version (EPA 1988a) was
proposed December 21, 1988 in response to
SARA. The proposed  NCP is organized into the
following subparts:

    •    Subpart A  ~  Introduction

    •    Subpart B   —  Responsibility and
         Organization  for Response

    •    Subpart C ~ Planning and Preparedness
     •    Subpart D  —  Operational Response
         Phases for Oil Removal

     •    Subpart E  —  Hazardous Substance
         Response

     •    Subpart F  —  State Involvement in
         Hazardous Substance Response

     •    Subpart G  —  Trustees for Natural
         Resources

     •    Subpart H — Participation by Other
         Persons

     •    Subpart I ~  Administrative Record for
         Selection of Response Action

     •    Subpart J — Use of Dispersants and
         Other Chemicals

     Subpart E, Hazardous Substance Response,
contains a detailed plan covering the entire range
of authorized activities involved in abating and
remedying releases  or threats of releases of
hazardous    substances,    pollutants,    and
contaminants.   It contains provisions  for both
removal  and  remedial response.  The remedial
response process set forth by the proposed NCP
is a seven-step process, as described below. Risk
information plays a role in each step.

     Site discovery or notification. Releases of
hazardous substances,  pollutants, or contaminants
identified by federal,  state, or local government
agencies or private parties are reported to the
National  Response Center or EPA.    Upon
discovery, such potential sites are screened to
identify release situations warranting further
remedial response consideration. These sites are
entered into the CERCLA Information System
(CERCLIS). This computerized system serves as
a data  base of site information and tracks the
change in status of a site through the response
process. Risk information is used to determine
which  substances are hazardous and, in some
cases, the quatities that constitute a release that
must be reported (i.e., a reportable quantity, or
RQ, under CERCLA section  103(a)).

     Preliminary assessment  and site inspection
(PA/SI).   The preliminary assessment involves
collection and review of all available information

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                                                                                          Page 2-5
and may include offsite reconnaissance to evaluate
the source and nature of hazardous  substances
present and to identify the responsible party(ies).
At the conclusion of the preliminary assessment,
a site may be referred for further action, or a
determination may be made that no further action
is needed.   Site inspections, which  follow the
preliminary assessment for sites needing further
action, routinely include the collection  of samples
and are conducted to help determine the extent
of the problem and to obtain information needed
to determine whether  a removal  action is
warranted.  If, based on the site inspection, it
appears likely that the site should be  considered
for inclusion on the National Priorities List
(NPL), a listing site inspection (LSI) is  conducted.
The LSI is a more extensive investigation than the
SI, and a main objective of the LSI is to collect
sufficient data about a site to support Hazard
Ranking System (HRS) scoring. One of the main
objectives of the PA/SI is to collect risk-related
information for sites so that the  site can be scored
using the HRS and priorities may be set for more
detailed studies, such as the RI/FS.

   Establishing priorities for remedial action.
Sites  are scored using the HRS, based on data
from the PA/SI/LSI. The HRS scoring process is
the primary mechanism for determining the sites
to be included on the NPL and, therefore, the
sites eligible for Superfund-financed remedial
action. The HRS is a numerical  scoring model
that is based on many of the factors affecting risk
at a site. A revised version of the HRS (EPA
1988b) was proposed December 23,  1988.

    Remedial investigation/feasibility study
(RI/FS). As described in Section 1.1, the RI/FS
is the framework for determining appropriate
remedial actions at  Superfund sites.  Although
RI/FS activities technically are removal  actions
and therefore not restricted to  sites on the NPL
(see sections  101(23) and 104(b) of CERCLA),
they most frequently are undertaken at  NPL sites.
Remedial  investigations are conducted  to
characterize the contamination at the  site and to
obtain information needed to identify, evaluate,
and select cleanup alternatives.  The feasibility
study  includes an analysis of alternatives based
on the nine NCP evacuation criteria. The human
health evaluation described in  this manual, and
the environmental evaluation described elsewhere,
 are the guidance for developing risk information
 in the RI/FS.

    Selection of remedy.      The  primary
 consideration in selecting a remedy is that it be
 protective of human health and the environment,
 by eliminating, reducing,  or controlling risks posed
 through each pathway. Thus, the risk information
 developed in the RI/FS is a key input to remedy
 selection. The results of the RI/FS are reviewed
 to identify a preferred alternative,  which is
 announced to  the public in a Proposed Plan.
 Next, the lead agency reviews any resulting public
 comments on the Proposed Plan, consults with the
 support agencies to evaluate whether the preferred
 alternative is still the most appropriate, and then
 makes a final decision.    A record of decision
 (ROD) is written to document the rationale for
 the selected  remedy.

    Remedial design/remedial action. The
 detailed design of the selected remedial action is
 developed  and then implemented.   The risk
 information developed previously in the RI/FS
 helps  refine the remediation goals that the remedy
 will attain.

    Five-year review. Section 121(c) of CERCLA
 requires a periodic review of remedial actions, at
 least  every five years after initiation of such
 action, for  as  long as  hazardous substances,
 pollutants, or contaminants that may pose a threat
 to human health  or the environment remain at
 the site.   If it is  determined during a five-year
 review that the action no longer protects human
 health and the environment,  further remedial
 actions will need to be considered.

    Exhibit 2-2 diagrams the general steps of the
 Superfund remedial process, indicating where in
 the process the various parts of the human health
 evaluation are conducted.

 2.1.3     REMEDIAL INVESTIGATION/
         FEASIBILITY  STUDY GUIDANCE

    EPA's interim final Guidance for Conducting
Remedial Investigations and Feasibility  Studies
 Under CERCLA (EPA 1988c) provides  a detailed
 structure for conducting field studies to support
 remedial decisions and for identifying, evaluating,
 and selecting remedial action alternatives under
 CERCLA.   This  1988 guidance document is a

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Page 2-6
                               EXHIBIT 2-2

            ROLE OF THE HUMAN HEALTH EVALUATION IN
                  THE SUPERFUND REMEDIAL PROCESS
Site
Discovery




Preliminary Assessment/
Site Inspection/Listing
Site Inspection
(PA/SI/LSI)




HI
NI

IS Scoring/
>L Listing



Rented!
Investig
Feasibil
Study
(RI/FS)

al
ation/
ity
a



HUMAN
WSAtttt
EVALUATION





PART A
Baseline R
Assessme
(RI)
-••••••I
U|
nt 1



Selection
' of
Remedy

PARTC
Risk Evaluation
of Remedial
Alternatives (FS)
Development/
Refinement
of Preliminary
Remediation
Goals (FS)
Remedial
^. Design/
Remedial
Action
(RD/RA)


              "The RI/FS can be undertaken prior to NPL listing.

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                                                                                        Page 2-7
revision of two separate guidances for remedial
investigations and for feasibility studies published
in 1985. These guidances have been consolidated
into a single document and revised to:

    •    reflect new emphasis and provisions of
         SARA;

    •    incorporate aspects of new or revised
         guidance related to RI/FSs;

    •    incorporate  management   initiatives
         designed  to streamline  the  RI/FS
         process; and

    •    reflect experience gained from previous
         RI/FS  projects.

    The  RI/FS consists of the following general
steps:

    •    project scoping (during the RI);

    •    site characterization (RI);

    •    establishment  of   remedial   action
         objectives (FS);

    •    development   and    screening of
         alternatives (FS); and

    •    detailed analysis of alternatives (FS).

Because Section 1.1 describes each of these steps,
focusing on the role that risk information plays in
the RI/FS, a discussion  of the steps  is not
repeated here. The RI/FS  guidance  provides the
context into which the human health evaluation
fits and should be used in conjunction with this
manual.

2.1.4 ARARS GUIDANCE

    The interim final CERCLA Compliance with
Other Laws Manual (EPA 1988d; EPA 1989a), or
ARARs guidance, was developed to assist in the
selection of onsite remedial actions that meet the
applicable  or    relevant   and    appropriate
requirements  (ARARs)  of  the Resource
Conservation  and Recovery Act  (RCRA), Clean
Water  Act (CWA),  Safe Drinking Water Act
(SDWA), Clean Air Act (CM), and other federal
and state environmental laws,  as  required by
CERCLA section 121. Part I of the manual
discusses  the overall procedures for identifying
ARARs  and  provides  guidance on the
interpretation and analysis of RCRA requirements.
Specifically

     •    Chapter 1  defines "appliable" and
         "relevant and appropriate," provides
         matrices listing  potential chemical-
         specific, location-specific, and action-
         specific requirements from RCRA,  CWA,
         and SDWA, and  provides general
         procedures for identifying and analyzing
         requirement,

     •    Chapter 2 discusses special issues of
         interpretation and  analysis  involving
         RCR^A requirements, and provides
         guidance on when RCRA requirements
        will be ARARs for  CERCLA remedial
         actions;

     •    Chapter 3  provides guidance for
        compliance with CWA substantive (for
        onsite    and   offsiite   actions)   and
        administrative (for offsite actions)
        requirements for direct  discharges,
        indirect discharges,  and dredge and fill
        activities;

     •    Chapter 4  provides guidance for
         compliance  with  requirements  of the
         SDWA  that may  be applicable or
        relevant and appropriate  to  CERCLA
        sites; and

     •    Chapter 5  provides guidance  on
        consistency  with  policies" for ground-
        water protection.

The manual also contains a hypothetical scenario
illustrating how ARARs are identified and used,
and an appendix summarizing the provisions of
RCRA, CWA and SDWA.

    Part II of the ARARs guidance covers the
Clean Air Act,  other federal statutes, and state
requirements.  Specifically:

    •   Chapter  1 provides an introduction to
        Part II  of the guidance, and also includes
        extensive summary tables;

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 Page 2-8
     •   Chapter 2  describes Clean Air Act
         requirements and related RCRA and
         state requirements;

     •   Chapters 3 and 4 provide guidance for
         compliance with several other federal
         statutes;

     •   Chapter 5 discusses potential ARARs for
         sites contaminated  with radioactive
         substances;

     •   Chapter 6 addresses requirements specific
         to mining, milling, or smelting sites; and

     •   Chapter  7 provides guidance  on
         identifying  and complying with state
         ARARs.

2.1.5     SUPERFUND  EXPOSURE
         ASSESSMENT MANUAL

     The Superfund Exposure Assessment Manual
(EPA 1988e),  which  was developed by the
Superfund program specifically as a companion
document to the original  Superfund Public Health
Evaluation Manual (EPA 1986), provides RPMs
and regional risk assessors with the guidance
necessary to conduct exposure assessments that
meet the needs  of the Superfund human health
risk evaluation process.  Specifically, the manual:

     •  provides an overall description of the
         integrated exposure assessment as it is
         applied to uncontrolled hazardous waste
         sites; and

     •   serves  as  a   source  of reference
         concerning the  use of estimation
         procedures and computer modeling
         techniques   for   the   analysis  of
         uncontrolled sites.

    The analytical  process  outlined  in the
Superfund Exposure Assessment Manual provides
a framework  for the assessment of exposure to
contaminants  at or migrating from uncontrolled
hazardous waste sites. The application of both
monitoring and modeling procedures to the
exposure assessment process is outlined  in the
manual. This  process considers all contaminant
releases and exposure routes and assures that an
 adequate level of analytical detail is applied to
 support the human health risk assessment process.

     The exposure assessment process described in
 the Superfund Exposure Assessment Manual is
 structured  in five segments:

     (1) analysis of contaminant releases from a
        subject site into environmental media;

     (2) evaluation   of  the  transport   and
        environmental fate of the contaminants
        released;

     (3) identification,    enumeration,    and
        characterization of potentially exposed
        populations;

     (4) integrated exposure analysis; and

     (5) uncertainty analysis.

     Two recent publications from EPA's Office
 of Research and Development, the Exposure
Factors Handbook (EPA 1989b) and the Exposure
Assessment Methods Handbook  (EPA 1989c),
 provide useful information to supplement the
Superfund Exposure Assessment Manual.  All three
of these key exposure assessment references should
be used in conjunction with Chapter 6 of this
manual.
2.2 RELATED  SUPERFUND
    STUDIES

    This section identifies and briefly describes
other Superfund studies related to, and sometimes
confused with, the RI/FS human health evaluation.
It contrasts the objectives and methods and
clarifies the relationships  of these other studies
with RI/FS health risk assessments. The types of
studies discussed are endangerment assessments,
ATSDR health assessments,  and ATSDR health
studies.

2.2.1 ENDANGERMENT ASSESSMENTS

    Before taking enforcement action against
parties responsible for a hazardous waste site,
EPA must determine that  an imminent and
substantial endangerment to public health or the

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                                                                                        Page 2-9
environment exists as a result of the site. Such a
legal determination is  called an endangerment
assessment.  For remedial sites, the process for
analyzing whether there may be an endangerment
is described in this Human Health Evaluation
Manual and  its  companion Environmental
Evaluation Manual. In the past, an endangerment
assessment often was prepared as a study separate
from the baseline risk assessment.  With the
passage of SARA and changes in Agency practice,
the need to perform a detailed endangerment
assessment as  a separate effort from the baseline
risk assessment has been eliminated.

     For administrative orders requiring a remedial
design or   remedial action,   endangerment
assessment determinations are now based on
information developed in the site baseline risk
assessment. Elements included in the  baseline
risk assessment conducted at a Superfund site
during the RI/FS process fully satisfy the
informational requirements of the endangerment
assessment. These elements include the following:

     •   identification of the hazardous wastes
         or hazardous  substances present in
         environmental media;

     •   assessment of exposure, including a
         characterization  of the environmental
         fate and transport mechanisms for the
         hazardous wastes and substances present,
         and of exposure pathways;

     •   assessment  of  the  toxicity  of the
         hazardous wastes or substances present;

     •   characterization of human health risks;
         and

     •   characterization of the impacts and/or
         risks to the environment.

     The  human  health and environmental
evaluations that  are  part  of the RI/FS are
conducted for purposes of determining the
baseline risks posed by the site, and for ensuring
that the selected remedy will be protective of
human health and  the environment.  The
endangerment assessment is  used to support
litigation by determining that an imminent and
substantial endangerment exists.   Information
presented in the human health and environmental
evaluations is basic to the legal determination of
endangerment.

    In  1985,  EPA produced a draft manual
specifically written for endangerment assessment,
the Endangerment Assessment Handbook. EPA
has determined that a guidance separate from the
Risk Assessment Guidance for Superfund (Human
Health Evaluation Manual and Environmental
Evaluation  Manual)  is  not  required   for
endangerment    assessment   therefore,     the
Endangerment Assessment Handbook will not be
made final and should no longer be used.

2.2.2 ATSDR HEALTH ASSESSMENTS

    CERCLA section 104(i), as amended, requires
the Agency for Toxic  Substances  and Disease
Registry (ATSDR) to conduct health assessments
for all sites listed or proposed to be fisted on the
NPL. A health assessment includes a preliminary
assessment of the potential  threats that individual
sites and facilities pose to human health.  The
health assessment is required to be completed "to
the   maximum   extent   practicable" before
completion of the RI/FS. ATSDR personnel,
state personnel (through cooperative agreements),
or contractors  follow six basic steps, which are
based on the same general risk assessment
framework as the EPA human health evaluation:

     (1)  evaluate  information on the  site's
         physical, geographical, historical, and
         operational    setting,    assess    the
         demographics of nearby populations, and
         identify health concerns of the affected
         community(ies);

     (2)  determine contaminants of concern
         associated with the site;

     (3)  identify and evaluate environmental
         pathways;

     (4)  identify and evaluate  human exposure
         pathways;

     (5)  identify and  evaluate public health
         implications based on available medical
         and toxicological  information;  and

     (6)  develop conclusions concerning the
         health threat posed by the site and make

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Page 2-10
         recommendations   regarding
         public health activities.
further
    The  purpose   of the  ATSDR  health
assessment is to assist in the evaluation of data
and information on the release of toxic substances
into the environment in order to assess any
current or future impact on public health, develop
health  advisories  or other  health-related
recommendations, and identify studies or actions
needed to evaluate and prevent human health
effects.  Health  assessments are intended to help
public health and regulatory officials determine if
actions should be taken to reduce human exposure
to hazardous  substances and  to recommend
whether  additional  information  on human
exposure and associated risks is needed. Health
assessments also are written for the benefit of the
informed community associated with a site, which
could include citizen groups, local leaders, and
health professionals.

    Several important differences exist between
EPA human health evaluations and ATSDR
health  assessments.     EPA  human  health
evaluations include quantitative, substance-specific
estimates of the risk that a site poses to human
health. These estimates depend on statistical and
biological models that use data from human
epidemiologic investigations and animal toxicity
studies.  The information generated from a human
health evaluation is used in risk management
decisions to establish cleanup levels and select a
remedial alternative.

    ATSDR health  assessments, although they
may employ quantitative data, are more qualitative
in nature. They focus not only on the possible
health threats posed by chemical contaminants
attributable to a site, but consider all health
threats, both chemical and physical, to which
residents near a site may be subjected. Health
assessments focus on the medical and public
health concerns  associated with exposures at a site
and discuss especially sensitive populations, toxic
mechanisms, and possible disease outcomes. EPA
considers the information in a health assessment
 along with the results of the  baseline risk
assessment to give a complete picture of health
threats.  Local health professionals and residents
use the information  to understand the potential
health threats  posed by specific waste  sites.
Health assessments may lead to pilot health effects
studies, epidemiologic studies, or establishment of
exposure or disease registries.

     EPA's Guidance for Coordinating ATSDR
Health Assessment Activities with the Superfund
Remedial Process (EPA 1987) provides information
to EPA and ATSDR managers  for use  in
coordinating human health  evaluation activities.
(Section 2.1, in its discussion of CERCLA,
provides further information on the statutory basis
of ATSDR health assessments.)

2.2.3 ATSDR HEALTH STUDIES

     After  conducting  a  health assessment,
ATSDR may determine that additional health
effects information is needed at a site and, as a
result, may undertake a pilot study, a full-scale
epidemiological study, or a disease registry. Three
types of pilot studies are predominant:

     (1)  a symptom/disease prevalence study
         consisting of a measurement of self-
         reported disease occurrence, which may
         be validated through medical records if
         they are available;

     (2)  a human exposure study consisting of
         biological sampling of persons who have
         a  potentially high likelihood of exposure
         to determine if actual exposure can be
         verified, and

     (3)  a  cluster investigation study consisting
         of an investigation of putative disease
         clusters to determine if the cases  of a
         disease are excessively high in the
         concerned community.

     A fill-scale epidemiological study is an
analytic investigation that evaluates  the possible
causal    relationships   between   exposure  to
hazardous  substances and  disease outcome by
testing a scientific hypothesis.     Such an
epidemiological study is usually not undertaken
unless a pilot study reveals  widespread exposure
or increased prevalence of disease.

     ATSDR, in cooperation with the states, also
may choose to follow up the results of a health
assessment by establishing and maintaining
national registries of persons exposed to hazardous
substances  and persons with serious diseases or

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                                                                                            Page 2-11
illness. A registry is a system for collecting and
maintaining, in a structured record, information on
specific persons from a defined population. The
purpose of a registry of persons exposed to
hazardous substances is to facilitate development
of new scientific knowledge through identification
and subsequent follow-up of persons exposed to
a defined substance at selected sites.
     Besides identifying and tracking of exposed
persons, a registry also is used to coordinate the
clinical and  research activities that involve the
registrants. Registries serve an important role in
assuring the uniformity and quality  of the
collected data and ensuring that  data collection  is
not duplicative,  thereby reducing the overall
burden to exposed or potentially exposed persons.

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Page 2-12


                                 REFERENCES  FOR  CHAPTER 2
Environmental Protection Agency (EPA). 1985. National Oil and Harardous Substances Pollution Contingency Plan. Final Rule. 50
     Federal Register 47912 (November 20, 1985).

Environmental Protection Agency (EPA). 1986. Superfund Public Health Evaluation Manual.   Office of Emergency and Remedial
     Response. EPA/540/1-86/060. (OSWER Directive 9285.4-1).

Environmental Protection Agency (EPA). 1987. Guidance for Coordinating ATSDR Health Assessment Activities with the Superfund
     Remedial Process. Office of Emergency and Remedial Response. (OSWER Directive 9285.442).

Environmental Protection Agency (EPA). 1988a. National Oil and Hazardous Substances Pollution Contingency Plan. Proposed Rule.
     53 Federal Register 51394 (December 21, 1988).

Environmental Protection Agency (EPA). 1988b. Hazard Ranking System (EfRS) for Uncontrolled Hazardous Substance Releases.
     Proposed Rule. 53 Federal Register 51962 (December 23, 1988).

Environmental Protection Agency (EPA). 1988c. Guidance for Conducting Remedial Investigations and Feasibility Studies Under
     CERCLA Interim Final. Office of Emergency and Remedial Response. (OSWER Directive 9355.3-01).

Environmental Protection Agency (EPA).  1988d. CERCLA compliance with Other Laws Manual. Part I. Interim Final. Office of
     Emergency and Remedial Response. (OSWER Directive  9234.1-01).

Environmental Protection Agency (EPA). 1988c. Superfund Exposure Assessment Manual. Office of Emergency and Remedial
     Response. EPA/540/1-88/001. (OSWER Directive 9285.5-1).

Environmental Protection Agency (EPA). 1989a. CERCLA Compliance with Other Laws Manual. Part II. Interim Final. Office of
     Emergency and Remedial Response. (OSWER Directive  9234.1-02).

Environmental Protection Agency (EPA). 1989b. Exposure Factors Handbook. Office of Health and Environmental Assessment.
     EPA/600/8-89/043.

Environmental  Protection Agency (EPA).  1989c.   Exposure Assessment Methods  Handbook. Draft.   Office of Health and
     Environmental Assessment.

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                                 CHAPTER 3

              GETTING  STARTED:  PLANNING
                  FOR THE  HUMAN  HEALTH
                  EVALUATION  IN THE  RI/FS
    This chapter discusses issues  related to
planning the human health evaluation conducted
during the RI/FS.  It presents the goals of the
RI/FS process as a whole and the human health
evaluation in particular (Sections 3.1 and 3.2). It
next discusses the way in which a site that is
divided into operable units should be treated in
the human health evaluation (Section 3.3). RI/FS
scoping is discussed in Section 3.4, and Section 3.5
addresses the level of effort and detail necessary
for a human health evaluation.
3.1 GOAL OF THE RI/FS

    The  goal of  the  RI/FS  is  to  gather
information sufficient to support an informed risk
management decision regarding which remedy
appears to be most appropriate for a given site.
The RI/FS provides the context  for all site
characterization activity, including the  human
health evaluation.  To attain this goal efficiently,
EPA must identify and characterize  hazards in a
way that will contribute directly to the selection
of an  appropriate remedy. Program experience
has shown that Superfund sites are complex, and
are characterized by heterogeneous wastes, extreme
variability in contamination levels, and a variety
of environmental settings and potential exposure
pathways. Consequently, complete characterization
of a site  during the RI/FS  in the sense  of
eliminating uncertainty, is not feasible, cost-
effective, or necessary for selection of appropriate
remedies.     This  view has motivated the
"streamlined approach" EPA is taking to help
accomplish the goal of completing  an RI/FS in  18
months at a cost of $750,000 per operable unit
and $1.1 million per site.   The streamlined
approach recognizes that the elimination of all
uncertainties is not possible or necessary and
instead strives only for sufficient data to generally
characterize a site and support remedy selection.
The resulting remedies are flexible and incorporate
specific   contingencies to  respond  to new
information discovered during remedial action and
follow-up.
3.2 GOAL OF THE RI/FS HUMAN
    HEALTH EVALUATION

    As  part of the  effort to streamline the
process and reduce the cost and time required to
conduct the RI/FS, the Superfund human health
evaluation   needs  to  focus   on providing
information necessary to justify action at a site
and to select the best remedy for the site. This
should include characterizing the contaminants,
the potential exposures, and the potentially
exposed population sufficiently to determine what
risks need to be reduced or eliminated and what
exposures need to be prevented. It is important
to recognize that information should be developed
only to help EPA determine what actions are
necessary  to reduce risks, and not to fully
characterize site risks or eliminate all uncertainty
from the analysis.

    In a logical extension of this view, EPA has
made a policy  decision to  use,  wherever
appropriate, standardized assumptions, equations,
and values in the human health evaluation to
achieve the goal of streamlined assessment. This
approach has the added benefit of making human

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Page 3-2
health evaluation easier to review, easier to
understand, and more consistent from site to site.
Developing unique exposure assumptions or non-
standard methods of risk assessment should not be
necessary for most sites. Where justified by site-
specific data or by changes in knowledge over
time,   however,   non-standard  methods and
assumptions may be used.
3.3  OPERABLE UNITS

     Current practice in designing remedies for
Superfund sites often divides sites into operable
units that address discrete aspects of the site (e.g.,
source control,  ground-water remediation) or
different  geographic portions of the site. The
NCP defines operable unit as "a discrete action
that comprises an  incremental  step toward,
comprehensively addressing site problems." RI/FSs
may be conducted for the entire site and operable
units broken out during or after the feasibility
study,  or operable  units  may  be  treated
individually from the start, with focused RI/FSs
conducted for each operable unit. The best way
to address the risks of the operable unit will
depend on the needs of the site.

     The human health evaluation  should focus on
the subject of the RI/FS, whether that is an
operable unit or the site as a whole. The baseline
risk assessment and other risk information
gathered will provide the justification for taking
the action for the operable  unit.  At the same
time, personnel involved in conducting the human
health evaluation for a focused RI/FS must be
mindful of other potential  exposure pathways,  and
other actions that are being contemplated for the
site to address other potential exposures. Risk
assessors should foresee that exposure pathways
outside the scope of the focused RI/FS may
ultimaately be combined with exposure pathways
that are directly addressed by the focused RI/FS.
Considering risks from all related operable units
should prevent the  unexpected discovery of high
multiple pathway risks during the human health
evaluation for the  last operable  unit.  Consider,
for example, a site that will be addressed in two
operable units:  a surface soil  cleanup at the
contamination source  and  a separate ground-water
cleanup. Risks associated with residuals from the
soil cleanup and the ground-water cleanup may
need to be considered as a cumulative total if
there is the potential for exposure to both media
at the same time.
3.4      RI/FS  SCOPING

     Planning the human health evaluation prior
to beginning the detailed analysis is an essential
step in the process.  The RPM  must make up-
front decisions about, for example, the scope of
the baseline risk assessment, the appropriate level
of detail and documentation, trade-offs between
depth and breadth in the analysis, and the staff
and monetary resources to commit.

     Scoping is the initial planning phase of the
RI/FS process, and many of the planning steps
begun here are continued and refined in later
phases. Scoping activities typically begin with the
collection of existing site data, including data from
previous investigations such as the preliminary
assessment and site inspection. On the basis  of
this  information,  site management planning  is
undertaken  to identify probable boundaries of the
study area, to  identify  likely remedial action
objectives and  whether interim actions may be
necessary or appropriate,  and  to establish whether
the site may best be remedied as one site or as
several separate operable units. Once an overall
management strategy is  agreed upon, the RI/FS
for a specific project or the site as a whole is
planned.

     The development of remedial alternatives
usually begins during or soon after scoping, when
likely response  scenarios may first be identified.
The development  of alternatives requires:

     •    identifying remedial action  objectives;

     •    identifying potential treatment, resource
         recovery, and containment  technologies
         that will satisfy these objectives; and

     •    screening the technologies based on their
         effectiveness, implementabiliry, and cost.

Remedial alternatives may be developed to address
a contaminated medium, a specific area of the
site, or the entire site.   Alternative remedial
actions for specific media and site  areas either can
be carried through the FS process separately or
combined into comprehensive alternatives for the

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                                                                                       Page 3-3
entire site.  The approach is flexible to allow
alternatives to be considered in combination at
various points in the process. The RI/FS guidance
discusses planning in greater detail.
3.5 LEVEL OF EFFORT/LEVEL OF
    DETAIL OF THE HUMAN
    HEALTH EVALUATION

    An important part of scoping is determining
 the appropriate level of effort/level of detail
necessay  for  the  human  health  evaluation.
Human health evaluation can be thought of as
spanning a continuum of complexity, detail, and
level of effort, just as sites vary in conditions and
complexity.    Some of the site-specific factors
affecting  level of effort that the  RPM must
consider include the following

    •   number and  identity  of chemicals
        present;

    •   availability of ARARs and/or applicable
        toxicity  data;

    •   number and complexity of exposure
        pathways (including complexity of release
        sources and transport media), and the
        need for environmental fate and
        transport  modeling to  supplement
        monitoring data;

    •   necessity for precision of the results,
        which in turn depends on site conditions
        such  as the  extent of contaminant
        migration, characteristics of potentially
        exposed populations, and enforcement
        considerations (additional quantification
        may be warranted for some  enforcement
        sites); and

    •  quality  and   quantity  of available
        monitoring data.1
     This manual is written to address the most
 complex sites, and as a result not all of the steps
 and procedures of the Superfund human health
 evaluation process described in this manual apply
 to all remedial sites. For example, Section 6.6
 provides procedures and equations for estimating
 chemical intakes through numerous exposure
 routes, although for many sites, much of this
 information will  not apply (e.g., the exposure
 route does not exist or is determined to be
 relatively unimportant). This manual establishes
 a generic framework that is broadly applicable
 across sites, and it provides specific  procedures
 that cover a range of sites or situations that may
 or may not be appropriate for any individual site.
 As a consequence of attempting to cover the wide
 variety of Superfund site conditions, some of the
 process  components,  steps, and  techniques
 described in the manual do not apply to some
 sites. In  addition, most of the components can
 vary greatly in level of  detail.    Obviously,
 determining which elements of the process  are
 necessary,  which are desirable, and which  are
 extraneous is a key decision for each site. All
 components should not be forced into the assess-
 ment of a  site, and the evaluation should be
 limited to  the complexity and level of detail
 necessary  to adequately assess risks for the
 purposes described in Sections 3.1 and 3.2.

     Planning related to the collection and analysis
 of chemical data is perhaps the most important
 planning step. Early coordination among the risk
 assessors,  the remainder  of the RI/FS  team,
 representatives of other agencies involved in the
risk assessment or related studies (e.g., ATSDR,
 natural resource trustees such as the Department
 of the Interior, state agencies), and the RPM is
 essential and preferably should occur during the
 scoping stage of the RI/FS.  Detailed guidance on
planning related to collection and analysis of
chemical data is given in Chapter 4 of this
manual.

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Page 3-4

                                   ENDNOTE FOR CHAPTER 3
1. All site monitoring data must be subjected to appropriate quality assurance/quality control programs. Lack of acceptable data may
limit by necessity the amount of data available for the human health evaluation, and therefore may limit the scope of the evaluation.
Acceptability is determined by whether data meet the appropriate data quality objectives (see Section 4.1.2).

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        CHAPTER  4
DATA COLLECTION
/FROM:     N
 •Site discover/
 • Preliminary
  assessment
 •Site inspection
\»NPLIisting>
                  Toxicity
                Assessment
                                   Risk
                              Characterization
             V  Exposure
               Assessment
/TO
  •Selection of
   remedy
  • Remedial
   design
  • Remedial
   action
          DATA COLLECTION
    • Collect existing data
    • Address modeling parameter
      needs
    • Collect background data
    • Conduct preliminary exposure
      assessment
    • Devise overall strategy for
      sample collection
    • Examine QA/QC measures
    • Identify special analytical needs
    • Take active role during workplan
      development and data collection

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                                   CHAPTER  4
                           DATA  COLLECTION
    This  chapter discusses  procedures for
acquiring reliable chemical release and exposure
data for quantitative human health risk assessment
at hazardous waste sites.'The chapter is intended
to be a limited discussion of important sampling
considerations with respect to risk assessment it
is not intended to be a complete guide on how to
collect data or design  sampling plans.

    Following a general background section
(Section 4.1), this chapter addresses the following
eight important areas:

     (1) review of available site information
        (Section 4.2);

    (2) consideration  of modeling parameter
        needs (Section 4.3);

    (3) definition of background sampling needs
        (Section 4.4);

    (4) preliminary  identification of potential
        human exposure (Section 4.5);

    (5) development of an overall strategy for
        sample collection (Section 4.6);

    (6) definition of required QA/QC measures
        (Section 4.7);

    (7) evaluation  of the need for Special
        Analytical Services  (Section 4.8); and

    (8) activities during workplan development
        and data collection (Section 4.9).
4.1  BACKGROUND INFORMATION
     USEFUL FOR DATA
     COLLECTION

     This section provides background information
on the types of data needed for risk assessment,
overall data needs of the RI/FS, reasons and steps
for identifying risk assessment data needs early,
use of the Data Quality Objectives for Remedial
Response Activities (EPA 1987a,b, hereafter
referred to as the DQO guidance), and other data
concerns.

4.1.1      TYPES OF DATA

     In general, the types of site data needed for
a baseline risk assessment include the following

     •    contaminant identities;
       ACRONYMS FOR CHAPTER 4

     CLP - Contract Laboratory Program
    DQO = Data Quality Objectives
     FIT = Field Investigation Team
     FSP = Field Sampling Plan
     HRS = Hazard Ranking System
     IDL = Instrument Detection Limit
    MDL = Method Detection Limit
    PA/SI = Preliminary Assessment/Site Inspection
   QA/QC = Quality Assurance/Quality Control
   QAPjP = Quality Assurance Project Plan
     RAS = Routine Analytical Services
    RI/FS = Remedial  Investigation/Feasibility Study
     SAP = Sampling and Analysis Plan
     SAS = Special Analytical Services
    SMO = Sample Management Office
    SOW = Statement of Work
     TAL = Target Analyte List
     TCL = Target Compound List
     TIC = Tentatively Identified Compound

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Page 4-2




                                        DEFINITIONS FOR CHAPTER 4

   Analytes. The chemicals for which a sample is analyzed.

   Anthropogenic Background Levels. Concentrations of chemicals that are present in the environment due to human-made, non-
       site sources (e,g., industry, automobiles).

   Contract Laboratory Program (CLP). Analytical program developed for Superfund waste site samples to fill the need for legally
       defensible analytical results supported by a high level of quality assurance and documentation.

   Data Quality Objectives (DOOs). Qualitative and quantitative statements to ensure that data of known and documented quality
       are obtained during an RI/FS to support an Agency decision.

   Field Sampling Plan (FSP). Provides guidance  for all field work by defining in detail the sampling and data gathering methods
       to be used on a project.

   Naturally Occurring Background Levels. Ambient concentrations of chemicals that are present in the environment and have
       not been influenced by humans (e.g., aluminum, manganese).

   Quality Assurance Project Plan ('OAPjP'). Describes the policy, organization, functional activities, and quality assurance and
       quality control protocols necessary to achieve DQOs dictated by the intended use of the data (RI/FS Guidance).

   Routine Analytical Services (RAS). The set of CLP analytical protocols that are used to analyze most Superfund site samples.
       These  protocols are provided in the EPA Statements of Work for the CLP (SOW for Inorganics, SOW for Organics) and
       must be followed by every CLP laboratory.

   Sampling and Analysis Plan (SAP). Consists of a Quality Assurance Project Plan (QAPjP) and a Field Sampling Plan (FSP).

   Sample Management Office (SMO).  EPA contractor providing management, operational, and administrative support to the
       CLP to facilitate  optimal use of the program.

   Special Analytical Services (SAS). Non-standardized analyses conducted under the CLP to meet user requirements that cannot
       be met using RAS, such as shorter analytical turnaround time, lower detection limits, and analysis of non-standard matrices
       or non-TCL compounds

   Statement of Work (SOW) for the CLP. A document that specifies the instrumentation, sample handling procedures, analytical
       parameters and procedures, required quantitation limits, quality  control requirements, and report format to be used by CLP
       laboratories. The SOW also contains the TAL and TCL..

   Target Analyte List (TAL~). Developed by EPA for Superfund site sample analyses. The TAL is a list of 23  metals plus total
       cyanide routinely analyzed using RAS.

   Target Compound List (TCL~). Developed by EPA for Superfund site  sample analyses.  The TCL, is a list of analytes (34
       volatile organic chemicals, 65 semivolatile organic chemicals,  19 pesticides, 7 polychlorinated biphenyls. 23 metals, and
       total cyanide) routinely analyzed using RAS.
          contaminant concentrations  in the key              Most of these data are obtained during the
          sources and media of interest;2                  course of a remedial investigation/feasibility study
                                                             (RI/FS).  Other sources of information, such as
          characteristics of sources,  especially         preliminary  assessment/site inspection (PA/SI)
          information related to release potential;         reports, also may be available.
          and
                                                             4.1.2      DATA NEEDS AND THE RI/FS
          characteristics of the environmental
          setting that may affect the fate, transport,              The  RI/FS has four primary data collection
          and persistence of the contaminants.             components:

                                                                  (1) characterization of site conditions;

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                                                                                           Page 4-3
     (2)  determination  of the nature of the
         wastes;

     (3) risk assessment; and

     (4) treatability testing.

The site and waste characterization components of
the   RI/FS   are   intended  to   determine
characteristics of the site (e.g., ground-water
movement, surface water and soil characteristics)
and  the  nature and extent of contamination
through  sampling and analysis of sources and
potentially  contaminated media.  Quantitative risk
assessment, like site characterization, requires data
on concentrations of contaminants in each of the
source areas  and  media  of concern.    Risk
assessment also requires  information  on  other
variables necessary for  evaluating the fate,
transport, and persistence of contaminants and
estimating current and potential human  exposure
to these contaminants. Additional data  might be
required  for environmental risk  assessments (see
EPA 1989a).

     Data also are collected during the  RI/FS to
support the design  of remedial alternatives. As
discussed in the DQO guidance (EPA  1987a,b),
such data include results  of analyses  of
contaminated media  "before and after"  bench-scale
treatability tests. This information usually is not
appropriate for use in a baseline risk assessment
because these media typically are assessed only for
a few individual parameters potentially affected by
the  treatment being tested.     Also, initial
treatability testing may involve  only a screening
analysis that generally is not sensitive  enough and
does not  have  sufficient quality  assurance/quality
control  (QA/QC)   procedures  for  use  in
quantitative risk assessment.

4.1.3     EARLY IDENTIFICATION OF DATA
         NEEDS

     Because the RI/FS and other site studies
serve a number of different purposes (e.g., site
and  waste characterization, design of  remedial
alternatives),  only a subset of  this information
generally is useful for risk assessment. To ensure
that all risk assessment data needs will be met, it
is important to identify those needs early in the
RI/FS planning  for a site.    The  earlier the
requirements are identified, the better the chances
are of developing an RI/FS that meets the risk
assessment data collection needs.

     One  of the earliest stages of the RI/FS at
which risk assessment data needs can be addressed
is the site scoping meeting. As discussed in the
Guidance for Conducting Remedial Investigations
and Feasibility Studies Under CERCLA (EPA
1988a, hereafter referred to as RI/FS guidance),
the scoping meeting is part of the initial planning
phase of site remediation. It is at this meeting
that the  data  needs  of each of the RI/FS
components (e.g.,  site and waste characterization)
are  addressed together. Scoping meeting attendees
include the RPM, contractors conducting the
RI/FS (including the baseline risk assessment),
onsite personnel (e.g., for construction), and
natural resource trustees (e.g., Department of
Interior).      The  scoping  meeting allows
development of a comprehensive sampling and
analysis plan (SAP) that will satisfy the needs of
each RI/FS component while helping to ensure
that time and budget constraints are met. Thus,
in addition to aiding the effort to meet the risk
assessment data  needs, this meeting can help
integrate these needs with other objectives of the
RI/FS and thereby help make maximum use of
available resources and avoid duplication of effort.

    During scoping activities, the risk assessor
should identify, at least in preliminary fashion, the
type and duration of possible exposures (e.g.,
chronic, intermittent), potential exposure routes
(e.g., ingestion offish, ingestion of drinking water,
inhalation  of dust), and key exposure points (e.g.,
municipal  wells,   recreation  areas)  for each
medium. The relative importance of the potential
exposure    routes   and exposure  points  in
determining risks should be discussed, as should
the  consequences of not studying them adequately.
Section 4.5 and Chapter 6 provide guidance for
identifying exposure pathways that may exist at
hazardous  waste  sites.   If potential exposure
pathways are identified early in the RI/FS process,
it will be easier to reach a  decision on the
number, type, and location of samples  needed to
assess exposure.

    During the planning stages of the RI/FS, the
risk assessor also  should determine if non-routine
(i.e., lower)  quantitation limits are needed to
adequately characterize risks at a site. Special
Analytical Services (SAS) of the EPA Contract

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 Page 4-4
 Laboratory Program (CLP) may be needed to
 achieve such lower  quantitation limits.   (See
Section 4.8 for additional information concerning
 quantitation limits.)

 4.1.4     USE OF THE DATA QUALITY
          OBJECTIVES (DQO) GUIDANCE

     The DQO guidance (EPA 1987a,b) provides
 information on the review of site data and the
 determination of data quality needs for sampling
 (see the box below).
       OVERVIEW OF DQO GUIDANCE

      According to the DQO guidance (EPA 1987a and
    b), DQO are qualitative and quantitative statements
    established prior to data collection, which specify the
    quality of the data required to support Agency decisions
    during remedial response activities The DQO for a
    particular site vary according to the end use of the data
    (i.e.,  whether  the data  are  collected to support
    preliminary  assessments/site  inspections,  remedial
    investigations/feasibility studies, remedial designs, or
    remedial actions).

      The DQO process consists of three stages. In Stage
    1 (Identify Decision Types), all available site infomation
    is compiled and analyzed in order to develop a
    conceptual model of the site that describes suspected
    sources, contaminant pathways, and potential receptors.
    The outcome of Stage 1 is a definition of the objectives
    of the site investigation and an identification of data
    gaps.  Stage 2 (Identify Data Uses/Needs) involves
    specifying the data necessary to meet the objectives set
    in Stage  1, selecting the sampling approaches and the
    analytical options for the site, and evaluating multiple-
    option approaches to allow more timely or cost-effective
    data collection and evaluation. In Stage 3 (Design Data
    Collection Program), the methods to be used to obtain
    data of acceptable quality are specified in such products
    as the SAP or the workplan.
 Use of this guidance will help ensure that all
 environmental data collected in support of RI/FS
 activities are of known and documented quality.
 4.1.5
OTHER DATA CONCERNS
     The simple existence of a data collection plan
 does, not guarantee usable data. The risk assessor
 should plan an active role  in oversight of data
 collection to ensure that relevant data have been
 obtained. (See Section 4.9 for more information
                                             on the active role that the risk assessor must
                                             play.)

                                                  After data have been collected, they should
                                             be carefully reviewed to identify reliable, accurate,
                                             and verifiable  numbers that can be used to
                                             quantify risks.    All  analytical data must be
                                             evaluated to  identify the chemicals of potential
                                             concern (i.e., those to be carried through the risk
                                             assessment).  Chapter 5 discusses the criteria to
                                             be considered in selecting the subset of chemical
                                             data appropriate for baseline risk assessment.
                                             Data that do  not meet the  criteria are  not
                                             included in the quantitative risk assessment; they
                                             can  be  discussed qualitatively  in the  risk
                                             assessment report, however, or may be the basis
                                             for further  investigation.
4.2 REVIEW OF AVAILABLE SITE
    INFORMATION

    Available site information must be reviewed
to (1) determine basic site characteristics, (2)
initially identify potential exposure pathways and
exposure points, and (3)  help determine data
needs (including modeling needs).  All available
site information (i.e., information existing at the
start of the RI/FS)  should be reviewed in
accordance with Stage 1 of the DQO process.
Sources of available site information include:

    •    RI/FS scoping information;

    •    PA/SI data and Hazard Ranking  System
         (HRS) documentation;

    •    listing  site inspection (LSI)  data
         (formally referred to as expanded site
         inspection, or ESI);

    •    photographs (e.g., EPA's Environmental
         Photographic  Interpretation Center
         [EPIC]);

    •    records on removal actions taken at the
         site; and

    •    information on amounts of hazardous
         substances  disposed (e.g.,  from site
         records).

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                                                                                        Page 4-5
 If available, LSI (or ESI) data are especially useful
 because they represent fairly extensive site studies.

     Based on a review of the existing data, the
 risk assessor should formulate a conceptual model
 of the site that identifies all potential or suspected
 sources of  contamination, types and concentrations
 of contaminants detected at  the site, potentially
 contaminated  media, and potential exposure
 pathways,  including  receptors (see Exhibit 4-1).
 As discussed previously, identification of potential
 exposure pathways, especially the exposure points,
 is a key element in the determination of data
 needs for the risk assessment. Details concerning
 development of a conceptual model for a site are
 provided in the DQO  guidance (EPA 1987a,b) and
 the RI/FS guidance (EPA 1988a).

     In most cases, site information available at
 the  start of the RI/FS is insufficient to fully
 characterize the site  and the potential exposure
 pathways. The conceptual model developed at this
 stage should be  adequate to determine the
 remaining  data needs.   The remainder of this
 chapter addresses risk assessment data needs in
 detail.
 4.3 ADDRESSING  MODELING
     PARAMETER NEEDS

     As  discussed  in  detail in  Chapter  6,
 contaminant release, transport, and fate models
 are often needed to supplement monitoring data
 when   estimating   exposure   concentrations.
 Therefore, a preliminary site modeling strategy
 should be developed during RI/FS scoping  to
 allow model input data requirements to be
 incorporated into the data collection requirements.
 This  preliminary identification of models and
 other related data requirements will ensure that
 data for model calibration and validation are
 collected along with other physical and chemical
 data at the site. Exhibit 4-2 lists (by medium)
 several site-specific parameters often needed  to
 incorporate fate and transport models in risk
assessments.

     Although default values for some modeling
 parameters are available,  it is preferable to obtain
 site-specific values for as many input parameters
 as is feasible.  If the model is not sensitive to a
 particular parameter for which a default value is
 available, then a default value may be used.
 Similarly, default values may be used if obtaining
 the site-specific model parameter would be too
 time  consuming or expensive.    For example,
 certain airborne dust emission models use a
 default value for the average  wind speed at the
 site;   this  is  done  because representative
 measurements of wind speed at the site would
 involve significant amounts of time (i.e., samples
 would have to be collected over a large part of
 the year).

    Some model parameters are needed only if
 the sampling conducted at a site is sufficient to
 support complex models. Such model parameters
 may not be necessary if only simple fate and
 transport models are used in the risk assessment.
 4.4 DEFINING BACKGROUND
     SAMPLING  NEEDS

     Background sampling  is conducted  to
 distinguish   site-related   contamination from
 naturally occurring or other non-site-related levels
 of chemicals, The following subsections define the
 types of background  contamination and provide
 guidance on the appropriate location and number
 of background  samples.

 4.4.1     TYPES OF BACKGROUND

     There are  two different types of background
 levels of chemicals:

     (1)  naturally occurring  levels, which are
         ambient concentrations of chemicals
         present in the environment that have not
         been  influenced  by  humans  (e.g.,
         aluminum, manganese); and

     (2)  anthropoeeenic    levels.   which   are
         concentrations of chemicals that are
         present in  the  environment  due to
         human-made, non-site sources  (e.g.,
         industry,  automobiles).

Background  can  range from localized to
ubiquitous. For example, pesticides ~ most  of
which are not naturally occurring (anthropogenic)
"  may be ubiquitous in certain areas  (e.g.,

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Page 4-6
                              EXHIBIT 4-1
            ELEMENTS OF A CONCEPTUAL EVALUATION MODEL
                          VARIABLES
                               HYPOTHESES TO
                                 BE TESTED
     SOURCES
• CONTAMINANTS
• CONCENTRATIONS
•TIME
• LOCATIONS
• SOURCE EXISTS
• SOURCE CAN BE CONTAINED
• SOURCE CAN BE REMOVED
  AND DISPOSED
• SOURCE CAN BE TREATED
                      • MEDIA
                      • RATES OF MIGRATION
                      • TIME
                      • LOSS AND GAIN FUNCTIONS
                          • PATHWAY EXISTS
                          • PATHWAY CAN BE
                           INTERRUPTED
                          • PATHWAY CAN BE
                           ELIMINATED
                      • TYPES
                      • SENSITIVITIES
                      • TIME
                      • CONCENTRATIONS
                      • NUMBERS
                          • RECEPTOR IS NOT
                            IMPACTED BY MIGRATION
                            OF CONTAMINANTS
                          • RECEPTOR CAN BE
                            RELOCATED
                          • INSTITUTIONAL CONTROLS
                            CAN BE APPLIED
                          • RECEPTOR CAN BE
                            PROTECTED
    SOURCE: EPA 1987a

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                                                                                      Page 4-7
                                       EXHIBIT 4-2

            EXAMPLES OF MODELING PARAMETERS FOR WHICH
            INFORMATION MAY NEED TO BE OBTAINED DURING
                        A SITE  SAMPLING INVESTIGATION
Type of Modeling
                 Modeling Parameters1
Source Characteristics


Soil


Ground-water



Air
Surface Water
Sediment


Biota
Geometry, physical/chemical conditions, emission rate, emission
    strength, geography

Particle size, dry weight, pH, redox potential, mineral class, organic
    carbon and clay content, bulk density, soil porosity

Head measurements, hydraulic conductivity (pump and slug test
    results), saturated thickness of aquifer, hydraulic gradient, pH,
    redox potential, soil-water partitioning

Prevailing wind direction, wind speeds, stability class, topography,
    depth of waste, contaminant concentration in soil and soil gas,
    fraction organic content of soils, silt content of soils, percent
    vegetation, bulk density of soil, soil porosity

Hardness, pH, redox potential, dissolved oxygen, salinity,
    temperature, conductivity, total suspended solids, flow rates
    and depths for rivers/streams, estuary and embayment
    parameters such as tidal cycle, saltwater incursion extent,
    depth and area, lake parameters such  as area, volume, depth,
    depth to thermocline

Particle size distribution, organic content, pH, benthic oxygen
    conditions, water content

Dry weight, whole body, specific organ, and/or edible portion
    chemical concentrations, percent moisture, lipid content,
    size/age, life history stage
    "These parameters are not necessarily limited to the type of modeling with which they are
associated in this exhibit. For example, many of the parameters listed for surface water are also
appropriate for sediments.

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Page 4-8
agricultural areas); salt runoff from roads during
periods of snow may contribute high ubiquitous
levels of sodium.      Polycyclic  aromatic
hydrocarbons (PAHs) and lead are other examples
of anthropogenic, ubiquitous chemicals, although
these chemicals also may be present at naturally
occurring levels in the environment due  to natural
sources (e.g., forest fires may be a source of
PAHs,  and lead is a natural component of soils in
some areas).

4.4.2     BACKGROUND SAMPLING
         LOCATIONS

     Background samples are  collected at or near
the hazardous waste site in areas not influenced
by site contamination.  They are collected from
each medium of concern in these offsite areas.
That is, the locations of background samples must
be  areas  that  could  not  have  received
contamination from the site, but that do have the
same basic characteristics as  the medium of
concern at the site.

     Identifying background  location requires
knowing which direction is upgradient/upwind/
upstream. In general, the direction of water flow
tends to be relatively constant, whereas  the
direction of air flow is  constantly changing.
Therefore, the determination  of background
locations  for air monitoring requires constant  and
concurrent monitoring of factors such as wind
direction.

4.4.3     BACKGROUND SAMPLE SIZE

     In appropriate circumstances, statistics may
be used to evaluate background sample data.
Because the  number of background samples
collected is important for statistical hypothesis
testing, at some sites a statistician should be
consulted when determining background sample
size. At all sites, the RPM should decide the
level of statistical analysis  appliable to  a
particular situation.

     Often, rigorous   statistical analyses  are
unnecessary because site- and  non-site-related
contamination clearly differ. For most sites, the
issue will not be whether a difference in chemical
concentrations can be demonstrated between
contaminated and background areas, but rather
that of establishing a reliable representation of the
extent (in three dimensions) of a contaminated
area. However, statistical analyses are required
at some sites, making a basic understanding of
statistics necessary.   The following discussion
outlines some basic statistical concepts in the
context of background data evaluation for risk
assessment. (A general statistics textbook should
be reviewed for additional detail. Also, the box
below lists EPA guidance that might be useful.)
     STATISTICAL METHODS GUIDANCE

   Statistical Methods for Evaluating Ground-
   water Monitoring Data from Hazardous Waste
   Facilities (EPA 1988b)

   Surface Impoundment Clean  Closure
   Guidance Manual (EPA 1988c)

   Love Canal Emergency Declaration Area
   Habitability Study (EPA 1988d)

   Soils Sampling Quality Assurance Guide (EPA
   1989b)
    A statistical test of a hypothesis is a rule
used for deciding whether or not a statement (i.e..
the null hypothesis) should be rejected in favor of
a  specified  alternative statement (i.e., the
alternative  hypothesis).    In  the context  of
background contamination at  hazardous waste
sites, the null hypothesis can be expressed as
"there is no difference between contaminant
concentrations in background areas and onsite,"
and the alternative hypothesis can be expressed as
"concentrations are higher onsite." This expression
of the alternative hypothesis implies a one-tailed
test of significance.

    The  number of background samples collected
at a site  should be sufficient to accept or reject
the null hypothesis with a specified likelihood of
error.   In statistical hypothesis testing there are
two types of error.  The null hypothesis may be
rejected when it is true (i.e., a Type I error), or
not rejected when it is false (i.e., a Type II error).
An example of a Type I error at a hazardous
waste site would be to conclude that contaminant
concentrations in onsite soil  are higher than
background soil concentrations  when in fact they

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                                                                                         Page 4-9
are not. The corresponding Type II error would
be  to  conclude  that  onsite  contaminant
concentrations are not higher than background
concentrations when in fact they are. A Type I
error  could  result  in unnecessary remediation,
while a Type II error could result in a failure to
clean  up a site when such an action is necessary.

    In customary notations, a '(alpha) denotes the
probability that a Type I  error will  occur, and ft
(beta) denotes the probability that a Type II error
will occur. Most statistical comparisons refer to
a , also known as the level of significance of the
test.  If a = 0.05, there is a 5 percent (i.e., 1 in
20) chance   that we  will  conclude that
concentrations of contaminants are higher than
background when they actually are not.

    Equally  critical considerations in determining
the number of background samples are   0  and a
concept  called "power." The power of a statistical
test has the  value  1  - ft and is defined as the
likelihood that the  test procedure  detects a false
null hypothesis.  Power functions for commonly
used statistical tests can be found in most general
statistical textbooks. Power curves are a function
of a (which normally is freed at 0.05), sample size
(i.e., the number of background and/or onsite
samples), and the  amount of variability in  the
data.  Thus, if a 15 percent likelihood of failing
to detect a false null hypothesis is desired (i.e.,   ft
= 0.15), enough background samples must be
collected to  ensure that the power of the test is
at least 0.85.

    A small number of background samples
increases the likelihood of a Type II error. If an
insufficient number of background samples is
collected, fairly large differences between site and
background concentrations may not be statistically
significant, even though concentrations in  the
many site samples  are  higher  than the few
background samples.   To guard against this
situation, the statistical power associated with  the
comparison of background samples with site
samples should be  evaluated.

    In  general, when trying to detect small
differences as statistically  significant,  the number
of background samples should be similar to  the
number of onsite samples that will  be used for the
comparison(s) (e.g., the number of samples taken
from  one well). (Note that this does not  mean
that the background sample size must equal the
total number of onsite samples.) Due to the
inherent variability of air concentrations (see
Section 4.6), background sample size for air needs
to be relatively large.

4.4.4     COMPARING BACKGROUND
         SAMPLES TO SITE-RELATED
         CONTAMINATION

     The medium sampled influences the kind of
statistical comparisons that can be made with
background data.   For example, air monitoring
stations and ground-water wells are normally
positioned based  on onsite factors and gradient
considerations.    Because  of this purposive
placement (see Section 4.6.1), several wells or
monitors cannot be assumed to be a random
sample from a single population and hence cannot
be evaluated collectively  (i.e., the sampling results
cannot be combined). Therefore, the information
from each well or  air monitor should be  compared
individually with background.

     Because there typically are many site-related,
media-specific  sampling  location data to compare
with background, there usually is a "multiple
comparison problem" that must be addressed. In
general, the probability of experiencing a Type I
error in the entire  set of statistical tests increases
with the number of comparisons being made. If
a  =0.05, there is a 1  in 20  chance of a Type I
error in any single test. If 20 comparisons are
being made, it therefore is likely that at least one
Type I error  will  occur among all 20  tests.
Statistical Analysis of Ground-water Monitoring
Data atRCRA Facilities (EPA 1989c) is useful
for designing sampling plans for comparing
information from many freed locations with
background.

     It may  be  useful at  times to look at
comparisons other than onsite versus background.
For example,  upgradient wells can  be compared
with downgradient wells.  Also, there may be
several areas within the site that should be
compared   for   differences  in   site-related
contaminant concentration.    These  areas of
concern should be established before  sampling
takes place. If a more complicated comparison
scheme is planned, a  statistician should be
consulted  frequently  to help distribute  the
sampling effort and design the analysis.

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  Page 4-10
      A statistically significant difference between
  background samples and site-related contamination
  should not, by itself, trigger a cleanup action. The
  remainder of this manual still must be applied so
  that the toxicological  ~ rather than simply the
  statistical -- significance of the contamination can
  be  ascertained.
4 . 5 PRELIMINARY IDENTIFI-
      CATION OF POTENTIAL
      HUMAN EXPOSURE

      A preliminary identification of potential
 human   exposure provides   much   needed
 information for the SAP. This activity involves
 the identification of (1) media of concern, (2)
 areas of concern (i.e., general locations of the
 media to be sampled), (3) types of chemicals
 expected at the site, and (4) potential routes of
 contaminant transport through the environment
 (e.g.,  inter-media transfer, food  chain). This
 section  provides  general information on  the
 preliminary identification of potential human
 exposure pathways, as well as specific information
 on the various media. (Also, see Chapter 6 for
 a detailed discussion of exposure assessment.)

 4.5.1     GENERAL INFORMATION

      Prior to discussing various specific exposure
 media, general information on the following is
 provided:   media, types of chemicals, areas of
 concern, and routes of contaminant transport is
 addressed.

      Media of concern (including biota). For risk
 assessment purposes, media of concern at a site
 are:

      •   any currently  contaminated media to
          which individuals may be exposed or
          through  which  chemicals may  be
          transported to potential receptors: and

      •   any currently uncontaminated media that
          may become contaminated in the future
          due to contaminant transport.

 Several medium-specific factors in sampling may
 influence the risk assessment.    For example,
 limitations in sampling  the medium may limit the
detailed evaluation of exposure pathways described
in Chapter 6. To illustrate this, if soil samples
are not collected at the surface of a site, then it
may  not be possible to accurately evaluate
potential exposures involving direct contact with
soils  or exposures involving the release of
contaminants from soils via wind erosion (with
subsequent inhalation of airborne contaminants by
exposed individuals).  Therefore, based on the
conceptual model of the site discussed previously,
the risk assessor  should  make sure  that
appropriate samples are collected from each
medium of concern.

    Areas of concern. Areas of concern refer to
the general sampling locations at or near the site.
For large sites,  areas of concern may be treated
in the RI/FS  as "operable units," and may  include
several media.   Areas of concern also  can be
thought of as the locations of potentially exposed
populations (e.g., nearest residents) or biota (e.g.,
wildlife feeding  areas).

    Areas of concern should be identified based
on site-specific characteristics. These areas are
chosen purposively by the  investigators during the
initial scoping meeting. Areas of concern should
include areas of the site that

    (1)  have different chemical types;

    (2)  have different anticipated concentrations
         or hot spots;

    (3)  are a release source of concern;

    (4)  differ from each other in terms of the
         anticipated  spatial or temporal variability
         of contamination;

    (5)  must  be  sampled using different
         equipment and/or

    (6)  are more or less  costly to sample.

    In some instances, the risk assessor may want
to estimate concentrations that are representative
of the site as a whole, in addition to each area of
concern. In these cases, two conditions generally
should be met in defining areas of concern: (1)
the boundaries of the areas of concern should not
overlap and (2) all of the  areas of concern

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                                                                                         Page 4-11
 together should account for the entire area of the
 site.

     Depending on the exposure pathways that
 are being evaluated in the risk assessment, it may
 not be  necessary   to determine site-wide
 representative values.   In this case,  areas  of
 concern do not have to account for the entire
 area of the site.

     Types of chemicals. The types of chemicals
 expected at a hazardous waste site may dictate the
 site areas and media sampled. For example,
 certain    chemicals     (e.g.,    dioxins)    that
 bioconcentrate in aquatic life also are likely to be
 present in the sediments. If such chemicals are
 expected at a particular site and humans are
 expected to ingest  aquatic  life, sampling of
 sediments and aquatic life for the chemicals may
 be particularly important.

     Due to differences in the relative toxicities  of
 different species of the same chemical (e.g., Cr+3
 versus Cr+), the species should be noted when
 possible.

     Routes of contaminant transport. In addition
 to medium-specific concerns, there may be several
 potential  current and future routes of contaminant
 transport within a medium and between media at
 a site. For instance, discharge of ground water or
 surface runoff to surface water could occur.
 Therefore, when possible, samples should be
 collected based on routes of potential transport.
 For cases in which  contamination has not yet
 reached points of human exposure but may be
 transported to those areas in the future, sampling
 between the  contaminant source and the  exposure
 locations should be conducted to help  evaluate
 potential future concentrations to  which
 individuals  may be exposed (e.g.,  through
 modeling).     (See Chapter  6 for additional
 discussion on contaminant transport.)
4.5.2
SOIL
     Soil represents a medium of direct contact
exposure and  often is the main source of
contaminants released into other media. As such,
the number, location, and type  of samples
collected from soils will have a significant effect
on the risk assessment. See the box on this page
                                           for guidance that provides additional  detailed
                                           information concerning soil sampling, including
                                           information on sampling locations, general  soil
                                           and   vegetation   conditions,   and   sampling
                                           equipment, strategies, and techniques. In addition
                                           to the general sampling considerations discussed
                                           previously, the following  specific issues related to
                                           soil  sampling are  discussed below     the
                                           heterogeneous nature of soils, designation of hot
                                           spots, depth of samples, and fate  and transport
                                           properties.
                                                   SOIL SAMPLING GUIDANCE

                                             Test Methods for Evaluating Solid Waste {SW-
                                             846):   Physical/Chemical  Methods  (EPA
                                             1986a)

                                             Field Manual for Grid Sampling of PCS SjpW
                                             Sites to Verify Cleanups  (EPA  1986t>)

                                             A Compendium ofSuperfund Field Operations
                                             Methods (EPA 1987c)

                                             Soil Sampling Quality Assurance Guide (EPA
                                             Review Draft 1989b)
    Heterogeneous nature of soils. One of the
largest problems in sampling soil (or other solid
materials) is that its generally heterogeneous
nature makes collection of representative samples
difficult (and compositing of samples virtually
impossible - see Section 4.6.3). Therefore, a
large number of soil samples may be required to
obtain sufficient data to calculate  an  exposure
concentration. Composite  samples sometimes are
collected to obtain a more homogeneous sample
of a particular area; however, as discussed in a
later section, compositing samples also serves to
mask contaminant hot spots (as well as areas of
low contaminant concentration).

    Designation of hot spots. Hot spots (i.e.,
areas of very high contaminant concentrations)
may have a significant impact on direct contact
exposures. The sampling plan should consider
characterization of hot spots through extensive
sampling, field screening, visual observations, or
a combination of the above.

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Page 4-12
     Depth of samples.  Sample depth should be
applicable for  the  exposure  pathways and
contaminant transport routes of concern and
should be chosen purposively within that depth
interval. If a depth interval is chosen purposively,
a random procedure to select a sampling point
may be established.    Assessment of surface
exposures will be more certain if samples are
collected from the shallowest depth that can be
practically obtained, rather than, for example, zero
to  two feet.    Subsurface  soil samples are
important, however,  if soil disturbance is likely or
if leaching of chemicals to ground water is of
concern, or if the site has current or potential
agricultural uses.

     Fate and transport properties. The sampling
plan should consider physical and chemical
characteristics of soil that are important for
evaluating fate and transport.  For  example, soil
samples being collected to identify potential
sources of ground-water contamination must be
able to  support models  that  estimate both
quantities of chemicals leaching to ground water
and the time needed for chemicals to leach to and
within the ground water.

4.5.3     GROUND WATER

     Considerable expense and effort normally are
required for the installation and development of
monitoring wells and the collection of ground-
water samples. Wells must not introduce foreign
materials and must provide a representative
hydraulic connection to the geologic formations of
interest. In addition, ground-water  samples need
to be collected using an approach that adequately
defines the contaminant plume with respect to
potential  exposure points.  Existing potential
exposure points (e.g., existing drinking water wells)
should be sampled.

     More detailed information concerning ground-
water sampling considerations (e.g., sampling
equipment, types, and techniques) can be found in
the  references in the  box  on this page. In
addition to the general sampling considerations
discussed previously in  Section 4.5.1, those specific
for ground water - hydrogeologic properties, well
location and depth, and filtered vs. unfiltered
samples ~ are discussed below.
        GROUND-WATER SAMPLING
                  GUIDANCE

   Practical Guide to Ground-water Sampling
   (EPA 1985a)

   A Compendium ofSuperfundFiett Operations
   Methods (EPA I987c)

   Handbook: Ground Water (EPA 1987
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                                                                                         Page 4-13
concentrations in unfiltered versus filtered samples
can provide important information on the form in
which a chemical exists in ground water. For
instance, if the concentration of a chemical is
much greater in unfiltered samples compared to
filtered samples, it is likely that the majority of
the chemical is sorbed onto particulate matter and
not  dissolved  in the ground  water.    This
information  on the form  of chemical (i.e.,
dissolved or suspended on particulate matter) is
important to understanding chemical  mobility
within the aquifer.

     If chemical analysis reveals significantly
different concentrations in the filtered and
unfiltered samples, try to determine whether there
is a high concentration of suspended particles or
if apparently high concentrations are due  to
sampling  or   well   construction   artifacts.
Supplementary samples can be collected in a
manner that will minimize the influence of these
artifacts. In addition, consider the effects of the
following.

     •    Filter size. A 0.45 urn filter may screen
         out some potentially mobile particulate
         to which contaminants are absorbed and
         thus    under-represent     contaminant
         concentrations.      (Recent   research
         suggests that a 1.0 urn  may be a more
         appropriate filter size.)

     •    Pumping velocity.  Pumping at too high
         a rate will entrain particulate (to which
         contaminants are absorbed) that would
         not normally be mobile; this could
         overestimate contaminant concentrations.

     •    Sample oxidation. After  contact with air,
         many metals oxidize and form  insoluble
         compounds that may be  filtered out this
         may underestimate inorganic chemical
         concentrations.

     •    Well construction materials. Corrosion
         may elevate some metal concentrations
         even in stainless steel wells.

     If unfiltered water is of potable quality, data
from unfiltered water samples should be used to
estimate exposure (see Chapter 6). The RPM
should ultimately decide the type of samples that
are collected.   If only one type of sample is
collected (e.g., unfiltered), justification for not
collecting the other type of sample (e.g., filtered)
should be provided in the sampling plan.

4.5.4     SURFACE WATER AND SEDIMENT

     Samples need to be collected from any nearby
surface water body potentially receiving discharge
from the site. Samples are needed at a sufficient
number of sampling points to  characterize
exposure pathways,  and at potential discharge
points to the water body to determine if the site
(or some other source) is contributing to surface
water/sediment  contamination.  Some important
considerations for surface water/sediment sampling
that may affect the risk assessment for  various
types and portions of water bodies (i.e., lotic
waters,  lentic waters, estuaries,  sediments) are
discussed below.    More detailed information
concerning surface water and sediment sampling,
such as selecting sampling locations and sampling
equipment, types, and techniques, is provided in
the references given in the box below.
     SURFACE WATER AND SEDIMENT
           SAMPLING GUIDANCE

   Procedures  for  Handling  and  Chemical
   Analysis of Sediment and  Water Samples
   (EPA and COE 1981)

   Sediment Sampling Quality Assurance User's
   Guide (EPA 1984)

   Methods Manual for Bottom Sediment Sample
   Collection (EPA 1985b)

   A Compendium ofSuperfund Field Operations
   Methods (EPA 1987c)

   An  Overview  of Sediment Quality  in  the
   United States (EPA 1987e)

   Proposed Guide for Sediment Collection,
   Storage,  Characterization  and Manipulation
   (The American Society for Testing and
   Materials, undated)

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Page 4-14
     Lotic waters. Lotic waters are fast-moving
 waters such as rivers and streams.  Variations in
 mixing across the stream channel and downstream
 in rivers  and streams can make it difficult to
 obtain representative samples.    Although the
 selection of sampling points will be highly
 dependent on the exposure pathways of concern
 for a particular site, samples generally should be
 taken both toward the middle of the channel
 where the majority of the flow occurs and along
 the banks  where flow is generally lower. Sampling
 locations should be downgradient of any possible
 contaminant sources such as tributaries  or effluent
 outfalls.   Any facilities (e.g., dams, wastewater
 treatment plants) upstream that affect flow volume
 or water quality should be considered  during the
 timing of sampling.    "Background" releases
 upstream could confound the interpretation of
 sampling results by diluting contaminants or by
 increasing  contaminant loads.     In general,
 sampling  should begin downstream and proceed
 upstream.

     Lentic waters. Lentic waters are slow-moving
 waters such as  lakes, ponds, and impoundments.
 In general,  lentic waters require more samples
 than lotic waters because of the relatively low
 degree of mixing of lentic waters.   Thermal
 stratification is a major factor to be considered
 when sampling lakes.    If the water body is
 stratified, samples from each layer should be
 obtained. Vertical composites of these layers  then
 may be made,  if appropriate. For small shallow
 ponds, only  one or two sample locations (e.g., the
 intake and the  deepest points) may be adequate
 depending on the exposure pathways of concern
 for the site. Periodic release of water should be
 considered when sampling  impoundments,  as this
 may   affect   chemical    concentrations    and
 stratification.

     Estuaries.   Contaminant concentrations in
 estuaries will depend on tidal flow and salinity-
 stratification, among other factors. To obtain a
 representative  sample,  sampling should be
 conducted through a tidal cycle by taking three
 sets of samples on a given day: (1) at low tide;
 (2) at high tide; and (3) at "half tide." Each layer
 of salinity should be sampled.

     Sediments.   Sediment samples  should be
 collected in a manner that minimizes disturbance
 of the sediments and potential contamination of
subsequent samples.  Sampling in flowing waters
should begin downstream and end upstream.
Wading should be avoided. Sediments of different
composition (i.e., mud, sand, rock) should not be
composite. Again, it is important to obtain data
that will support the evaluation of the potential
exposure pathways of concern. For example, for
pathways such as incidental ingestion, sampling of
near-shore sediments may be important; however,
for dermal absorption of sediment contaminants
during recreational use such as swimming,  samples
from different points throughout the water body
may be important.    If ingestion of benthic
(bottom-dwelling) species or surface water will be
assessed during the risk assessment, sediment
should be sampled so that characteristics needed
for modeling (e.g., fraction of organic  carbon,
particle size distribution) can be determined (see
Section 4.3).

4.5.5   AIR

     Guidance for developing an air sampling plan
for Superfund sites is provided in Procedures for
Dispersion Modeling and Air Monitoring for
Superfund Air Pathway Analysis (EPA  1989e).
That document is Volume IV of a series of four
technical guidance manuals called Procedures for
Conducting Air Pathway Analyses for Superfund
Applications (EPA 1989e-h). The other three
volumes  of  the series include discussions of
potential air pathways, air emission  sources, and
procedures  for estimating potential  source
emission rates associated with both the baseline
site evaluation and remedial activities at the site.

     Air monitoring  information,  along with
recommendations  for proper selection and
application of air dispersion models, is included
in Volume IV.  The section on air monitoring
contained in this volume presents  step-by-step
procedures to develop, conduct, and evaluate the
results of air  concentration  monitoring to
characterize downwind exposure conditions from
Superfund air emission sources. The first step
addressed is the process  of collecting and
reviewing existing air  monitoring  information
relevant to the specific site, including  source,
receptor, and environmental data.  The second
step   involves   determining   the   level  of
sophistication for the air monitoring program; the
levels range from simple screening procedures to
refined techniques. Selection of a given level will

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                                                                                         Page 4-15
depend on technical considerations (e.g., detection
limits) and available resources. The third step on
air monitoring is  development  of the  air
monitoring plan and includes determination of the
type of air monitors,  the number and location of
monitors,   the frequency   and  duration of
monitoring, sampling and analysis procedures, and
QA/QC procedures. Step four details the day-to-
day activities  related to conducting  the  air
maintenance and calibration, and documentation
of laboratoty results and QA/QC procedures. The
fifth  and final  step involves the procedures
necessary to (1) summarize and evaluate the air
monitoring results for validity, (2) summarize the
statistics  used,  (3) determine site-related air
concentrations  (by comparison of upwind and
downwind concentrations),  and (4) estimate
uncertainties  in the  results  related  to the
monitoring equipment and  program and the
analytical techniques  used in the laboratory.

     Given the difficulties of collecting sufficient
air samples to characterize both temporal and
spatial variability of air concentrations, modeling
~ along or in conjunction with monitoring ~ is
often used in the risk assessment. For the most
efficient sampling program, the section in Volume
IV on modeling should be used in  conjunction
with the section on monitoring.

     Volume IV also contains a comprehensive
bibliography of other sources of air monitoring
and modeling guidance. Note, however, that while
this volume contains  an extensive discussion on
planning and conducting air sampling, it does  not
provide details concerning particular monitoring
equipment and techniques. The box on this page
lists some sources of detailed information on air
sampling.   The following paragraphs  address
several specific aspects of air sampling: temporal
and spatial considerations, emission sources,
meteorological  conditions.

     Temporal and spatial considerations. The
goal of air sampling at a site is to adequately
characterize air-related contaminant exposures. At
a minimum, sampling results should be adequate
for predictive short-term and long-term modeling.
When  evaluating long-term inhalation exposures,
sample results  should be  representative of the
long-term average air concentrations at the long-
term exposure points.   This  requires an air
sampling plan of sufficient  temporal scale to
         AIR SAMPLING GUIDANCE

   Technical Assistance Document for Sampling
   and Analysis of Toxic Organic Compounds m
   Ambient Air (EPA 1983)

   A Compendium of Superfund Field Operations
   Methods (EPA 1987c)

   Procedures for Dispersion Modeling and Air
   Monitoring  for  Superfund  Air  Pathway
   Analysis (EPA 1988f)
encompass the range of meteorological and
climatic conditions potentially affecting emissions,
and of sufficient spatial scale to characterize
associated air concentrations at potential exposure
points. If acute or subchronic exposures resulting
from episodes of unusually large emissions are of
interest, sampling over a much smaller time scale
would be needed.

    Emission sources.     Selection of the
appropriate type of air monitor will depend on
the emission source(s) being investigated as well
as the exposure routes to be evaluated.   For
example, if inhalation of dust is an exposure
pathway  of concern,  then  the  monitoring
equipment must be able to collect respirable dust
samples.

    Meteorological conditions.     Site-specific
meteorological conditions should be obtained (e.g.,
from the National Weather  Service) or  recorded
during the air sampling program with sufficient
detail and  quality assurance to  substantiate and
explain the air  sampling  results. The review of
these  meteorological data can help indicate the
sampling    locations    and     frequencies.
Meteorological   characteristics  also  will be
necessary if air modeling is to be conducted.
4.5.6
BIOTA
    Organisms sampled for human health risk
assessment purposes should be those that are
likely to be consumed by humans. This may
include animals such as commercial and game fish
(e.g., salmon, trout, catfish), shellfish (e.g., oysters,
clams, crayfish), fowl (e.g., pheasant, duck), and

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Page 4-16
terrestrial mammals (e.g., rabbit, deer), as well as
plants such as grains (e.g., wheat, corn), vegetables
(e.g., spinach, carrots), and fruit (e.g., melons,
strawberries).    An effort should be made to
sample species that are consumed most frequently
by humans. Guidance for collecting biota samples
is provided in the references given in the box
below.    The following paragraphs address the
following special aspects of biota sampling
portion vs.  whole sampling, temporal concerns,
food preference, fish sampling, involvement by
other agencies.
       BIOTA SAMPLING GUIDANCE

   Food and Drug Administration's Pesticide
   Analytical Manual (FDA 1977)

   Cooperative Agreement on the Monitoring of
   Contaminants in Great Lakes Sport Fish for
   Human Health Purposes (EPA 1985c)

  v FDA's Pesticides and Industrial Chemicals in
   Domestic Foods  (FDA 1986)

   A Compendium of Superfund Field Operations
   Methods (EPA 1987c)

   Guidance  Manual  for  Assessing Human
   Health Risks from Chemically Contaminated
   Fish and Shellfish (EPA 1989i)
    Portion vs. whole sampling. If only human
exposure is of concern, chemical concentrations
should be measured only in edible portion(s) of
the biota.  For many fish species, estimates of
concentrations in fillets (skin on or skin off) are
the most appropriate measures of exposure
concentrations.  Whole body measurements may
be needed, however, for certain species of fish
and/or for environmental risk assessments. For
example, for some species, especially small ones
(e.g., smelt), whole body concentrations are most
appropriate. (See Risk Assessment Guidance for
Superfund   Environmental Evaluation Manual
(EPA 1989a) for more information concerning
biota  sampling for environmental assessment.)
The edible portion of an organism can vary with
species  and with  the potentially exposed
subpopulation.
     Temporal concerns, Any conditions that may
result in non-representative sampling, such as
sampling during a species' migration or when
plants are not in season, should be avoided.

     Food preferences.   At some sites, human
subpopulations in the area may have different
food consumption patterns that need to be
evaluated. For example, some people commonly
eat the hepatopancreas of shellfish.  In these
Cases,  organ  concentrations would be  most
appropriate for estimating exposure.  Another
example of a less common food preference is
consumption  of relatively large  quantities of
seaweed and other less commonly  eaten seafoods
in some Asian communities.

     Fish sampling.  It is recommended that fish
of "catchable" size be sampled instead of young,
small fish because extremely young fish are not
likely to be consumed. Older, larger fish also
generally are more likely to have been exposed to
site-specific  contaminants  for  a long time,
although for some species (e.g., salmon) the
reverse is true.  Both bottom-dwelling (benthic)
and open-water species should be sampled if both
are used as a food source.

     Other agencies. Biota sampling may  involve
other federal  agencies  such as  the Fish and
Wildlife Service or the Department  of Agriculture.
The equivalent state  agencies  also may  be
involved. In such cases, these agencies should be
involved early in the scoping process.
4.6 DEVELOPING AN  OVERALL
    STRATEGY FOR SAMPLE
    COLLECTION

    For each medium at a site, there are several
strategies for collecting samples. The sampling
strategies for a site must be appropriate for use
in a quantitative risk assessment; if inappropriate,
even the strictest. QA/QC procedures associated
with the strategy will not ensure the usability of
sample results.    Generally, persons actually
conducting the field investigation will determine
the strategy.   As discussed in Section 4.1, risk
assessors also should be involved in discussions
concerning the strategy. The following areas of
major  concern   (from  a  risk  assessment

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                                                                                          Page 4-17
perspective) are discussed in this section:  sample
size, sampling location, types of samples, temporal
and meteorological factors, field analyses, and cost
of sampling.   Many  of these areas also are
discussed for specific media in Section 4.5. See
the box in the opposite column and Section 4.5
for more detailed guidance on sampling strategy.
4.6.1
DETERMINE SAMPLE  SIZE
     Typically, sample size and sample location
(see Section 4.6.2) are determined at the same
time. Therefore, much of the discussion in this
subsection is  also  pertinent to  determining
sampling location. The discussion on statistics in
Section 4.4 is  useful for both sample size and
location  determinations.

  A number of considerations are associated
with determining an appropriate number of
samples   for  a  risk  assessment.      These
considerations include the following four factors:

     (1)  number of areas of concern that will be
         sampled;

     (2)  statistical methods that are planned;

     (3)  statistical performance (i.e., variability
         power, and certainty) of the data that
         will be collected; and

     (4)  practical considerations of logistics and
         cost.

In short, many decisions must be made by the
risk assessor related to the appropriate sample
size for  an investigation. A statistician  cannot
estimate an appropriate sample size without the
supporting information provided by a risk assessor.
The following paragraphs discuss these four factors
as they relate to sample size determinations.

     Areas of concern.   A major factor that
influences how many samples are appropriate is
the  number  of areas  of concern that are
established prior to sampling. As discussed in the
next subsection, if more areas of concern are
identified, then more samples generally will be
needed to characterize the site.    If the total
variability in chemical concentrations is reduced
substantially by subdividing the site into  areas of
concern, then the statistical performance  should
   SAMPLING STRATEGY GUIDANCE

Test Methods for Evaluating Solid Waste (SW-
846):   Physical/Chemical Methods (EPA
1986a)

Data   Quality  Objectives  for  Remedial
Response Activities:  Development Process
(EPA 1987a)

Data   Quality  Objectives  for  Remedial
Response  Activities:    Example  Scenario:
RI/FS Activities at a Site with Contaminated
Soils and Ground  Water (EPA 1987b)

Expanded Site Inspection (ESI) Transitional
Guidance for  FY1988 (EPA I987f)

Quality Assurance Field Operations Manual
(EPA'l987g)

Statistical  Methods  for  Evaluating   the
Attainment ofSuperfund Cleanup Standards:
Volume 1,  Soils  and  Solid Media (EPA
1988f)

Proposed  Guidelines for  Exposure-related
Measurements (EPA 1988g)

Interim   Report   on   Sampling  Design
Methodology (EPA 1988h)

Standard Handbook  of Hazardous Waste
Treatment and Disposal (Freeman 1989)

Soil Sampling Quality Assurance Guide (EPA
1989b)
                                           improve and result in a more accurate assessment
                                           of the site.

                                               Statistical methods. A variety of statistical
                                           manipulations may need to be performed on the
                                           data used in the risk assessment. For example,
                                           there may be comparisons  with background
                                           concentrations, estimates  of upper confidence
                                           limits  on means, and determinations  of the
                                           probability of identifying hot spots. Each of these
                                           analyses   requires different calculations for
                                           determining a sample size  that will yield a

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Page 4-18
specified statistical performance.  Some of the
available guidance, such as the Ground-water
Monitoring guidance (EPA 1986c), the RCRA
Delisting guidance (EPA 1985d),  and the Soils
Cleanup Attainment guidance (EPA  1988f),
address these strategies in detail.

     Statistical performance (i.e., variability,
power, and certainty). If samples will be taken
from an area that is anticipated to have a high
degree of variability in chemical concentrations,
then many  samples may be required to achieve a
specified  level  of  certainty and power. If
contaminant concentrations in an area are highly
variable and only a few samples can be obtained,
then the risk assessor should anticipate (1) a great
deal  of  uncertainty  in  estimating mean
concentrations at the site, (2) difficulty in defining
the distribution of the data (e.g., normal), and (3)
upper confidence limits  much higher than the
mean. Identification of multiple areas of concern
- each with its own set of samples and descriptive
statistics --  will help reduce the total variability if
the areas of concern are defined so that  they are
very different in their contaminant  concentration
profiles.   Risk assessors  should discuss in the
scoping meeting both the anticipated variability in
the data and the desired  power and  certainty of
the statistics that will be estimated from the data.

     As discussed in Section 4.4.3, power is the
likelihood  of detecting a false null  hypothesis.
Power is particularly important when comparing
site characteristics with background. For example,
if a 10 percent difference in mean concentrations
needs to be determined with 99 percent likelihood
(i.e., power of 0.99), a very large number of
samples will likely be  needed (unless the site and
background variabilities are extremely low). On
the  other  hand,  if the  investigator  is  only
interested in whether the onsite average conditions
are 100 times  larger than background or can
accept a lower chance of detecting the difference
if it exists  (i.e., a lower power), then a smaller
sample size could be accommodated.

     The other statistical performance  quantity
besides power  that may need to be  specified is
the certainty of the calculations. One minus the
certainty is  the significance level (i.e.,  a), or false
positive rate (see also Section 4.4.3). The higher
the desired certainty level (i.e., the lower the
significance level), the greater the true difference
must be to observe a statistical difference. In the
case of upper confidence limits on estimates of
mean concentrations, the higher the desired
certainty level, the higher will be the  upper
confidence limit. This follows from the fact that
in general, as certainty increases (i.e., a becomes
smaller), the  size of the confidence interval also
increases.

    Practical considerations.   Finally,  questions
of practicality, logistics, sampling equipment,
laboratory constraints, quality assurance, and cost
influence the  sample size that will be available for
data analysis. After the ideal sample size has
been determined using other factors,  practical
considerations can be introduced to modify the
sample size if necessaty.
4.6.2
ESTABLISH SAMPLING LOCATIONS
     There  are three  general strategies  for
establishing sample locations: (1) purposive, (2)
completely random, and (3) systematic. Various
combinations  of these general strategies are
possible and acceptable.

     Much of the discussion on statistics in the
preceding subsection and in  Section 4.4 is
appropriate here. Typically, a statistician should
be consulted when determining sampling location.

     Purposive  sampling.    Although areas of
concern are established purposively (e.g., with the
intention of identifying contamination),  the
sampling locations within the areas of concern
generally should not be sampled purposively if the
data  are to be used  to provide  defensible
information for a  risk assessment.  Purposively
identified sampling locations are  not discouraged
if the objective  is site characterization, conducting
a chemical inventory, or the evaluation of visually
obvious contamination.   The sampling results,
however, may overestimate or underestimate the
true conditions at the site depending on the
strategies of the sampling team.  Due to the bias
associated with the  samples, data from purposively
identified sampling locations generally should not
be averaged, and distributions of these  data
generally should not be  modeled and used to
estimate other relevant statistics. After areas of
concern have  been  established purposively,
ground-water    monitoring    well     locations,
continuous air monitor locations, and soil sample

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                                                                                       Page 4-19
locations should be determined randomly or
systematically within the areas of concern.

    Random sampling.    Random sampling
involves  selecting sampling locations in an
unbiased manner. Although the investigator may
have chosen the area of concern purposively, the
location of random sampling points within the
area should be independent  of the investigator
(i.e., unbiased). In addition, the sampling points
should be independent of each other; that is, it
should not be possible to predict the location of
one sampling point based on the location of
others.    Random sampling  points  can be
established by choosing a  series of pairs of
random numbers that can be mapped onto a
coordinate system that has been established for
each area of concern.

    Several positive features  are associated with
data collected in a random sampling program.
First, the data can be averaged and used to
estimate  average concentrations for the area of
concern (rather than simply an average of the
samples that were acquired). Second, estimates of
the  uncertainty  of the average and   the
distributional  form  of the  concentration
measurements are informative and simple to
estimate when they  are determined from data  that
were  obtained randomly. Finally,  if there is a
trend or  systematic behavior to the chemical
concentrations (e.g., sampling is occurring along
a chemical gradient), then random sampling is
preferred  because it reduces the likelihood that all
of the high concentration locations are sampled to
the  exclusion of the low concentration locations.

    Systematic sampling.   Systematic sample
locations are established across an area of concern
by laying out a grid of sampling locations that
follow a regular pattern. Systematic sampling
ensures that the sampling effort across the area of
concern is uniform and that samples  are  collected
in each area. The sampling location grid should
be determined by randomly identifying a single
initial location from which the grid is constructed.
If such a random component is not introduced,
the  sample is essentially purposive. The grid  can
be formed in several patterns including square,
rectangular, triangular, or hexagonal, depending on
the  shape of the area.  A square pattern is often
the  simplest to establish. Systematic sampling is
preferable to  other types of sampling if  the
objective is to search for small areas with elevated
concentrations.        Also,    geostatistical
characterizations --  as described in the DQO
guidance (EPA 1987a,b) -- are best done with data
collected from a systematic sample.

    Disadvantages of systematic sampling include
the need for special variance calculations in order
to estimate confidence limits on the average
concentration.   The  Soils Cleanup  Attainment
guidance (EPA 1988f) discusses these  calculations
in further detail.

4.6.3     DETERMINE TYPES OF SAMPLES

    Another item of concern  is the determination
of the types of samples to be collected. Basically,
two types of samples may be collected at a site
grab and composite.

    Grab samples. Grab samples represent a
single unique part of a medium collected at a
specific location and time.

    Composite samples. Composite samples --
sometimes referred to as continuous samples for
air - combine subsamples from different locations
and/or times. As such, composite samples may
dilute or otherwise misrepresent  concentrations
at specific points and, therefore, should be avoided
as the only inputs to a risk  assessment.  For
media such as soil, sediment, and ground water,
composite samples generally may be used to assess
the presence or absence of contamination,
however, they may be used in risk assessment only
to represent average concentrations (and thus
exposures) at a site.   For example, "hot spots"
cannot be determined using composite samples.
For surface water and air, composite samples may
be useful if concentrations and  exposures are
expected to vary over time or  space, as will often
be  the   case  in a large  stream  or  river.
Composites then can be used to estimate daily or
monthly average concentrations, or to  account for
stratification due to depth or varying flow rates
across a stream.

4.6.4     CONSIDER TEMPORAL AND
         METEOROLOGICAL FACTORS

    Temporal   (time)  and meteorological
(weather) factors also must be considered when
determining sampling strategies.  The sampling

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Page 4-20
design should account for fluctuations in chemical
concentrations due to these factors because in
general, the  variability in sampling  results
increases with increasing complexity of these
factors.     When these factors are  complex,
specialized and detailed sampling designs are
needed to maintain a constant and certain  level of
accuracy in the results. Countering this need,
however,  is  the  cost of the  sampling. The
following paragraphs address the interactions of
the  single sampling event, annual/seasonal
sampling cycle, variability estimation, and  the cost
of sampling.

     Single sampling event.  Variability measures
from a single sampling event will underestimate
the overall  variability  of concentrations across an
area of concern, which in turn will result in the
underestimation of the confidence limits on the
mean. The  reason for this underestimation is that
temporal  variability is not included  in an
evaluation  of the total environmental variability
at the site.

     Annual/seasonal sampling cycle. The ideal
sampling strategy incorporates a full  annual
sampling cycle.   If this strategy cannot  be
accommodated in the investigation, at least two
sampling events should  be  considered.   These
sampling events should take place during opposite
seasonal extremes. For example, sampling periods
that may be considered extremes in temporal
sampling include (1)  high waterflow water, (2)
high recharge/low recharge,  (3) windy/calm, and
(4) high  suspended solids/clear water. This type
of sampling requires some  prior knowledge of
regional  seasonal dynamics.    In addition,  a
sampling team that can mobilize rapidly might be
needed if the particular year of sampling is not
typical and the extreme conditions occur at an
unusual time.    See the box on this page for
examples of seasonal variability.

     Variability estimation.  The simple variance
estimators  that are often used in risk assessment
require  that  the  data  are independent  or
uncorrelated. Certain types of repeated samples,
however, (e.g., those from ground-water wells or
air monitors)  actually are time  series data that
might be correlated.    In other words, the
concentration of a contaminant in an aquifer
measured at a well on  a given day will depend, in
part, on what the concentration in the aquifer was
          SEASONAL VARIABILITY

     Regardless  of  the  medium sampled,  sample
   composition may vary depending on the time of year
   and weather conditions when the sample is collected.
   For example,  rain storms  may greatly alter soil
   composition and thus affect the types and concentrations
   of chemicals  present  on  solid material; heavy
   precipitation and runoff from snowmelt may directly
   dilute chemical concentrations or change the types of
   chemicals present in surface water heavy rain also may
   result in sediment loading to water bodies, which could
   increase contamination or affect the concentrations of
   other contaminants through adsorption and settling in
   the water column; if ground-water samples are collected
   from an area heavily dependent on ground water for
   irrigation, the composition of a sample collected during
   the summer growing season may greatly differ from the
   composition of a sample collected  in the winter.
on the previous day.   To reduce this dependence
(e.g., due to seasonal variability), sampling of
ground-water wells and air monitors should be
either separated in time or the data should be
evaluated using statistical models with variance
estimators that can accommodate a correlation
structure. Otherwise, if time series data that are
correlated are treated as a random sample and
used to calculate upper confidence limits  on the
mean,    the   confidence    limits    will   be
underestimated.

     Ideally, samples  of various media should be
collected in a manner that accounts for time and
weather factors. If seasonal fluctuations cannot be
characterized  in the investigations,   details
concerning meteorological, seasonal, and climatic
conditions during sampling  must be documented.
4.6.5
USE FIELD SCREENING ANALYSES
     An important component of the overall
sampling strategy is the use of field screening
analyses.    These types  of analyses  utilize
instruments that range from relatively simple (e.g.,
hand-held organic vapor detectors) to more
sophisticated (e.g., field gas chromatography).
(See Field Screening Methods Catalog [EPA 1987h]
for more information.) Typically, field screening
is used to  provide  threshold indications of
contamination. For example, on the basis of soil
gas screening, the field investigation team may
determine that contamination of a particular area

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                                                                                        Page 4-21
 is indicated and therefore detailed sampling is
 warranted.    Although field screening results
 usually are not  directly  used in  the risk
 assessment,  they  are useful for streamlining
 sampling and the overall RI/FS process.

 4.6.6     CONSIDER TIME AND COST OF
         SAMPLING

     Two primary constraints in sampling are time
 and cost. Time consuming or expensive sampling
 strategies for some media may prohibit multiple
 sampling points. For example, multiple ground-
 water wells and air monitors on a grid sampling
 pattern are  seldom located within a single area of
 concern. However, multiple surface water and soil
 samples within  each area of concern are easier to
 obtain.   In the case of ground water and air,
 several areas of concern may have to be collapsed
 into a single area so that multiple samples will be
 available for  estimating environmental variability
 or so that the dynamics of these media can be
 evaluated  using accepted models of fate and
 transport.

     In general, it is important to remember when
 developing the sampling strategy that detailed
 sampling must be balanced against the time  and
 at involved. The goal of RI/FS sampling is not
 exhaustive site characterization, but rather to
 provide sufficient information to form the basis
 for site remediation.
4.7 QA/QC MEASURES

     This section presents an  overview of the
following quality" assurance/quality  control
(QA/QC) considerations that are of particular
importance  for  risk  assessment sampling:
sampling protocol, sampling devices, QC samples,
collection procedures, and sample preservation.
Note, however, that the purpose of this discussion
is to provide background information;  the risk
assessor will not be responsible for most QA/QC
evaluations.

     The Quality Assurance Field Operations
Manual (EPA 1987g) should be reviewed. In
addition, the EPA Environmental Monitoring
Support Laboratory in  Las Vegas, Nevada,
 (EMSL-LV)  currently is writing a guidance
 document concerning the development of quality
 assurance sample designs for Superfund site
 investigations. Regional QA/QC contacts (e.g.,
 the regional Environmental Semites Division) or
 EMSL-LV  should  be consulted if more
 information concerning QA/QC procedures for
 sampling is desired.

 4.7.1     SAMPLING PROTOCOL

     The sampling protocol for a risk assessment
 should include the following:

     •   objectives of the study;

     •  procedures  for sample  collection,
         preservation, handling, and transport;
         and

     •   analytical strategies that will be used.

 Presenting the objectives of the RI sampling is
 particularly important because these  objectives
 also  will  determine the focus  of the  risk
 assessment.   There should be instructions on
 documenting conditions present during sampling
 (e.g., weather conditions, media conditions).
 Persons collecting samples must be adequately
 trained and experienced in sample collection.  Test
 evaluations of the precision attained by persons
 involved in  sample  collection  should be
 documented (i.e.,  the individual collecting a
 sample should do so in a manner that ensures
 that a homogeneous, valid sample is  reproducibly
 obtained). The discussion of analytical strategies
 should specify quantitation limits to be achieved
 during analyses of each medium.
4.7.2
SAMPLING DEVICES
    The devices used to collect, store, preserve,
and transport samples must not alter the sample
in any way (i.e., the sampling materials cannot be
reactive, sorptive, able to leach analytes, or cause
interferences with the laboratory analysis). For
example,  if the wrong materials are used to
construct wells for the collection of ground-water
samples, organic chemicals may be adsorbed to the
well materials and not be present in the collected
sample.

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Page 4-22
4.7.3    QC SAMPLES

    Field QC samples (e.g., field blanks, trip
blanks, duplicates,   split samples) must be
collected, stored, transported, and analyzed in  a
manner identical to those for site samples The
meaning and purpose of blank samples  are
discussed in detail in Chapter 5. Field duplicate
samples  are usually two  samples collected
simultaneously from the same sampling location
and  are  used as  measures  of  either  the
homogeneity of the medium sampled in  a
particular location or the precision in sampling.
Split samples are usually one sample that is
divided into equal fractions and sent to separate
independent laboratories for analysis. These split
samples are used to check precision and accuracy
of laboratory analyses. Samples  may  also be split
in the  same laboratory, which can  provide
information on precision.     The laboratory
analyzing the samples should not be aware of the
identity of the field QC samples (e.g., labels on
QC samples should be identical to those on the
site samples).

4.7.4    COLLECTION  PROCEDURES

    Collection procedures should not alter the
medium sampled.    The general environment
surrounding the location  of the sample should
remain the same  so that the collected  samples
are representative  of the situation due to the  site
conditions, not due to conditions posed by the
sampling  equipment.

4.7.5    SAMPLE  PRESERVATION

    Until analysis   by  the laboratory,  any
chemicals in the samples must be maintained as
close to the same concentrations and identities
as in the environment from which they came.
Therefore, special procedures may be needed to
preserve the samples during the period between
collection and analysis.
4.8 SPECIAL ANALYTICAL
    SERVICES

    EPA's SAS, operated by the CLP, may be
necessary for two main reasons: (1) the standard
laboratory methods used by EPA's Routine
Analytical Services (RAS) may not be appropriate
(e.g., lower detection limits may be needed),4and
(2) chemicals other than those on the target
compound list (TCL, i.e., chemicals usually
analyzed under the Superfund program) may be
suspected at the site and therefore may need to be
analyzed.   A discussion on the  RAS  detection
limits is provided in Chapter 5.  Additional
information on SAS  can be found in the User's
Guide to the Contract Laboratory Program (EPA
1988i).

    In reviewing the historical data at a site, the
risk assessor should determine if non-TCL
chemicals are expected. A indicated above, non-
TCL chemicals may require,  special sample
collection and analytical procedures using SAS.
Any such needs should be discussed at the scoping
meeting. SAS is  addressed in greater detail in
Chapter 5.
4.9 TAKING AN ACTIVE ROLE
    DURING WORKPLAN
    DEVELOPMENT AND DATA
    COLLECTION

    The risk assessor should be sure to take an
active role during workplan development and data
collection. This role involves three main steps:

    (1)  present risk assessment sampling needs
        at the scoping meeting

    (2)  contribute to the workplan and review
        the Sampling and Analysis Plan; and

    (3)  conduct interim reviews of outputs of
        the field investigation.

See Chapter 9 for information on the role of the
RPM during workplan development and data
collection.

4.9.1     PRESENT RISK ASSESSMENT
        SAMPLING NEEDS AT SCOPING
        MEETING

    At the scoping meeting, the uses of samples
and data to be collected are identified, strategies
for sampling and analysis are developed, DQOs
are established, and priorities for sample collection

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                                                                                        Page 4-23
 are assigned based on the importance of the data
 in meeting RI/FS objectives. One of the RI/FS
 objectives,  of course, is the  baseline  risk
 assessment. Therefore, the risk assessment data
 needs and their fit with those of other RI/FS
 components  are  discussed.    If certain  risk
 assessment sampling needs are judged infeasible
 by the scoping meeting attendees, all persons
 involved with site investigation should be made
 aware of the potential effects of exclusion on the
 risk assessment.

 4.9.2     CONTRIBUTE TO WORKPLAN AND
         REVIEW SAMPLING AND ANALYSIS
         PLAN

    The outcome of the scoping  meeting is the
 development of a workplan and a SAP.  The
 workplan documents the decisions and evaluations
 made during the scoping  process and presents
 anticipated future tasks,  while the  SAP specifies
 the sampling strategies,  the numbers, types, and
 locations of samples, and the level of quality
 control. The SAP consists of a quality assurance
 project plan (QAPjP) and  a field  sampling plan
 (FSP). Elements  of the workplan and the SAP
 are discussed in detail in Appendix  B of the RI/FS
 guidance (EPA 1988a).  Both the  workplan and
 the SAP generally are written by  the personnel
 who will be involved in the collection  of the
 samples; however, these documents should be
 reviewed by all personnel who will be using the
 resulting  sample data.

    Review the workplan. The workplan should
 describe the tasks  involved  in conducting the risk
 assessment.      It also  should  describe  the
 development of a preliminary assessment of public
 health and environmental impacts at the site. The
 risk  assessor should review  the completed
workplan  to  ensure that all feasible risk
 assessment sampling needs have been addressed as
 discussed in the scoping meeting.  In particular,
 this review should focus on the descriptions of
 tasks related to:

    •    field investigation (e.g., source testing,
        media sampling), especially with respect
        to
         ~ background
           medium,
concentrations    by
         ~ quantification of present and future
           exposures, e.g.,

           - exposure pathways

           - present and potential future land
             use

           -  media  that  are  or  may  be
             contaminated

           - locations of actual and potential
             exposure

           -  present   concentrations  at
             appropriate  exposure  points,

         ~ data needs for statistical analysis of
           the above, and

         — data needs for  fate and  transport
           models;

     •   sample  analysis/validation, especially with
         respect to

         - chemicals of concern, and
         -- analytical  quantification levels;

     •   data evaluation;  and

     •   assessment of risks.

In reviewing the above, the precise information
necessary to satisfy the remainder of this guidance
should be anticipated.

     Review the SAP. The risk assessor should
carefully review and evaluate all  sections of the
SAP to determine if data gaps identified in the
workplan will be addressed adequately by the
sampling program.   Of particular importance is
the presentation of the objectives. In the QAPjP
component of the SAP, the risk assessor should
pay particular attention to  the QA/QC procedures
associated with sampling  (e.g., number of field
blanks, number of duplicate samples -- see Section
4.8). The SAP should document the detailed, site-
specific procedures that will be followed to ensure
the quality of the resulting samples. Special
considerations in reviewing the SAP are  discussed
in Section 4.1.3.

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Page 4-24
    In reviewing the FSP, pay particular attention
to the information  on sample location and
frequency, sampling equipment  and procedures,
and sample handling  and analysis. As discussed
in Section 4.5, the sampling procedures should
address:

    •    each medium of concern,

    •    background  concentration,

    •    all potential  exposure points within each
         medium;

    •    migration to potential exposure points,
         including data for models;

    •    potential  exposures based on possible
         future land uses;

    •    sufficient data to satisfy concerns about
         distributions  of sampling data and
         statistics;  and

    •    number and location of samples.

The analytical plans  in  the FSP should  be
reviewed to ensure that DQOs set during the
scoping meeting will be met.

    The  SAP may be revised or amended several
times during the site  investigation. Therefore, a
review of all  proposed changes to the SAP that
potentially may affect the data needs for risk
assessment is necessary. Prior to any changes in
the SAP during actual  sampling, compliance of the
changes with the objectives of the SAP must be
checked. (If risk assessment objectives are not
specified in the original SAP, they will not be
considered  when  changes  to an  SAP  are
proposed.)

4.9.3     CONDUCT INTERIM REVIEWS OF
         FIELD INVESTIGATION OUTPUTS

    All sampling results should be reviewed as
soon as they are available to determine if the risk
assessment data needs outlined in the workplan
have been met by the sampling. Compare the
actual number, types, and locations of samples
collected with those  planned in the SAP.
Sampling locations frequently are changed in the
field when access to a planned sampling location
is obstructed. The number of samples  collected
may be altered if, for instance, there is an
insufficient amount  of a certain medium  to collect
the planned number of samples (e.g., if several
wells are found to be dry).

    If certain sampling needs have not been met,
then the field investigators should be contacted to
determine why these samples were not collected.
If possible, the risk assessor should obtain samples
to fill these data gaps. If time is critical, Special
Analytical Services  (see Section 4.7) may be  used
to  shorten the analytical  time.   If this is not
possible, then the risk assessor should evaluate all
sampling results as discussed in Chapter 5,
documenting the potential effect that these data
gaps will have on the quantitative risk assessment.
In general, the risk assessment should not be
postponed due to these data gaps.

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                                                                                                          Page 4-25

                                   ENDNOTES  FOR CHAPTER 4
1. Some information that is appropriate for the assessment of human health risks also may be suitable and  necessary for an
environmental evaluation of the site. Procedures for conducting an environmental evaluation of the hazardous waste site are outlined
in the companion volume of this guidance, the Environmental Evaluation Manual (EPA 1989a), and are not discussed in this chapter.

2. The term "media" refers to both environmental media (e.g., soil) and biota (e.g., fish).

3. "Areas of Concern" within the context of this guidance should be differentiated from the same terminology used by the Great Lakes
environmental community. This latter use is defined by the International Joint Commission as an area found to be exceeding the Great
Lakes Water Quality Agreement objectives.

4. New  routine services that provide lower detection  limits are currently under development. Contact the headquarters Analytical
Operation Branch for further information.

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Page 4-26

                                  REFERENCES  FOR CHAPTER 4
American Society of Testing and Materials (ASTM). Undated. A Proposed Guide for Sediment Collection. Storage. Characterization.
      and Manipulation. Draft. Available from G. Allen Burton, Dept of Biological Sciences, Wright State University, Dayton, Ohio
      45435.

      •     Provides information concerning how to collect contaminated sediments, sediment spiking, dilution procedures,
           and QA/QC. Will probably be in the annual ASTM manual.

Environmental Protection Agency (EPA). 1981. Procedures for Handling and Chemical Analysis of Sediment and Water Samples.
      Great Lakes Laboratory.

Environmental Protection Agency (EPA).  1983.   Technical Assistance  Document for Sampling and Analysis of Toxic Organic
      Compounds in Ambient Air. Office of Research and  Development.

      •     Provides guidance to persons involved in designing and implementing ambient air monitoring programs for toxic
           organic compounds.   Includes guidance on selecting sampling/analytical methods, sampling strategy, QA
           procedures, and data format. Outlines policy issues.

Environmental Protection Agency (EPA). 1984. Sediment Sampling Quality Assurance User's Guide. Environmental Monitoring
      Support Laboratory. Las Vegaa, NV. NTIS PB-85-233-542.

      •     Overview of selected sediment models presented as a foundation for stratification of study of regions and
           selection of locations for sampling sites, methods of sampling,  sampling preparation  and analysis. Discussion
           of rivers, lakes, and estuaries.

Environmental Protection Agency (EPA). 1985a. Practical  Guide to Ground-water Sampling.  Environmental Research Laboratory.
      Ada, OK EPA 600/2-85/104.

      •     Contains information on laboratory and  field  testing of sampling materials and procedures. Emphasizes
           minimizing errors in sampling and analysis.

Environmental Protection Agency (EPA). 1985b. Methods Manual for Bottom Sediment Sample Collection. Great Lakes National
      Program Office. EPA 905/4-85/004.

      •     Provides guidance on survey planning, sample collection, document preparation, and quality assurance for
           sediment sampling surveys.  Sample site selection, equipment/containers, collection field  observation, preservation,
           handling custody procedures

Environmental Protection Agency (EPA). 1985c. Cooperative  Agreement on the Monitoring of Contaminants in Great  Lakes Sport
      Fish for Human Health Purposes. Region V, Chicago,  IL

      •     Discusses sampling protocols and  sample composition used for sport fish (chinook salmon, coho salmon, lake
           trout, and rainbow trout), maximum composite samples (5 fish) and length ranges which would be applicable
           to hazardous waste sites contaminating lakes or  streams used for recreational fishing.

Environmental Protection Agency (EPA). 1985d. Petitions to Delist Hazardous Wastes Guidance Manual. Office of Solid Waste.
      EPA/530/SW-85/003.

Environmental Protection Agency (EPA). 1986a. Test Methods for Evaluating Solid Waste  (SW-846? Physical/Chemical Methods.
      Office of Solid Waste.

      •     Provides analytical procedures to test solid waste to determine if it is a hazardous  waste as defined under RCRA. Contains
           information for collecting solid waste samples and for determining reactivity, corrosivity, ignitability, composition of waste,
           and mobility of waste compounds.

Environmental Protection Agency (EPA). 1986b. Field Manual for Grid Sampling of PCR Spill Sites to Verify Cleanups. Office of
      Toxic Substances. EPA/560/5-86/017.

      •     Provides detailed, step-by-step guidance for using hexagonal grid sampling includes sampling design, collection,
           QA/QC and reporting.

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                                                                                                               Page 4-21


 Environmental Protection Agency (EPA).  1986c. Resource Conservation and Recovery Act (RCRA) Ground-water Monitoring
      Technical Enforcement Guidance Document. Office of Waste Programs Enforcement.

      •     Contains a detailed presentation of the elements and procedures essential to the design and operation of ground-
            water monitoring systems that meet the goals of RCRA and its regulations. Includes appendices on statistical
            analysis and some geophysical techniques.

 Environmental Protection Agency (EPA). 1987a. Data Quality Objectives for Remedial Response Activities: Development Process.
      Office of Emergency and Remedial Response  and Office  of Waste Programs Enforcement. EPA/540/G-87/003. (OSWER
      Directive 9335.O-7B).

      •     Identifies (1) the framework and process by which data quality objectives (DQOs qualitative and quantitative
            statements that specify the quality of the data required to support Agency decisions during remedial response
            activities) are developed and (2) the individuals responsible for development of DQOs. Provides procedures
            for determining a quantifiable degree of certainty that can be used in making site-specific decisions. Provides
            a formal  approach to integration  of DQO development with sampling and anafysis plan development. Attempts
            to improve the overall quality and cost effectiveness of data collection and analysis activities.

 Environmental Protection Agency (EPA). 1987b. Data  Quality Objectives for Remedial Response Activities Example Scenario: RI/FS
      Activities at a  Site with Contaminated Soils and Ground Water. Office of Emergency and Remedial Response and Office of
      Waste Programs Enforcement. EPA/540/G-87/004.

      •     Companion to EPA 1987a. Provides detailed examples of the process for development of data quality objectives
            (DQOs)  for RI/FS activities under CERCLA.

 Environmental Protection Agency (EPA).  1987c. A Compendium of Suoerfund Field Operations Methods. Office of Emergency and
      Remedial  Response.  EPA/540/P-87/001. (OSWER Directive 9355.0-14).

 Environmental Protection Agency (EPA).  1987d. Handbook Ground Water.  Office of Research and Development. EPA/625/6-
      87/016.

      •     Resource document that brings together the available technical information in a form convenient for personnel
            involved in ground-water management. Also addresses minimization of uncertainties in order to make reliable
            predictions about contamination response to corrective or preventative measures.

 Environmental Protection Agency (EPA). 1987e. An Overview of Sediment Quality in the United States. Office of Water Regulation
      and Standards.

            Good primer. Contains many references.

 Environmental Protection Agency (EPA). 1987f  Expanded Site Inspection (ESI} Transitional  Guidance  for FY 1988.  Office of
      Emergency and Remedial Response. (OSWER Directive 9345.1-.02).

      •     Provides reader with a consolidated ready reference of general methodologies and activities for conducting
            inspection work on site-s being investigated for the NPL.

 Environmental Protection Agency (EPA). 1987g.  Quality Assurance Field Operations Manual. Office of Solid Waste and Emergency
      Response.

      •     Provides guidance  for the selection and definition of field methods, sampling procedures, and custody
            responsibilities.

 Environmental Protection Agency (EPA).  1987h. Field Screening  Methods Catalog.  Office of Emergency and Remedial Response.

      •     Provides a listing of methods to be used during field screening,  and includes method descriptions, their
            application to particular sites, their limitations and uses, instrumentation requirements, detection limits, and
            precision and accuracy information.

Environmental Protection Agency (EPA). 1988a. Guidance for Conducting Remedial Investigations and Feasibility Studies Under
      CERCLA. Interim Final. Office of Emergency  and Remedial Response. (OSWER Directive 9355.3-01).

      •     Provides the user (e.g., EPA personnel, state agencies, potentially responsible parties (PRPs), federal facility
            cordinators, and contractors assisting in RI/FS-related activities) with an overall understanding of the  RI/FS
            process Includes general information concerning  scoping meetings, the development of conceptual  modefs at
            the beginning of a site investigation, sampling, and analysis.

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Page 4-28
Environmental Protection Agency (EPA). 1988b. Statistical Methods for Evaluating Ground Water from Hazardous Waste Facilities.
      Office of Solid Waste.

      •     Specifies five different statistical methods that are appropriate for ground-water monitoring. Outlines aampling
           procdures and performance standards that are designed to help minimize the occurrence of Type I and Type
           II errors.

Environmental Protection Agency (EPA). 1988c. Surface Impoundment Clean Closure Guidance Manual. Office of Solid Waste.

Environmental Protection Agency (EPA). 1988d. Love Canal Emergency Declaration Area Habitabilitv Study Report. Prepared by
      CH2M Hill and Life Systems for EPA Region II.

      •     Provides a formal comparison of samples with background as well as detailed discussions concerning problems
           associated with sampling to evaluate data.

Environmental Protection Agency (EPA). 1988e. Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites.
      Interim Final. Office of Emergency and Remedial Response. (OSWER Directive 9283.1-2).

      •     Provides guidance to develop, evaluate, and select ground-water remedial actions at Superfund sitea, focusing
           on policy issues and establishing cleanup levels.  Also  includes  discussion of data collection activities for
           characterization of contamination.

Environmental Protection Agency (EPA). 1988f. Statistical Methods  for Evaluating the Attainment of Superfund Cleanup Standards.
      Volume I Soils and Solid Media. Draft. Office of Policy, Planning, and Evaluation.

      •     Provides statistical procedures that can be used in conjunction with attainment objectives defined by EPA to
           determine, with the desired confidence, whether a site does indeed attain a cleanup standard. It also provides
           guidance on sampling of soils to obtain baseline information onsite, monitor cleanup operations, and verify
           attainment of cleanup objectives

Environmental Protection Agency (EPA). 1988g. Proposed Guidelines for Exposure-related Measurements. 53 Federal  Register 48830
      (December 2, 1988).

      •     Focuses on  general principles of chemical measurements in various physical and biological  media. Assists
           those who must recommend,  conduct, or evaluate an exposure assessment.

Environmental Protection Agency (EPA). 1988h. Interim Report on Sampling Design Methodology.  Environmental Monitoring
      Support Laboratory. Las Vegas, NV. EPA/600/X-88/408.

           Provides guidance concerning the statistical determination of the number of samples to be collected.

Environmental Protection Agency (EPA).  1988i. User's Guide to  the Contract Laboratory Program. Office of Emergency  and
      Remedial Response.

Environmental Protection Agency (EPA). 1989a.  Risk Assessment Guidance for Superfund Environmental Evaluation Manual.
      Interim Final. Office of Emergency and Remedial Response.  EPA/540/1-89/001A (OSWER Directive 9285.7-01),

Environmental Protection Agency (EPA). 1989b. Soil Sampling Quality Assurance Guide. Review Draft. Environmental Monitoring
      Support Laboratory. Las Vegas, NV.

      •     Replaces earlier edition NTIS Pb-84-198-621. Includes DQOs, QAPP, information concerning the purpose
           of background sampling, selection of numbers of samples and sampling sites, error control, sample design,
           sample documentation.

Environmental Protection Agency (EPA). 1989c. Statistical Analysis of Ground-water Monitoring Data at RCRA Facilities. Office
      of Solid Waste.

Environmental Protection Agency (EPA). 1989d. Ground-water Sampling for Metals Analyses.  Office of Solid Waste  and Emergency
      Response. EPA/540/4-89-001.

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                                                                                                               Page 4-29


Environmental Protection Agency (EPA). 1989e. Air Superfund National Technical Guidance Series. Volume IV Procedures for
      Dispersion Modeling and Air Monitoring for Suoerfund Air Pathway Analysis. Interim Final. Office of Air Quality Planning and
      Standards. Research Triangle Park NC. EPA/450/1-89004.

      •    This volume discusses procedures for dispersion modeling and air monitoring for superfund air pathway analyses.
           Contains recommendations for proper selection and application of air dispersion models and procedures to
           develop, conduct, and evaluate the results of air concentration monitoring to characterize downwind exposure
           conditions from Superfund air emission sources.

Environmental Protection Agency (EPA). 1989f Air Suoerfund National Technical Guidance Series. Volume I:  Application of Air
      Pathway Analyses for Superfund Activities. Interim Final. Office of Air Quality Planning and Standards. Research Triangle Park
      NC. EPA/450/1-89/001.

      •    Provides recommended procedures for the conduct of air pathway analyses (APAs) that meet the needs of the
           Superfund program. The procedures are intended for use by EPA remedial project managers, enforcement
           project managers, and air experts as well as by EPA Superfund contractors. The emphasis of this volume is
           to provide a recommended APA procedure  relative to the  remedial phase  of the Superfund process.

Environmental Protection Agency (EPA). 1989g. Air Suoerfund National Technical Guidance Series. Volume II Estimation of
      Baseline Air Emissions at Superfund sites. Interim Final. Office of Air Quality Planning and Standards. Research Triangle Park,
      NC. EPA/450/1-89/002.

      •    This volume provides information concerning procedures for developing baseline emissions from landfills and
           lagoons. Describes baseline emissions from  both undisturbed sites and sites where media-disturbing activities
           are taking place.  The procedures described  for landfills may be applied to solid hazardous waste, and those
           for lagoons may be applied to liquid hazardous waste.

Environmental Protection Agency (EPA).  1989h. Air Superfund National Technical Guidance  Series. Volume III: Estimation of Air
     Emissions from Cleanup Activities at Superfund Sites. Interim Final. Office of Air Quality Planning and Standards. Research
      Triangle Park, NC.  EPA/450/1-89/003.

      •    This volume provides technical guidance for estimating air emissions from  remedial activities at NPL sites that
           may impact local air quality for both onsite workers at a site and the surrounding community while the remedial
           activities are occurring. Discusses methods to characterize air quality impacts during soil removal, incineration,
           and air stripping.

Environmental Protection Agency (EPA).  1989i. Guidance Manual for Assessing Human Health Risks from Chemically Contaminated
      Fish and Shellfish. Office of Marine and Estuarine Protection. EPA/503/8-89/002.

      •    Study designed to measure concentrations of toxic substances in edible tissues offish and shellfish.

Environmental Protection Agency (EPA) and Army Corps of Engineers (COE). 1981. Procedures for Handling and  Chemical Analysis
      of Sediment and Water Samples. Technical Committee on Dredged and Fill Material. Technical Report EPA/DE-81-1.

Food and Drug Administration (FDA). 1977. Pesticide Analytical Manual. Volume  I.

      •    Provides a skin-on  fillet (whole fish sampling) protocol  used in USEPA monitoring of sportfish in the Great
           Lakes. Also includes  information on compositing.

Food and Drug Administration (FDA). 1986. Pesticides and Industrial Chemicals in Domestic Foods

      •    Provides guidance for sampling designs for fishery products from the market.

Freeman, H.M. 1989. Standard Handbook of Hazardous Waste Treatment and Disposal. McGraw-Hill.  New York.

      •    Provides detailed information concerning sampling and monitoring of hazardous wastes at remedial action sites
           (Chapters 12 and 13).

Gilbert, R.O. 1987. Statistical Methods for Environmental Pollution Monitoring. Van Nostrand Reinhold. New York.

      •    Provides statistical analysis information by  providing sampling plans, statistical tests, parameter estimation
           procedure techniques and references to pertinent publications. The statistical techniques discussed are relatively
           simple, and examples, exercise, and case studies are provided to  illustrate procedures.

-------

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       CHAPTER  5

DATA  EVALUATION

/FROM: "\
•Site discovery
• Preliminary
assessment
•Site Inspection
\«NPL listing J



Data
Collection

^-

j Data
Evaluation
H -w-

Toxicity
Assessment

\
\
Exposure
Assessment

i
Rl!
Charactt
i


' r~\Q>:
•Selection of
5k remedy
jrization ^ •Renedial
design
b I • hemeaial
\^ action

             DATA EVALUATION
        • Combine data available from
          site investigations
        • Evaluate analytical methods
        • Evaluate quantitation limits
        • Evaluate qualified and coded data

        * Evaluate blanks
        • Evaluate tentatively identified
          compounds
        • Compare site data with
          background
        • Identify chemicals of potential
          concern

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                                    CHAPTER 5
                           DATA  EVALUATION
    After a site sampling investigation has been
completed (see Chapter 4), a large quantity of
analytical data is usually available. Each sample
may have been analyzed for the presence of over
one hundred chemicals, and many of those
chemicals may have been detected. The following
nine steps should be followed to organize the data
into a form appropriate for a  baseline  risk
assessment:

    (1)  gather all data available from the site
         investigation  and  sort  by  medium
         (Section 5.1);

    (2)  evaluate  the analytical methods used
         (Section 5.2);

    (3)  evaluate the quality of data with respect
         to sample quantitation limits (Section
         5.3);

    (4)  evaluate the quality of data with respect
         to qualifiers and codes (Section 5.4);

    (5)  evaluate the quality of data with respect
         to blanks  (Section 5.5);

    (6)  evaluate tentatively identified compounds
         (Section 5.6);

    (7)  compare potential    site-related
         contamination with background (Section
         5.7);

    (8)  develop a set of data for use in the risk
         assessment (Section  5.8); and

    (9)  if appropriate, further limit the number
         of chemicals to be carried through the
         risk assessment (Section 5.9).
    Prior to conducting any of these stepsr the
EPA remedial project manager fRPIVf) should be
consulted to determine if certain steps should be
modifiedr addedr or deleted as a result of site-
specific conditions. Also, some  of the steps may
be conducted outside the context of the risk
assessment (e.g., for the feasibility study). The
rationale for not evaluating certain data based on
any of these steps must be fully discussed in the
text of the risk assessment report.

    The following sections address each of the
data evaluation steps in detail,  and Exhibit 5-1
presents a flowchart of the process. The outcome
of this evaluation is (1) the identification of a set
        ACRONYMS FOR CHAPTER 5

     CLP = Contract Laboratory Program
   CRDL - Contract-Required Detection Limit
   CRQL = Contract-Required Quantitation
           Limit
      DL = Detection Limit
      FIT = Field Investigation Team
     IDL == Instrument Detection Limit
    MDL = Method Detection Limit
      ND = Non-detect
      PE = Performance Evaluation
     PQL = Practical Quantitation Limit
   QA/QC = Quality Assurance/Quality Control
      QL = Quantitation Limit
     RAS = Routine Analytical Services
     SAS = Special'Analytical Services
    SMO = Sample Management Office
    SOW = Statement of Work
     SQL = Sample Quantitation Limit
   SVOC = Semivolatile Organic Chemical
     TCL = Target Compound List
     TIC « Tentatively Identified Compound
     TOC «= Total Organic Carbon
     TOX «• Total Organic Halogens
   . VOC «• Volatile Organic Chemical

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    5-2
                                   DEFINITIONS FOR CHAPTER 5

     Chemicals of Potential Concern,  Chemicals that are potentially site-related and whose data are of sufficient quality for use
         in the quantitative risk assessment.

     Common Laboratory Contaminants.  Certain organic cbemfcsto (considered by EPA to tec acetone, 2-butanone, methylene
         chloride, toluene, and the phthalate esters) that are commonly used in the laboratory and thus may be introduced into
         a sample from laboratory cross-contamination, not from ttie site.

     Contract-recroired Quantitation Limit (CRQL).  Chemical-specific levefe that a CLP laboratory must be able to routinely and
         reliably detect and quantitate in specified sample matrices. May or may not be equal to the reported quantitatlon limit
         of a given  chemical in a given sample.

     Detection Limit  CDL>. The lowest amount that can be distinguished from the normal "noise" of an analytical instrument or
         method.

     Non-detects CNDs). Chemicals that are not detected in a particular sample above a certain limit, usually the quantitation limit
         for the chemical in that sample. Non-detects may be indicated by a "IT data qualifier.

     Positive Data. Analytical results for which measurable concentrations (i.e., above a quantitation limit) are reported.  May have
         data qualifiers attached (except a U, which indicates a goo-detect).

     Quantitation Limit CQL1. The lowest level at which a chemical can be accurately and reproducibly quantitated. Usually equal
         to the instrument detection limit multiplied by a (actor of three to five, but varies for different chemicals and different
         samples.
of chemicals that are likely to be site-related and
(2) reported concentrations that are of acceptable
quality for use in the quantitative risk assessment.
If the nine data evaluation steps are followed, the
number of chemicals to be considered in the
remainder of the risk assessment usually will be
less than the number of chemicals initially
identified.      Chemicals  remaining  in  the
quantitative risk assessment based upon this
evaluation are referred to in this guidance as
"chemicals of potential  concern."
5.1  COMBINING  DATA
     AVAILABLE FROM SITE
     INVESTIGATIONS

     Gather data, which may be from several
different sampling periods  and based on several
different analytical  methods, from all available
sources, including field investigation team (FIT)
reports, remedial investigations, preliminary site
assessments, and ongoing site characterization and
alternatives screening activities.   Sort data by
medium.   A useful table format for presenting
data is shown in Exhibit 5-2.

     Evaluate data from different time periods to
determine if concentrations are  similar or if
changes have occurred between sampling periods.
If the methods used to analyze samples from
different time periods are similar in terms of the
types of analyses conducted and the QA/QC
procedures followed, and if the concentrations
between sampling periods are similar, then the
data  may  be combined for the  purposes of
quantitative risk  assessment in order to obtain
more information to characterize the  site. If
concentrations of chemicals change significantly
between sampling periods, it may be useful to
keep  the  data  separate  and evaluate risks
separately.  Alternatively, one could use only the
most recent  data  in the quantitative  risk
assessment and evaluate older data in a qualitative
analysis of changes in concentrations over time.
The RPM should be consulted on the elimination
of any data sets from the risk assessment, and
justification for such elimination must be fully
described in the risk assessment report.

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                                                                                                                             Page 5-3

  (Sampling dtta from
Mch fnodfcini of conoom
      (Sec. 5.1).
f Cntfnlctiei of poMfsWl
I conom tof ojUAnptwVt
V   rtsk
                                                 EXHIBIT 5-1
                                          DATA EVALUATION
    Analytical
method appropriate
  for quantitative
 risk amument
  Eliminate data associated with
Inappropriate methods. Possibly use
     qualitatively In other risk
      assessment sections.
                                       tea
                                chemical not detected
                                    In a sample
                                    (Sec. 5.3)7
                              quanltltatlon limn (QL)
                             > health-based reference
                                 concentration?
                                                                         YES
                                    NO

Reanalyze or address L
qualitatively.** appropriate. \

|useQLor1/2CX-M
proxy concentration.
YES.

                                                Generally eliminate
                                                    chemical.
                                                                                              Do other
                                                                                           sample* In same
                                                                                         medium test positive?
                                                                                  It QL cannot be reduce
                                                                                    UMQLoM/iQLas
                                                                                   proxy concentration, c
                                                                                    eHmlnale chemical In
                                                                                   sample, as approprlaM
                                     OuaNflers
                                 and codes anached
                                   data (Sec. 5.4)7
                              Evaluate qualified data, and
                             eliminate, modify, or leave data
                              as they are, as appropriate.
                                                                                                    Sample
                                                                                               concentration^. 10x
                                                                                                    concentration?
     Blank
  conuurti ration
   (Sec. 55)7
     Common lab
     contaminants?
                                                                     Sample
                                                                 concentration^ 5x
                                                                     concentration?
                                                        Eliminate blank
                                                        contaminants.
                                                                  Expected to be
                                                               present and are primary
                                                                        nts at site?
compounds (DC*;
   Sec. 5.6)7
I Ellmlnai* TIC* (a* appropi
i



uu). i*
Use SAS. If possible, to confirm Identity arid cor
otherwise use TIC* as they are (as approp

icent ration;
date).
                         Calculate rick of background chemical*
                         separately from site-related chemicals.
                                    NOTE:  See text for details
                                             concerning specific
                                             steps In this flowchart.

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                                                     EXHIBIT  5-2
                         EXAMPLE OF OUTPUT FORMAT FOR VALIDATED DATA
                                                               AreaX
Sample Medium
Sample ID
Sample or Screen Depth
Date Collected
Units
Blanks or Duplicates
Soil
SRB-3-1
o-r
12/14/87
ug/kg

Soil
SRB-3-1DU
o-r
12/14/87
ug/kg
Duplicate
Soil
SRB-3-2
2-4'
12/10/87
ug/kg

  Chemical
CRQL"    Concentration    Quallfer*
CRQL*   Concentration  Qualifer*     CRQL'    Concentration   Qualifer*
Aroclor-1016
Arodor-1221
Aroclor-1232
Aroclor-1242
Aroclor-1248
Aroclor-1254
Arodor-1260
80
80
80
80
80
160
160
80
80
80
40
30
120
210
U
U
U
J
J
J

80
80
80
80
80
160
160
80
80
80
42
36
110
220
U
U
U
J
J
J

2000°
2000C
2000C
TSKXf
2000?
2000"
2000C
2000
2000
2000
2000
2000
1800
2100
UJ
UJ
UJ
UJ
UJ
J

Note: All values other than qualifiers must be entered as numbers, not as labels.




"Contract-required quantitation limit (unless otherwise noted). Values for illustration only.




'Refer to section 5.4 for an explanation of qualifiers.




'Sample quantitation limit.
                                                                                                                                          II

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                                                                                                          Page 5-5
5.2 EVALUATION OF ANALYTICAL
     METHODS

     Group data according to the types of analyses
conducted  (e.g.,  field  screening  analysis,
semivolatiles analyzed by  EPA methods for water
and wastewater, semivolatiles analyzed by EPA's
Superfund Contract Laboratory Program  [CLP]
procedures)  to determine  which analytical method
results are appropriate for use in quantitative risk
assessment.  Often, this determination has been
made already by regional and contractor staff.

     An overview of EPA analytical methods is
provided in the box below. Exhibit 5-3 presents
examples of the types of data that are not usually
appropriate for use in quantitative risk assessment,
even though they may  be available from a site
investigation.
                 OVERVIEW OF THE CLP AND OTHER EPA ANALYTICAL METHODS

     The EPA Contract Laboratoty Program (CLP) is intended to provide analytical services for Superfund waste site samples.
   As discussed in the User's Guide to the Contract Laboratory Program (EPA 1988a, hereafter referred to as the CLP User's
   Guide), the program was developed to Gil the need for legally defensible results supported by a high level of quality assurance
   (i.e., data of known quality) and documentation.

     Prior to becoming CLP  laboratories, analytical laboratories must meet stringent requirements for laboratory space and
   practices, instrumentation, personnel  training,  and qualify control  (QQ, and  also must successfully analyze performance
   evaluation (PB) samples. Before the first samples are shipped to the laboratory, audits of CLP labs are conducted to verify all
   Representations made by laboratory management. Continuing performance is monitored by periodic PE sample analyses, routine
   and remedial audits, contract compliance screening of data packages, and oversight by EPA.

     Superfund samples are most commonly analyzed using the Routine Analytical Services (RAS) conducted by CLP laboratories.
   Under RAS, all data are generated using the same analytical protocols specifying instrumentation, sample handling, analysis
   parameters, required qoanlitation limits, QC requirements, and report format. Protocols are provided in the CLP Statement
   of Worfc {SOW) for, Jnorfflflics (EPA I988b) and the CLP ftatement of Work for Qrqanics (1988c). The SOWs also contain
   EPA's target anajyte or compound lists (TAJU for inorganics, TCL for organics), which are the lists of anatytes and required
   quantitation limits (QLs) f°r which every Superfund site sample is routinely analyzed under RAS. As of June  1989, analytes
   On the TCL/TAL consist of 34 volatile organic chemicals (VOCs), 65 semivolatile organic chemicals (SVOCs), 19 pesticides,
   7 polychlorinated biphenyls, 23 metals, and total cyanide. Finally, the SOW specifies data qualifiers that may be placed on
   certain data by the laboratory to communicate information and/or QC problems,

     CLP labs are required to submit RAS data packages to EPA's Sample Management Office (SMO) and to the EPA region
   from which the samples originated within  35  days of receipt of samples.  SMO provides management, operational, and
   administrative  support to the CLP to facilitate optimal use of the program.  SMO personnel identify incomplete or missing
   elements and verify compliance with QA/QC requirements in the appropriate SOW.  In addition to the SMO review, all CLP
   data are inspected by EPA-appointed regional data validators.  Using Laboratory Data Validation Functional Guidelines issued
   by EPA headquarters (hereafter referred to as  Functional Guidelines for Inorganics [EPA 1988dJ and Functional Guidelines
   for Organics [EPA  1988e]), regional guidelines, and professional judgment, the person validating data identifies deviations from
   the SOW, poor QC results, matrix interferences, and other analytical problems that may compromise the potential uses of the
   data. In the validation process, data may be flagged with qualifiers  to alert  data users of deviations from QC requirements.
   These qualifiers differ from those qualifiers attached to the data by the laboratory.

     In addition  to RAS, non-standard analyses  may be conducted  using  Special Analytical Services (SAS)  to meet  user
   requirements such as short turnaround time, lower QLs, non-standard matrices, and the testing of analytes other than those on
   the Target Compound List*  Under SAS, the user requests specific analyses, QC procedures, report formats, and timeframe
   needed,

     Examples of other BPA analytical methods include those described in Test Methods for Evaluating Solid Waste (EPA 1986;
   hereafter referred to as SW-846 Methods) and Methods for Organic Chemical Analysis of Municipal and Industrial Wastewater
   (EPA 1984; hereafter referred to as EPA 600 Methods).  The SW-846 Methods provide analytical procedures to test solid waste
   to determine if it is a hazardous waste as defined under the Resource Conservation and Recovery Act (RCRA). These methods
   include procedures for collecting solid waste samples and for determining reactivity, corrosivity, ignitability, composition of waste,
   aad mobility of waste components. The EPA 600 Methods are used in regulatory programs under the Clean  Water Act to
   determine chemicals present in municipal and industrial wastewaters.

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Page 5-6
                                    EXHIBIT 5-3

     EXAMPLES OF THE TYPES OF DATA POTENTIALLY UNSUITABLE
                  FOR A QUANTITATIVE RISK ASSESSMENT
Analytical Instrument
     or Method                     Purpose of Analysis             Analytical Result
 HNu Organic Vapor Detector         Health and Safety,               Total Organic Vapor
                                 Field Screen

Organic Vapor Analyzer             Health and Safety,               Total Organic Vapor
                                 Field Screen

Combustible Gas Indicator           Health and Safety               Combustible  Vapors,
                                                               Oxygen-deficient
                                                               Atmosphere

Field Gas Chromatography11           Field  Screen/Analytical           Specific Volatile  and
                                 Method                        Semi-volatile Organic
                                                               Chemicals
1 Depending on the detector used, this instrument can be sufficiently sensitive to yield adequate data for
use in a quantitative risk assessment; however, a confirming analysis by GC/MS should be performed on
a subset of the samples in a laboratory prior to use.

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                                                                                            5-7
    Analytical results that are not specific for a
particular compound (e.g., total organic carbon
[TOC], total organic halogens [TOX]) or results
of insensitive analytical methods (e.g., analyses
using portable field instruments such as organic
vapor analyzers and other field screening methods)
may  be  useful when considering sources  of
contamination or potential fate and transport of
contaminants. These types of analytical results,
however, generally  are not  appropriate for
quantitative risk assessment; therefore, the risk
assessor may not want to include them in the
summary of chemicals of potential concern for the
quantitative risk assessment.  In addition, the
results of analytical methods associated with
unknown, few, or no  QA/QC procedures should
be eliminated from  further quantitative use.
These types of results, however, may be useful for
qualitative discussions of risk in other sections of
the risk assessment report.

    The outcome of this step is a set of site data
that has been developed according to a standard
set of sensitive, chemical-specific methods (e.g.,
SW-846 Methods [EPA 1986], EPA 600 Methods
[EPA 1984], CLP Statements of Work [EPA
1988b,c]), with QA/QC procedures that are well-
documented and traceable.   The data resulting
from  analyses conducted under the CLP, which
generally  comprise the majority of results available
from a Superfund site investigation, fall into this
category.

    Although the CLP was developed to ensure
that consistent QA/QC methods are used when
analyzing Superfund site samples, it does not
ensure that all analytical results are consistently
of sufficient quality  and reliability for use  in
quantitative risk assessment. Neither the CLP nor
QA/QC procedures associated with other methods
make judgments concerning the ultimate  "usability"
of the data. Do not accept at face  value all
remaining analytical results, whether from the CLP
or  from   some  other  set   of analytical
methodologies. Instead, determine ~ according  to
the steps discussed below ~ the limitations and
uncertainties associated with the data so that only
data that are appropriate and reliable for use  in
a quantitative risk assessment are carried through
the process.
5.3 EVALUATION OF
    QUANTITATION  LIMITS

    This step involves evaluation of quantitation
limits and detection limits (QLs and DLs) for all
of the chemicals assessed at the site.    This
evaluation may lead to the  re-analysis of some
samples,  the use  of "proxy"  (or estimated)
concentrations, and/or the elimination of certain
chemicals from further consideration (because they
are believed to be  absent from the site). Types
and definitions of QLs and DLs are presented in
the box on the next page.

    Before eliminating  chemicals because  they are
not  detected  (or  conducting  any  other
manipulation of the data), the following points
should be  considered:

    (1) the sample quantitation limit (SQL) of
        a chemical  may  be greater  than
        corresponding standards, criteria, or
        concentrations derived from toxicity
        reference values (and, therefore, the
        chemical may be present at levels greater
        than  these  corresponding reference
        concentrations,  which may result in
        undetected risk); and

    (2) a particular SQL may be significantly
        higher than positively detected values in
        other samples in a data set.

These two points are discussed in detail in the
following  two subsections.  A third subsection
provides guidance for situations where only some
of the samples for a given medium test positive
for a particular chemical. A fourth subsection
addresses the special situation where SQLs are not
available.    The final subsection addresses the
specific steps involved  with elimination of
chemicals  from the quantitative risk assessment
based on their QLs.

5.3.1    SAMPLE  QUANTITATION LIMITS
        (SQLs) THAT ARE GREATER THAN
        REFERENCE  CONCENTRATIONS

    As discussed in Chapter 4, QLs needed for
the site investigation should be specified in the
sampling plan.  " For some chemicals, however,
SQLs obtained under RAS or SAS may exceed

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Page 5-8
certain reference concentrations  (e.g., maximum
contaminant levels  [MCLS],  concentrations
corresponding to a 10" cancer risk). The box on
the next page illustrates this problem. For certain
chemicals (e.g., antimony), the CLP contract-
required quantitation limits (CRQLs) exceed the
corresponding   reference   concentrations for
noncarcinogenic effects, based on  the EPA-verified
reference dose and  a 2-liter per  day ingestion  of
water by a 70-kilogram person.'Estimation  of
cancer risks for several other chemicals (e.g.,
arsenic, styrene) at their CRQLs  yields cancer
risks exceeding 10"4, based on  the same water
ingestion factors. Most potential carcinogens with
EPA-derived  slope factors have CRQLs that yield
cancer risk levels exceeding  10"6in water, and
none of the carcinogens with EPA-derived  slope
factors have  CRQL values yielding less than 107
cancer risk levels (as of the publication date  of
this manual;  data not  shown).
     Three  points   should  be  noted  when
considering this example.

     (1)   Review of site information  and  a
          preliminary  determination of  chemicals
          of potential concern at a site prior to
          sample  collection  may  allow  the
          specification of lower QLs (i.e., using
          SAS) before an investigation begins (see
          Chapter 4). This is the  most efficient
          way to  minimize the problem  of QLs
          exceeding levels  of potential concern.

     (2)   EPA's  Analytical Operations  Branch
          currently is working to reduce the CRQL
          values for several chemicals  on the TCL
          and TAL, and  to develop an  analytical
          service  for chemicals with  special
          standards (e.g., MCLs).
         TYPES AND DEFINITIONS OF DETECTION LIMITS AND QUANTITATION LIMITS

     Strictly interpreted, the detection limit (DL) is the lowest amount of a chemical that can be "seen" above the normal, random
   noise of an analytical instrument or method, A chemical present below that level cannot reliably be distinguished from noise.
   DLs are chemical-specific and instrument-specific and are determined by statistical treatment of multiple analyses in which the
   ratio of the lowest amount observed to the electronic noise level (i.e., the signal-to-noise ratio) is determined. On any given
   day in any given sample, the calculated limit may not be attainable; however, a properly calculated limit can be used as an overall
   general measure of laboratory performance.

     Two types of DLs may be described — instrument DLs (IDLs) and method DLs (MDLs). The IDL is generally the lowest
   amount of a substance that can be detected by an instrument it is a measure only of the DL for the instrument, and does not
   consider any effects that sample matrix, handling, and preparation may  have. The MDL, on the other hand, takes into account
   the  reagents, sample matrix, and preparation steps applied to a sample in specific analytical methods.

     Due to the irregular nature of instrument or method noise, reproducible quantitation of a chemical is not possible at the DL.
   Generally, a factor of three to five is applied to the DL to obtain a quantitation limit (QL), which is considered to be the lowest
   level at which a chemical may be accurately and reproducibly quantitated. DLs indicate the level at which a small amount would
   be "seen; whereas QLs indicate the levels at which measurements can be "trusted."

     Two types of QLs may be described — contract-required QLs (CRQLs) and sample QLs (SQLs). (Contract-required detection
   limits  [CRDL] is the term used for inorganic chemicals.  For the purposes of this manual, however, CRQL will refer to both
   organic and inorganic chemicals.) In order to participate in the CLP, a  laboratory must be able to meet EPA CRQLs. CRQLs
   are  chemical-specific and vary depending on the medium analyzed and the amount of chemical expected to be present in the
   sample. As the name implies, CRQLs are not necessarily the lowest detectable levels achievable, but rather are levels that a
   CLP laboratory should routinely and reliably detect and quantitate in a variety of sample matrices. A specific sample may
   require adjustments to the preparation or analytical method (e.g., dilution, use of a smaller sample aliquot) in order to be
   analyzed. In these cases, the reported QL must in turn be adjusted. Therefore, SQLs, not CRQLs, will be the QLs of interest
   for  most samples. In fact, for the same chemical, a specific SQL may be higher than, lower than, or equal to SQL values for
   other samples. In addition, preparation or analytical adjustments such as dilution of a sample for quantitation of an extremely
   high level of only one compound could result in non-detects for all other compounds included as analytes for a particular
   method, even though these compounds may have been present at trace  quantities in the undiluted sample. Because SQLs take
   into account sample characteristics, sample preparation, and analytical adjustments, these values are  the most relevant QLs for
   evaluating nondetected chemicals.

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                                                                                              Page 5-9
          EXAMPLE OF HEALTH RISKS FROM INGESTION OF WATER CONTAMINATED
                WITH SELECTED CHEMICALS AT THEIR QUANTTTATION LIMITS0
   Chemical
                  CRQL or                   Cancer Risk
  CAS #         CRDL (ug/L)b  CRDL/RfC0  at CRQL or CRDLd
   Antimony
   Arsenic
   Benz(a)pyrene
   Bis(2-Chloroethyl)ether
   2,4-Dinitrotoluene
   Hexachlorobenzene
   N-Nitroso-di-n-dipropylamine
   PCB-1254
   PCB-1260
   Styrene
   Vinyl chloride
 7440-36-0
 7440-38-2
  50-32-8
 111-444
 121-14-2
 118-74-1
 621-64-7
11096-69-1
11096-82-5
 100-42-5
  75-014
60
10
10
10
10
10
10
 1
 1
 5
10
4.3
             SxlO"4
             3X10-3
             3xlO'4
             2xlO'4
             5xlO-4
             2xlO-3
             2X10-4
             4xlO'4
             7X10-4
   a All values in this example are for illustration purposes only.

   ^ CRQL = Contract-required quantitation limit (organics) of the Contract Laboratory Program (revised April 1989).
     CRDL = Contract-required detection limit (inorganics) of the Contract Laboratory Program (revised July 1988).

     The CRQL and CRDL values presented here are for the regular multi-media multi-concentration CLP methods.

   c RfC =  Reference concentration (based or. the August 1989 reference dose for oral exposure, assuming a 70-kilogram.
             adult drinks 2 liters of contaminated water per day).

   <* Cancer Risk at CRQL or CRDL = Excess upper-bound lifetime cancer risk (based on the August 1989 s!0p« factor for
             oral exposure, assuming a 70-kilogram adult drinks 2 liters of contaminated water per day).

   e PCB-1260 slope factor was used.
     (3)  In  several situations,  an analytical
         laboratory may be able to attain QLs in
         particular samples that are below or
         above the  CRQL values

     If SAS  was not specified before sampling
began and/or if a chemical is not detected in any
sample from a particular medium at the QL, then
available modeling data, as well as professional
judgment, should be used to evaluate whether the
chemical  may  be present above reference
concentrations.    If the available information
indicates the chemical is not present, see Section
5.3.5 for guidance on eliminating chemicals. If
there  is some indication that the chemical is
present,  then either re-analyze  selected samples
using SAS, if time allows, or address the chemical
qualitatively. In determining which option is most
appropriate for a site, a screening-level risk
assessment should be performed by assuming that
               the chemical is present in the sample at the SQL
               (see Section 5.3.4 for situations where SQLs are
               not available). Carry the chemical through the
               screening risk assessment, essentially conducting
               the assessment on the SQL for the particular
               chemical.   In this way, the risks that would be
               posed if the chemical is present at the SQL  can
               be compared with risks posed by other chemicals
               at the  site.

                    Re-analyze the  sample.   This (preferred)
               option discourages  elimination  of questionable
               chemicals (i.e., chemicals that may be  present
               below their QL but above a level of potential
               concern) from the risk assessment. If time allows
               and a sufficient quantity of the sample is available,
               submit a SAS request  to re-analyze the sample
               at QLs that are below reference concentrations.
               The possible outcome of this option is inclusion
               of chemicals positively detected at levels above

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Page 5-10
reference concentrations but below the QLs that
would normally have been attained under routine
analysis of Superfund samples  in the CLP
program.

    Address the chemical qualitatively. A  second
and less desirable option for a chemical that may
be present below its QL (and possibly above its
health-based reference concentration)  is to
eliminate the chemical from the quantitative risk
assessment, noting that if the chemical was
detected at a lower QL, then  its  presence and
concentration could contribute significantly to the
estimated risks.

5.3.2     UNUSUALLY  HIGH SQLs

    Due to  one or more sample-specific problems
(e.g., matrix interferences), SQLs for a particular
chemical in some samples may be unusually high,
sometimes greatly exceeding the positive results
reported for the same chemical in  other samples
from  the data set. Even if these  SQLs do not
      EXAMPLE OF UNUSUALLY HIGH
           QUANTITATION LIMITS

    In this example, concentrations of semivolatile organic
   chemicals in soils have been determined using the CLP's
   RAS.

           	Concentration (ue/lcg')	
   Chemical Sample 1  Sample 2 Sample 3  Sample 4

   Phenol    330 Ua     390    19,000 U   490
   a U = Compound was analyzed for, but not detected.
   Value presented (e.g., 330 U) is the SQL,

    The QLs presented in this example (i.e., 330 to 19,000
   ug/kg) vary widely from sample to sample. SAS would
   not aid in reducing the unusually high QL of 19,000
   ug/kg noted in Sample  3, assuming  it  was due to
   unavoidable matrix interferences. In this case, the result
   for phenol in Sample 3 would be eliminated from the
   quantitative risk assessment because it would cause the
   calculated exposure concentrations (from Chapter 6) to
   exceed the maximum detected concentration (in this
   case 490 ug/kg). Thus, the data set would be reduced
   to three samples: the non-detect in Sample 1 and the
   two detected values in Samples 2 and 4.
exceed health-based standards or criteria, they may
still present problems.   If the SQLs cannot be
reduced by re-analyzing the sample (e.g., through
the use of SAS or sample cleaning procedures to
remove matrix interferences), exclude the samples
from the quantitative risk assessment if they cause
the calculated exposure concentration (i.e., the
concentration calculated according  to guidance in
Chapter 6) to exceed the maximum detected con-
centration for a particular sample set.  The box
on this page presents an example  of how to
address a situation with unusually  high QLs.

5.3.3     WHEN ONLY SOME SAMPLES IN A
         MEDIUM TEST POSITIVE  FOR A
         CHEMICAL

     Most analytes at a site are not positively
detected in each sample collected and analyzed.
Instead, for a particular chemical the data set
generally will contain some samples with positive
results and others with non-detected results. The
non-detected results usually are reported as SQLs.
These limits indicate that the chemical was not
measured above certain levels, which may vary
from sample to sample.  The chemical may be
present at a concentration just below the reported
quantitation limit, or it may not be present in the
sample at all (i.e., the concentration in the  sample
is  zero).

     In determining the concentrations most
representative of potential exposures at the site
(see Chapter 6), consider the positively detected
results together with the non-detected results (i.e.,
the SQLs). If there is reason to believe that the
chemical is present in a  sample at a concentration
below the SQL, use one-half of the SQL as a
proxy concentration. The SQL value itself can be
used  if  there  is  reason  to  believe   the
concentration is closer to it than to one-half the
SQL (See the next subsection for  situations
where SQLs are  not available.) Unless site-
specific information indicates that a chemical is
not likely to be present in a sample, do not
substitute the value zero in place of the SQL (i.e.,
do not assume that a chemical that  is not detected
at  the SQL would not be  detected in the sample
if the analysis was extremely sensitive). Also, do
not simply omit the non-detected results from the
risk assessment.

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                                                                                        Page 5-11
5.3.4     WHEN SQLS ARE NOT AVAILABLE

     A fourth situation concerning QLs may
Sometimes be encountered when evaluating site
data. For some sites, data summaries may not
provide the SQLs.  Instead, MDLs, CRQLS, or
even IDLs may have been substituted wherever a
chemical was not detected.    Sometimes, no
detection or quantitation limits may be provided
with the data. As a first step in these situations.
always attempt to obtain the SOLs. because these
are the most appropriate limits to consider when
evaluating non-detected chemicals (i.e., they
account  for  sample   characteristics,   sample
preparation, or analytical adjustments that may
differ from sample to sample).

     If SQLs cannot be obtained, then, for CLP
sample analyses, the CRQL should be used as the
QL of interest for each non-detected chemical,
with the understanding that these  limits may
overestimate or underestimate the actual SQL.
For samples analyzed by methods different from
CLP methods, the MDL may be used as the QL,
with the understanding that in most cases this will
underestimate the SQL (because the MDL is  a
measure of detection limits only and does not
account for sample  characteristics or matrix
interferences). Note that the IDL  should rarely
be used for non-detected chemicals since it is  a
measure only  of the detection limit for  a
particular instrument and does not consider the
effect of sample handling and preparation or
sample characteristics.

5.3.5    WHEN CHEMICALS ARE NOT
       DETECTED IN ANY SAMPLES IN A
         MEDIUM

    After considering the discussion provided in
the above subsections, generally eliminate those
chemicals  that have not been detected in any
samples of a particular medium. On CLP data
reports, these chemicals will be designated in each
sample with a U qualifier preceded by the  SQL or
CRQL (e.g., 10 U).    If information exists to
indicate that the chemicals are present, they
should not be eliminated.    For example, if
chemicals  with  similar  transport and  fate
characteriatics are detected frequently in soil at  a
site, and some of these chemicals also  are detected
frequently in ground  water while the others are
not detected, then the undetected chemicals are
probably present in the  ground  water and
therefore may need to be included in the risk
assessment as  ground-water  contaminants.

     The outcome of this step is a data set that
only contains chemicals for which positive data
(i.e., analytical results for which measurable
concentrations are reported) are available in at
least one sample from each medium. Unless
otherwise indicated,  assume at this point  in the
evaluation of data that positive data to which no
uncertainties are  attached concerning either the
assigned identity of the chemical or the reported
concentration (i.e., data that are not  "tentative,"
"uncertain," or "qualitative") are appropriate for
use in the quantitative risk assessment.
5.4 EVALUATION  OF QUALIFIED
    AND CODED DATA

    For CLP analytical results, various qualifiers
and codes (hereafter referred to as qualifiers) are
attached to certain data by either the laboratories
conducting the analyses or by persons performing
data validation. These qualifiers  often pertain to
QA/QC problems and generally indicate questions
concerning    chemical    identity,     chemical
concentration, or both.  All qualifiers must be
addressed before the chemical can be used in
quantitative risk assessment. Qualifiers used by
the laboratory may differ  from those used by data
validation personnel in either identity or meaning.

5.4.1    TYPES OF QUALIFIERS

    A list of the qualifiers that laboratories are
permitted to use under the CLP ~ and their
potential use in risk assessment - is presented in
Exhibit 5-4.   A similar list addressing data
validation qualifiers is provided in Exhibit 5-5.
In general, because the data validation process is
intended to assess the effect of QC issues on data
usability, validation data qualifiers are attached to
the data after the  laboratory  qualifiers  and
supersede  the laboratory qualifiers. If data have
both laboratory and validation qualifiers and they
appear contradictory, ignore the  laboratory
qualifier and consider only the validation qualifier.
If qualifiers have been attached to certain data by
the laboratory and have not been removed,
revised, or superseded during data validation, then

-------
    5-12
                                      EXHIBIT 5-4

    CLP LABORATORY DATA QUALIFIERS AND THEIR POTENTIAL USE
                      IN QUANTITATIVE RISK ASSESSMENT
Qualifier     Definition
                                               Indicates:
Uncertain      Uncertain     Include Data in Quantitative
 Identity?    Concentration?        Risk  Assessment?
Inorganic Chemical Data:'
      B     Reported value is
            < CRDL, but > IDL.

      U     Compound was analyzed for,
            but not detected.

      E     Value is estimated due to
            matrix  interferences.

      M     Duplicate injection precision
            criteria not met.

      N     Spiked sample recovery not
            within control limits.

      S     Reported value was determined
            by the Method of Standard
            Additions (MSA).

      W     Post-digestion spike for furnace
            AA analysis  is out of control
            limits, while  sample absorbance
            is <50% of spike absorbance.
      «j«
            Duplicate analysis was not
            within control limits.

      +     Correlation coefficient for
            MSA was O.995.
No
Yes
No
No
No
No
7
Yes
Yes
Yes
Yes
No
Yes
'
Yes
Yes
Yes
Yes
    No
    No


    No
Yes
Yes


Yes
Yes
Yes


Yes
Organic Chemical Data:b

      U     Compound was analyzed for,
            but not detected.
    Yes


 (continued)
Yes

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                                                                              Page 5-13

                             EXHIBIT 5-4 (continued)

   CLP LABORATORY DATA QUALIFIERS AND THEIR POTENTIAL USE
                    IN QUANTITATIVE  RISK ASSESSMENT
Indicates:
Qualifier Definition
Uncertain
Identity?
Uncertain
Concentration?
Include Data in Quantitative
Risk Assessment?
    J      Value is estimated,               No, for       Yes                 ?
           either for a tentatively             TCL chem-
           identified compound (TIC)          icals;
           or when a compound is present
           (spectral identification            Yes, for
           criteria are met, but the            TICs
           value  is 
-------
Page 5-14
                                     EXHIBIT  5-5

                 VALIDATION DATA QUALIFIERS AND THEIR
           POTENTIAL  USE IN  QUANTITATIVE RISK ASSESSMENT
Qualifier     Definition
                                            Indicates:
uncertain     Uncertain     Include Data in Quantitative
 Identity?   Concentration?       Risk Assessment?
Inorganic and Organic Chemical Data:'
    U       The material was analyzed         Yes
            for, but not detected. The
            associated numerical value
            is the SQL.

    J       The associated numerical          No
            value is an estimated quantity.

    R       Quality control indicates that      Yes
            the data are unusable (compound
            may or may not be present).
            Re-sampling and/or re-analysis is
            necessary for verification.

    Z       No analytical result (inorganic
            data only).

    Q       No analytical result (organic
            data only).

    N       Presumptive evidence of          Yes
            presence of material (tentative
            identification).b
                                                       Yes
                 Yes


                 Yes
Yes


No
                 Yes
-- = Not applicable

"Source  EPA  1988d,e.

b Organic chemical data only.

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                                                                                                Page 5-15
evaluate the laboratory qualifier itself. If it is
unclear whether the data have been validated,
contact the appropriate data validation and/or
laboratory personnel.

      The type of qualifier and other site-specific
 factors determine how qualified data are to be
 used in a risk assessment.    As seen in Exhibits
 5-4 and 5-5, the type of qualifier attached to
 certain data often indicates how that data should
 be used in a risk assessment. For example, most
 of the laboratory  qualifiers for both inorganic
 chemical data and organic chemical data (e.g., J,
 E, N)  indicate uncertainty in  the reported
 concentration of the chemical, but not in its
 assigned identity.  Therefore, these data can be
 used just as positive data with no qualifiers or
 codes.  In general, include  data with qualifiers that
 indicate uncertainties in concentrations but not in
 identification.

     Examples showing the use of certain qualified
 data are presented in the next two boxes. The
 first box addresses the J qualifier, the  most
 commonly encountered data  qualifier in Superfund
 data packages. Basically, the guidance here is to
 use J-qualified concentrations the same way as
         EXAMPLE OF J QUALIFIERS

     la this example, concentrations of volatile organic
   chemicals in ground water have been determined using
   the CLP's RAS.

                   Concentration (ug/U
                         >lc 2 Satanic 3  Sanmte 4
Tetrachloro-
 etaene   14,000 J*    40
                              30
20J
   * J - Toe numerical value » an estimated quantity,

   b U = Compound was analyzed for, but not detected.
   Value presented («.g., 30 U) Is the SQL,

     TetrachtDFethene  was, delected  in three of  four
   sample* at concentrations of 14,000 pg/1, 40 jig/1, and
   20 ug/I; therefore, these concentrations - as well as the
   nofr-detect - should be Used in determining representa-
   tive concentrations.
                                                     positive data that do not have this qualifier. If
                                                     possible, note potential uncertainties associated
                                                     with the qualifier, so that if data qualified with a
                                                     J  contribute  significantly to the  risk,  then
                                                     appropriate caveats can be attached.
                                                          EXAMPLE OF VALIDATED DATA
                                                             CONTAINING R QUALIFIERS

                                                         In this example, concentrations of inorganic chemicals
                                                       in ground water have been determined using the CLP's
                                                       RAS.

                                                                       Concentration (iig/L)
                                                       Chemical  Sample  1  Sample 2  Sample 3  Sample 4

                                                       Manganese  310    SOORa         30URk 500
                                                       "R =  Quality control indicates  that the  data are
                                                       unusable (compound  may or may not be present),

                                                       b u = compund was  analyzed for, but not detected,
                                                       Value presented (e.g., 30 U) is the SQL.

                                                         These data have been validated, and therefore the  R
                                                       qnatifiers indicate that the person conducting the data
                                                       validation rejected the  data for manganese in Samples
                                                       2 and 3. The "UR" qualifier means that manganese was
                                                       not detected in Sample 3; however, the data validator
                                                       rejected the non-detected  result. Eliminate these two
                                                       samples so  that the data set now consists of only two
                                                       samples  (Samples 1 and 4).
     An illustration of the use of R-qualified data
is presented in the box in this column. The
definition, and therefore the  use  of the  R
qualifier, differs depending on whether the data
have been validated or not. (Note that the CLP
formerly used R  as a laboratory qualifier to
indicate low spike recovery for inorganic. This
has been changed, but older data may still have
been qualified by the laboratory with an R.) If it
is known that the R  data qualifier indicates that
the  sample result was rejected by  the data
validation personnel, then  this result should be
eliminated from the risk assessment; if the R data
qualifier was placed on the  data  to indicate
estimated data due to low spike  recovery (i.e., the
R was placed on the data by the laboratory and

-------
 Page 5-16
not by the validator), then use the R-qualified
data in a manner similar to the use of J-qualified
data (i.e., use the R-qualified concentrations the
same way as positive data that do not have this
qualifier).    If possible,  note whether the R-
Requalified data are overestimates or underestimates
of actual expected chemical concentrations so that
appropriate caveats may be attached if data
qualified with an R contribute significantly to the
risk.

5.4.2 USING THE APPROPRIATE
      QUALIFIERS

     The information presented in Exhibits 5-4
and  5-5 is based  on the most  recent EPA
guidance documents concerning qualifiers: the
SOW for Inorganic and the SOW for Organics
(EPA 1988b,c) for laboratory qualifiers, and the
Functional Guidelines for Inorganic and the
Functional Guidelines for Organics (EPA 1988d,e)
for validation qualifiers. The types and definitions
of qualifiers, however, may  be periodically updated
within the CLP program. In  addition, certain
EPA regions may have their own data qualifiers
and associated definitions.    These  regional
qualifiers are generally  consistent  with the
Functional Guidelines, but are designed to convey
additional information to data users.

     In general, the risk assessor should check
whether the information presented in this section
is current by contacting the appropriate regional
CLP or headquarters Analytical Operations
Branch staff. Also, if definitions are not reported
with the data, regional  contacts should be
consulted prior to evaluating qualified data.
These variations may affect how data with certain
qualifiers should be used  in a risk assessment.
Make sure that definitions of data qualifiers used
in the data set for the site have been reported
with  the data and are current. Never guess about
the definition of qualifiers.
 5.5 COMPARISON OF
     CONCENTRATIONS
     DETECTED IN BLANKS WITH
     CONCENTRATIONS
     DETECTED IN SAMPLES

     Blank  samples  provide a  measure of
 contamination that has been introduced into a
 sample set either (1) in  the field while the
 samples were being collected or transported to the
 laboratory or (2) in the laboratory during sample
 preparation or analysis. To  prevent the inclusion
 of non-site-related contaminants in the risk
 assessment, the concentrations of chemicals
 detected in blanks must  be compared with
 concentrations of the same chemicals detected in
 site samples.   Detailed definitions of different
 types of blanks are provided in the box on the
 next page.

     Blank data  should be compared with results
 from samples with which the blanks are associated.
 It is often impossible, however, to determine the
 association between certain blanks and data. In
 this case, compare the blank data with results
 from the entire sample data set.   Use  the
 guidelines  in the following paragraphs when
 comparing sample concentrations with blank
 concentrations.

     Blanks containing common  laboratory
 contaminants. As discussed in the CLP SOW for
 Organics  (EPA 1988c) and the  Functional
 Guidelines for Organics (EPA 1988e), acetone, 2-
 butanone (or methyl ethyl ketone), methylene
 chloride, toluene, and the  phthalate esters are
 considered by EPA to be common laboratory
 contaminants. In accordance with the Functional
 Guidelines  for Organics (EPA 1988e) and  the
 Functional Guidelines for Inorganic (EPA 1988d),
 if the blank contains detectable levels of common
 laboratory contaminants, then the sample results
 should be considered as positive results only if the
 concentrations in the sample exceed  ten times the
 maximum amount detected in anv  blank. If the
 concentration  of a   common    laboratory
 contaminant is  less than ten times the blank
 concentration, then conclude that the chemical
was not detected in the particular sample and, in
 accordance with EPA guidance, consider  the
blank-related concentrations of the chemical to be

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                                                                                                     Page 5-17
                                            TYPES OF BLANKS

     Blanks are analytical quality control samples analyzed in the same manner as site samples. They are used in the measurement
   of contamination that has been introduced into a sample either (1) in the field while the samples were being collected or
   transported to the laboratory or (2) in the laboratory during sample preparation or analysis, Four types of blanks — trip, field,
   laboratory calibration, and laboratory reagent (or method) — are described below. A discussion on the water used for the blank
   also is provided.

     Trip Blank. This type of blank is used to indicate potential contamination due to migration of volatile organic chemicals
   (VOCs) from the air on the site or in sample shipping containers, through the septum or around the lid of sampling vials, and
   into  the sample. A trip blank consists of laboratory distilled, deionized water in a 40-ml glass vial sealed with a teflon septum
   The  blank accompanies the empty sample bottles to the field as well as the  samples returning to the laboratory for analysis; it
   is not opened until it is analyzed in the lab with the actual site samples. The containers and labels for trip blanks should be
   the same as the containers and labels for actual samples, thus making the laboratory  "lind" to the identity of the blanks.

     Field Blank. A field blank is used to determine if certain field sampling  or cleaning procedures (e.g., insufficient cleaning
   of sampling equipment) result in cross-contamination of site samples. Like the trip blank, the field blank is a sample of distilled,
   deionized water taken to the field with empty sample bottles and is analyzed in the laboratory along with the actual samples.
   Unlike the trip blank, however, the field blank sample is opened in the field and used as a sample would be (e.g., it is poured
   through cleaned sampling equipment or it is poured from container to container in the vicinity of a gas-powered pump). As
   with trip blanks, the field blanks' containers and labels should be the same  as for actual samples,

     Laboratory Calibration Blank. This type of blank is distilled, deionized  water injected directly into an instrument without
   having been treated with reagents appropriate to the analytical method used to analyze actual site samples. This type of blank
   is used to indicate  contamination in the instrument itself, or possibly in the  distilled, deionized water.

     Laboratory Reagent Or Method Blank. This blank results from the treatment of distilled, deionized  water with all of the
   reagents and manipulations (e.g., digestions  or extractions) to which site  samples will  be subjected. Positive results in the
   reagent blank may indicate either contamination of the chemical reagents  or the glassware and implements used to store or
   prepare the sample and resulting solutions.  Although a laboratory following good laboratoty practices will have its analytical
   processes under control, in some instances method blank contamination cannot be entirely eliminated.

     Water Used for Blanks. For all the blanks described above, results are reliable only if the water comprising the blank was
   clean. For example, if the laboratory water comprising the trip blank was contaminated with VOCs prior to being taken to the
   field,  then the source of VOC contamination  in the trip  blank cannot be isolated  (see laboratory calibration blank).
the quantitation limit for the chemical in that
sample. Note that if aU samples contain levels of
a common laboratory contaminant that are less
than ten times the  level  of contamination noted
in the blank,  then completely eliminate that
chemical from the set of sample results.

     Blanks containing  chemicals that are not
common laboratory contaminants. As discussed
in the  previously referenced guidance, if the  blank
contains detectable levels of one or more organic
or inorganic chemicals that are not considered by
EPA to be common laboratory contaminants (e.g.,
all other chemicals on the TCL),  then consider
site  sample  results  as  positive only if the
concentration  of the chemical in the site  sample
exceeds five times the maximum amount  detected
in any blank. Treat samples containing less than
five times the  amount in any blank as non-detects
and, in accordance  with EPA guidance, consider
the blank-related chemical concentration to be the
quantitation limit for the chemical in that sample.
Again, note that if aU samples contain levels of a
TCL chemical  that are less than five times the
level of contamination noted in the blank, then
completely eliminate that chemical from the set of
sample results.
5.6 EVALUATION  OF
     TENTATIVELY IDENTIFIED
     COMPOUNDS

     Both the identity and reported concentration
of a tentatively identified compound (TIC) is
questionable (see the box on the next page for
background on  TICs). Two options for addressing
TICS exist, depending on the relative number of
TICs compared to non-TICs.

-------
Page 5-1
5.6.1     WHEN FEW TICs ARE PRESENT

    When only a few TICs are present compared
to the TAL and TCL chemicals, and no historical
or other site information indicates that either a
particular TIC may indeed be present at the site
(e.g., because it may be a by-product of a chemical
operation conducted when the site was active) or
that the estimated concentration may be very high
(i.e., the risk would be dominated by the TIC),
then generally do not include the TICS in the risk
assessment.    Otherwise, follow the guidance
provided in the next subsection. Consult with the
RPM  about omitting TICS from the quantitative
         TENTATIVELY IDENTIFIED
                COMPOUNDS

     EPA'* TCL may be a Hmited subset of the organic
   compounds that could actually be encountered at a
   particular site.  Thus, although the CLP RAS requires
   the laboratory to analyze samples only for compounds
  1 on (he TCL, the analysis of VOCs and SVOCS may
   indicate the presence of additional organic compounds
   not on the TCL.  These additional compounds are
   shown by "peaks" on  the chromatograms.   {A
   chromatogratn is a paper representation of the response
   of the instrument to the presence of a compound.) The
   CLP laboratory must attempt to identify the 30 highest
   peaks (10 VOCs and 20 SVOCs) using computerized
   searches of a library containing mass spectra (essentially
   "fingerprints" for particular compounds).  When the
   mass spectra match to a certain degree, the compound
   (or general class of compound) is named; however, the
   assigned identity  is in most cases highly uncertain.
   These compounds are called  tentatively  identified
   compounds (TICs),

     The CLP SOW provides procedures to obtain a rough
   estimate of concentration of TICs.  These estimates,
   however, are highly uncertain and could be orders of
   magnitude higher or lower than the actual concentration.
   For TICs,  therefore,  assigned  identities may  be
   inaccurate, and quantitation is certainly inaccurate. Due
   to these uncertainties, TIC information often is not
   provided with data summaries from site investigations.
   Additional sampling and analysts under SAS may reduce
   the uncertainty associated with TICs and, therefore, TIC
   information should be sought when it is absent from
   data summaries.
risk assessment, and document reasons for
excluding TICS in the risk assessment report.

5.6.2     WHEN  MANY TICs ARE PRESENT

     If many TICs are present relative to the TAL
and TCL compounds identified,  or  if TIC
concentrations appear high  or site  information
indicates that TICs are indeed present,  then
further evaluation  of  TICs  is  necessary. If
sufficient time is available, use SAS to confirm
the identity and to positively and reliably measure
the concentrations of TICs prior to their use in
the risk assessment. If SAS methods to identify
and measure TICs are unavailable, or if there is
insufficient time to use  SAS, then the  TICS should
be included as chemicals of potential concern in
the risk assessment and the uncertainty in both
identity and concentration should be noted (unless
information exists to indicate that the TICs are
not present).
5.7  COMPARISON  OF SAMPLES
     WITH BACKGROUND

     In some cases, a comparison of sample
concentrations with background concentrations
(e.g., using the geometric  mean concentrations of
the two data sets) is useful for identifying the
non-site-related chemicals  that are found at or
near the site.   If background risk might be a
concern, it should be calculated separately from
site-related risk. Often, however, the comparison
of samples with background is unnecessary because
of the  low risk usually posed by the background
chemicals compared to site-related chemicals.

     As discussed in Chapter 4,  information
collected during the RI can provide information
on two types of background chemicals:   (1)
naturally occurring chemicals that have not been
influenced by humans and (2) chemicals that are
present due to anthropogenic sources. Either type
of background chemical can be either localized or
ubiquitous.

     Information on background chemicals may
have been obtained by the collection of site-
specific background samples and/or from other
sources (e.g.,  County  Soil Conservation Service
surveys, United States  Geological Survey [USGS]

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                                                                                       Page 5-19
reports). As discussed in Chapter 4, background
concentrations should be from the site or the
vicinity of the site.

5.7.1     USE APPROPRIATE BACKGROUND
         DATA

    Background samples collected during the site
investigation should not be used if they were
obtained from areas influenced or potentially
influenced by  the site. Instead, the literature
sources mentioned in  the previous paragraph may
be consulted to determine background levels of
chemicals in the vicinity of the site. Care must be
taken in using literature sources, because the data
contained therein might represent nationwide
variation in a particular parameter rather than
variation typical of the geographic region or
geological setting in which the site is located. For
example,  a    literature    source   providing
concentrations of chemicals in ground water on a
national  scale may  show  a wide range of
concentrations  that is not representative of the
variation in concentrations that would be expected
at a particular site.

5.7.2     IDENTIFY  STATISTICAL METHODS

    In cases where background comparisons will
be made, any statistical methods that will be used
should be identified prior to the collection of
samples (see  Chapter 4). Guidance documents
and  reports   that  are available  to  aid in
background comparison are listed in Section 4.4.3.
Prior to conducting the steps discussed in the next
two subsections, the RPM should be consulted to
determine the type of comparison to  be made, if
any. Both a justification for eliminating chemicals
based on a background comparison and a brief
overview of the type of comparison conducted
should be included in the risk assessment report.

5.7.3     COMPARE  CHEMICAL
         CONCENTRATIONS WITH
         NATURALLY OCCURRING LEVELS

    As defined previously, naturally occurring
levels are levels of chemicals that are present
under ambient conditions and that have not been
increased by anthropogenic sources. If inorganic
chemicals are  present at the site at naturally
occurring levels, they  may be  eliminated from the
quantitative risk assessment. In some cases,
however, background concentrations may present
a significant risk, and, while cleanup may or may
not elimimte this risk, the background risk may
be  an important site  characteristic to those
exposed. The RPM will always have the  option
to consider the risk posed by naturally occurring
background chemicals separately.

    In  general,  comparison with  naturally
occurring levels is applicable only to inorganic
chemicals, because the majority of organic
chemicals found at Superfund sites are not
naturally occurring  (even though they may be
ubiquitous). The presence of organic  chemicals
in background  samples collected during a site
investigation actually may indicate  that the sample
was collected  in an area  influenced by site
contamination and therefore does not  qualify as
a true background sample. Such samples should
instead be included with other site samples in the
risk assessment. Unless  a very strong case can be
made for the natural occurrence of an organic
chemical, do not eliminate it  from the quantitative
risk assessment for this reason.

5.7.4     COMPARE  CHEMICAL
         CONCENTRATIONS  WITH
         ANTHROPOGENIC LEVELS

    Anthropogenic    levels   are   ambient
concentrations resulting from  human  (non-site)
sources.   Localized anthropogenic  background  is
often caused by a point source such as a nearby
factory.  Ubiquitous anthropogenic  background  is
often from nonpoint sources  such as automobiles.
In  general, do not eliminate anthropogenic
chemicals because, at many  sites,  it is  extremely
difficult to conclusively show at this stage of the
site investigation that such chemicals are present
at the site due to operations not related to the
site or the surrounding area.

    Often, anthropogenic background  chemicals
can be identified and considered separately  during
or at the end of the risk assessment.   These
chemicals also can be omitted entirely from the
risk assessment, but, as discussed for natural
background, they may present a significant risk.
Omitting  anthropogenic background  chemicals
from the risk  assessment could result in the loss
of important  information for those potentially
exposed.

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 Page 5-20
 5.8 DEVELOPMENT OF A SET OF
     CHEMICAL DATA AND
     INFORMATION FOR USE IN
     THE RISK ASSESSMENT

     After the evaluation of data is complete as
 specified in previous sections, a list of the samples
 (by medium) is made that will be used to estimate
 exposure concentrations, as discussed in Chapter
 6 of this guidance. In addition, as shown in the
 flowchart in Exhibit 5-1, a list of chemicals of
 potential concern (also by medium) will be needed
 for the quantitative risk assessment. This list
 should include chemicals that were

     (1)  positively detected in at least one CLP
         sample  (RAS or SAS) in a given
         medium, including (a) chemicals with no
         qualifiers attached (excluding samples
         with unusually high detection limits), and
         (b) chemicals  with qualifiers attached
         that  indicate  known identities  but
         unknown concentrations  (e.g., J-qualified
         data);

    (2)  detected at levels significantly elevated
         above levels of the same chemicals
         detected in associated blank samples;

    (3)  detected at levels significantly elevated
         above naturally occurring levels of the
         same  chemicals;

    (4)  only tentatively identified but either may
         be associated  with the site based on
         historical information or have been
        confirmed by SAS; and/or

    (5) transformation products of chemicals
        demonstrated to be present.

    Chemicals that were not detected in samples
from a given medium (i.e., non-detects) but that
may be present at the site also may be included
in the  risk assessment if an evaluation of the risks
potentially present at  the  detection limit is
desired.
 5.9 FURTHER REDUCTION IN
     THE NUMBER OF
     CHEMICALS (OPTIONAL)

     For certain sites, the list of potentially site-
 related chemicals remaining after quantitation
 limits, qualifiers,  blank contamination, and
 background have been evaluated may be lengthy.
 Carrying a large number of chemicals through a
 quantitative risk assessment may be complex and
 it may consume significant amounts of time and
 resources. The resulting risk assessment report,
 with its large, unwieldy tables and text, may be
 difficult to  read and understand, and it may
 distract from the dominant risks presented by the
 site. In these cases, the  procedures discussed in
 this section ~ using chemical  classes, frequency of
 detection, essential nutrient information,  and a
 concentration-toxicity screen ~ may be used to
 further reduce the number of chemicals  of
 potential concern in each medium.

     If conducting a risk assessment on a large
 number of chemicals is feasible (e.g., because of
 adequate   computer   capability),   then   the
 procedures presented in this section should not be
 used. Rather, the most important chemicals (e.g.,
 those  presenting 99 percent  of  the risk)  ~
 identified after the risk assessment ~ could be
 presented in the main text of the report, and the
 remaining chemicals could be presented in the
 appendices.

 5.9.1 CONDUCT INITIAL ACTIVITIES

    Several  activities must be conducted before
 implementing any of the procedures described in
 this section:   (1) consult with the RPM; (2)
 consider how the rationale for the procedure
 should be documented; (3)  examine historical
 information on the site; (4) consider concentration
 and toxicity  of the chemicals; (5) examine the
 mobility, persistence,   and bioaccumulation
 potential of the chemicals; (6) consider special
 exposure routes;  (7) consider the treatability of
the chemicals; (8) examine  applicable or relevant
and appropriate requirements (ARARs); and (9)
examine the need for the procedures.   These
activities are described below.
                                                     Consultation with the RPM.   If a large
                                                 number of chemicals are of potential concern at

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                                                                                          Page 5-21
a particular site, the RPM should be consulted.
Approval by the RPM must be obtained prior to
the elimination of chemicals based on any of these
procedures.  The concentration-toxicity screen in
particular may be needed only in rare instances.

     Documentation of rationale. The rationale
for eliminating chemicals from the quantitative
risk assessment based on the procedures discussed
below must be clearly stated in the risk assessment
report.   This documentation,  and its possible
defense at a later date, could be fairly resource-
intensive. If a continuing need to justify this step
is  expected,  then any plans to eliminate chemicals
should be reconsidered.

     Historical information. Chemicals reliably
associated with site activities based on historical
information generally  should not be  eliminated
from the quantitative risk assessment, even if the
results of the procedures given in this section
indicate that such an elimination is possible.

    Concentration and toxicity. Certain aspects
of concentration and toxicity of the chemicals also
must be considered prior to eliminating chemicals
based on the results of these  procedures. For
example,    before    eliminating   potentially
carcinogenic chemicals, the  weight-of-evidence
classification should be considered in conjunction
with the concentrations detected at the site. It
may be practical and conservative to retain a
chemical that was detected at low concentrations
if that chemical is a Group A  carcinogen. (As
discussed in detail in Chapter 7, the weight-of-
evidence classification is an indication of the
quality and quantity  of data underlying a
chemical's  designation as a potential human
carcinogen.)

     Mobility, persistence, and bioaccumulation.
Three factors that must  be considered when
implementing these procedures  are the mobility,
persistence, and bioaccumulation of the chemicals.
For example, a highly volatile (i.e., mobile)
chemical such as benzene,  a  long-lived  (i.e.,
persistent) chemical such as dioxin, or a readily
taken-up and concentrated (i.e., bioaccumulated)
chemical such as DDT,  probably should remain in
the risk assessment.  These procedures do not
explicitly include  a mobility,  persistence, or
bioaccumulation component, and therefore the
risk assessor must pay special attention to these
factors.

    Special exposure routes. For some chemicals,
certain  exposure routes need to be considered
carefully before using these procedures.   For
example, some chemicals are highly volatile and
may pose a significant inhalation risk due to the
home use of contaminated water, particularly for
showering.    The procedures described in this
section may not account for exposure routes  such
as this.

    Treatability.    Some chemicals are more
difficult to treat than others and as a result should
remain as chemicals of potential concern because
of their importance during the  selection  of
remedial alternatives.

    ARARs. Chemicals with ARARs (including
those relevant to land ban compliance) usually are
not appropriate for exclusion from the quantitative
risk assessment based on the procedures in this
section.   This may, however, depend in part on
how the chemicals' site concentrations in specific
media compare with their ARAR concentrations
for these media.

    Need for procedures. Quantitative  evaluation
of aU chemicals of potential concern is the most
thorough approach in a risk assessment. In
addition, the time required to implement and
defend the selection procedures discussed in this
section  may  exceed the time needed to simply
carry all the chemicals of potential  concern
through  the risk assessment. Usually, carrying all
chemicals of potential  concern through the risk
assessment will not be a difficult task, particularly
given the widespread use of computer spreadsheets
to calculate exposure concentrations of chemicals
and their associated risks. Although the tables
that result  may indeed  be  large, computer
spreadsheets  significantly increase the ability to
evaluate a number  of chemicals in a relatively
short period of time.   For these reasons, the
procedures discussed here may be needed only  in
rare instances. As previously stated, the approval
of these  procedures by the RPM must be obtained
prior to implementing any  of these  optional
screening procedures at a particular site.

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Page 5-22
5.9.2     GROUP CHEMICALS BY CLASS

     At times, toxicity values to be used in
characterizing risks are available only for certain
chemicals within a chemical class. For example,
of the polycyclic aromatic hydrocarbons (PAHs)
considered to be potential carcinogens, a slope
factor currently is available (i.e., as this manual
went to press) for benz(a)pyrene only. In these
cases, rather than eliminating the other chemicals
within the class from quantitative evaluation
because of a lack of toxicity  values, it may be
useful to group data for such a class of chemicals
(e.g., according to structure-activity relationships
or other similarities) for consideration in later
sections of the risk assessment. For example, the
concentrations of only one group of chemicals
(e.g., carcinogenic PAHs) would be considered
rather than concentrations of  each of the seven
carcinogenic PAHs currently on the TCL.

     To group chemicals by class, concentrations
of chemicals within each class are  summed
according to procedures discussed in Chapter 6 of
this guidance.  Later in the risk assessment, this
chemical class concentration  would be used to
characterize risk using toxicity values (i.e., RfDs
or slope factors) associated with  one of the
chemicals in the particular class.

     Three notes  of caution when grouping
chemicals should be considered: (1) do not group
solely by toxicity characteristics; (2) do not group
aU carcinogenic chemicals or all noncarcinogenic
chemicals without regard to structure-activity or
other chemical similarities; and (3) discuss in the
risk assessment report that grouping can produce
either over- or under-estimates of the true risk.

5.9.3     EVALUATE FREQUENCY  OF
         DETECTION

     Chemicals that are infrequently detected may
be artifacts in the data due to sampling, analytical,
or other problems, and therefore may  not be
related to site operations or disposal practices.
Consider the chemical as  a  candidate for
elimination from the quantitative risk assessment
if: (1) it is  detected infrequently in one  or
perhaps two  environmental media, (2) it is not
detected in any other sampled media or at high
concentrations, and (3) there is no reason to
believe that  the  chemical may be  present.
Available modeling results may indicate whether
monitoring data that show infrequently detected
chemicals are representative of only their sampling
locations or of broader areas. Because chemical
concentrations at a site are spatially variable, the
risk assessor can use modeling results to project
infrequently detected chemical concentrations over
broader areas when determining whether the
subject chemicals are relevant to the overall risk
assessment.     Judicious use of modeling to
supplement available monitoring data often can
minimize the need for the RPM to resort to
arbitrarily setting   limits  on inclusion of
infrequently detected chemicals in the risk
assessment. Any detection frequency limit to be
used (e.g., five percent) should be approved by the
RPM prior to using this screen. If, for example,
a frequency of detection limit of five percent is
used,  then at least 20 samples of a medium would
be needed (i.e., one detect in 20 samples equals
a five percent frequency of detection).

    In addition to available monitoring data and
modeling results, the risk assessor will need to
consider other relevant factors (e.g., presence of
sensitive  subpopulations) in recommending
appropriate  site-specific limits on inclusion of
infrequently detected chemicals in the quantitative
risk assessment.  For example, the risk assessor
should consider whether the chemical  is expected
to be present based on historical data or any
other    relevant   information   (e.g.,   known
degradation products of chemicals present at the
site, modeling results). Chemicals expected  to be
present should not be eliminated. (See the
example of chemicals with similar transport and
fate characteristics in Section 5.3.5.)

    The reported  or modeled concentrations and
locations of  chemicals should be  examined to
check for hotspots, which may be  especially
important for short-term exposures  and which
therefore should not be eliminated  from the risk
assessment.     Always consider  detection of
particular chemicals  in all sampled media because
some  media may be sources of contamination for
other  media.   For example, a chemical that is
infrequently detected in soil (a potential ground-
water  contamination source) probably  should  not
be eliminated as a site contaminant if the  same
chemical is frequently detected in ground water.
In addition, infrequently detected chemicals with

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                                                                                          Page 5-23
concentrations  that greatly exceed reference
concentrations should not be eliminated.

5.9.4     EVALUATE ESSENTIAL NUTRIENTS

     Chemicals that are (1)  essential human
nutrients, (2) present at low concentrations (i.e.,
only slightly elevated above naturally occurring
levels), and (3) toxic only at very high doses (i.e.,
much higher than those that could be associated
with contact at the site) need not be considered
further in the  quantitative risk assessment.
Examples of such chemicals are iron,  magnesium,
calcium,  potassium, and sodium.

     Prior to eliminating such chemicals from the
risk assessment, they must be shown to be present
at levels that are not associated with adverse
health effects. The determination of acceptable
dietary levels for essential nutrients, however,
often  is  very  difficult.     Literature values
concerning acceptable dietary levels may conflict
and may change fairly often as new studies are
conducted. For  example, arsenic ~  a potential
carcinogen - is  considered by  some scientists to
be an essential  nutrient based on  animal
experiments; however, acceptable dietary levels are
not well  known  (EPA 1988f). Therefore,  arsenic
should be retained in the risk assessment, even
though  it may be an essential  nutrient  at
undefined dietary levels. Another example of a
nutrient that is difficult to characterize is sodium.
Although an essential element in the diet, certain
levels  of sodium may be associated  with blood
pressure effects in some sensitive individuals
(although data indicating an association between
sodium in drinking water and  hypertension are
inadequate [EPA 1987]).

    Another problem with determining acceptable
dietary levels for essential  nutrients is that
nutrient levels often are presented in the literature
as concentrations within the human  body (e.g.,
blood  levels). To  identify  an  essential nutrient
concentration to be used for comparison with
concentrations in a particular medium at a site,
blood (or other tissue) levels of the chemical from
the literature must be converted to concentrations
in the  media of concern for the site (e.g., soil,
drinking  water).
     For these reasons, it may not be possible to
compare essential nutrient concentrations with site
concentrations  in order to eliminate essential
nutrient chemicals.    In general, only essential
nutrients present at low concentrations (i.e., only
slightly elevated above background) should be
eliminated to help ensure that chemicals present
at potentially toxic concentrations are evaluated in
the quantitative risk assessment.

5.9.5 USE A CONCENTRATION-TOXICITY
      SCREEN

     The objective of this screening procedure is
to identify the chemicals in a particular medium
that -- based on  concentration and toxicity -- are
most likely to contribute significantly to risks
calculated for exposure scenarios involving that
medium, so that  the risk assessment is focused on
the "most  significant" chemicals.

     Calculate individual chemical scores. Two
of the most important factors when determining
the potential effect of including a chemical in the
risk assessment are its measured concentrations at
the site and its toxicity.   Therefore, in this
screening procedure, each chemical in a medium
is first scored  according to  its concentration and
toxicity  to obtain a risk factor (see the box below).
Separate scores  are calculated for each medium
being evaluated.
      INDIVIDUAL CHEMICAL SCORES
    R£  >* risk factor for chemical i in


    C|-  « concentration of sfeemiea! i ia
           medtoiB j; and

    T§-  - toodcily value for chemical i la
           medium j (i.e., either the slope
           footer or 1/IWD).

-------
Page 5-24
     The units for the risk factor R(j depend on
the medium being  screened. In general, the
absolute units do not matter, as long as units
among chemicals in a medium are the same. The
concentration used in the above equation should
be the maximum detected concentration, and
toxicity values should be obtained in accordance
with the procedures discussed in Chapter 7.

     Chemicals without toxicity values cannot be
screened using this procedure.  Such chemicals
should always  be discussed in  the risk assessment
as chemicals of potential concern;  they should not
be eliminated from the risk assessment. Guidance
concerning chemicals without toxicity values  is
provided in Chapter 7.

     For some  chemicals, both oral and inhalation
toxiciry values are available. In these cases, the
more conservative toxicity values (i.e., ones
yielding the larger risk factor when used in the
above equation) usually should be used. If only
one exposure route is likely for the medium being
evaluated, then the toxiciry values corresponding
to that exposure route should be  used.

     Calculate  total chemical scores (per medium).
Chemical-specific risk factors are summed to
obtain the total risk factor for all chemicals of
potential concern in a medium (see the box on
this page). A separate R, will be calculated for
carcinogenic and noncarcinogenic effects.  The
ratio of the risk factor for each chemical to the
total  risk  factor (i.e.,R^R,) approximates the
relative risk for each chemical in medium j.

     Eliminate chemicals.     After  carefully
considering the factors discussed previously in this
subsection, eliminate from the risk assessment
chemicals with R/Rj ratios that are very  low
compared with the ratios of other chemicals in the
medium. The RPM may wish to specify a limit
for this ratio (e.g., 0.01; a lower fraction would be
needed if site  risks are expected to be high). A
chemical that contributes less than the specified
fraction of the total risk factor for each medium
would not be considered further in the  risk
assessment for  that medium. Chemicals  exceeding
the limit would be considered likely to contribute
significantly to risks, as calculated in subsequent
         TOTAL CHEMICAL SCORES

     R; «  R# + R# + R^ -f .  . „ + R0

   where:

     Ry = total risk factor for medium j; and

     R;j +.,.-*• R,y = risk factors for
          chemicals 1 through i  in
          medium j.
stages of the risk assessment.   This screening
procedure could greatly reduce the number of
chemicals carried through a risk assessment,
because in many cases only a few chemicals
contribute significantly to the total risk for a
particular medium.

    The risk factors developed in this screening
procedure are to be used only for potential
reduction of the number of chemicals carried
through the risk assessment and have no meaning
outside of the context of the  screening  procedure.
They  should not be considered as a quantitative
measure of a chemical's toxicity or risk or as a
substitute for the risk assessment procedures
discussed in Chapters 6, 7, and 8 of this guidance.
5.10 SUMMARY AND
      PRESENTATION  OF DATA

     The section of the risk  assessment report
summarizing the results of the  data collection-and
evaluation should be titled "Identification of
Chemicals of Potential Concern"  (see Chapter 9).
Information in this section should be presented in
ways that readily support the calculation of
exposure    concentrations  in  the  exposure
assessment portion of the  risk assessment.
Exhibits 5-6 and 5-7 present examples of tables to
be included in this section of the risk assessment
report.

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                                                                                   Page 5-25
                                     EXHIBIT  5-6


               EXAMPLE  OF TABLE  FORMAT FOR PRESENTING
                  CHEMICALS  SAMPLED  IN  SPECIFIC  MEDIA
                                         Table X
                              Chemicals Sampled in Medium Y
                           (and in Operable Unit Z, if appropriate)
                                Name of Site, Location of Site
Chemical
Chemical A
* Chemical B
Frequency of
Detection"
3/25
25/25
Range
of Sample
Quantitation
Limits (units)
5-50
1-32
Range
of Detected
Concentrations
(units)
320-4600
16-72
Background
Levels
100-140

~ = Not available.

* Identified as a chemical of potential concern based on evaluation of data according to procedures
described in text of report.

"Number of samples in which the chemical was positively detected over the number of samples
available.

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Page 5-26
                             EXHIBIT 5-7

          EXAMPLE OF TABLE FORMAT FOR SUMMARIZING
               CHEMICALS OF POTENTIAL CONCERN IN
                         ALL MEDIA SAMPLED
                                Table W
                          Summary of chemicals of
                     Potential Concern at Site X, Location Y
                     (and in Operable Unit Z, if appropriate)
Concentration
Chemical
Chemical A
Chemical B
Chemical C
Chemical D
Soils
(mg/kg)
5-1,100
0.5-64
2-12
Ground Water
(ug/L)
5-92
15-890
Surface Water
(ug/L)
2-30
50-11,000
Sediments
(ug/kg)
100-45,000
Air 3
(ug/m3)
0.1-940
~ = Not available.

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                                                                                         Page 5-27
5.10.1 SUMMARIZE DATA COLLECTION
      AND EVALUATION RESULTS IN TEXT

     In the introduction for this section of the risk
assessment report, clearly discuss in bullet form
the steps involved in data evaluation.    If the
optional screening procedure described in Section
5.9 was used in determining chemicals  of potential
concern, these steps should be included in the
introduction. If both historical data and current
data were used in the data evaluation, state this
in the introduction.   Any special site-specific
considerations in collecting and evaluating the
data should be mentioned. General uncertainties
concerning the quality associated with either the
collection or the analysis of samples should be
discussed so that the potential effects  of these
uncertainties on later sections of the risk
assessment can be determined.

     In the next part of the report, discuss the
samples  from each medium selected for use in
quantitative risk assessment. Provide  information
concerning the sample collection methods used
(e.g., grab, composite) as well as the number and
location  of samples.    If this information is
provided in the RI report, simply refer to the
appropriate sections. If any samples  (e.g., field
screening/analytical samples) were excluded
specifically from  the quantitative  risk  assessment
prior to evaluating the data, document this along
with reasons for the exclusion. Again, remember
that such samples, while not used  in  the
quantitative risk assessment, may be useful for
qualitative discussions and therefore should not be
entirely excluded from the risk assessment.

     Discuss the data evacuation either by  medium,
by medium within each operable unit  (if the site
is sufficiently large to be divided into specific
operable  units), or by discrete areas within each
medium in an operable unit. For each medium,
if several source areas with different types and
concentrations of chemicals exist, then the
medium-specific  discussion for each source area
may be separate. Begin the discussion  with those
media (e.g., wastes, soils) that are potential
sources of contamination for other media (e.g.,
ground water, surface water/sediments). If no
samples or data were available for a particular
medium, discuss this in the text. For  soils data,
discuss surface soil results separately from those
of subsurface soils. Present ground-water results
 by aquifer if more than one aquifer was sampled.
 Discuss surface water/sediment results by the
 specific surface water body sampled.

     For each medium, identify in the report the
 chemicals for which samples were analyzed, and
 list the analytes that were detected in at least one
 sample. If any detected  chemicals were eliminated
 from the quantitative risk assessment based on
 evaluation of data  (i.e., based on evaluation of
 data quality, background  comparisons, and  the
 optional screening procedures, if used), provide
 reasons for the  elimination in the text (e.g.,
 chemical was detected  in blanks at similar
 concentrations to those detected in samples or
 chemical was  infrequently  detected).

     The  final  subsection of  the text is a
 discussion of general trends in the data results.
 For example,  the text may mention (1) whether
 concentrations of chemicals of potential concern
 in most media were close  to the detection limits
 or (2) trends concerning chemicals detected in
 more than  one medium  or in more than one
 operable unit at the  site. In addition, the location
 of hot spots should  be discussed,  as well as any
 noticeable trends apparent from sampling results
 at different times.

 5.10.2    SUMMARIZE DATA  COLLECTION
         AND EVALUATION RESULTS IN
         TABLES AND GRAPHICS

    As shown in Exhibit 5-6, a separate table that
 includes all  chemicals detected in a medium can
 be provided for each medium  sampled at a
 hazardous waste site or for each medium within
 an operable unit  at  a site. Chemicals  that have
 been determined to be of potential concern based
 on the  data evaluation should be designated in the
 table with an asterisk to the left of the chemical
 name.

    For each chemical, present the frequency of
 detection in  a certain medium (i.e., the number of
 times a chemical was detected over the total
 number of samples considered) and the range of
 detected or quantified values in the samples. Do
 not present the QL or similar  indicator of a
minimum level (e.g., <10 mg/L, ND) as the lower
end of the range; instead, the  lower and upper
bound  of the range  should be the minimum and
maximum detected values, respectively. The range

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Page 5-28
of reported QLs obtained for each chemical in
various samples should be provided in a separate
column. Note that these QLs should be sample-
specific;  CRQLs, MDLs, or other types of non-
sample-specific values should be provided only
when SQLS are not available. Note that the range
of QLs would not include any limit values (e.g.,
unusually high QLs) eliminated based on the
guidance in Section 5.3.    Finally, naturally
occurring concentrations of chemicals used in
comparing sample concentrations may be provided
in a separate column.   The source of these
naturally  occurring levels should be provided in a
footnote.  List the identity of the samples used in
determining concentrations presented in the table
in an appropriate footnote.

     The final table in this section is a list of the
chemicals of potential concern presented by
medium at the  site  or by medium within each
operable unit at the site. A sample table format
is presented in Exhibit 5-7.

     Another useful  type of presentation  of
chemical concentration data is the isopleth (not
shown).  This graphic characterizes the monitored
or modeled concentrations of chemicals at a site
and   illustrates  the    spatial  pattern of
contamination.

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                                                                                         Page 5-29

                              ENDNOTE FOR CHAPTER 5
1. Note that the values in this example are for illustration purposes only. Many CRQLs and CRDLs are in the process of being
lowered, and the RfDs and slope factors may have changed.

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Page 5-30

                                   REFERENCES FOR  CHAPTER 5
Environmental Protection Agency (EPA). 1984. Methods for Organic Chemical Analysis of Municipal and Industrial Wastewater (EPA
      600 Methods) as presented in 40 CFR Part 136, Guidelines Establishing Teat Procedures for the Analysis of Pollutants Under
      the Clean Water Act.

      •     Used to determine chemicals present in municipal and industrial wastewater as provided under the Clean Water Act.
           Analytical methods for priority pollutants, including sample preparation, reagents, calibration procedures, QA/QC analytical
           procedures, and calculation.

Environmental Protection Agency (EPA). 1986. Test Methods for Evaluating Solid Waste (SW-846} Phvsical/Chimcal Methods.
      Office of Solid Waste.

      •     Provides analytical procedures to test solid waste to determine if it is a hazardous waste as defined under RCRA. contains
           information for collecting solid waste samples and for determining reactivity, corrosivity, ignitability, composition of waste,
           and mobility of waste components.

Environmental Protection Agency  (EPA).  1987. Drinking Water, Proposed Substitution of Contaminants and Proposed List of
      Additional Substances Which May Require Regulation Under the Safe Drinking Water Act. 52 Fedetal Register 25720  (July 8,
      1987).

Environmental Protection Agency (EPA).  1988a. User's Guide to the  Contract Laboratory Program. Office of Emergency and
      Remedial Response.

      •     Provides requirements, and analytical procedures of the CLP protocols developed from technical caucus recommendations
           for both organic and inorganic analysis. Contains information on CLP objectives and orientation, CLP structure, description
           of analytical services, utilization of analytical services, auxiliary support services, and program quality assurance.

Environmental Protection Agency (EPA). 1988b. contract Laboratory Program Statement of Work for Inorganics Analysis Multi-
      media. Multi-concentration. Office of Emergency and Remedial Response. SOW No. 788.

      •     Provides procedures required by EPA for analyzing hazardous waste disposal site samples (aqueous and solid) for inorganic
           chemicals (25 elements plus cyanide).   Contains analytical, document control, and quality assurance/quality control
           procedures.

Environmental Protection Agency (EPA). 1988c. Contract Laboratory ProgramStatement of Work for Organics Analysis Multi-
      media. Multi-concentration. Office of Emergency and Remedial Response. SOW No. 288.

      •     Provides procedure required by EPA for analyzing aqueous  and solid hazardous waste samples for 126 volatile,  semi-
           volatile, pesticide, and PCB  chemicals. Contains  analytical, document control, and quality assurance/quality  control
           procedures.

Environmental Protection Agency (EPA). 1988d.  Laboratory Data Validation Functional Guidelines for Evaluating Inorganics Analysis.
      Office of Emergency and Remedial Response.

      •     Provides guidance in laboratory data evaluation and validation for hazardous waste site samples analyzed under the EPA
           CLP program. Aids in determining data problems and shortcomings and potential actions to be taken.

Environmental Protection Agency (EPA). 1988e. LaboratorvData Validation Functional Guidelines for Evaluating Organics Analysis
      (Functional Guidelines for Organics).  Office of Emergency and Remedial Response.

      •     Provides guidance in laboratory data evaluation and validation for hazardous waste site samples analyzed under the EPA
           CLP program. Aids in determining data problems and shortcomings and potential actions to be taken.

Environmental Protection Agency (EPA). 1988f Special Report on Ingested Inorganic Arsenic: Skin Cancer. Nutritional Essentiality.
      Risk Assessment  Forum. EPA 625/3-87/013.

      •     Technical report concerning the  health effects of exposure to ingested arsenic. Includes epidemiologic studies suitable for
           dose-response evaluation from Taiwan, Mexico, and Germany. Also includes discussions on pathological characteristics and
           significance of arsenic-induced skin lesions, genotoxicity of arsenic, metabolism and distribution, dose-response estimates
           for aresnic ingestion and arsenic as an essential nutrient.

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          CHAPTER 6
EXPOSURE  ASSESSMENT

/FROM: A
•Site discovery
• Preliminary
assessment
•Site inspection
\«NPL listing 	 /




Data
Collection

^-

Data
Evaluation
A
f
Toxicity
Assessment

Exposure
Assessment

i
F
Risk
Characterization
t
\
\
k



•Selection of
remedy
• Remedial
design
• Remedial
\^ action

           EXPOSURE ASSESSMENT

           Characterize physical setting

           Identify potentially exposed
           populations

           Identify potential exposure
           pathways

           Estimate exposure
           concentrations
          1 Estimate chemical intakes

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                                  CHAPTER  6
                    EXPOSURE  ASSESSMENT
    This chapter describes the procedures for
conducting an exposure assessment as part of the
baseline risk  assessment process at Superfund
sites. The objective of the exposure assessment  is
to estimate the type and magnitude of exposures
to the chemicals of potential concern that are
present at or migrating from a site. The results
of the exposure assessment are combined with
chemical-specific     toxicity    information  to
characterize  potential risks.

    The procedures and information presented
in this chapter represent some new approaches to
exposure assessment as well as a synthesis of
currently available exposure assessment guidance
and information published by EPA. Throughout
this  chapter,  relevant  exposure   assessment
documents are referenced as sources of more
detailed information supporting the exposure
assessment process.
6.1 BACKGROUND

    Exposure is defined as the contact of an
organism (humans in the case of health risk
assessment) with a chemical or physical agent
(EPA 1988a). The magnitude of exposure is
determined by measuring or estimating the
amount of an agent available at the exchange
boundaries (i.e., the lungs, gut, skin) during a
specified time period. Exposure assessment is  the
determination or estimation (qualitative  or
quantitative)  of the magnitude, frequency,
duration,  and  route of exposure.   Exposure
assessments may consider past, present, and future
exposures, using varying assessment  techniques  for
each phase. Estimates of current exposures can
be based on measurements or models of existing
conditions, those of future  exposures can be based
on models of future conditions, and those of past
exposures can be based on measured or modeled
past concentrations  or measured chemical
concentrations in tissues.  Generally, Superfund
exposure assessments are concerned with current
and future exposures.   If human monitoring is
planned to assess current or past exposures, the
Agency for Toxic Substances and Disease Registry
(ATSDR) should be consulted to take the lead in
conducting these studies and in assessing the
current health status of the people near the site
based on the monitoring results.

6.1.1    COMPONENTS OF AN
        EXPOSURE ASSESSMENT

    The general procedure for conducting an
exposure assessment is  illustrated in Exhibit 6-1.
This procedure is based on EPA's published
Guidelines for Exposure Assessment (EPA 1986a)
and on  other related  guidance (EPA 1988a,
1988b). It is an adaptation of the generalized
exposure assessment process to the particular
needs  of Superfund  site risk assessments.
Although some exposure assessment activities may
have been started earlier (e.g., during RI/FS
scoping or even before the RI/FS process began),
the detailed exposure assessment process begins
after the chemical data have been collected and
       ACRONYMS FOR CHAPTER 6

  ATSDR = Agency for Toxic Substances and Disease
          Registry
    BCF = Bioconcentration Factor
     GDI = Chronic Daily Intake
   CEAM = Center for Exposure Assessment Modeling
   NOAA = National Oceanographic and Atmospheric
          Administration
   NTGS = National Technical Guidance Studies
  OAQPS = Office of Air Quality Planning and
          Standards
    RME — Reasonable Maximum Exposure
     SDI = Subchronic Daily Intake
   SEAM « Superfund Exposure Assessment Manual
   USGS = U.S. Geological Survey

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Page 6-2
                                       DEFINITIONS FOR CHAPTER 6

     Absorbed Dose.  Tbe amount of a substance penetrating the exchange boundaries of an organism after contact  Absorbed
           dose is calculated from the intake and the absorption efficiency.  It usually is expressed at mass of a substance absorbed
           into the body per unit body weight per unit time (e.g., mg/kg-day).

     Administered Dose.  The  mass of a substance given to  an organism and In  contact with *n «K&*nge boundary 
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                                                                     Page 6-3
                     EXHIBIT  6-1

   THE  EXPOSURE ASSESSMENT PROCESS
      STEP1
Characterize Exposure
	Setting	


•  Physical Environment

•  Potentially Exposed
   Populations
                        STEP 3
                    Quantify Exposure
           Exposure
           Concentration
      STEP 2
  Identify Exposure
	Pathways


 • Chemical Source/
   Release

 • Exposure Point

 • Exposure Route
 Intake
 Variables
                       Pathway-
                       Specific
                       Exposure

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Page 6-4
      potential future populations that may differ
      under an alternate land use.

      Step 2 - Identification of exposure pathways
      (Section 6.3).   In this step, the exposure
      assessor identifies those pathways by which
      the  previously identified populations may be
      exposed. Each exposure pathway  describes
      a unique meehanism by which a population
      may be exposed to the chemicals at or
      originating from the  site. Exposure pathways
      are  identified based on consideration of the
      sources, releases, types, and  locations of
      chemicals at the  site; the likely environmental
      fate (including persistence,  partitioning,
      transport, and intermedia transfer) of these
      chemicals; and the location and activities of
      the    potentially exposed    populations.
      Exposure points (points of potential contact
      with the chemical) and routes of exposure
      (e.g., ingestion, inhalation) are identified for
      each exposure pathway.

      Step 3 - Quantification of exposure (Section
      6.4). In this step, the assessor quantifies the
      magnitude,  frequency  and   duration of
      exposure for each pathway identified in Step
      2. This step is most often conducted in  two
      stages: estimation of exposure concentrations
      and calculation of intakes.

      Estimation   of exposure  concentrations
      (Section 6.5V   In this part of step 3,  the
      exposure   assessor    determines     the
      concentration of chemicals  that will be
      contacted   over  the  exposure   period.
      Exposure concentrations are estimated using
      monitoring data and/or chemical transport
      and environmental fate models.  Modeling
      may be used to estimate future chemical
      concentrations in media that are currently
      contaminated  or   that   may   become
      contaminated, and current concentrations in
      media and/or at locations for which there are
      no monitoring data.

      Calculation of intakes (Section 6.6V In this
      part of step 3,  the  exposure assessor
      calculates chemical-specific exposures for each
      exposure pathway  identified in Step 2.
      Exposure estimates are expressed in terms
      of the mass of substance in contact with the
      body per unit body weight per unit time (e.g.,
     mg chemical per kg body weight per day, also
     expressed as mg/kg-day). These exposure
     estimates are termed "intakes"  (for the
     purposes of this manual) and represent the
     normalized exposure rate.   Several terms
     common in  other EPA  documents and the
     literature are equivalent or related to intake
     (see box on this page and definitions box on
     page 6-2). Chemical intakes are calculated
     using equations  that include variables for
     exposure concentration, contact rate, exposure
     frequency, exposure duration, body weight,
     and exposure averaging time. The values of
     some of these variables depend on site
     conditions and the characteristics of the
     potentially exposed population.
          TERMS EQUIVALENT OR
            RELATED TO INTAKE

   Normalized Exposure Rate. Equivalent to intake

   Administered Dose. Equivalent to intake ,

   Applied Dose.  Equivalent to intake

   Absorbed Dose. Equivalent to intake multiplied by
   an absorption factor
     After intakes have been estimated, they are
organized by population, as appropriate (Section
6.7).   Then, the sources of uncertainty (e.g.,
variability in analytical data, modeling results,
parameter assumptions)  and their effect on the
exposure estimates  are evaluated and summarized
(Section 6.8). This information on uncertainty is
important to site  decision-makers  who must
evaluate the results of the exposure and risk
assessment and make decisions regarding the
degree of remediation required at a site. The
exposure assessment concludes with a summary of
the estimated intakes for each pathway evaluated
(Section 6.9).

6.1.2     REASONABLE  MAXIMUM EXPOSURE

     Actions  at Superfund sites  should be based
on  an estimate of the reasonable  maximum
exposure (RME) expected to occur under both
current and  future  land-use conditions.  The
reasonable maximum exposure is defined here as

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                                                                                        Page 6-5
the highest exposure that is reasonably expected
to occur at  a  site. RMEs are  estimated for
individual pathways.  If a population is exposed
via more than one pathway, the combination of
exposures across pathways also must represent an
RME.

     Estimates  of the  reasonable  maximum
exposure   necessarily    involve   the  use  of
professional judgment. This chapter provides
guidance for  determining the RME at a site and
identifies   some  exposure variable values
appropriate for use in this determination. The
specific values  identified should be regarded as
general recommendations, and could change based
on site-specific information and the particular
needs of the EPA remedial project manager
(RPM).  Therefore, these recommendations should
be used in conjunction with input from the RPM
responsible for the site.

     In  the  past,  exposures generally were
estimated for an average and an upper-bound
exposure case, instead of a single exposure case
(for both current and future  land use) as
recommended here. The advantage of the two
case approach  is  that the resulting range of
exposures provides  some measure  of the
uncertainty surrounding these estimates. The
disadvantage  of this approach is that the upper-
bound estimate  of exposure may be above the
range of possible exposures, whereas the average
estimate is lower than exposures potentially
experienced  by much  of the population. The
intent of the RME is to estimate a conservative
exposure case (i.e., well above the average case)
that is still within the range of possible exposures.
Uncertainty is still evaluated under this approach.
However, instead of combining many sources of
uncertainty  into  average and  upper-bound
exposure estimates, the variation in individual
exposure variables  is used to evaluate  uncertainty
(See Section  6.8).   In this way, the variables
contributing most to uncertainty in the exposure
estimate are more easily identified.
 6.2     STEP 1: CHARACTERI-
         ZATION OF EXPOSURE
         SETTING

     The first step in evaluating  exposure at
 Superfund sites is to  characterize the site with
 respect to its physical characteristics as well as
 those of the human populations on and near the
 site. The output of this  step is a qualitative
 evaluation of the site and surrounding populations
 with respect to those characteristics that influence
 exposure. All information gathered during this
 step will support the identification of exposure
 pathways in Step 2. In addition, the information
 on the potentially exposed populations will be
 used in Step 3 to determine the values of some
 intake variables.

 6.2.1     CHARACTERIZE PHYSICAL
         SETTING

    Characterize the exposure setting with respect
 to the general physical characteristics of the site.
 Important  site characteristics include the
 following:

    •   climate   (e.g.,   temperature,
        precipitation);

    •   meteorology (e.g., wind speed  and
        direction);

    •   geologic setting (e.g., location  and
        characterization of underlying strata);

    •   vegetation (e.g., unvegetated, forested,
        grassy);

    •   soil type (e.g., sandy, organic, acid,
        basic);

    •   ground-water hydrology (e.g., depth,
        direction and type of flow); and

    •   location and description of surface water
        (e.g., type, flow rates, salinity).

    Sources of this information include site
descriptions and data from  the preliminary
assessment (PA), site inspection (SI), and remedial
investigation (RI) reports. Other sources include
county  soil surveys, wetlands maps, aerial

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 Page 6-6
photographs,  and  reports  by  the National
Oceanographic   and Atmospheric Association
(NOAA) and the U.S. Geological Survey (USGS).
The assessor also should consult with appropriate
technical experts  (e.g.,  hydrogeologists, air
modelers) as needed to characterize the site.

6.2.2     CHARACTERIZE POTENTIALLY
         EXPOSED POPULATIONS

     Characterize the populations on or near the
site with respect to location relative to the site,
activity patterns, and the presence of sensitive
subgroups.

     Determine location of current populations
relative to the site. Determine the distance and
direction of potentially exposed populations from
the site.   Identify those populations that are
closest to or actually living on the site and that,
therefore, may have the  greatest potential for
exposure. Be sure to include potentially exposed
distant populations, such as public water supply
consumers  and distant consumers of fish or
shellfish or agricultural products from the site
area. Also  include populations that could  be
exposed in the future to chemicals that have
migrated from the site.  Potential sources of this
information  include:

     •   site visit;

     •   other information gathered as part of
         the SI or during the initial stages of the
         RI

     •   population surveys conducted near the
         site;

     •   topographic, land use, housing or other
         maps; and

     •   recreational and commercial fisheries
         data.

     Determine current land use. Characterize
the activities   and activity  patterns  of the
potentially exposed population.  The following
land use categories  will be applicable most often
at Superfund sites:

     •   residential;
     •   commercial/industrial;  and
     •    recreational.

     Determine the current land use or uses of
the site and surrounding area. The best source
of this information is a site visit.   Look for
homes, playgrounds, parks, businesses,  industries,
or other land uses on or in the vicinity of the site.
Other sources on local land use include

     •    zoning maps;

     •    state or local zoning or other land use-
         related laws and regulations;

     •    data from the U.S.  Bureau of the
         Census;

     •    topographic, land use, housing or other
         maps  and

     •    aerial  photographs.

     Some land uses at a site may  not fit neatly
into one of the three land use categories and
other land use classifications  may be more
appropriate (e.g., agricultural land use). At some
sites it may be most appropriate to have  more
than one land use category.

     After defining the land use(s) for a site,
identify human activities and activity patterns
associated with each land use. This is basically
a "common sense" evaluation and is not based on
any specific data sources, but rather on a general
understanding of what activities  occur in
residential, business, or recreational areas.

     Characterize activity patterns  by doing the
following.

     •    Determine the percent of time that the
         potentially exposed population(s) spend
         in the potentially contaminated  area.
         For  example, if the potentially exposed
         population is commercial  or industrial,
         a reasonable maximum daily exposure
         period is likely to  be 8 hours (a typical
         work day). Conversely,  if the population
         is residential, a maximum daily exposure
         period of 24 hours is possible.

     •    Determine if activities occur primarily
         indoors, outdoors, or both.  For example,

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                                                                                            Page 6-7
         office workers may spend all their time
         indoors, whereas construction workers
         may spend all their time outdoors.

     •   Determine how activities change with
         the seasons.     For example, some
         outdoor,   summertime    recreational
         activities (e.g., swimming, fishing) will
         occur less frequently or not at all during
         the winter months. Similarly, children
         are likely to play outdoors leas frequently
         and with more clothing during the winter
         months.

     •   Determine if the site itself may be used
         by local populations, particularly if access
         to the site is not restricted or otherwise
         limited  (e.g., by distance).  For example,
         children living in the area could play
         onsite, and local residents could hunt or
         hike onsite.

     •   Identify any  site-specific population
         characteristics that  might influence
         exposure. For example,  if the site is
         located near major commercial  or
         recreational fisheries or shellfisheries,
         the potentially exposed population is
         likely to eat more locally-caught fish and
         shellfish than populations located inland.

     Determine future land use. Determine if any
activities associated with a current land use  are
likely to be different under an alternate future
land use. For example, if ground water is not
currently used in the area of the site as a source
of drinking water but is of potable quality, future
use of ground water as drinking water would be
possible.   Also determine if land use of the site
itself could change in the future.  For example, if
a  site is  currently classified  as industrial,
determine  if it could  possibly be  used for
residential or recreational purposes in the future.

     Because residential land use is most often
associated with the greatest exposures, it is
generally the most conservative choice to make
when deciding what type of alternate land use
may occur  in the future. However, an assumption
of  future  residential  land use may not  be
justifiable if the probability that the site will
support residential use in the future is exceedingly
small.
     Therefore, determine possible alternate future
land uses baaed on available information and
professional judgment.     Evaluate pertinent
information  sources, including (as available):

     •   master plans (city or county projections
         of future land use);

     •   Bureau of the Census projections; and

     •   established land use trends  in the general
         area   and   the  area    immediately
         surrounding  the site (use Census Bureau
         or state or local reports, or use general
         historical  accounts of the  area).

Note that while these sources provide potentially
useful information, they should not be interpreted
as providing proof that a certain land use will or
will not occur.

     Assume  future residential land use if it  seems
possible based on the evaluation of the available
information.  For example, if the site is currently
industrial but is located near residential areas in
an urban area, future residential land use may be
a reasonable possibility. If the site is industrial
and is located in a very rural area with a low
population density and  projected  low growth,
future residential use would probably be  unlikely.
In this case, a more likely alternate future land
use may be recreational. At some sites, it may be
most reasonable to  assume that the  land use will
not change in the future.

     There are no hard-and-fast rules by which to
determine alternate future land use. The use of
professional judgment in this step is critical.  Be
sure to consult with the RPM about any decision
regarding alternate future land use. Support  the
selection of any alternate land use with a logical,
reasonable  argument in the exposure assessment
chapter  of the risk assessment report.   Also
include a qualitative statement of the likelihood
of the future  land use occurring.

     Identify  subpopulations of potential concern.
Review information on the site area to determine
if any subpopulations may  be at increased risk
from chemical  exposures  due to  increased
sensitivity, behavior patterns that may result in
high exposure, and/or current or past exposures
from other sources. Subpopulations that may be

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more sensitive to  chemical exposures include
infants and children, elderly people, pregnant and
nursing women, and people with chronic illnesses.
Those potentially at higher risk due to behavior
patterns include children, who are more likely to
contact soil, and persons who may eat large
amounts of locally caught fish or locally grown
produce  (e.g.,  home-grown  vegetables).
Subpopulations at higher risk due to exposures
from other sources include individuals exposed to
chemicals during  occupational activities and
individuals  living in industrial areas.

    To identify Subpopulations of potential
concern in the site area, determine locations of
schools, day care centers, hospitals,  nursing homes,
retirement  communities, residential areas with
children, important commercial or recreational
fisheries near the site, and major industries
potentially involving chemical exposures. Use
local census data and information from local
public health officials for this determination.
6.3      STEP 2: IDENTIFICATION
         OF EXPOSURE PATHWAYS

    This section  describes  an approach for
identifying potential human exposure pathways at
a Superfund  site. An exposure pathway describes
the course a chemical or physical agent takes from
the source to the exposed individual. An exposure
pathway analysis links the sources,  locations, and
types  of environmental releases with population
locations and activity patterns to determine the
significant pathways of human exposure.

    An exposure pathway generally consists of
four elements: (1)  a source and mechanism of
chemical release,  (2) a retention or transport
medium (or media in cases  involving media
transfer of chemicals), (3) a point of potential
human contact with the contaminated medium
(referred to  as the exposure point),  and (4) an
exposure route (e.g., ingestion) at the contact
point. A  medium contaminated as a result of a
past release can be a contaminant source for other
media (e.g.,  soil contaminated from a previous
spill could be a contaminant source  for ground
water  or surface water).  In some cases, the source
itself (i.e., a tank, contaminated soil) is the
exposure point, without a release to any other
medium.    In these latter cases, an exposure
pathway consists of (1) a source, (2) an exposure
point, and (3) an exposure route. Exhibit 6-2
illustrates the basic elements of each type of
exposure pathway.

    The following sections  describe the basic
analytical process  for identifying exposure
pathways  at  Superfund  sites  and for selecting
pathways for quantitative analysis. The pathway
analysis described below is meant to be a
qualitative evaluation  of pertinent site and
chemical  information,   and  not a  rigorous
quantitative evaluation of factors such as source
strength, release rates, and chemical fate and
transport.  Such factors are considered  later in
the exposure assessment during the quantitative
determination of exposure concentrations  (Section
6.5).

6.3.1    IDENTIFY SOURCES AND
        RECEIVNG MEDIA

    To  determine possible release sources for a
site in the absence of remedial action, use all
available site descriptions and data from the PA,
SI, and RI reports.   Identify potential release
mechanisms and receiving media for past, current,
and future  releases. Exhibit  6-3 lists some typical
release sources, release  mechanisms, and receiving
media at Superfund sites. Use monitoring data in
conjunction with  information on source locations
to support the analysis of past, continuing,  or
threatened releases.      For  example, soil
contamination near an old tank would suggest the
tank  (source)  ruptured  or  leaked  (release
mechanism) to the ground (receiving media). Be
sure to note any source that could be an exposure
point in addition to a release source (e.g., open
barrels or  tanks,  surface waste piles or lagoons,
contaminated  soil).

    Map  the suspected source areas and the
extent of contamination using the available
information and monitoring data. As an aid in
evaluating  air sources and releases, Volumes I and
II of the National Technical Guidance  Studies
(NTGS;  EPA 1989a,b) should be consulted.

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                                                                                          Page 6-9
                                          EXHIBIT  6-2

                             ILLUSTRATION OF EXPOSURE
                                          PATHWAYS
                                          Prevailing Wind Direction
Exposure
   Point
                                                                 Transport
                                                                 Medium (Air)
                                                                       Release Mechanism
                                                                       (Volatilization)
                                                   Release
                                                 Mechanism
                                                     (Spill)
         Ground-WaterFlow   ...—-—
                                                                                 	Release Mechanism
                                                                                  ) (Site Leaching)
                                                                         Transport Medium
                                                                         (Ground Water)

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Page 6-10
                                          EXHIBIT 6-3

                 COMMON CHEMICAL RELEASE SOURCES AT
               SITES IN THE ABSENCE OF REMEDIAL ACTION
                 Receiving
                 Medium
Release
Mechanism
Release Source
                Air
                 Surface water
                 Ground water
Volatilization
Fugitive dust
generation


Surface runoff

Episodic overland


Ground-water
seepage


Leaching
Surface wastes ~ lagoons,
 ponds, pits, spills
Contaminated surface water
Contaminated surface soil
Contaminated wetlands
Leaking drums

Contaminated surface soil
Waste piles
Contaminated surface soil

Lagoon overflow
Spflls, leaking containers

Contaminated ground water
Surface or buried wastes
Contaminated soil
                 Soil
                 Sediment
                 Biota
Leaching

Surface runoff

Episodic overland
flow

Fugitive dust
generation
deposition

Tracking
Surface runoff,
Episodic overland
flow

Ground-water
seepage

Leaching
Uptake
(direct contact,
ingestion, inhalation)
Surface or buried wastes

Contaminated surface soil

Lagoon overflow
Spflls, leaking containers

Contaminated surface soil
Waste piles


Contaminated surface soil
Surface wastes — lagoons,
 ponds, pits, spills
Contaminated surface soil

Contaminated ground water
Surface or buried wastes
Contaminated soil

Contaminated soil, surface
 water, sediment, ground
 water or air
Other biota

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                                                                                        Page 6-11
6.3.2     EVALUATE FATE AND TRANSPORT
         IN RELEASE MEDIA

    Evaluate the fate and transport of the
chemicals to predict future exposures and to help
link sources with currently contaminated media.
The fate and transport analysis conducted at this
stage of the exposure assessment is not meant to
result  in a quantitative evaluation of media-
specific chemical concentrations.   Rather, the
intent is to identify media that are receiving or
may receive site-related chemicals. At this stage,
the assessor should answer the questions: What
chemicals occur in the  sources at the site and in
the environment?  In what media (onsite  and
offsite) do they occur now? In what media and
at what location may they occur in the future?
Screening-level analyses using available  data and
simplified calculations or analytical models may
assist in this qualitative evaluation.

    After  a  chemical   is  released  to  the
environment it may be:

    •   transported (e.g., converted downstream
        in water or  on suspended sediment or
        through the  atmosphere);

    •   physically transformed (e.g., volatilization,
        precipitation);

    •   chemically transformed (e.g., photolysis,
        hydrolysis, oxidation, reduction, etc.);

    •   biologically    transformed    (e.g,
        biodegradation);  and/or

    •   accumulated in  one or more media
         (including the receiving medium).

    To determine the fate of the chemicals of
potential concern at a particular site, obtain
information on their  physical/chemical and
environmental fate properties. Use computer data
bases  (e.g.,  SRC's  Environmental Fate
CHEMFATE, and BIODEG data bases; BIOSIS;
AQUIRE) and the open literature as necessary
as sources for up-to-date information on the
physical/chemical and fate properties of the
chemicals of potential concern. Exhibit  6-4 lists
some important  chemical-specific fate parameters
and briefly describes how these can be used to
evaluate a chemical's  environmental fate.
     Also consider site-specific characteristics
(identified in Section 6.2.1) that may influence
fate and transport.     For  example, soil
characteristics such as moisture  content, organic
carbon content, and cation exchange capacity can
greatly  influence the movement of many chemicals.
A high water table may increase the probability of
leaching of chemicals in soil to ground water.

     Use all applicable chemical  and site-specific
information to evaluate transport within and
between media and retention or accumulation
within  a single medium. Use monitoring data to
identify media that are contaminated now and the
fate pathway analysis to identify media that may
be contaminated now (for media not sampled) or
in the  future.     Exhibit 6-5  presents  some
important questions to consider when developing
these pathways. Exhibit 6-6 presents a series of
flow charts useful  when evaluating the fate and
transport of chemicals at a site.

6.3.3     IDENTIFY EXPOSURE POINTS AND
         EXPOSURE ROUTES

     After   contaminated or   potentially
contaminated media have been identified, identify
exposure points by determining if and where any
of the potentially exposed populations (identified
in Step 1) can contact these media. Consider
population locations and activity patterns  in the
area, including those of subgroups that may be of
particular concern. Any point of potential contact
with a contaminated medium is an exposure  point.
Try to  identify those exposure points where the
concentration that will be contacted is the
greatest.    Therefore, consider including any
contaminated media or sources onsite as a
potential exposure point if the site is currently
used, if access to the site  under current conditions
is not restricted or otherwise limited (e.g., by
distance), or if contact is possible under an
alternate future land use. For potential offsite
exposures, the highest exposure concentrations
often will be  at  the points closest  to and
downgradient or downwind of the site. In some
cases, highest concentrations may be encountered
at points distant from the site. For example, site-
related chemicals may be transported and
deposited in a distant water body  where they may
be subsequently  bioconcentrated by aquatic
organisms.

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Page 6-12
                                              EXHIBIT 6-4

                      IMPORTANT  PHYSICAL/CHEMICAL AND
                        ENVIRONMENTAL  FATE  PARAMETERS
      Koc      provides a measure of the extent of chemical partitioning between organic carbon and water at
               equilibrium. The higher the K, the more likely a chemical is to bind to soil or sediment than to
               remain in water.

      Kd       provides a soil or sediment-specific measure  of the extent of chemical partitioning between soil
               or  sediment and  water,  unadjusted for dependence  upon organic  carbon. To  adjust  for  the
               fraction  of organic carbon  present  in soil  or sediment  (foc) use Kd= Kocxf,c. The higher the Kd,
               the more likely a chemical is to bind to soil or sediment than to remain in water.


      Kow      provides a measure  of the extent of  chemical  partitioning  between  water and  octanol  at
               equilibrium.  The  greater  the  Kowthe  more likely  a chemical is to partition to octanol  than  to
               remain in water. Octanol  is used as a surrogate for lipids (fat), and Kow,  can be used to predict
               bioconcentration  in  aquatic organisms.


      Solubility is  an upper limit on a chemical's  dissolved concentration in water  at a  specified temperature.
               Aqueous  concentrations  in excess of  volubility  may  indicate  sorption onto sediments,  the
               presence of solubilizing  chemicals  such as solvents,  or the  presence  of a non-aqueous phase
               liquid.


      Henry's Law Constant provides a measure of the  extent of chemical partitioning between air and water at
               equilibrium. The higher the Henry's Law constant, the more likely  a chemical is to volatilize
               than  to remain  in the water.


      Vapor Pressure is the pressure exerted by a chemical vapor in equilibrium with its  solid  or  liquid  form at
               any given temperature. It is used to  calculate the rate of volatilization of a pure  substance from a
               surface or in  estimating  a Henry's  Law constant for  chemicals  with low water  solubility.  The
               higher the vapor pressure, the more likely  a  chemical is to exist in  a gaseous state.


      Diffusivity describes the movement of a molecule  in a liquid or gas medium as a result of differences in
               concentration. It is  used  to  calculate  the  dispersive component of  chemical  transport.  The
               higher the  diffusivity, the  more likely  a  chemical is  to  move in response  to  concentration
               gradients.

      Bioconcentration Factor (BCF)  provides  a measure of the extent of chemical  partitioning at equilibrium
               between a  biological medium such as  fish tissue or plant tissue and an external medium  such as
               water. The  higher the BCF, the greater  the  accumulation in  living tissue is likely to be.

      Media-specific  Half-life provides a  relative measure of the persistence of a chemical in  a given medium,
               although actual  values can vary greatly  depending on site-specific conditions. The  greater the
               half-life, the more persistent a chemical  is likely to be.

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                                                                               Page 6-13
                            EXHIBIT  6-5

IMPORTANT CONSIDERATIONS FOR  DETERMINING
    THE ENVIRONMENTAL FATE AND TRANSPORT
   OF THE CHEMICALS OF POTENTIAL  CONCERN
                    AT A SUPERFUND SITE
  What are the principal mechanisms for change or removal in each of the environmental
    media?
   How does the chemical behave in air, water, soil, and biological media? Does it
    bioaccumulate or biodegrade? Is it absorbed or taken up by plants?
  Does the agent react with other compounds in the environment?
  , Is there intermedia transfer? What are the mechanisms for intermedia transfer? What
    are the rates of the intermedia transfer or reaction mechanism?
  , How long might the chemical remain in each environmental medium? How does its
    concentration change with time in each medium?
 , What are the products into which the agent might degrade or change in the environment?
    Are these products potentially of concern?
  Is a steady-state concentration distribution in the environment or in specific segments of
    the environment achieved?

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Page  6-14
                                                 EXHIBIT 6-6

                                           FLOW CHART FOR
                            FATE AND TRANSPORT ASSESSMENTS
         Environmental fate and transport assessment atmosphere
                                             Contaminant Release
*
Potential
Volatilization of
Contaminants
from Site
*
Consider Direction
and Rate of
Contaminant
Migration within
Air, Major
Mechanisms: Wind
Currents,

i *






*
Potential Release of
Fugitive Dust/
Contaminated
Particles from Site
*
Consider Direction and
Distance of Paniculate
Movement with Wind
Currents; Major
Mechanisms: Wind Speed
Particle Size, Gravitations
Settling, Precipitation

"



i
il


                     Consider
                   Contaminant
                    Transfer to
                  Ground Water;
                   Assess Fate in
                   this Medium
                                         Coals!
                                      Contaminants
                                     Potentially Reach
                                      Agricultural,
                                       Hunting or
                                      Fishing Areas?
                                     No
                                               Yes
Consider Transfer
of Contaminants to
Plants or Animals
Consumed by Ha.
mans; Assess Fate
  in these Media
                       Determine
                       Probable
                     Boundaries of
                       Elevated
                     Concentrations
   Identify
  Populations
Directly Exposed
 to Atmospheric
 Contaminants
Consider Transfer
 of Contaminants
to Surface Water;
 Assess Fate in
  this Medium
           Source: Adapted from EPA 1988b.
                                             (continued)

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                                                                             Page 6-15
                        EXHIBIT 6-6  (continued)

                          FLOW CHART FOR
              FATE AND TRANSPORT ASSESSMENTS

Environmental fate and transport assessment: surface water and sediment
                               Contaminant Release

                                     1
                            Release to Surface Water



1





t




r~













Consider Direction and Rate of Contaminant
Migration Within Waterbody
Assess Distance Downstream, or Areas of Lakes and Estuaries

Major Mechanisms: Currents in Affected Rivers or Streams;
Dispersion in Impoundments; Tidal Currents and Flushing in
Estuaries; Partitioning to Sediment

*

Estimate Surface Water Contaminant Concentrations

Major Factors: Source Release Strength, Dilution Volume

,
t
Could Exchange
of Water
Between Surface
Water and
Ground Water
be Significant?


*
No 1








Could Water be
Used for Irriga-
tion or Watering
Livestock, or
Does Waterbody
Support
Commercial or
Sport Fish
Population?





* + *
a
H H
* i
Consider
Transferor
Contaminants
to Ground
Water; Assess
Fate in this
Medium







Consider
Transfer of
Contaminants to
Plants or
Animals
Consumed by
Humans; Assess
Fate In these
Media

|






Is Contaminant
Volatile?























* *

No j Yes I









Estimate
Concentrations
in Sediment


Consider
Sediment as a
Source of 4
Surface Water
Contaminants








t
Identify Human
Populations
Directly
Exposed to
Surface
Water


Consider
Transfer of
Contaminants
to Air;
Assess Fate
in this Medium


















Identify Human
Populations
Directly
Exposed to
Sediment


 Source: Adapted from EPA 1988k
                               (continued)

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Page 6-16
                                        EXHIBIT  6-6  (continued)

                                           FLOW CHART FOR
                            FATE AND TRANSPORT ASSESSMENTS
        Environmental fate and transport assessment: soils and ground water
                                         Contaminant Release
                                                1
                                                              Release to Soils at or
                                                              Surrounding the Site
                                             Consider Rate of Contaminant Percolation Through Unsatnrated
                                            Soils Based on Soil Permeabilities, Water or Liquid Recharge Rates
                 Release to Ground
                Water Beneath Site
                              Could
                           Contaminants
                            Potentially
                           Reach Ground
                             Water?
            Consider Direction and Rate or
              Ground Water Flow Using
            Available Hydrogeologic Data,
            or by Assuming These Will Ap-
            proximate Surface Topography
                                           _L
                          No
                                    _L
                                    Yes
Does
Contaminated
Soil Support
Edible Species?
t
No

Are Contaminants Vola-
tile? Are Contaminants
in Fine Particle Form or
Sorbed to Particulates?
t
H

No 1
1

Yes

 No II Yes
                             Yes
                                           No
                                                      Yes
     Consider
    Transfer of
   Contaminants
    to Surface
   Water; Assess
    Fate in this
     Medium
                              Is Well Water Used for
                             Irrigation or for Watering
                             Livestock, or Could it be?
  Identify
  Human
Populations
  Directly
Exposed to
Well Water
                                            Yes
Consider Transfer of Contami-
  nants to Plants or Animals
   Consumed by Humans;
  Assess Fate in these Media
Could Contaminants
Reach A Surface
Waterbody?
r-^-ir-1-! .
Could Contaminants
Reach Any Wells
Located
Bo-,vn gradient?
* t
Is Plume Sufficiently Near
Ground Surface to Allow
Direct Uptake of Contami-
nated Ground Water by
Plants or Animals?
Consider Transfer of
  Contaminants to
Atmosphere: Assess
Fate in this Medium
 Identify Human
  Populations
Directly Exposed
    to Soils
  Source: Adapted from EPA 1988b.

-------
     After determining exposure points, identify
probable   exposure   routes   (i.e.,   ingestion,
inhalation,  dermal contact) based on the media
contaminated and the anticipated activities at the
exposure points. In some instances, an exposure
point may  exist but an exposure route may not
(e.g., a person touches contaminated soil but is
wearing  gloves).    Exhibit  6-7  presents a
population/exposure route matrix that can be used
in determining potential exposure routes at a site.

6.3.4     INTEGRATE  INFORMATION  ON
         SOURCES, RELEASES, FATE AND
         TRANSPORT, EXPOSURE POINTS,
         AND EXPOSURE ROUTES INTO
         EXPOSURE PATHWAYS

     Assemble the information developed in the
previous three steps and determine the complete
exposure pathways that  exist for the site. A
pathway is complete if there is (1) a source or
chemical release from a source, (2) an exposure
point  where contact  can occur, and (3) an
exposure route by which contact can occur.
Otherwise, the pathway  is incomplete, such as the
situation where  there is a source releasing to air
but there are no nearby people.  If available from
ATSDR, human monitoring  data  indicating
chemical accumulation or chemical-related effects
in the site area can be used as evidence to
support  conclusions about which exposure
pathways are complete; however, negative data
from such studies should not be used to conclude
that a pathway is incomplete.

     From all complete exposure pathways at a
site, select those pathways  that will be evaluated
further in the exposure assessment. If exposure
to a sensitive subpopulation is possible, select that
pathway for quantitative evaluation. All pathways
should be selected for further evaluation unless
there is sound justification (e.g., based on the
results of a screening analysis) to eliminate a
pathway from   detailed analysis.     Such a
justification  could be based on one of the
following:

     •    the exposure resulting from the pathway
         is much less  than that from another
         pathway involving the same medium at
         the same exposure point;
                                     Page 6-17

     •   the potential magnitude of exposure
         from a pathway is low or

     •   the probability of the exposure occurring
         is very low and the risks associated with
         the  occurrence are  not  high (if a
         pathway has catastrophic consequences,
         it should be selected for evaluation even
         if its probability of occurrence is very
         low).

     Use professional judgment and experience to
 make these decisions. Before deciding to exclude
 a pathway from quantitative analysis, consult with
 the RPM. If a pathway is excluded from further
 analysis, clearly  document the reasons for the
 decision in the exposure assessment section of the
 risk assessment report.

     For some complete pathways it may not be
 possible to quantify exposures in the subsequent
 steps of the analysis because of a lack of data on
 which to  base estimates of chemical release,
 environmental concentration, or human intake.
 Available modeling results should complement and
 supplement the available monitoring data to
 minimize such problems. However, uncertainties
 associated with the modeling results may be too
 large to justify quantitative exposure assessment
 in the absence of monitoring data to validate the
 modeling results.     These pathways should
 nevertheless be carried through  the exposure
 assessment so that risks  can be  qualitatively
 evaluated  or so that this information can be
 considered during the uncertainty analysis of the
 results of the exposure assessment (see Section
 6.8) and the risk assessment (see Chapter 8).

 6.3.5    SUMMARIZE INFORMATION ON
        ALL  COMPLETE  EXPOSURE
        PATHWAYS

     Summarize pertinent information on all
 complete exposure pathways at the  site by
 identifying potentially exposed  populations,
 exposure media, exposure  points,  and exposure
 routes.    Also note  if the pathway has  been
 selected for quantitative evaluation; summarize the
justification if a pathway has been excluded.
 Summarize  pathways for current land use and any
 alternate  future  land use separately.  This
 summary information is useful for defining the
 scope of the next step (quantification of exposure)

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Page 6-18
                                          EXHIBIT 6-7

                   MATRIX OF POTENTIAL EXPOSURE ROUTES
Exposure Medium/ Residential
Exposure Route Population
Ground Water
Ingestion
Dermal Contact
Surface Water
Ingestion
Dermal Contact
Sediment
Incidental Ingestion
Dermal Contact
Ajr
Inhalation of Vapor
Phase Chemicals
Indoors
outdoors
Inhalation of
Particulate
Indoors
Outdoors
Soil/Dust
Incidental Ingestion
Dermal Contact
Ingestion
Fish and Shellfish
Meat and Game
Dairy
Eggs
Vegetables

L
L

L
L

C
C



L
L


L
L

L, C
L,C

L
L
L,C
L
L
Commercial/Industrial
Population

A
A

A
A

A
A



A
A


A
A

A
A

—
—
—


Recreational
Population


—

L,C
L,C

C
L,C



—
L


—
L

L,C
L,C

L
L
L
L
L
                       L — lifetime exposure
                       C = exposure in children may be significantly greater than in adults
                       A - exposure to adults (highest exposure is likely to occur during occupational activities)
                       	Exposure of this population via this route is not likely to occur.

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                                                                                       Page 6-19
and also  is useful as documentation of the
exposure pathway analysis. Exhibit 6-8 provides
a sample format for presenting this information.
6.4      STEP 3: QUANTIFICATION
         OF EXPOSURE GENERAL
         CONSIDERATIONS

    The next step in  the exposure assessment
process is to quantify the magnitude, frequency
and duration of exposure for the populations and
exposure pathways selected for quantitative
evaluation. This step is most often conducted in
two stages: first, exposure concentrations are
estimated, then, pathway-specific intakes are
quantified.    The specific methodology for
calculating exposure concentrations and pathway-
specific exposures are  presented in Sections 6.5
and 6.6, respectively. This section describes some
of the basic concepts behind these processes.

6.4.1    QUANTIFYING THE REASONABLE
         MAXIMUM EXPOSURE

    Exposure is defined as the contact of an
organism with a chemical or physical agent. If
exposure occurs over time, the total exposure can
be divided by a time period  of interest to obtain
an average exposure  rate per unit time.  This
average exposure rate also can be expressed as a
function of body weight. For the purposes of this
manual, exposure normalized for time and body
weight is termed "intake",  and is expressed in units
of mg chemical/kg body weight-day.

    Exhibit 6-9 presents a generic equation for
calculating chemical intakes and defines the intake
variables. There are three categories of variables
that are used to estimate intake

    (1)  chemical-related variable ~ exposure
         concentration,

    (2) variables  that describe the exposed
         population  — contact rate, exposure
         frequency and duration, and body weight
         and
    (3) assessment-determined
        averaging time.
variable  --
     Each intake variable in the equation has a
range of values.    For Superfund  exposure
assessments, intake variable values for a given
pathway   should  be  selected  so  that the
combination of all intake variables results in an
estimate of the reasonable maximum  exposure for
that  pathway.    As defined previously, the
reasonable maximum exposure (RME) is the
maximum exposure that is reasonably expected to
occur at a site. Under this approach, some intake
variables  may not be at their individual maximum
values but when  in combination with  other
variables will result in estimates of the RME.
Some recommendations for determining the values
of the individual intake variables are discussed
below. These recommendations are based on
EPA's determination of what would result in an
estimate of the RME. As discussed previously, a
determination of "reasonable" cannot be based
solely on  quantitative  information, but also
requires  the use  of professional judgment.
Accordingly, the recommendations below are based
on a combination of quantitative information and
professional judgment.    These are general
recommendations,  however, and could change
based on  site-specific information or the particular
needs of the risk manager. Consult with the RPM
before varying from these recommendations.

     Exposure concentration.  The concentration
term in the intake equation is the arithmetic
average of the concentration that is contacted over
the exposure period. Although this concentration
does not reflect the maximum concentration that
could be contacted at any one time, it is regarded
as a reasonable estimate of the concentration
likely to be contacted over time. This is because
in most situations, assuming long-term contact
with the maximum  concentration  is  not
reasonable.  (For exceptions to this generalization,
see discussion of hot spots in Section 6.5.3.)

     Because of the uncertainty associated with
anv estimate of exposure concentration, the upper
confidence limit fi.e.. the 95 percent upper
confidence limit) on the arithmetic average will he
used for this variable.    There are standard
statistical  methods which can be used to calculate
the upper confidence limit on the arithmetic
mean. Gilbert (1987, particularly sections 11.6
and 13.2) discusses methods that can be applied
to data that  are distributed normally or log
normally.    Kriging  is  another  method that

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Page 6-20
                                              EXHIBIT 6-8

                EXAMPLE OF TABLE  FORMAT  FOR SUMMARIZING
                    COMPLETE  EXPOSURE PATHWAYS AT A  SITE
        Potentially Exposed
        Population
Exposure Route, Medium
and Exposure Point
Pathway Selected
for Evaluation?
Reason for Selection
or Exclusion
        Current Land Use
        Residents
        Residents
        Industrial
        Workers
        Future Land Use
        Residents
        Residents
Ingestion of ground water         Yes
from local wells down-
gradient of the site

Inhalation of chemicals           Yes
volatilized from ground
water during home use
Direct contact with               Yes
chemicals of potential
concern in soil on the
site
Direct contact with chemi-        Yes
cals of potential concern
in soil on the site

Ingestion of chemicals            No
that have accumulated in
fish located in onsite
ponds
                     Residents use ground
                     water from local wells
                     as drinking water.

                     Some of the chemicals
                     of potential concern  in
                     ground water are volatile,
                     and ground water is  used
                     by local residents.

                     Contaminated soil is in
                     an area potentially used
                     by outside maintenance
                     workers.
                     Area could be developed
                     in the future as a
                     residential area.

                     The potential for signifi-
                     cant exposure via this
                     pathway is low because
                     none of the chemicals of
                     potential concern accumulate
                     extensively in fish.

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                                                                          Page 6-21
                        EXHIBIT  6-9

    GENERIC EQUATION FOR CALCULATING
                  CHEMICAL INTAKES
                 I =  C K CR \ EFD
                           BW
AT
Where:
       I    =  intake; the amount of chemical at the exchange boundary
               (mg/kg body weight-day)

   Chemical-related variable

       C   =  chemical concentration; the average concentration contacted
               over the exposure period (e.g., ing/liter water)

   Variable? that describe the exposed population

       CR  =  contact rate; the amount of contaminated medium contacted
               per unit time or event (e*g=s liters/day)
       EFD =  exposure frequency and duration; describes how long and how
               often exposure occurs. Often calculated using two terms
               (EF and ED):
            EF  = exposure frequency (days/year)

            ED  = exposure duration (years)
       BW  =  body weight; the average body weight over the exposure period
               (kg)

   Assessment-determined variable

       AT  =  averaging time; period over which exposure is averaged (days)

-------
Page 6-22
potentially can be used (Clark 1979 is one of
several reference books on kriging). A statistician
should be consulted for more  details or for
assistance with  specific methods.

     If there is great  variability in measured or
modeled concentration values (such as when too
few samples are taken or when model inputs are
uncertain), the upper confidence limit on the
average  concentration  will be high,  and
conceivably could be above the maximum detected
or modeled value. In  these cases, the maximum
detected or modeled value should be used to
estimate exposure concentrations. This could be
regarded by some as too conservative an estimate,
but given the uncertainty in  the data in these
situations, this approach is regarded as reasonable.

     For some sites, where a screening level
analysis is regarded as sufficient to characterize
potential exposures,  calculation of the upper
confidence limit on the arithmetic average is not
required. In these cases, the maximum detected
or modeled concentration should  be used as the
exposure concentration.

     Contact rate.    Contact rate  reflects the
amount of contaminated medium contacted per
unit time or event. If statistical data are available
for a contact rate, use the 95th percentile value
for this variable. (In this case and throughout this
chapter, the 90th percentile value can be used if
the 95th percentile value is not available.) If
statistical  data are not available, professional
judgment  should be  used to  estimate a value
which approximates the 95th percentile value. (It
is recognized that such estimates will not be
precise.    They  should,  however, reflect a
reasonable estimate of an upper-bound value.)

     Sometimes several separate terms are used to
derive an estimate of contact rate. For example,
for  dermal contact with chemicals in water,
contact rate is estimated by combining information
on  exposed skin surface area, dermal permeability
of  a chemical,  and exposure time.    In such
instances, the combination of variables used to
estimate intake should result in an  estimate
approximating   the  95th  percentile  value.
Professional judgment  will be needed to determine
the appropriate combinations of variables. (More
specific guidance for determining contact rate for
various pathways is given in Section 6.6.)
     Exposure frequency and duration. Exposure
frequency and duration are used to estimate the
total time of  exposure.     These  terms  are
determined on a site-specific basis. If statistical
data are available, use the 95th percentile value
for exposure time.  In the absence of statistical
data (which is usually the case), use reasonable
conservative  estimates of exposure time. National
statistics are available on the upper-bound (90th
percentile) and average (50th percentile) number
of years spent by individuals at one residence
(EPA 1989d). Because of the data on which they
are based, these values may underestimate the
actual time that someone might live in one
residence.  Nevertheless, the upper-bound value of
30 years can be used for exposure duration when
calculating  reasonable maximum  residential
exposures.     In some cases, however, lifetime
exposure (70 years by convention) may be  a more
appropriate assumption. Consult with the RPM
regarding  the appropriate exposure duration for
residential exposures. The exposure frequency and
duration selected must be appropriate for the
contact rate selected.   If a long-term average
contact rate (e.g., daily fish ingestion rate averaged
over a  year) is used, then a daily exposure
frequency  (i.e., 365 days/year) should be assumed.

     Body weight. The value for body weight is
the average body weight over the exposure period.
If exposure occurs only during childhood years,
the average child body weight during the exposure
period should be used to estimate intake. For
some pathways, such as soil ingestion, exposure
can occur throughout the lifetime but the majority
of exposure occurs during childhood (because of
higher contact rates). In these cases, exposures
should be calculated separately  for age groups
with similar contact rate to body weight ratios; the
body weight used in the intake calculation for
each age group is the average body weight for that
age group. Lifetime exposure is, then calculated
by taking the time-weighted average of exposure
estimates over all age groups.   For pathways
where contact rate to body weight ratios are fairly
constant over a lifetime (e.g., drinking water
ingestion), a body weight of 70 kg is used.

     A constant body weight over the period of
exposure is used primarily by convention, but also
because body weight is not always independent of
the other variables in the exposure equation (most
notably, intake).     By keeping body weight

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                                                                                          Page 6-23
constant, error from this dependence is minimized.
The average body weight is used because, when
combined with the other variable values in the
intake equation, it is believed to result in the beat
estimate of the RME. For example, combining a
95th percentile contact rate with a 5th percentile
body weight is not considered reasonable because
it is unlikely that smallest person would have the
highest intake. Alternatively, combining  a 95th
percentile intake with a 95th percentile body
weight is not considered a maximum because a
smaller person could have a higher contact rate to
body weight ratio.

    Averaging time, The averaging time selected
depends on the type of toxic effect being assessed.
When evaluating  exposures to  developmental
toxicants, intakes are calculated by  averaging over
the exposure event (e.g., a day or  a  single
exposure incident).  For acute toxicants, intakes
are calculated by averaging over the shortest
exposure period that could produce an effect,
usually an exposure event or a day.    When
evacuating    longer-term    exposure  to
noncarcinogenic toxicants, intakes are calculated
by averaging intakes over the period of exposure
(i.e., subchronic or chronic daily intakes). For
carcinogens, intakes  are calculated by prorating
the total cumulative dose  over a lifetime (i.e.,
chronic  daily  intakes, also called lifetime average
daily  intake).    This distinction  relates to the
currently held scientific opinion that the
mechanism of action for each category is different
(see Chapter 7 for a discussion).  The approach
for carcinogens is based on the assumption that
a high dose received over a short period of time
is equivalent to a corresponding low dose  spread
over a lifetime  (EPA 1986b). This approach
becomes problematic as the  exposures in question
become  more intense but less frequent, especially
when there is evidence that the agent has  shown
dose-rate related carcinogenic effects.  In some
cases, therefore,  it may be necessary to consult a
toxicologist to assess the  level of uncertainty
associated with the exposure assessment for
carcinogens. The discussion of uncertainty  should
be included in both the exposure assessment and
risk characterization chapters   of the  risk
assessment report.
6.4.2
TIMING CONSIDERATIONS
     At many Superfund sites, long-term exposure
to relatively low chemical concentrations (i.e.,
chronic daily intakes) are of greatest concern. In
some situations, however, shorter-term exposures
(e.g., subchronic daily intakes) also may  be
important. When deciding whether to evaluate
short-term exposure, the following factors should
be considered:

     •   the toxicological characteristics of the
         chemicals  of potential concern;

     •   the occurrence  of high chemical
         concentrations or the potential for a
         large release;

     •   persistence of the  chemical  in the
         environment; and

     •   the characteristics of the population that
         influence the duration of exposure.

     Toxicity considerations. Some chemicals can
produce an effect after a single or very short-term
exposure to relatively low concentrations. These
chemicals include acute toxicants such as skin
irritants   and    neurological    poisons,   and
developmental  toxicants.  At sites where these
types of chemicals are present, it is  important to
assess exposure for the shortest time period that
could result in an effect. For acute toxicants this
is usually a single exposure event or a  day,
although multiple exposures over several days also
could result in an effect.   For developmental
toxicants, the  time period of concern is the
exposure event. This is based on the assumption
that a single exposure at the critical time  in
development is sufficient to produce an adverse
effect. It should be noted that the critical  time
referred to can occur in almost any segment of
the human population (i.e.,  fertile men and
women, the conceptus, and the child up to the age
of sexual maturation [EPA 1989e]).

     Concentration    considerations.       Many
chemicals can produce an effect after a single or
very short-term exposure, but only if exposure is
to a relatively high concentration.  Therefore, it
is important that the assessor identify possible
situations where a short-term exposure to a high
concentration could occur. Examples of such a

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Page 6-24
situation include sites where contact with a small,
but highly contaminated area is possible (e.g., a
source or a hot spot), or sites where there is a
potential for a large chemical  release (e.g.,
explosions, ruptured drums, breached lagoon
dikes). Exposure should be determined for the
shortest period of time that could produce an
effect.

     Persistence considerations. Some chemicals
may degrade rapidly in the environment. In these
cases, exposures should be assessed only for that
period of time in which the chemical will be
present at the site. Exposure assessments in these
situations may need to include evaluations of
exposure to the breakdown products, if they are
persistent or toxic at the levels predicted to occur
at the site.

     Population considerations. At some sites,
population activities are such that exposure would
occur only for a short time period (a few weeks
or  months),  infrequently, or intermittently.
Examples of this would be seasonal exposures
such as during vacations or other recreational
activities.    The period of time  over which
exposures are averaged in these instances depends
on the type of toxic effect being assessed (see
previous discussion  on averaging time, Section
6.4.1).
6.5      QUANTIFICATION OF
         EXPOSURE:  DETERMINA-
         TION OF EXPOSURE
         CONCENTRATIONS

    This section describes the basic approaches
and methodology for  determining exposure
concentrations of the chemicals of potential
concern in different environmental media using
available  monitoring data and appropriate models.
As discussed in Section 6.4.1, the concentration
term in the exposure equation is the average
concentration contacted at the exposure point or
points over the  exposure period. When estimating
exposure concentrations, the objective is to
provide a conservative estimate of this average
concentration  (e.g.,  the  95  percent  upper
confidence limit on the arithmetic mean chemical
concentration).
     This section provides an overview of the basic
concepts and approaches for estimating exposure
concentrations.     It  identifies  what type  of
information is needed to estimate concentrations,
where to find it, and how to interpret and use it.
This section is not designed to  provide all the
information  necessary   to  derive exposure
concentrations  and, therefore, does not detail the
specifics of potentially  applicable  models nor
provide the data necessary to run the models or
support concentration estimates.     However,
sources  of such information,  including the
Superfund Exposure Assessment Manual (SEAM;
EPA 1988b)  are referenced throughout the
discussion.

6.5.1     GENERAL CONSIDERATIONS FOR
         ESTIMATING  EXPOSURE
         CONCENTRATIONS

     In general,  a great deal of professional
judgment is required   to estimate exposure
concentrations. Exposure concentrations may  be
estimated by (1) using monitoring data alone, or
(2) using a combination of monitoring data, and
environmental fate and transport models. In most
exposure assessments,  some combination  of
monitoring data and environmental modeling will
be required to estimate exposure  concentrations.

     Direct use of monitoring data.   Use  of
monitoring    data   to    estimate    exposure
concentrations is normally applicable where
exposure involves  direct  contact with the
monitored medium (e.g.,  direct contact with
chemicals in soil or sediment), or in cases where
monitoring has occurred directly at an exposure
point (e.g., a residential drinking water well  or
public water supply).    For these exposure
pathways, monitoring data generally provide the
best estimate of current exposure  concentrations.

     As the first step in estimating exposure
concentrations, summarize available monitoring
data.   The manner in which the  data are
summarized depends upon the site characteristic
and the pathways being evaluated. It may be
necessary to divide chemical data from a particular
medium into subgroups  based on the location of
sample points  and the potential exposure
pathways.   In other instances, as when the
sampling point is an exposure point (e.g., when
the sample is from an existing drinking water well)

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                                                                                        Page 6-25
it may not be appropriate to group samples at all,
but may be most appropriate to treat the sample
data separately when estimating intakes. Still, in
other instances, the assessor may wish to use the
maximum concentration from a medium as the
exposure concentration for a given pathway as a
screening approach to place an upper bound on
exposure.    In these cases it is important to
remember that if a screening level approach
suggests a potential health concern, the  estimates
of exposure should be modified to reflect more
probable  exposure conditions.

     In those instances where it is appropriate to
group sampling data from a particular medium,
calculate for each exposure medium and each
chemical the 95 percent upper confidence limit on
the arithmetic  average chemical concentration.
See Chapter 5 for  guidance on  how to treat
sample concentrations below the quantitation
limit.

     Modeling  approaches.  In some instances,  it
may not  be appropriate to use monitoring data
alone, and fate and transport models may be
required  to estimate exposure concentrations.
Specific instances where monitoring data alone
may not be adequate are as follows.

     •    Where  exposure  points are  spatially
         separate  from  monitoring    points.
         Models  may be required when exposure
         points  are  remote  from sources  of
         contamination if mechanisms for  release
         and transport to exposure points exist
         (e.g.,    ground-water  transport,  air
         dispersion),

     •    Where temporal distribution of data is
         lacking. Typically,  data from Superfund
         investigations are collected over  a
         relatively short period of time.   This
         generally will give a clear indication of
         current site conditions, but both long-
         term and short-term exposure estimates
         usually  are required in  Superfund
         exposure assessments. Although there
         may be  situations where it is reasonable
         to assume that concentrations  will
         remain  constant over a long period of
         time,  in many cases the time span of the
         monitoring data is not adequate to
         predict future exposure concentrations.
         Environmental models may be required
         to make these predictions.

     •    Where monitoring data are restricted by
         the limit of quantitation. Environmental
         models may be needed to predict
         concentrations of contaminants that may
         be present at concentrations that are
         below the quantitation limit but that may
         still cause toxic effects (even at such low
         concentrations).   For example, in the
         case of  a ground-water plume discharging
         into a river, the dilution afforded by the
         river may be sufficient to reduce the
         concentration of the chemical to a level
         that could not be detected by direct
         monitoring. However, as  discussed in
         Section 5.3.1, the chemical may  be
         sufficiently toxic or bioaccumulative that
         it  could present a health risk  at
         concentrations  below the  limit  of
         quantitation. Models may be required
         to make exposure estimates in these
         types of situations.

     A wide variety of models are available for
use in exposure assessments. SEAM (EPA 19S8b)
and the Exposure Assessment Methods Handbook
(EPA  1989f) describe  some of  the models
available and provide guidance in selecting
appropriate  modeling techniques.    Also,  the
Center for  Exposure Assessment Modeling
(CEAM ~ Environmental Research Laboratory
(ERE) Athens),  the Source Receptor Analysis
Branch (Office  of Air Quality Planning and
Standards, or OAQPS), and  modelers in EPA
regional offices can provide assistance in selecting
appropriate models.  Finally,  Volume IV of the
NTGS  (EPA 1989c) provides guidance for air and
atmospheric dispersion modeling for Superfund
sites. Be sure to discuss the fate and transport
models to be used in the exposure assessment with
the RPM.

     The level of effort  to  be expended  in
estimating exposure concentrations will depend on
the type and quantity of data available, the level
of detail required in the assessment, and the
resources available for the assessment. In general,
estimating exposure concentrations  will involve
analysis of site monitoring data and application of
simple, screening-level analytical models. The
most important factor in determining the level of

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Page 6-26
effort will be the quantity and quality of the
available data.  In general, larger data sets will
support the use of more sophisticated models.

     Other considerations.    When evaluating
chemical contamination at a site, it is important
to review the spatial distribution of the data and
evaluate it in ways that have the most relevance
to the pathway being assessed.  In short, consider
where the contamination is with respect to known
or anticipated population activity patterns. Maps
of both concentration distribution and activity
patterns will  be  useful for the exposure
assessment.   It is the intersection of activity
patterns and contamination  that  defines an
exposure area.  Data from random sampling or
from systematic grid pattern sampling may be
more representative of a given exposure pathway
than data collected only from hot spots.

     Generally, verified GC/MS laboratory data
with adequate quality control will be required to
support quantitative  exposure  assessment. Field
screening data generally  cannot be incorporated
when estimating exposure concentrations because
they are derived using less sensitive analytical
methods and are subject to less stringent quality
control.

     Other areas to be considered in estimating
exposure concentrations are as follows.

     •   Steady-state vs.   non-steadv-state
         conditions.    Frequently, it may be
         necessary  to   assume   steady-state
         conditions because  the  information
         required  to estimate non-steady-state
         conditions (such as source depletion
         rate) is not readily available. This is
         likely  to overestimate long-term exposure
         concentrations for certain pathways.

     •   Number and type of exposure parameters
         that must be assumed.   In developing
         exposure models, values for site-specific
         parameters    such   as    hydraulic
         conductivity, organic carbon content of
         soil, wind speed and direction, and soil
         type may be required.  These values may
         be generated as part of the RI. In eases
         where these values are not available,
         literature values may  be substituted. In
         the absence of applicable  literature
         values, the assessor must consider if a
         reliable exposure concentration estimate
         can be made.

     •    Number and type of fate processes to
         be considered. In some cases, exposure
         modeling   may  be    limited to
         considerations of mass balance, dilution,
         dispersion, and equilibrium partitioning.
         In other cases, models of more complex
         fate processes, such as chemical reaction,
         biodegradation, and photolysis may be
         needed. However,  prediction of such
         fate processes requires significantly larger
         quantities of model calibration  and
         validation data than required for  less
         complex fate processes. For those sites
         where these more complex fate processes
         need to be modeled, be sure to consult
         with the RPM regarding the added  data
         requirements.

6.5.2     ESTIMATE EXPOSURE
         CONCENTRATIONS IN GROUND
         WATER

     Exposure concentrations  in ground water can
be based on monitoring data alone  or on a
combination of monitoring and modeling. In
some cases, the exposure assessor may favor the
use of monitoring data over  the use of complex
models to develop exposure concentrations.  It is
most appropriate to use ground-water sampling
data  as estimates of exposure concentrations when
the sampling points correspond to exposure
points, such as samples  taken from a  drinking
water tap. However, samples taken directly from
a domestic well or drinking water tap should be
interpreted cautiously.  For example, where the
water is acidic, inorganic chemicals such as  lead
or copper may  leach from the distribution system.
Organic chemicals such as phthalates may migrate
into water  from plastic piping.    Therefore,
interpretations of these data should consider the
type and operation of the pumping, storage, and
distribution system involved.

     Most of the time, data from monitoring wells
will be used to estimate chemical concentrations
at the exposure point.  Several issues should be
considered when using monitoring well data to
estimate these  concentrations. First, determine if
the aquifer has sufficient production capacity and

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                                                                                        Page 6-21
is of sufficient quality to support drinking water
or other uses.   If so, it generally should be
assumed that water could be drawn from anywhere
in the aquifer,  regardless  of the  location  of
existing wells relative to the  contaminant plume.
In a few situations, however, it may not be
reasonable to assume that water will be  drawn
from directly beneath  a specific source (e.g., a
waste management unit such as a landfill) in the
future. In these cases, it should be assumed that
water could be drawn from directly adjacent to the
source.   Selection of the location(s) used  to
evaluate future ground-water  exposures should  be
made in consultation  with  the RPM.  Second,
compare  the construction of wells (e.g., drinking
water wells) in the area with the construction  of
the monitoring wells.  For example, drinking water
wells may draw water from more than one aquifer,
whereas individual monitoring wells are usually
screened in a specific aquifer. In some cases it
may be appropriate to separate data from  two
aquifers that have very  limited  hydraulic
connection if drinking water wells in the area
draw) water from only one of them. Consult a
hydrogeologist  for assistance in the  above
considerations.

    Another issue to  consider is filtration  of
water samples. While filtration of ground-water
samples  provides  useful  information  for
understanding chemical transport within an  aquifer
(see Section 4.5.3 for  more details), the use  of
filtered samples  for estimating exposure is very
controversial    because   these    data    may
underestimate chemical concentrations  in water
from an unfiltered tap.  Therefore,  data from
unfiltered samples  should be used to estimate
exposure concentrations.  Consult with the RPM
before using data from  filtered  samples.

     Ground-water monitoring data are often  of
limited use for evaluating long-term exposure
concentrations  because  they are generally
representative of current site conditions and not
long-term trends. Therefore, ground-water models
may   be  needed  to   estimate   exposure
concentrations. Monitoring data should be used
when possible to calibrate the models.

    Estimating exposure concentrations in  ground
water using models can be a complex task because
of the many physical and chemical processes that
may affect transport and transformation in ground
water. Among the important mechanisms that
should be considered when estimating exposure
concentrations in ground water are leaching from
the surface, advection (including infiltration, flow
through the unsaturated zone, and flow with
ground water), dispersion, sorption (including
adsorption, resorption, and ion exchange), and
transformation (including biological degradation,
hydrolysis, oxidation,  reduction,  complexation,
dissolution,   and precipitation).      Another
consideration is that not all chemicals may be
dissolved in water, but may be present instead in
nonaqueous phases  that float on top of ground
water or sink to the bottom of the aquifer.

     The proper selection and application of soil
and ground-water models requires a thorough
understanding of the physical, chemical, and
hydrogeologic characteristics of the  site. SEAM
(EPA 1988b) provides a discussion of the factors
controlling soil and ground-water contaminant
migration as well as descriptions of various soil
and ground-water models. For more in-depth
guidance on the selection and application of
appropriate  ground-water  models,  consult
Selection Criteria for  Mathematical Models  Used in
Exposure Assessments Ground-water Models  (EPA
1988c). As with all modeling, the assessor should
carefully evaluate the applicability of the model to
the site being evaluated, and should consult with
a hydrogeologist as necessary.

     If ground-water  modeling is not used, current
concentrations can  be  used to represent future
concentrations in ground water assuming steady-
state conditions. This assumption should be noted
in the exposure assessment Chapter and in the
uncertainties and conclusions'   of the  risk
assessment.

6.5.3     ESTIMATE EXPOSURE
         CONCENTRATIONS IN  SOIL

     Estimates  of current exposure  concentrations
in soil  can be based  directly on summarized
monitoring  data  if  it  is  assumed  that
concentrations remain constant over time.  Such
an assumption may  not be appropriate for some
chemicals and  some sites  where leaching,
volatilization, photolysis, biodegradation,  wind
erosion, and surface runoff will reduce chemical
concentrations over time.  Soil monitoring data
and site conditions should be carefully screened to

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 Page 6-28
 identify situations where source depletion is likely
 to be important.   SEAM (EPA 1988b) gives
 steady-state equations for estimating many of these
 processes. However, incorporating  these processes
 into the calculation of exposure concentrations for
 soil involves considerable effort. If a modeling
 approach is not adopted in these situations,
 assume a constant concentration over time and
 base exposure concentrations on monitoring data.
 This assumption should be clearly documented,

     In evaluating  monitoring  data  for the
 assessment of soil contact exposures, the spatial
 distribution of the data is a critical factor. The
spatial distribution of soil contamination can be
 used as a basis  for estimating the average
 concentrations contacted over time  if it is assumed
 that contact with soil  is spatially random (i.e., if
 contact with soil in all areas of the site is equally
 probable). Data from random sampling programs
 or samples from evenly spaced grid networks
 generally can be considered as representative  of
 concentrations across the site. At many sites
 however, sampling programs are  designed to
 characterize only obviously contaminated soils or
 hot spot areas. Care must be taken in evaluating
 such  data   sets   for  estimating  exposure
 concentrations.  Samples from areas where direct
 contact is not realistic (such as where a steep
 slope or thick vegetation prevents current access)
 should not be considered when estimating current
 exposure concentrations for direct  contact
 pathways.   Similarly, the depth  of the sample
 should be considered, surface soil samples should
 be evaluated separately from subsurface samples
 if direct contact with surface soil or inhalation of
 wind blown dust are potential exposure pathways
 at the site.

     In some cases,  contamination  may  be
 unevenly distributed across a site, resulting in hot
 spots (areas of high contamination relative to
 other areas of the site). If a hot spot is located
 near an area which, because of site or population
 characteristics, is visited or used more frequently,
 exposure to the hot  spot should be assessed
 separately. The area over which  the activity is
 expected to occur should be considered when
 averaging the monitoring data for a hot spot. For
 example, averaging soil data over an area the size
 of a residential backyard (e.g., an eighth of an
 acre) may be most appropriate for evaluating
 residential soil pathways.
6.5.4     ESTIMATE EXPOSURE
         CONCENTRATIONS IN AIR

     There  are three general approaches  to
estimating exposure concentrations in air: (1)
ambient    air    monitoring, (2)  emission
measurements coupled with dispersion modeling,
and (3) emission modeling coupled with dispersion
modeling.   Whichever approach is used, the
resulting exposure concentrations should be  as
representative as possible of the specific exposure
pathways being  evaluated. If long-term exposures
are being evaluated, the exposure concentrations
should be representative of long-term averages.
If short-term exposures are  of interest, measured
or modeled peak concentrations may be most
representative.

     If monitoring data have been collected at a
site, their adequacy for use in a risk assessment
should be  evaluated  by considering  how
appropriate they are for the exposures being
addressed. Volume II of the NTGS (EPA 1989b)
provides guidance for measuring emissions and
should  be  consulted  when  evaluating  the
appropriateness of emission data. See  Chapter 4
(Section 4.5.5) for  factors to consider when
evaluating the  appropriateness of ambient air
monitoring data.    As  long as there  are no
significant analytical problems  affecting air
sampling data,  background  levels  are  not
significantly higher than potential site-related
levels, and site-related levels are not below the
instrument detection limit, air monitoring data can
be used to derive exposure concentrations. There
still will  be uncertainties inherent in using these
data because they usually are not representative
of actual long-term average air concentrations.
This may be because there were only a few sample
collection periods, samples were collected during
only  one type of meteorological or climatic
condition, or because the source of the chemicals
will change over time. These uncertainties should
be mentioned in the risk assessment.

     In the absence of monitoring data, exposure
concentrations often can  be  estimated using
models.    Two kinds of models are used  to
estimate air concentrations: emission models that
predict the  rate  at which chemicals may be
released into the air from a source, and dispersion
models that predict associated concentrations  in
air at potential receptor points.

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                                                                                        Page 6-29
     Outdoor air modeling. Emissions may occur
 as a result of the volatilization of chemicals from
 contaminated  media or as  a result of the
 suspension of onsite soils. Models that predict
 emission rates for volatile chemicals or dust
 require numerous input parameters,  many of
 which are site-specific. For volatile chemicals,
 emission  models for surface water and soil are
 available in SEAM (EPA 1988b). Volume IV of
 the NTGS (EPA 1989c) also provides guidance for
 evaluating volatile emissions at Superfund sites.
 Emissions due to suspension of soils may result
 from wind erosion of exposed soil particles and
 from vehicular disturbances of the  soil. To
 predict soil or dust emissions, EPA's fugitive dust
 models provided in AP42 (EPA 1985b) or models
 described in SEAM (1988b) may be used.
 Volume IV of the NTGS (EPA 1989c)  also will
 be useful in evaluating fugitive dust emissions at
 Superfund sites.   Be sure to  critically review all
 models before use to determine their applicability
 to the situation  and site being evaluated. If
 necessary, consult with air modelers in EPA
 regional offices, the Exposure Assessment Group
 in EPA headquarters or the Source Receptor
 Analysis Branch in OAQPS.

     After emissions have  been estimated or
 measured,  air dispersion models can be applied to
 estimate air concentrations at receptor points. In
 choosing a dispersion model, factors that must be
 considered include the type of source and the
 location of the receptor relative to the source.
 For area or point sources, EPA's Industrial Source
 Complex model (EPA 1987a) or the simple
 Gaussian dispersion models discussed in SEAM
 (EPA 1988b) can provide  air concentrations
 around the source Other models can be found
 in Volume IV of the NTGS (EPA 1989c). The
 Source Receptor Analysis Branch of OAQPS also
 can be contacted for  assistance. Again, critically
review all  models for their applicability.

     Indoor air modeling. Indoor emissions may
occur as a result of transport of outdoor-generated
dust  or  vapors  indoors,  or as  a result  of
volatilization  of chemicals indoors during use of
contaminated water (e.g., during showering,
cooking, washing). Few models are available for
estimating indoor air concentrations from outside
sources.    For dust  transport indoors, it can
generally be assumed that indoor concentrations
are less than those outdoors. For vapor transport
indoors, concentrations indoors and outdoors can
be assumed to  be equivalent in most cases.
However, at sites where subsurface soil gas or
ground-water seepage are entering indoors, vapor
concentrations inside could exceed those outdoors.
Vapor concentrations resulting from indoor use of
water may be  greater than  those  outdoors,
depending on the emission source characteristics,
dispersion  indoors,   and indoor-outdoor sir
exchange rates.   Use models  discussed in the
Exposure Assessment Methods  Handbook (EPA
1989f) to evaluate volatilization of chemicals from
indoor use of water.

6.5.5     ESTIMATE EXPOSURE
         CONCENTRATIONS  IN SURFACE
        WATER

    Data from  surface water sampling and
analysis may be used alone or in conjunction with
fate and transport models to estimate exposure
concentrations.   Where the sampling points
correspond to   exposure points,  such as at
locations where fishing or recreational activities
take place, or at the intake to a drinking water
supply, the monitoring data can be used  alone to
estimate exposure concentrations. However, the
data must be carefully screened. The complexity
of surface water processes may lead  to certain
limitations in monitoring data. Among these are
the following.

    •   Temporal representativeness. Surface
        water bodies are subject to seasonal
        changes in flow, temperature,  and depth
        that may significantly affect the  fate and
        transport of contaminants. Releases to
        surface water bodies often depend on
        storm conditions to produce  surface
        runoff and soil erosion.    Lakes are
        subject to seasonal stratification and
        changes in biological activity.  Unless the
        surface  water monitoring program has
        been designed to account  for these
        phenomena, the data may not represent
        long-term average  concentrations or
        short-term  concentrations that  may occur
        after storm events.

    •   Spatial  representativeness. Considerable
        variation in concentration can occur with
        respect  to  depth and lateral location in
        surface  water bodies, sample locations

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Page 6-30
         should be examined relative to surface
         water mixing zones.   Concentrations
         within  the mixing  zone  may  be
         significantly higher than at downstream
         points where complete mixing has taken
         place.
     •   Quantitation limit limitations. Where
         large surface water bodies are involved,
         contaminants that enter as a result of
         ground-water discharge or runoff from
         relatively small areas may be significantly
         diluted.  Although  standard analytical
         methods may not be  able to detect
         chemicals at these levels, the toxic effects
         of the chemicals and/or their potential
         to bioaccumulate may nevertheless
         require  that  such concentrations be
         assessed.

     •   Contributions from other sources.
         Surface water bodies are  normally subject
         to contamination from many sources
         (e.g., pesticide   runoff, storm water,
         wastewater    discharges, acid  mine
         drainage).    Many of the chemicals
         associated with these sources may be
         difficult to distinguish from site-related
         chemicals. In many cases background
         samples will be useful in assessing site-
         related    contaminants from  other
         contaminants    (see    Section   4.4).
         However, there may be other cases
         where a release and transport model may
         be required to make the distinction.

     Many analytical and numerical models are
available to estimate the release of contaminants
to surface water and to  predict the fate of
contaminants once released. The models range
from simple  mass  balance  relationships to
numerical codes that contain terms for chemical
and  biological reactions  and interactions  with
sediments. In  general,  the level  of information
collected during the RI will tend  to limit the use
of the more complex models.

     There are several documents that can be
consulted when selecting models to estimate
surface water exposure concentrations, including
SEAM (EPA 1988b), the Exposure Assessment
Methods Handbook (EPA  1989f), and Selection
Criteria for Mathematical Models  Used in Exposure
Assessments: Surface Water Models (EPA 1987b).
SEAM lists equations for surface water runoff and
soil erosion and presents the basic mass balance
relationships for estimating the effects of dilution.
A list of available numerical  codes  for more
complex  modeling also is provided. The selection
criteria document (EPA 1987b)  provides a more
in-depth  discussion of numerical codes and other
models.  In addition, it provides guidelines and
procedures for evaluating the appropriate level of
complexity required for various applications. The
document lists criteria to consider when selecting
a surface water model, including  (1) type of water
body, (2) presence of steady-state  or transient
conditions, (3) point versus non-point sources of
contamination,  (4) whether 1, 2, or 3 spatial
dimensions should be considered, (5) the degree
of mixing, (6) sediment  interactions, and (7)
chemical processes.    Each of the referenced
documents should be consulted prior to any
surface water modeling.

6.5.6     ESTIMATE EXPOSURE
         CONCENTRATIONS IN SEDIMENTS

     In general, use  sediment monitoring data to
estimate  exposure concentrations.     Sediment
monitoring data can be expected  to provide better
temporal representativeness than surface water
concentrations. This will especially be true in the
case of contaminants  such as PCBs, PAHs, and
some inorganic  chemicals, which are likely to
remain bound to the  sediments.   When using
monitoring   data   to   represent    exposure
concentrations for direct contact exposures,  data
from surficial, near-shore sediments should be
used.

     If modeling is needed to estimate sediment
exposure  concentrations,  consult SEAM (EPA
1988b). SEAM treats surface water and sediment
together for the purpose of listing available
models  for the  release  and transport of
contaminants. Models for soil  erosion releases
are equally applicable for estimating  exposure
concentrations for surface water and sediment.
Many of the numerical models  listed in SEAM
and the surface water selection criteria document
(EPA 1987b)  contain sections devoted to sediment
fate and transport.

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                                                                                         Page 6-31
 6.5.7     ESTIMATE CHEMICAL
         CONCENTRATIONS IN FOOD

     Fish and shellfish. Chemical  concentrations
 in  fish  and shellfish  may be  measured or
 estimated.    Site-specific measured values  are
 preferable to estimated values, but before using
 such values, evaluate the sampling plan to
 determine if it was adequate to characterize the
 population and species of concern (see Section
 4.5.6 for some sampling considerations).  Also
 examine  analytical procedures to determine if the
 quantitation limits were low enough to detect the
 lowest concentration potentially  harmful to
humans.  Inadequate sampling  or high levels of
 quantitation may lead to erroneous conclusions.

     In  the absence   of adequate  tissue
 measurements, first consider whether the chemical
 bioconcentrates (i.e., is taken up from water) or
 bioaccumulates (i.e.,  is  taken up  from food,
 sediment, and water). For example, low molecular
 weight  volatile   organic  chemicals do  not
 bioaccumulate in  aquatic organisms to a great
 extent.   Other chemicals accumulate in some
 species but not in others. For example, PAHs
 tend to accumulate in mollusk species but not in
 fish, which rapidly metabolize the chemicals. For
 those chemicals that bioconcentrate in aquatic
 species  of  concern,  use the organism/water
 partition  coefficient (i.e.,  bioconcentration factor,
 or  BCF) approach to  estimate  steady-state
 concentrations. BCFs that estimate concentrations
 in edible tissue (muscle)  are generally more
 appropriate for assessing human exposures from
 fish or shellfish ingestion than those that estimate
 concentrations in the whole body, although this is
 not true for all aquatic species or applicable to all
 human populations consuming fish or shellfish.
 When data  from multiple experiments are
 available, select the BCF from a test that used a
 species most similar to the species of concern at
 the site, and multiply the BCF directly by the
 dissolved chemical concentration in water to
 obtain estimates of tissue concentrations.  Be
 aware that the study from which the BCF is
 obtained should reflect  a steady  state  or
 equilibrium condition, generally achieved over
 long-term exposures (although some chemicals
 may reach steady state rapidly in certain species).
 For some chemicals, BCFs may overestimate tissue
 levels in fish that may be exposed only for a short
 period of time.
     When no BCF is available, estimate the BCF
with a regression equation based on octanol/water
partition coefficients (Kow). Several equations are
available in the literature. Those  developed for
chemicals with structural similarities to the
chemical of concern should be used in preference
to general equations because of better statistical
correlations.

     The  regression equation  approach  to
estimating   BCFs can   overestimate  or
underestimate concentrations in  fish tissue
depending upon the chemical of concern and the
studies used to develop the regression equations.
For example, high molecular weight PAHs (such
as benz(a)pyrene)  with  high Kow values lead to
the  prediction of high fish  tissue  residues.
However, PAHs are rapidly metabolized in the
liver,   and  do  not  appear  to  accumulate
significantly in fish. Regression equations using
K ow cannot   take  into    account  such
pharmacokinetics,   and thus may  overestimate
bioconcentration.  On the  other hand, studies used
to develop regression equations which were not
representative of  steady-state conditions will tend
to underestimate  BCFs.

     Typical methods for estimating fish tissue
concentrations are  based on dissolved chemical
concentrations in water. While chemicals present
in sediment and biota may also bioaccumulate in
fish, there are only limited data available to
estimate contributions to fish from  these sources.
However, chemicals that readily  adsorb  to
sediments, such as PCBs,  can be present in surface
water at concentrations below detection limits and
still significantly bioaccumulate. Some models are
available to assess the contribution of chemical
concentrations  in   sediment  to    chemical
concentrations in  aquatic biota. CEAM (ERL
Athens) may be of assistance in  choosing and
applying an appropriate model.

     Plants. Site-related chemicals may be present
in plants as a result of  direct deposition onto
plant surfaces, uptake from the soil, and uptake
from the air. When possible, samples of plants or
plant products  should be used to estimate
exposure concentrations.    In the absence  of
monitoring data, several modeling approaches are
available for estimating exposure concentrations in
plants.   Use  of these models, however, can

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 Page 6-32
 introduce substantial uncertainty into an exposure
 assessment.

     If deposition onto plants is the source of the
 chemical, air deposition modeling can be used in
 conjunction with plant interception fractions to
 estimate uptake. The plant interception fraction
 can be estimated by methods published in the
 literature or can be developed for a specific crop
 by considering crop yield and the area of the plant
 available for deposition.

     If soil  contamination is the  source of the
 chemical, calculate the concentration in plants by
 multiplying soil to plant partition coefficients by
 soil  concentrations.   Use the open literature or
 computerized   data bases  to obtain  these
coefficients from field, microcosm, or laboratory
 experiments that are applicable to the type of
 vegetation or crop of concern (see EPA 1985c
 sludge documents for some). In the absence of
 more specific information, use general BCFs
 published in the literature that are  not  crop-
 specific (see Baes et al. 1984 for  some). When
 using these  parameters, it is important to consider
 that many site-specific factors affect the extent of
 uptake.  These  factors include pH, the amount of
 organic material present in soil, and the presence
 of other chemicals.

     When literature values are not  available,
 consider equations published in the literature for
 estimating uptake into the whole plant, into the
 root, and translocation from the root into above
 ground parts (see Calamari et al. 1987). Such
 methods require physical/chemical parameters such
 as Kow or molecular weight and were  developed
 using a limited data base. Scientific judgment
 must always be applied in the development and
 application of any partition coefficient, and
 caution must be applied in using these values in
 risk assessment.

     Terrestrial animals, Use tissue monitoring
 data when available and appropriate for estimating
 human exposure to chemicals in the terrestrial
 food chain.  In the absence of tissue monitoring
 data, use transfer coefficients together with the
 total chemical mass ingested by an animal per day
 to estimate contaminant concentrations in meat,
 eggs, or milk.   Data to support modeling of
 uptake by terrestrial animals  generally are not
 available for birds, but are available for some
mammalian species. Terrestrial mammals such as
cattle are simultaneously exposed to chemicals
from several sources such as water, soil, corn
silage, pasture grass, and hay.    Cattle ingest
varying amounts of these sources per day, each of
which will contain a different  contaminant
concentration.    Because all  sources can be
important with regard to total body burden, an
approach based upon the daily mass of chemical
ingested per day is recommended because it can
be applied to input from many sources.

     Obtain transfer  coefficients from the
literature (see Ng et al. 1977,  1979, 1982 Baes et
al. 1984 for some), or  calculate them directly from
feeding studies (see Jensen et al.  1981; Jensen and
Hummel  1982; Fries  et al 1973; Van Bruwaene
et al. 1984). In the absence of this information,
use regression equations in the  literature for the
estimation of transfer  coefficients (see Travis and
Arms 1988). It is important to be aware that
regression equations that use feeding study results
from short-term exposures may underestimate
meat or  milk concentrations.    In addition,
regression equations which rely on Kow values may
overestimate exposures  for chemicals such as
benz(a)pyrene that  are  rapidly metabolized.
Information on the amount of feed, soil and  water
ingested by dairy and beef cows is available in the
literature and should be combined with chemical
concentrations in these media to estimate a daily
dose to the animal.

6.5.8     SUMMARIZE  EXPOSURE
         CONCENTRATIONS FOR EACH
         PATHWAY

     Summarize the exposure  concentrations
derived for each pathway. Exhibit 6-10 presents
a sample format.
6.6     QUANTIFICATION OF
        EXPOSURE:  ESTIMATION
        OF CHEMICAL INTAKE

    This section describes the methodology for
calculating chemical-specific intakes  for the
populations and exposure pathways selected for
quantitative evaluation. The general equation for
estimating intake was shown in Exhibit 6-9.
Remember that the intakes calculated in this  step

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                               EXHIBIT  6-10

    EXAMPLE OF TABLE  FORMAT FOR SUMMARIZING
                  EXPOSURE  CONCENTRATIONS
Populations/Pathways
    Exposure
    Concentration
     Comments
                                                                                     Page 6-33
Cu rrentfies iden ts
Ingestion of ground water:

      Benzene

      Chlordane

      Cyanide
     9ug/L

    5.3 ug/L

    llug/L
Concentrations are the 95 percent
upper confidence limit on the
arithmetic average of measured
concentrations in downgradient
monitoring wells.
Direct contact with soil:

      Manganese

      Selenium

      Mercury
 1200mg/kg

   48mg/kg

    2mg/kg
Concentrations are the 95 percent
upper confidence limit on the
arithmetic average of measured
concentrations in onsite surface
soils.
Inhalation of dust:

      Manganese

      Selenium

      Mercury
   1 mg/m3

 0.04 mg/m3

0.002 mg/m3
Concentrations are based on esti-
mates of fugitive dust generation
and dispersion to nearby homes.
Concentration inputs for air model
are 95 percent upper confidence
limit on the arithmetic average of
measured concentrations in onsite
soil.

-------
Page 6-34
are expressed as the amount of chemical at the
exchange boundary (e.g., skin, lungs, gut) and
available for absorption. Intake, therefore, is not
equivalent to absorbed dose, which is the amount
of a chemical absorbed into the blood stream.

     The  sections that follow  give standard
equations for estimating human intakes for all
possible exposure routes at a site. Values for
equation  variables are  presented for use in
evaluating residential exposures. Considerations
for deriving pathway-specific variable values for
populations other  than  residential (i.e.,
commercial/industrial or recreational)  also are
given. In  general, both upper-bound (e.g.,  95th
percentile  or maximum values) and average (mean
or median)  values are presented. These values
can be used to calculate the RME or to evaluate
uncertainty.    A general discussion of which
variable values should be used to calculate the
RME was provided in Section 6.4.1; more specific
guidance follows. A discussion of the uncertainty
analysis is presented in Section 6.8.

     The information presented below is organized
by exposure medium and exposure route.

6.6.1     CALCULATE GROUND-WATER AND
         SURFACE WATER INTAKES

     Individuals may be  exposed to chemicals of
potential  concern in ground water and surface
water by the following routes:

     (1) ingestion of ground water or surface
         water used as drinking water;

     (2) incidental ingestion of surface water
         while swimming and

     (3) dermal contact with ground water or
         surface water.

     Inhalation exposures to chemicals that have
volatilized from surface or ground water are
covered in Section 6.6.3.

     Intake from drinking water.    Calculate
residential intakes from ingestion of ground water
or surface water used as drinking water, using the
equation and  variable values presented, in Exhibit
6-11. As  discussed in section 6.5.3, chemical
concentration in water (CW) should be based on
data from unfiltered samples.  Develop pathway-
specific variable values as necessary. Ingestion
rates (IR) could be lower for residents who spend
a portion of their day outside the home (e.g., at
work). Also, exposure frequency (EF) may vary
with land use. Recreational users and workers
generally would be exposed less frequently than
residents.

     Intake from ingestion of surface water while
swimming.   Calculate intakes from incidental
ingestion of surface water while swimming. Use
the equation and variable values presented in
Exhibit 6-12. Chemical concentration in water
(CW) should represent unfiltered concentrations.
Incidental ingestion rates (IR) while swimming
have not been found in the available literature.
SEAM (EPA  1988b) recommends  using an
incidental ingestion rate  of 50  ml/hour  of
swimming. Exposure duration (ED) will generally
be less for recreational users  of a surface water
compared to residents living near the surface
water. Workers are not expected to be exposed
via this pathway.

     Intake from dermal contact.    Calculate
intakes from dermal contact with water while
swimming, wading, etc., or during household use
(e.g., bathing).

     Use  the  equation  and variable  values
presented in Exhibit  6-13.  In this caser  the
calculated exposure is actually  the absorbed dose.
not the amount of chemical that comes in  contact
with the skin  (le.. intake!   This is because
permeability  constants (PC) reflect the movement
of the chemical across the skin to the stratum
corneum and into the bloodstream. Be  sure to
record this information in  the  summary  of
exposure assessment results so that the calculated
intake is compared to an appropriate toxicity
reference value in the risk characterization
chapter.     Note  that PC  are based  on an
equilibrium partitioning and likely result in  an
over-estimation of absorbed dose over short
exposure periods  (e.g., < 1  hr).    The open
literature  should be consulted for chemical-specific
PC values. The values in SEAM (EPA 1988b) are
currently being  reviewed and should not be used
at this time. If  chemical-specific PC values are
not available, the permeability of water can be
used to derive  a default value. (See Blank et al.
[1984] for some values [e.g.,  8.4xl04cm/hr].) Note

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                              EXHIBIT  6-11

         RESIDENTIAL EXPOSURE:  INGESTION OF
              CHEMICALS IN DRINKING WATER a
       (AND BEVERAGES  MADE USING  DRINKING WATER)
                                                                                     Page 6-35
     Equation:
                      Intake (mg/kg-day)  =  CW x IR x EF x ED
                                               BWxAT
     Where:
     CW =
     IR  =
     EF  =
     ED  =
     BW =
     AT  =
Chemical Concentration in Water (ing/liter)
Ingestion Rate (liters/day)
Exposure Frequency (days/year)
Exposure Duration (years)
Body Weight (kg)
Averaging Time (period over which exposure is averaged — days)
  Variable Values:


             CW:

             IR:



             EF:

             ED:
            BW:
            AT:
      Site-specific measured or modeled value

      2 liters/day (adult, 90th percentile; EPA 1989d)
      1.4 liters/day (adult, average; EPA 1989d)
      Age-specific values (EPA 1989d)

      Pathway-specific value (for residents, usually daily — 365 days/year)

      70 years (lifetime; by convention)
      30 years (national upper-bound time (90th percentile)
       at one residence; EPA 1989d)
      9 years (national median time (50th percentile) at one residence;
       EPA 1989d)

      70 kg (adult, average; EPA 1989d)
      Age-specific values (EPA 1985a, 1989d)

      Pathway-specific period of exposure for noncarcinogenic effects
       (i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic
       effects (i.e., 70 years x 365 days/year).

"See Section 6.4.1 and 6.6.1 for a discussion of which variable values should be used to calculate the
 reasonable maximum exposure. In general, combine 95th or 90th percentile values for contact rate
 and exposure frequency and duration variables.

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Page 6-36
                                       EXHIBIT  6-12

                             RESIDENTIAL  EXPOSURE:
             INGESTION OF CHEMICALS IN SURFACE WATER
                                  WHILE SWIMMING a
              Equation:
                               Intake (mg/kg-day) = CW x CR x ET x EF x ED
                                                          BVVxAT
              Where:
              CW =
              CR  =
              ET  =
              EF  =
              ED  =
              BW =
              AT  =
Chemical Concentration in Water (rag/liter)
Contact Rate (liters/hour)
Exposure Time (hours/event)
Exposure Frequency (events/year)
Exposure Duration (years)
Body Weight (kg)
Averaging Time (period over which exposure is averaged — days)
          Variable Values:


                     CW:

                     CR:

                     ET:

                     EF:
                     ED:
                     BW:
                     AT:
      Site-specific measured or modeled value

      50 ml/hour (EPA 1989d)

      Pathway-specific value

      Pathway-specific value (should consider local climatic conditions
       [e. g., number of days above a given temperature] and age of
       potentially exposed population)
      7 days/year  (national average for swimming; USDOI in
       EPA 1988b, EPA 1989d)

      70 years (lifetime; by convention)
      30 years (national upper-bound time (90th percentile) at one
       residence;  EPA 1989d)
      9 years (national median time (50th percentile) at one residence;
       EPA 1989d)

      70 kg (adult, average; EPA 1989d)
      Age-specific values (EPA 1985a, 1989d)

      Pathway-specific period of exposure for noncarcinogenic effects
       (i.e., ED x  365 days/year), and 70 year lifetime for carcinogenic
       effects (i.e., 70 years x 365 days/year).
        "See Section 6.4.1 and 6.6.1 for a discussion of which variable values should be used to calculate the
         reasonable maximum exposure. In general, combine 95th or 90th percentile values for contact rate
         and exposure frequency and duration variables.

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                                                                                   Page 6-37
                              EXHIBIT  6-13

                     RESIDENTIAL  EXPOSURE:
     DERMAL CONTACT WITH CHEMICALS IN WATER3
Equation: L


Where:
CW =
SA =
PC =
ET =
EF =
ED =
CF =
BW =
AT =
Absorbed Dose (mg/kg-dav) = CW x SA x PC x ET x EF x ED x CF
BWxAT

Chemical Concentration in Water (mg/liter)
Skin Surface Area Available for Contact (cm2)
Chemical-specific Dermal Permeability Constant (cm/hr)
Exposure Time (hours/day)
Exposure Frequency (days/year)
Exposure Duration (years)
Volumetric Conversion Factor for Water (1 liter/1000 cm3)
Body Weight (kg)
Averaging Time (period over which exposure is averaged — days)












Variable Values:
















CW: Site-specific measured or modeled value
SA:
50th Percentile Total Bodv Surface Area (m2) (EPA 1989d. 1985a)
AGE (YRS) MALE FEMALE
3 < 6 0.728 0.711
6 < 9 0.931 0.919
9 < 12 1.16 1.16
12 < 15 1.49 1.48
15 < 18 1.75 1.60
Adult 1.94 1.69
50th Percentile Bodv Part-specific Surface Areas for Males (m2) (EPA 1989d. 1985a)
AGE (YRS) ARMS HANDS LEGS
3 < 4 0.096 0.040 0.18
6 < 7 0.11 0.041 0.24
9 < 10 0.13 0.057 0.31
Adult 0.23 0.082 0.55
















'See Section 6.4.1 and 6.6.1 for a discussion of which variable values should be used to calculate the
  reasonable maximum exposure. In general, combine 95th or 90th percentile values for contact rate and
  exposure frequency and duration variables.  Use 50th percentile values for SA; see text for rationale.
                               (continued)

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Page 6-38
                                   EXHIBIT 6-13 (continued)

                                 RESIDENTIAL  EXPOSURE
               DERMAL CONTACT WITH CHEMICALS IN WATER3
            NOTE: Values for children were calculated using age-specific body surface areas and the average
                    percentage of total body surface area represented by particular body parts in children,
                    presented in EPA 1985a. Values for adults presented in EPA 1989d or calculated from
                     information presented in EPA 1985a. Information on surface area of other body parts (e.g.,
                     head, feet) and for female children and adults also is presented in EPA 1985a, 1989d
                     Differences in body part surface areas between sexes is negligible.
                        PC: Consult open literature for values [Note that use of PC values results in
                              an estimate of absorbed dose.l
                        ET: Pathway-specific value (consider local activity patterns if information
                              is available)
                             2.6 hrs/day (national average for swimming; USDOI in
                              EPA 1988b, EPA 1989d)
                        EF: Pathway-specific value (should consider local climatic conditions
                              [e.g., number of days above a given temperature] and age of potentially
                              exposed population)
                             7 days/year (national average for swimming USDOI in EPA 1988b,
                              EPA 1989d)
                        ED: 70 years (lifetime; by convention)
                             30 years (national upper-bound time (90th percentile) at one residence;
                              EPA 1989d)
                             9 years (national median time (50th percentile) at one residence;
                              EPA 1989d)
                        CF:  1 liter/1000 cm3
                        BW: 70 kg (adult, average; EPA 1989d)
                             Age-specific values (EPA 1985a, 1989d)
                        AT: Pathway-specific period of exposure for noncarcinogenic effects
                              (i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
                              (i.e., 70 years x 365 days/year).
            "See Section 6.4.1 and 6.6.1 for a discussion of which variable values should be used to calculate
             the  reasonable maximum exposure.  In general, combine 95th or 90th percentile values for
             contact rate and exposure frequency and duration variables.

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                                                                                         Page 6-39
that this approach may underestimate dermal
permeability for some organic chemicals.

    To  calculate the  reasonable maximum
exposure for this pathway, 50th percentile values,
instead of 95th percentile values, are used for the
area of  exposed skin (SA).  This is  because
surface  area and body weight are  strongly
correlated and 50th  percentile values are most
representative of the surface  area of individuals  of
average weight (e.g.,  70 kg)  which is assumed for
this and  all other exposure  pathways. Estimates
of exposure for this pathway are still regarded as
conservative  because generally conservative
assumptions   are  used  to estimate   dermal
absorption (PC)  and exposure frequency and
duration.

    Consider pathway-specific variations for the
intake variables. SA  will vary with activity and
the extent of clothing  worn. For example, a
greater skin surface area would be in contact with
water during bathing or swimming than when
wading. Worker exposure via this pathway will
depend on the type of work performed at the site,
protective clothing worn, and the extent of water
use and contact.

6.6.2     CALCULATE SOIL SEDIMENT, OR
         DUST INTAKES

    Individuals may be exposed to chemicals of
potential concern in soil, sediment, or dust by the
following routes:

    (1) incidental ingestion; and
    (2) dermal contact.

Inhalation exposures  to airborne soil or dust are
discussed in Section 6.6.3.

    Incidental ingestion. Calculate intakes from
incidental ingestion of chemicals in  soil by
residents using the equation and variable values
presented in Exhibit 6-14.  Consider population
characteristics that might influence variable values.
Exposure duration (ED) may be less for workers
and recreational users.

    The value suggested for ingestion rate  (IR)
for children 6 years  old and younger are based
primarily on fecal tracer studies and account for
ingestion of indoor dust as  well as outdoor  soil.
These values should be viewed as representative
of long-term average daily ingestion rates for
children and should be used in conjunction with
an exposure frequency of 365  days/year. A term
can be used to account for the fraction of soil or
dust  contacted  that   is  presumed  to  be
contaminated (FI). In some cases, concentrations
in indoor dust can be equal to those in outdoor
soil. Conceivably, in these cases, FI could be
equal to 1.0.

    For ingestion of chemicals in sediment, use
the same equation as that used for ingestion of
soil. Unless more pathway-specific values can be
found in the open literature, use  as  default
variable values the same values as those used for
ingestion of soil.  In most instances, contact and
ingestion of sediments is not a relevant pathway
for industrial/commercial land use (a notable
exception to this could be workers repairing
docks).

    Dermal contact.  Calculate exposure from
dermal contact with chemicals  in soil by residents
using the equation and variable values presented
in Exhibit 6-15. As was the case with exposure to
chemicals in water, calculation of exposure for this
pathway results  in an estimate of the absorbed
dose,  not the amount of chemical in contact with
the skin (i.e.. intake!  Absorption factors (ABS)
are used to reflect the resorption of the chemical
from  soil and the absorption  of the chemical
across  the skin and into the blood stream.
Consult  the open literature for information on
chemical-specific absorption  factors.    In  the
absence  of chemical-specific information, use
conservative assumptions to estimate ABS.

    Again, as with dermal exposure to water, 50th
percentile body surface area (SA) values are used
to estimate contact rates. These values are used
along with average body weight because of the
strong correlation between surface area and body
weight.  Contact rates may vary with time of year
and may be greater for individuals contacting soils
in the warmer months  of the year  when less
clothing is worn (and hence, more skin is available
for contact). Adherence factors (AF) are available
for few soil types and body parts. The literature
should be reviewed to derive AF values for other
soil types and  other body parts.    Exposure
frequency (EF) is generally determined using site-
specific information and  professional judgment.

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Page 6-40
                                       EXHIBIT  6-14

                             RESIDENTIAL  EXPOSURE:

                      INGESTION OF  CHEMICALS  IN SOIL3
            Equation:
                             Intake  (mg/kg-day) = CS x IR x CF x FI x EF x ED
                                                          BWxAT
            Where:
            CS  =   Chemical Concentration in Soil (mg/kg)
            IR  =   Ingestion Rate (mg soil/day)
            CF  =   Conversion Factor (10 6kg/mg)
            FI  =   Fraction Ingested from Contaminated Source (unitless)
            EF  =   Exposure Frequency (days/years)
            ED  =   Exposure Duration (years)
            BW =   Body Weight (kg)
            AT  =   Averaging Time (period over which exposure is averaged — days)
        Variable Values:
                    CS:   Site-specific measured value

                    IR:    200 mg/day (children, 1 through 6 years old; EPA 1989g)
                          100 mg/day (age groups greater than 6 years old; EPA 1989g)

                          NOTE: IR values are default values and could change based
                           on site-specific or other information. Research is currently ongoing
                           to better define ingestion rates. IR values do not apply to individuals
                           with abnormally high soil ingestion rates (i.e., pica).

                    CF:   10 'kg/mg

                    FI:    Pathway-specific value (should consider contaminant location and
                           population  activity patterns)

                    EF:   365 days/year

                    ED:   70 years (lifetime; by convention)
                          30 years (national  upper-bound time (90th percentile) at one
                           residence; EPA 1989d)
                          9 years (national median time (50th percentile) at one residence;
                           EPA 1989d)

                    BW:   70 kg (adult, average; EPA 1989d)
                          16 kg (children 1 through 6 years old, 50th percentile; EPA 1985a)

                    AT:   Pathway-specific period of exposure for noncarcinogenic effects
                           (i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
                           (i.e., 70 years x 365 days/year).
       'See Section 6.4.1 and 6.6.2 for a discussion of which variable values should be used to calculate
        the reasonable maximum exposure. In general, use 95th or 90th percentile values for contact rate
        and exposure frequency and duration variables.

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                                                                                             Page 6-41
                                   EXHIBIT 6-15

                         RESIDENTIAL EXPOSURE:
         DERMAL CONTACT WITH CHEMICALS  IN SOIL3
      Equation:
                  Absorbed Dose (mg/kg-day) = CS \ CF x SA x AF \ ABS x EF * F.n
                                                          BWxAT
      Where:
      CS =
      CF =
      SA =
      AF =
      ABS =
      EF -
      ED =
      BW =
      AT =
    Chemical Concentration in Soil (mg/kg)
    Conversion Factor (10 •• kg/mg)
    Skin Surface Area Available for Contact (cmz/event)
    Soil to Skin Adherence Factor (mg/cm2)
    Absorption Factor (unitless)
    Exposure Frequency (events/year)
    Exposure Duration (years)
    Body Weight (kg)
    Averaging Time (period over which exposure is averaged — days)
  Variable Values:
              CS:   Based on site-specific measured vaiue

              CF:   10'* kg/mg

              SA:

              SOth Percentile Total Body Surface Area (m*) (EPA 1989d. 198Sa)
                          AGE (YRS)

                          3 < 6
                          6 <9
                          9 < 12
                          12  < 15
                          IS  < 18
                          Adult
                                MALE

                                0.728
                                0.931
                                1.16
                                1.49
                                1.75
                                1.94
   EEMALE

   0.711
   0.919
   1.16
   1.48
   1.60
   1.69
              SOth Percentile Body Part-specific Surface Areas for Males (m2) (EPA 1989d. 198Sa)
             AGE (YRS)
             3 < 4
             6 < 7
             9 < 10
             Adult
                          ARMS
                          0.096
                          0.11
                          0.13
                          0.23
0.040
0.041
0.057
0.082
LEGS
0.18
0.24
0.31
0.55
  NOTE:
Values for children were calculated using age-specific body surface areas and the average percentage
of total body surface area represented by particular body parts in children, presented in EPA 1985a.
Values for adults presented in EPA 1989d or calculated from information presented in EPA 1985a.
'See Section 6.4.1 and 6.6.2 for a discussion of which variable values should be used to calculate the reason-
 able maximum exposure. In general, combine 95th or 90th percentile values for contact rate and exposure
 frequency variables. Use SOth percentile values for SA; see text for rationale.
                                    (continued)

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Page 6-42
                                  EXHIBIT  6-15  (continued)

                                RESIDENTIAL  EXPOSURE:
                DERMAL CONTACT WITH CHEMICALS IN SOIL3
             NOTE (continued): Information on surface area of other body parts (e.g., head, feet) and forfemale
                   childen and adults also is presented in EPA 1985a, 1989d. Differences in body part surface
                   areas between sexes is negligible.
                        AF: 1.45 mg/cm2 — commercial potting soil (for hands; EPA 1989d, EPA
                               1988b)
                             2.77 mg/cm2- kaolin clay (for hands; EPA 1989d, EPA 1988b)
                        ABS: Chemical-specific value (this value accounts for resorption of
                              chemical from the soil matrix and absorption of chemical across
                              the skin; generally, information to support a determination of ABS is
                              limited — see text)
                        EF: Pathway-specific value (should consider local weather conditions
                               [e.g.,number of rain, snow and host-free days] and age of potentially
                               exposed population)
                        ED: 70 years (lifetime; by convention)
                             30 years (national upper-bound time (90th percentile) at one residence;
                              EPA 1989d)
                             9 years (national median time (50th percentile) at one residence;
                              EPA 1989d)
                        BW: 70 kg (adult, average; EPA 1989d)
                             Age-specific values (EPA 1985a, 1989d)
                        AT: Pathway-specific period of exposure for noncarcinogenic effects
                              (i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
                              (i.e., 70 years x 365 days/year).
            "See Section 6.4.1 and 6.6.2 for a discussion of which variable values should be used to calculate the
             reasonable maximum exposure. In general, combine 95th or 90th percentile values for contact rate
             and exposure frequency and duration variables.

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                                                                                          Page 6-43
 "Best guess" values for children potentially useful
in risk assessments are 3 times/week for fall and
 spring days (> 32°F) and 5 times/week for summer
days when children are not attending school. As
 discussed previously, in some cases, concentrations
 in indoor dust could be equal to that in outdoor
 environments. Therefore, at some sites, EF could
 be 365  days/year. Worker and recreational user
 contact  rates are dependent on the type of activity
 at the site. Exposure duration (ED) and exposure
 frequency (EF) may  be lower for workers and
recreational users.

     For dermal contact with sediment or dust,
 use the  same equation as that for dermal  contact
with soil. As default values, also use the variable
values given for dermal contact with soil unless
 more pathway-specific values can be found in the
 open literature.   Adherence factors for some
 sediments (particularly sandy  sediments) are likely
 to be much less than for soils because contact
with water may wash the sediment off the skin.
 Exposure frequency for sediments also is probably
 lower than that for soils at many sites.

6.6.3     CALCULATE AIR INTAKES

     Individuals may be exposed to chemicals of
potential concern in air by inhalation of chemicals
 in the vapor phase or adsorbed to particulate.
Dermal absorption of vapor phase chemicals is
considered to be lower than inhalation intakes in
many instances and generally is not considered in
 Superfund exposure assessments.

     As with  other pathways, the  inhalation
intakes  are expressed in units of mg/kg-day. The
combination of inhalation intakes with inhalation
RfDs (expressed in concentration units of mg/m3)
will be  discussed in Chapters 7 and 8.

     Inhalation  of   vapor-phase    chemicals.
 Calculate intakes from inhalation of vapor phase
chemicals using the equation and variable values
presented in Exhibit  6-16. Consider  variations
with land use.  Exposure time (ET) will generally
be less  for workers and recreational users. For
exposure times less than 24 hours per day, an
hourly inhalation rate (IR) based on activity, age,
and sex should be used instead of the daily IR
values.  Exposure duration (ED) may also  be less
for workers and recreational users.
     Inhalation of particulate phase chemicals.
Calculate intakes from inhalation of particulate
phase chemicals by modifying the equations and
variable values presented in Exhibit 6-16 for
vapor-phase  exposures.      Derive inhalation
estimates using the particulate concentration in
air,  the  fraction of the particulate that  is
respirable (i.e., particles 10 urn or less in size)
and the concentration of the  chemical in the
respirable fraction. Note that it may be necessary
to adjust intakes of particulate phase chemicals if
they are to be combined with toxicity values that
are based en exposure to the chemical in the
vapor phase.  This adjustment is done in the risk
characterization  step.

6.6.4     CALCULATE FOOD INTAKES

     Individuals may be exposed by ingestion of
chemicals of  potential concern that  have
accumulated  in food.  The primary food items of
concern are:

     (1) fish  and shellfish;

     (2) vegetables and other produce; and

     (3) meat, eggs, and dairy products (domestic
         and game species).

     Ingestion  of fish and shellfish. Calculate
intakes from  ingestion of fish and shellfish using
the equation and variable values given in Exhibit
6-17. Exposure  will depend in  part on the
availability of suitable  fishing areas. The chemical
concentration in fish or shellfish (CF) should be
the concentration in  the edible tissues (when
available).    The edible tissues will vary with
aquatic species and with population eating habits.
Residents near major commercial or recreational
fisheries or shell fisheries are likely to ingest
larger quantities  of locally caught fish and shellfish
than inland residents. In most instances, workers
are not likely to be exposed via this pathway,
although at some sites this may be possible.

     Ingestion of vegetables  or other produce.
Calculate intakes from ingestion of contaminated
vegetables or other produce using the  equation
and variable  values given in  Exhibit 6-18. This
pathway will  be most  significant for farmers and
for  rural and urban  residents  consuming
homegrown   fruits  and   vegetables.    For

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Page 6-44
                                        EXHIBIT 6-16

                              RESIDENTIAL  EXPOSURE
       INHALATION OF AIRBORNE  (VAPOR  PHASE) CHEMICALS3
            Equation:

                             Intake  (mg/kg-day) = CA x f R x ET x EF x ED
                                                         BWxAT
            Where:
            CA  =  Contaminant Concentration in Air (mg/m3)
            IR    =  Inhalation Rate (in/hour)
            ET  =  Exposure Time (hours/day)
            EF  =  Exposure Frequency (days/year)
            ED  =  Exposure Duration (years)
            BW = Body Weight  (kg)
            AT  =  Averaging Time (period over which exposure is averaged — days)
         Variable Values:
                    CA:    Site-specific measured or modeled value

                    IR:    30 mVday (adult, suggested upper bound value; EPA 1989d)
                           20 mVday (adult, average; EPA 1989d)
                           Hourly rates (EPA 1989d)
                           Age-specific values (EPA 1985a)
                           Age, sex, and activity based values (EPA 1985a)
                           0.6 mVhr — showering (all age groups; EPA 1989d)

                    ET    Pathway-specific values  (dependent on  duration of exposure-related
                            activities)
                           12 minutes — showering (90th percentile; EPA 1989d)
                           7 minutes — showering (50th percentile; EPA 1989d)

                    EF:    Pathway-specific value (dependent on frequency of showering or other
                           exposure-related  activities)

                    ED:    70 years (lifetime; by convention)
                           30 years (national upper-bound time (90th percentile) at one residence;
                           EPA 1989d)
                           9 years (national median time (50th percentile) at one residence;
                           EPA 1989d)

                    BW:   70  kg (adult,  average EPA  1989d)
                          Age-specific values (EPA 1985a,  1989d)

                    AT:   Pathway-specific period of exposure for noncarcinogenic effects
                           (i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
                           (i.e., 70 years x 365 days/year).
      "See Section 6.4.1 and 6.6.3 for a discussion of which variable values should be used to calculate the
       reasonable maximum exposure. In general, use 95th or 90th percentile values for contact rate and
       exposure frequency and duration variables.

       The equation and variable values for vapor phase exposure can be used with modification to calculate
       particulate exposure.  See text.

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                                                                                        Page 6-45
                                  EXHIBIT  6-17
         RESIDENTIAL EXPOSURE:  FOOD PATHWAY -
  INGESTION  OF CONTAMINATED FISH AND  SHELLFISH3
     Equation:
                        Intake (mg/kg-day) = CF x IR x FI x EF x ED
                                                  BWxAT
     Where:
           = Contaminant Concentration in Fish (mg/kg)
           = Ingestion Rate (kg/meal)
           = Fraction Ingested from Contaminated Source (unitless)
           = Exposure  Frequency  (meals/year)
           = Exposure Duration (years)
CF
IR
FI
EF
ED
BW  = Body Weight (kg)
AT  = Averaging Time (period over which exposure is averaged — days)
  Variable Values:
             CF:    Site-specific measured or modeled value

             IR:    0.284 kg/meal (95th percentile for fin fish; Paoe* al 1982)
                    0.113 kg/meal (50th percentile for fin fish; Pao etal 1982)

                    132 g/day (95th percentile daily intakes averaged over three days
                     for consumers of fin fish Pao  etal 1982)
                    38 g/day (50th percentile daily intake, averaged over three days
                     for consumers of fin fish; Pao etal 1982)
                    6.5 g/day (daily intake averaged over a year;  EPA 1989d.
                     NOTE: Daily intake values should be used in conjunction with
                     an exposure frequency of 365 days/year.)
                    Specific values for age, sex,  race, region and fish species are
                     available (EPA 1989d, 1989h)

             FI:    Pathway-specific value (should consider local  usage patterns)

             EF:    Pathway-specific value (should consider local  population patterns
                     if information is available)
                    48 days/year (average per capita for fish and shellfish; EPA Tolerance
                     Assessment System in EPA 1989h)

             ED:    70 years (lifetime; by convention)
                    30 years (national upper-bound time (90th percentile) at  one residence;
                     EPA 1989d)
                    9 years (national median time (50th percentile) at one residence;
                     EPA 1989d)

             BW:    70 kg (adult, average EPA 1989d)
                    Age-specific values (EPA 1985a, 1989d)

             AT:    Pathway-specific period of exposure for noncarcinogenic  effects
                     (i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
                     (i.e., 70 years x 365  days/year).
'See Section 6.4.1 and 6.6.4 for a discussion of which variable values should be used to calculate the
 reasonable maximum exposure. In general, use 95th or 90th percentile values for intake rate and
 exposure frequency and duration variables.

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Page 6-46
                                       EXHIBIT  6-18

              RESIDENTIAL EXPOSURE:  FOOD PATHWAY --
    INGESTION OF  CONTAMINATED FRUITS AND VEGETABLES
           Equation:
                             Intake (mg/kg-day) = CFxIRxFI  xEFxED
                                                        BWxAT
           Where:
               CF
               IR
               FI
               EF
               ED
               BW
               AT
    Contaminant Concentration in Food (mg/kg)
    Ingestion Rate (kg/meal)
    Fraction Ingested  from Contaminated Source  (unitless)
    Exposure Frequency (meals/year)
    Exposure Duration (years)
    Body Weight  (kg)
    Averaging Time (period over which exposure is averaged — days)
        Variable Values:


                   CF:


                   IR:


                   FI:



                   EF:

                   ED:
       Site-specific measured value or modeled value based on soil
        concentration and plant: soil accumulation factor or deposition factors

       Specific values for a wide variety of fruits and vegetables are available
        (Pao et al 1982)

       Pathway-specific value (should consider location and size of
        contaminated area relative to that of residential areas, as well as
        anticipated usage patterns)

       Pathway-specific value (should consider anticipated usage patterns)

       70 years (lifetime; by convention)
       30 years (national upper-bound time (90th percentile) at one residence;
        EPA 1989d)
       9 years  (national median time (SOth percentile) at one residence;
        EPA 1989d)

BW:  70 kg (adult, average EPA 1989d)
       Age-specific values (EPA 1985a, 1989d)

AT:    Pathway-specific period of exposure for noncarcinogenic effects
        (i.e., ED  x 365 days/year), and 70 year lifetime for carcinogenic effects
        (i.e., 70 years x 365 days/year).
      "See Section 6.4.1 and 6.6.4 for a discussion of which variable values should be used to calculate the
       reasonable maximum exposure.  In general, use 95th or 90th percentile values for contact rate and
       exposure frequency and duration variables.

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                                                                                       Page 6-47
 contaminated backyard gardens, the fraction of
 food ingested that is contaminated (FI) can be
 estimated using information on the fraction of
 fruits or vegetables consumed daily that is home
 grown (HF). EPA (1989d) provides HF values for
 fruit  (0.20,  average;  0.30  worst-case) and
 vegetables (0.25,  average; 0.40,  worst-case),
 (Worst-case values can be used as estimates of the
 95th percentile value.) Pao etal. (1982) provides
 specific values for a variety  of fruits and
 vegetables.

    Workers are not likely to be exposed via this
 pathway.  Recreational  users could be  exposed
 from consuming wild fruits or vegetables  from the
 site, although such exposures are likely to be
 negligible.

    Ingestion of meat, eggs, and dairy products.
 Calculate intakes from ingestion of contaminated
 meat and  dairy products using the equation and
 variable values given in Exhibit 6-19. Derive
 pathway-specific values as necessary.    Rural
 residents may consume poultry as well as livestock
 and wild game that have been  exposed  to
 contaminants at the site. The fraction of food
 ingested daily that is contaminated (FI) can be
 estimated for beef and dairy products  using
 information provided in EPA (1989d) on the
 fraction of these foods that is homegrown (HF).
 HF for beef is estimated to be 0.44 (average) and
 0.75 (worst-case).   HF for dairy products is
 estimated  to be 0.40 (average) and 0.75 (worst-
 case).  (Worst-case values can be used as estimates
 of the 95th percentile value.) Consider land-use
 variations. Workers are  not likely to be  exposed
 via this pathway. Exposure duration (ED) and
 exposure frequency (EF)  will likely be less for
 recreational users (e.g., hunters).
6.7      COMBINING  CHEMICAL
         INTAKES ACROSS
         PATHWAYS

    As discussed previously, the RME at a site
reflects the RME for a pathway as well as the
RME  across pathways. A given population may
be exposed to a chemical from several exposure
routes. For example, residents may be exposed to
chemicals in ground water via ingestion  of
drinking water and via inhalation of chemicals that
have volatilized from ground water during its use.
They also could be exposed to chemicals in vapors
or dust that have migrated from the site, To
calculate an  exposure that is a reasonable
maximum across pathways, it may be necessary to
combine the RME for one pathway with an
estimate of more typical exposure for another
pathway (see Section 8.3.1). The  average variable
values identified in the previous sections can be
used to calculate intakes for these more typical
exposures.   At this point in the assessment,
estimated  intakes  are not summed across
pathways;   this is  addressed  in  the  risk
characterization chapter. However, the assessor
should organize the results of the previous
exposure analyses (including any estimates of
typical exposure) by grouping all applicable
exposure pathway for each exposed population.
This organization will allow risks from appropriate
exposures   to  be  combined   in   the risk
characterization chapter (see Exhibit 6-22 for a
sample summary format).
6.8      EVALUATING
         UNCERTAINTY

    The discussion of uncertainty  is a very
important component of the exposure assessment.
Based on the sources and degree of uncertainty
associated with  estimates  of exposure, the
decision-maker will evaluate whether the exposure
estimates are the maximum exposures that can be
reasonably expected to occur. Section 8.4 provides
a discussion of how the exposure uncertainty
analysis is incorporated into the uncertainty
analysis for the entire risk assessment.

    The discussion of uncertainty in the exposure
assessment chapter should be separated into two
parts. The first part is a tabular summary of the
values used to estimate exposure and the range of
these  values.    The table should include the
variables that appear in the exposure equation as
well  as  those used  to estimate  exposure
concentrations (e.g., model variables). A simple
example of this table is shown in Exhibit 6-20.
For each variable, the table should include the
range of possible values, the midpoint of the
range (useful values for this part are given in
Exhibits 6-11 through 6-19), and the value used to
estimate exposure.  In addition,  a brief description

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Page 6-48
                                            EXHIBIT 6-19
                  RESIDENTIAL  EXPOSURE:  FOOD PATHWAY --
                  INGESTION OF CONTAMINATED MEAT, EGGS,
                                    AND DAIRY PRODUCTS  a
               Equation:
                                 Intake  (mg/kg-day) = CF x 1R x FI xJEF x ED
                                                            BW x,
               Where:
                  CF
                  IR
                  FI
                  EF
                  ED
                  BW
                  AT
     Contaminant Concentration in Food (mg/kg)
   Ingestion  Rate  (kg/meal)
   Fraction  Ingested from Contaminated  Source  (unitless)
     Exposure  Frequency (meals/year)
     Exposure  Duration (years)
     Body Weight (kg)
    Averaging Time  (period over which  exposure  is averaged — days)
           Variable Values:
                       CF;
       Site-specific measured or modeled value. Based on soil
        concentrations, plant  (feed)  accumulation factors,  and feed-to-meat
        or feed-to-dairy product transfer coefficients

IR:    0.28 kg/meal — beef (95th percentile Pao et al 1982)
       0.112 kg/meal — beef (50th percentile Pao et al 1982)
       Specific values for other meats are available (Pao et al 1982)

       0.150  kg/meal - eggs (95th percentile; Pao et al 1982)
       0.064 kg/meal - eggs (50th percentile; Pao et al 1982)

       Specific values for milk, cheese and other dairy products are available
        (Pao et al 1982)

FI:    Pathway-specific value (should consider location and  size of contaminated
        area relative to that of residential areas, as well as anticipated usage
        patterns)

EF:    Pathway-specific value  (should consider anticipated usage patterns)

ED:    70 years (lifetime; by convention)
       30 years (national upper-bound time (90tb  percentile) at one residence
        EPA 1989d)
       9 years (national median time (50th percentile) at one residence;
        EPA1989d)

BW:    70 kg (adult, average; EPA 1989d)
       Age-specific values (EPA 1985a, 1989d)

AT:    Pathway-specific period  of exposure for noncarcinogenic effects
        (i.e., ED x 365  days/year), and 70 year lifetime for carcinogenic effects
        (i.e., 70 years x 365 days/year).
          'See Section 6.4.1 and 6.6.4 for a discussion of which variable values should be used to calculate
           the reasonabk maximum exposure. In general, use 95th or 90th percentile values for contact rate
           and exposure frequency and duration.

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                                    EXHIBIT 6-20

          EXAMPLE OF TABLE FORMAT FOR SUMMARIZING
                 VALUES USED TO ESTIMATE EXPOSURE
                                                                                      Page 6-49
Variable
Range
Midpoint
Value Used
 Brief Rationale
 PCB concentration    ND -3,500      250
    in soil (mg/kg)                (arithmetic mean)
 Chronic exposure
    (mg/kg)
                              1,400       95th percentile upperbound
                                         estimate of mean concentration
 Acute exposure
    (mg/kg)
                              3,500
                              Maximum detected concentration
Adult soil ingestion
    rate (mg/d)
 0-170         17
         (arithmetic mean)
                    100        Range based on assumptions
                              regarding soil adherence and
                              percent ingestion. Value used
                              is from EPA 1989g.
 Exposure frequency
   (days/wk)
  1-7
                              Best professional judgment.
 Exposure duration
    (years)
 1-20
   10
     20
Best professional judgment.

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Page 6-50
of the selection rationale should be included. The
discussion that accompanies the table in the
exposure assessment chapter should identify which
variables have the greatest range and provide
additional justification for the use of values that
may be less certain.

    The second part of the uncertainty discussion
is to summarize the major assumptions of the
exposure assessment, to discuss the uncertainty
associated with each, and to describe how this
uncertainty is expected to affect the estimate of
exposure. Sources of uncertainty that should be
addressed include  1) the monitoring data, which
may or may not be representative of actual
conditions at the site;  2) the exposure models,
assumptions and input variables used to estimate
exposure concentrations; and 3) the values of the
intake variables used to calculate intakes. Each
of these sources  should be discussed in the
summary section of the exposure assessment. A
table may  be useful in  summarizing  this
information.   Exhibit 6-21 presents a sample
format.

    A supplemental approach to uncertainty
analysis is to use analytical methods (e.g.,  first-
order uncertainty analysis) or numerical methods
(e.g., Monte Carlo analysis). These methods and
their limitations are described in greater detail in
Section 8.4 It is recommended that these analyses
be used only after approval of the EPA project
manager, and then,  only as a part of the
uncertainty analysis (and not as a basis for the
reasonable maximum exposure).
6.9 SUMMARIZING AND
    PRESENTING THE EXPOSURE
    ASSESSMENT RESULTS

    At this point, the exposure assessor should
summarize the results of the exposure assessment.
The summary information should be presented in
table  format and should list the estimated
chemical-specific intakes for each pathway. The
pathways should be grouped by population so that
risks  can be combined across  pathways as
appropriate. The summary information should be
further  grouped  by current and  future use
categories. Within these categories, subchronic
and chronic daily intakes should be summarized
separately.  Exhibit 6-22 presents a  sample format
for this summary information. In addition to the
summary table, provide sample calculations for
each  pathway, to aid in the review  of the
calculations.

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                                    EXHIBIT  6-21

            EXAMPLE OF AN UNCERTAINTY TABLE FOR
                          EXPOSURE ASSESSMENT
                                                                                             Page 6-51
           ASSUMPTION
                                                    EFFECT ON EXPOSURE '
Potential
Magnitude
for Over-
Estimation
of Exposure
Potential
Magnitude
for Under-
Estimation
of Exposure
Potential
Magnitude
for Over-
or Under
Estimation
of Exposure
   Environmental Sampling and Analysis

        Sufficient samples may not have
        been taken to characterize the media
        being evaluated, especially with
        respect to currently available soil data.

        Systematic or random errors in the
        chemical analyses may yield erroneous
        data.
                                Moderate
                                Low
    Fate and Transport Modeling
       Chemicals in fish will be at            Low
       equilibrium with chemical
       concentrations  in water.

       Use of a Gaussian dispersion model
       to estimate air  concentrations offsite.

       Use of a box model to estimate         Low
       air concentrations onsite.

       Use of Cowherd's model to estimate
       vehicle emission factors.
                                Low
                Moderate
    Exposure Parameter Estimation
       The standard assumptions regarding
       body weight, period exposed, life
       expectancy, population characteristics,
       and lifestyle may not be representative
       of any actual exposure situation.

       The amount of media intake is assumed Moderate
       to be constant and representative
       of the exposed population.

       Assumption of daily lifetime            Moderate to
       exposure for residents.                High

       Use of "hot spot" soil data for          Moderate to
       upper-bound lifetime  exposure         High
                                Moderate
"As a general guideline, assumptions marked as "law", may affect estimates of exposure by less than one
 order of magnitude; assumptions marked "moderate" may affect estimates of exposure by between one and
 two orders of magnitude; and assumptions marked "high" may attect estimates of exposure by more than
 two orders of magnitude.

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Page 6-52
                                        EXHIBIT 6-22

            EXAMPLE  OF TABLE FORMAT FOR SUMMARIZING
              THE RESULTS  OF THE EXPOSURE ASSESSMENT-
                                  CURRENT  LAND USE3
Population
Residents












Exposure Pathway
Ingestion of ground water
that has migrated from
the site to downgradient
local wells


Inhalation of chemicals
that have volatilized from
ground water during use
Ingestion of fish
that have accumulated
chemicals in nearby
lake
Chemical
Benzene
Chlordane
Phenol
Cyanide
Nitrobenzene

Benzene


Chlordane
MEK
Phenol

Chronic Daily Intake
Carcinogenic
Effects
0.00025
0.00015
	 c
c

	 e

0.000013


0.00008
—
	 c

(CDD (ms/ks-dav)
Noncarcinogenic
Effects
b
0.00035
0.1
0.0003
0.0001
b



0.00019
0.005
0.08

        "Similar tables should be prepared for all subchronic daily intake (SDI) estimates as well as for all GDI
         and SDI estimates under future land use conditions.

        ' GDI for noncarcinogenic effects not calculated for benzene because it does not have an EPA-verifi~
         chronic reference dose (as of the publication date of this manual).
        'GDI for carcinogenic effects not calculated for chemicals not considered by EPA to be potential human
         carcinogens (as of the publicatation date of this manual).

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                                                                                                            Page 6-53

                                 REFERENCES  FOR CHAPTER 6
 Baes, C.F., III, Sharp, R.D., Sjoreen, AL., and Shore, R. W. 1984. A Review and Analysis of Parameters for Assessing Transport of
      Environmentally Released Radionuclides through Agriculture. Oak Ridge National Laboratory. Prepared for U.S. Department
      of Energy. ORNL-5786.

 Blank, I.H., Moloney, J., Alfred, B.S., Simon, I., and Apt, C. 1984. The Diffusion of Water Across the Stratum Corneum as a Function
      of its Water Content. J. Invest. Derm.  82188-194.

 Calamari, D., Vighi, M.,  and Bacci, E.   1987. The Use of Terrestrial Plant Biomass as a Parameter in the Fugacity Model.
      Chemosphere. 16:2539-2364.

 Clark, I. 1979. Practical Geostatistics. Applied Science Publishers, Ltd. London.

 Environmental Protection Agency (EPA). 1985a. Development of Statistical Distributions or Ranees of Standard Factors Used in
      Exposure Assessments. Office  of Health and Environmental Assessment.

 Environmental Protection Agency (EPA). 1985b. Compilation of Air Pollutant Emission Factors. Volume 1. Stationary Point and
     Area Sources. Fourth Edition. Office of Research and Development. Research Triangle Park, NC

 Environmental Protection Agency (EPA). 1985c. Environmental Profiles and Ha/ard Indices for Constituents of Municipal Sludge.
      Office of Water. (Individual documents are available for a number of substances).

 Environmental Protection Agency (EPA). 1986a. Guidelines for Exposure Assessment. 51 Federal Regi ster 34042 (September 24,
      1986).

 Environmental Protection Agency (EPA). 1986b. Guidelines for Carcinogen Risk Assessment. 51  Federal  Register 33992 (September
     24, 1986).

 Environmental Protection Agency (EPA). 1987a. Industrial Source Complex (ISC'! Dispersion Model User's Guide. Volume I. Office
     of Air Quality Planning and Standards.  Research Triangle Park NC. EPA/450/4-88/002a.

 Environmental Protection Agency (EPA). 1987b. SslRotinn Criteria fnr Mathematical  Models Used in Exposure Assessments Surface
     Water Models. Office of Health and Environmental Assessment. EPA/600/8-87/042.

 Environmental Protection Agency (EPA). 1988s. Proposed Guidelines for Exposure-related Measurements. 53 Federal Register 48830
     (December 2, 1988).

 Environmental Protection Agency (EPA). 1988b. Suoerfund Exposure Assessment Manual. Office of Emergency and Remedial
     Response. EPA/540/1-88/001. (OSWER Directive 9285.5-1).

 Environmental Protection Agency (EPA). 1988c. Selection Criteria fnr Mathematical Models Used in Exposure Assessment Ground-
     water Models. Office of Health and Environmental Assessment. EPA/600/8-88/075.

 Environmental Protection Agency (EPA). 1989a. Air SiipRrfiinH National Tet-.hnical Guidance Series Volume T-  Application of Air
     Pathway Analyses for Suoerfund Activities. Interim Final. Office of Air Quality Planning and Standards. Research Triangle Park,
     NC.  EPA/450/1-89/001.

Environmental Protection  Agency (EPA). 1989b. Air Snoerfund National Technical Guidance Series.  Volume II:  Estimation  of
     Baseline Air Emissions at Superfund Sites. Interim Final. Office of Air Quality Planning and Standards. Research Triangle Park,
     NC.  EPA/450/1-89/002.

Environmental Protection  Agency (EPA). 1989C.  Air SnperfnnH National Teo.linip.al rriiiHano.e  Series Volume TV" Procedures for
     Dispersion Modeling and Air Monitoring for Suoerfund Air Pathway Analysis. Interim Fina;. Office of Air Quality Planning and
     Standards. Research Triangle Park, NC. EPA/450/1-89/004.

Environmental  Protection Agency  (EPA). 1989d.  Exposure Factors Handbook. Office of Health and Environmental Assessment.
     EPA/600/8-89/043.

Environmental Protection  Agency (EPA). 1989e. PrnpnseH Amendments to the Guidelines for the Health Assessment of Susnect
     Developmental Toxicants. 54 Federal Register 9386 (March 6, 1989).

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Page 6-54


Environmental Protection  Agency  (EPA). 1989f.   Exposure  Assessment Methods Handbook. Draft.  Office  of Health  and
     Environmental Assessment.

Environmental Protection Agency (EPA). 1989g. Interim Final Guidance for Soil Ingestion Rates.  Office of Solid Waste and
     Emergency Response. (OSWER Directive 9850.4).

Environmental Protection Agency (EPA). 1989h. Guidance Manual for Assessing  Human Health Risks From Chemically Contaminated
     Fish and Shellfish. Office of Marine and Estuarine Protection. EPA/503/8-89/002

Fries, G.F., Marrow, G.S., and Gordon,  CH. 1973. Long-term  Studies of Residue Retention  and  Excretion by  Cows  Fed a
     Polychlorinated Biphenyl (Ardor 1254). J. Aerie. Food Chem. 21:117-121.

Gilbert, R.O. 1987. Statistical Methods for Environmental Pollution Monitoring. Van Nostrand Reinhold. New York.

Jensen, D.J., Hummel, RA, Mahle, N.H., Kocher,  CW., and Higgins, H.S. 1981.  A Residue Study on Beef Cattle Consuming 2,3,7,8-
     Tetrachlorodibenzo-p-dioxin. J. Aaric. Food Chem. 29:265-268.

Jensen, D.J. and Hummel, RA. 1982 Secretion of TCDD in Milk and Cream Following the Feeding of TCDD to Lactating Dairy
     Cows. Bull.  Env. Contain. Toxicol. 29:440-446.

Ng, Y.C, Colsher, C.S., Quinn, D.J. and Thompson, S.E. 1977. Transfer Coefficients for the Prediction of the Dose to Man Via the
     Forage-Cow-Miik Pathway from Radionuclides Released to the Biosphere. Lawrence Livermore National Laboratory, Univ.
     California. Prepared for U.S. Dept.  of Energy. UCRL-5139.

Ng, Y.C., Colsher, C.., and Thompson, S.E.  1979. Transfer Factors for Assessing the Dose  from Radionuclides in Agricultural
     Products. Biological Implications of Radionuctides Released From Nuclear Induatries. In:  Proceedings of an International
     Symposium on Biological Implications of Radionuclides Released from Nuclear Induatries. Vienna. March 26-30, 1979. IAEA-
     SM-237/54.  Vol. II.

Ng, Y.C, Colsher,  C.., and Thompson, S.E. 1982 Transfer Coefficients for Assessing the Dose from Radionucfides in Meat and Egg.
     Lawrence Livermore National Laboratory NUREG/CR-2976.

Pao, E.M., Fleming, KH., Gueuther, P.M., and Mickle, SJ. 1982. Food Commonly Eaten  bv Individuals: Amount Per Day and Per
     Eating Occassion.  U.S. Department of Agriculture.

Schaum, J.L 1984. Risk Analysis of TCDD Contaminated Soil. Office of Health and Environmental Assessment, U.S. Environmental
     Protection Agency. EPA/600/8-84/031.

Travis, CC and Arms, AD. 1988. Bioconcentration of Organics in Beef, Milk and Vegetation. Environ. Sci. Teehnol. 22:271-274.

VanBruwaene. R.. Gerber. G.B., Kerchmann. R.. Colard. J. and Van Kerkom. J. 1984. Metabolism  of 51Cr, 54Mn,  5'Fe and "Co
     in Lactating  Dairy Cows Health Physics 46:1069-1082.

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           CHAPTER 7

TOXICITY ASSESSMENT
/FROM:
 •Site discovery
 • Preliminary
  assessment
 •Site inspection
\»NPL listing ^
                    Toxicity
                   Assessment
                                      Risk
                                  Characterization
                    Exposure
                   Assessment
/TO\
  •Selection of
   remedy
  •Remedial
   design
  • Remedial
 . action    >
            TOXICITY ASSESSMENT


       • Gather qualitative and quantitative

         toxicity information for substances
         being evaluated


       • Identify exposure periods for which

         toxicity values are necessary

       • Determine toxicity values for

         noncarcinogenic effects


       • Determine toxicity values for

         carcinogenic effects

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                                    CHAPTER  7
                       TOXICITY  ASSESSMENT
    The purpose of the toxicity assessment is to
weigh available evidence regarding the potential
for particular contaminants to cause adverse
effects in exposed individuals and to provide,
where possible, an estimate of the  relationship
between the extent of exposure to a  contaminant
and the increased  likelihood and/or severity of
adverse effects.

    Toxicity assessment for contaminants found
at Superfund sites  is generally accomplished in
two steps:  hazard identification and dose-response
assessment. These two steps were first discussed
in the National Academy of Sciences' publication
entitled Risk Assessment in the Federal Government
- Managing the Process and more recently in
EPA's Guidelines for Carcinogen Risk Assessment
(NAS 1983, EPA  1986). The first step, hazard
identification,  is the process  of determining
whether exposure to an agent can cause an
increase in the incidence of a particular adverse
health effect (e.g.,  cancer, birth defect) and
whether the adverse health effect is likely to occur
in humans.    Hazard identification involves
characterizing the nature and strength of the
evidence  of causation.  The second step, dose-
response    evaluation  is  the  process  of
quantitatively evaluating the toxicity  information
and characterizing the relationship between the
dose of the contaminant administered or received
and the incidence, of adverse health effects in the
exposed population. From this quantitative dose-
response  relationship, toxicity values (e.g.,
reference doses and slope factors) are derived that
can be used to estimate the incidence or potential
for adverse  effects as a  function of human
 exposure  to the agent.  These toxicity values are
used in the risk characterization step to estimate
the likelihood of adverse effects occurring in
humans at different exposure levels.

    Toxicity  assessment is an integral part of the
overall Superfund site risk assessment. Although
toxicity  information  is  critical to the  risk
assessment, the amount of new toxicological
evaluation of primary data required to complete
this step is limited in most cases.   EPA has
performed the  toxicity assessment step for
numerous chemicals and has  made available the
resulting toxicity information and toxicity values,
which have undergone extensive peer review. At
some sites, however, there will be significant data
analysis and interpretation issues that should be
addressed by an experienced toxicologist.  This
chapter provides step-by-step guidance for locating
EPA toxicity assessments and accompanying
values, and advises how to determine which values
are most appropriate when multiple values exist.
Prior to this procedural discussion, background
        ACRONYMS FOR CHAPTER 7

     ADI = Acceptable Daily Intake
     AIC = Acceptable Intake for Chronic Exposure
     AIS = Acceptable Intake for SvbcbrooJc
           Exposure
  CRAVE ** Carcinogen Risk Assessment
           Verification Endeavor
   ECAO = Environmental Criteria and Assessment
           Office
    HAD ° Health Assessment Document
    HEA « Health Effects Assessment
  HEAST «* Health Effects Assessment Summary
           Tables
   HEED =» Health and Environmental Effects
           Document
   HEBP « Health and Environmental Effects
           Profile
     IRIS = Integrated Risk Information System
  LOAEi. = Lowest-Observed-Adverse-Effcct-Level
  NOAEi. = No-Obserwed-Adverse-Effeet-Level
   NOEL * No-Observed-Bffect-Level
     RfT> • Reference Dose (when used without
           other modifiers, RfD generally refers to
           chronic reference dose)
   R£Ddt - Developmental Reference Dose
    RfD* = Subchronic Reference Dose

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Page 7-2
                                          DEFINITIONS FOR CHAPTER 7                          !

  Acceptable Daily Intake (ADH. An estimate similar in concept to the RfD, but derived using a less strictly defined methodology.
      RfDs have replaced ADIs as the Agency's preferred values for use in evaluating potential noncarcinogenic health effects
      resulting from exposure to a chemical.

  Acceptable Intake for Chronic Exposure fAlC). An estimate similar in concept to the RfD, but derived using a less strictly
      defined methodology.   Chronic RfDs have replaced AlCs as the Agency's preferred values for use in evaluating potential
      noncarcinogenic health effects resulting from chronic exposure to a chemical.

  Acceptable Intake for Subchronic Exposure (AIS).  An estimate similar in concept to  the subchronic RfD, but derived using a
      less  strictly defined methodology,   Subchronic RfDs have replaced AISs  as the  Agency's preferred values  for use  in
      evaluating potential noncarcinogenic health effects resulting from subchronic exposure to a chemical.

  Chronic Reference Dose (RfDI.  An estimate (with uncertainty spanning perhaps an order of magnitude or greater) of a daily
      exposure level for the human population, including sensitive subpopulations, that is likely to be without an appreciable risk
      of deleterious effects during a lifetime.  Chrome RfDs are specifically developed to be protective for long-term exposure
      to a  compound (as a Superfund program guideline, seven years to lifetime).

  Developmental Reference Dose  CRfD^).  An estimate (with uncertainty spanning perhaps an order of magnitude or greater)
      of an exposure level for'the human population, including sensitive subpopulations, that is likely to be without an appreciable
      risk of developmental effects. Developmental RfDs  are used to evaluate the effects of a single exposure event,

  Dose-response Ev^lua^on.   The process of quantitatively evaluating toxicity information and characterizing the relationship
      between the dose of a  contaminant administered or received and the incidence of adverse health effects in the exposed
      population.   From  the quantitative  dose-response  relationship,  toxicity values  are  derived  that are used in the risk
 i    characterization step to estimate the likelihood of adverse effects occurring in humans at different exposure levels.

  Hazard Identification. The  process of determining whether exposure to an agent can cause an increase in the incidence of a
      particular adverse health effect (e.g., cancer, birth defect) and whether the adverse  health effect is likely to occur in humans.

  Integrated Risk Information  System f IRIS). An  EPA data base containing verified RfDs and slope factors and up-to-date health
      risk and EPA regulatory information for numerous chemicals.  IRIS is EPA's preferred source for toxicity information for
      Superfund.

  Lowest-Obsetved-Adverse-Bffect-Level (LQAEL).  In dose-response experiments, the  lowest exposure level at which there are
      statistically or biologically significant increases in frequency or severity of adverse effects between the exposed  population
      and its appropriate control group.

  No-Observed-Adverse-Effect-Level fNOAEL).  In dose-response experiments, an exposure level at which there are no statistically
      or biologically significant increases  in the frequency or severity of adverse effects between the exposed population and its
      appropriate control; some effects may be produced at this level, but they are not considered to be adverse, nor precursors
      to specific adverse effects. In an experiment with more than one NOAEL, the regulatory focus is primarily on the highest
      one, leading to the common usage of the term NOAEL to mean the highest exposure level without adverse effect.

  No-Observed-Effect-Level (NOEL).  In dose-response experiments, an  exposure  level  at which there are no statistically or
      biologically significant increases in the frequency or severity of any effect between the exposed population and its appropriate
      control.

  Reference Dose (RfP').  The Agency's preferred tenacity value for evaluating noncarcinogenic effects resulting from  exposures
      at Superfund sites.  See specific entries for chronic  RfD, subchronic RfD,  and developmental RfD.  The acronym  RfD,
      when used without other modifiers, either  refers genetically to all types  of RfDs  or specifically to chronic RfDs; it never
      refers specifically to subchronic or  developmental RfDs.
                                                         (continued)

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                                                                                              Page 7-3
                                    DEFINITIONS FOR CHAPTER 7
                                               (continued)
  Slope Factor.  A plausible upper-bound estimate of the probability of a response per unit intake of a chemical over a lifetime.
      The slope factor is used to estimate an upper-bound probability of an individual developing cancer as a result of a lifetime
      of exposure to a particular level of a potential carcinogen.

                        CR£D,1. An estimate (with uncertainty spanning perhaps an order of magnitude or greater) of a
      dally exposure level for the human population, including sensitive subpopulalions, that is likely to be without an appreciable
      risk of deleterious effects during a portion of « lifetime (as a Superf und program guideline, two weeks to seven years).

  Tooticitv Value. A numerical expression of a substance's dose-response relationship taat is used in risk assessments. The most
      common toxicity values used la Snperfand program risk assessments arc reference doses (for noncaranogenic effects) and
      slope {actors (for carcinogenic effects).

  Weight-of-Bvidence Classification. An EPA classification system for characterizing the extent to which the available data indicate
      that an agent is a human carcinogen. Recently, EPA has developed weight-of-evidence classification systems for some other
      kinds of toxic effects, such as developmental effects.
information regarding EPA's methods for toxicity
assessment is provided to assist the risk assessor
in understanding the basis of the toxicity values
and the limitations of their use. The steps of the
toxicity assessment are illustrated in Exhibit 7-1.

     Derivation and interpretation of toxicity
values requires  toxicological expertise and should
not be undertaken by those without training and
experience. Detailed guidance for deriving toxicity
values is beyond the scope of this document. For
those persons interested in obtaining additional
information  about EPA's methods for toxicity
assessment,  references to appropriate guidance
documents are  given throughout this chapter.
7.1 TYPES OF  TOXICOLOGICAL
     INFORMATION CONSIDERED
     IN TOXICITY ASSESSMENT

     This section summarizes information from
several EPA documents (especially EPA 1989a,f)
on the basic types of data used  in  toxicity
assessment. As part of the hazard identification
step of the toxicity assessment,  EPA gathers
evidence from a variety of sources regarding the
potential for a substance to cause adverse health
effects (carcinogenic and noncardnogenic) in
humans. These  sources may include controlled
epidemiologic inveatigations,  clinical  studies,  and
experimental    animal  studies.      Supporting
information may be obtained from sources such as
in vitro test results and comparisons of structure-
activity relationships.

7.1.1 HUMAN DATA

    Well-conducted epidemiologic studies  that
show  a positive association between an agent and
a disease are accepted as the most convincing
evidence about human risk. At present, however,
human data adequate to serve as the sole basis of
a dose-response assessment are available for only
a few chemicals. Humans are generally  exposed
in the workplace or by accident, and because these
types  of exposures are not intentional,  the
circumstances of the exposures (concentration and
time)  may  not be  well known.    Often the
incidence of effects is low, the number of exposed
individuals is  small, the latent period between
exposure and disease is long, and exposures are to
mixed and   multiple  substances.  Exposed
populations may be heterogeneous, varying in  age,
sex, genetic  constitution, diet, occupational  and
home  environment, activity patterns, and other
cultural factors affecting susceptibility. For these
reasons,   epidemiologic  data  require careful
interpretation.     If adequate  human studies
(confirmed for validity and applicability) exist
these  studies are  given first priority in the dose-
response assessment, and animal toxicity studies
are used as supportive evidence.

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Page 7-4
                                          EXHIBIT 7-1
                             STEPS IN TOXICITY ASSESSMENT
                               Step 1:  Gather  Toxicity Information--
                                       Qualitative  and Quantitative-
                                       for  Substances Being  Evaluated
                             Step  2: Identify Exposure Periods for
                                    Which  Toxicity Values Are Necessary
                               Step  3: Determine Toxicity Values for
                                      Noncarcinogenic  Effects
                               Step 4: Determine  Toxicity Values for
                                      Carcinogenic Effects
                               Step 5:  Summarize Toxicity Information

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                                                                                         Page 7-5
     Human studies having inadequate exposure-
response information for a quantitative assessment
are often used as supporting data.  Such studies
may establish a qualitative relationship between
environmental exposures and the presence of an
adverse effect in exposed human populations. For
example, case reports of exposures resulting in
effects similar to the types of effects observed in
animals provide support for the conclusions drawn
from the animal data.

7.1.2 ANIMAL DATA

     The toxicity  data base for most chemicals
lacks sufficient information on toxic effects in
humans.   In such cases, EPA may infer the
potential for the substance to cause an adverse
effect in humans from toxicity information drawn
from experiments conducted  on non-human
mammals, such as the rat,  mouse, rabbit, guinea
pig, hamster, dog, or monkey. The inference that
humans and animals (mammals) are similar, on
average, in  intrinsic  susceptibility to toxic
chemicals and that data from animals can in many
cases be used as a  surrogate for data from humans
is the basic premise of modern toxicology. This
concept is particularly important  in the regulation
of toxic chemicals.  There are  occasions, however,
in which observations in animals may be of
uncertain relevance to  humans. EPA considers
the  likelihood that the  agent will have adverse
effects  in humans to increase as similar results are
observed across sexes, strains, species, and routes
of exposure in animal studies.

7.1.3 SUPPORTING DATA

     Several other types  of studies used to support
conclusions about the likelihood of occurrence of
adverse health effects in humans are described
below. At the present time, EPA considers all of
these  types  of data  to  be supportive,  not
definitive, in assessing the potential for adverse
health effects in humans.

     Metabolic and other pharmacokinetic studies
may be used to provide  insights  into  the
mechanism of action of a particular compound.
By  comparing the metabolism  of  a compound
exhibiting a toxic  effect in an animal with  the
corresponding metabolism in humans, evidence for
the  potential of the compound to have toxic
effects in humans may be obtained.
     Studies using cell cultures or microorganisms
 may be used to provide insights into a compound's
 potential for biological activity. For example, tests
 for point mutations,  numerical and structural
 chromosome aberrations, DNA damage/repair, and
 cell transformation may provide supportive
 evidence of carcinogenicity  and may  give
 information on  potential   mechanisms of
 carcinogenicity. It should be noted, however, that
 lack of positive results in short-term tests for
 genotoxicity  is  not considered  a  basis for
 discounting positive results  in long-term
 carcinogenicity studies in animals.

     Structure-activity studies (i.e., predictions of
 toxicologic activity based on analysis of chemical
 structure) are   another potential source  of
 supporting data. Under certain circumstances, the
 known activity of one compound may be used to
 estimate the activity of another structurally related
 compound for which specific  data are lacking.
7.2  TOXICITY ASSESSMENT FOR
     NONCARCINOGENIC  EFFECTS

     This section summarizes how the types of
toxicity information presented in Section 7.1 are
considered in  the  toxicity assessment  for
noncarcinogenic effects.   A reference dose, or
RfD, is the toxicity  value used most often in
evaluating noncarcinogenic effects resulting from
exposures at Superfund sites. Additionally, One-
day or Ten-day Health Advisories (HAs) may be
used to  evaluate  short-term oral exposures. The
methods EPA uses for developing RfDs and HAs
are described below.  Various types of RfDs are
available depending on the exposure route (oral
or inhalation), the critical effect (developmental
or other), and the length of exposure being
evaluated (chronic, subchronic, or single event).
This  section  is intended to be a  summary
description only for additional details, refer to the
appropriate guidelines and other sources listed as
references for this chapter (especially EPA 1986b,
EPA 1989b-f).

    A chronic RfD  is defined as an estimate
(with uncertainty spanning perhaps an order of
magnitude  or greater) of a daily exposure level for
the human population, including  sensitive
subpopulations, that is likely  to be without an

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Page 7-6
appreciable risk of deleterious effects during a
lifetime. Chronic RfDs are specifically developed
to be protective for long-term exposure to a
compound. As a guideline for Superfund program
risk assessments, chronic RfDs generally should be
used to evaluate the potential noncarcinogenic
effects associated with exposure periods between
7 years (approximately 10 percent of a human
lifetime) and a lifetime. Many chronic RfDs have
been reviewed and verified by an intra-Agency
RfD Workgroup and entered into the Agency's
Integrated Risk Information System (IRIS).
          FORMER TERMINOLOGY

    Prior to the development of RfDs, noncareinogenic
   effects of chronic exposures were evaluated using values
   called acceptable daily intakes (ADIsI or acceptable
   intakes for chronic exposure (AICs). While ADIs and
   AICs are similar in concept to RfDs, RfDs have been
   derived using a more strictly defined methodology and
   represent the Agency's preferred toxicity values.
   Furthermore, many chronic RfDs have been reviewed
   and verified by an intra-Agency RfD Workgroup; these
   verified RfDs represent an Agency consensus and are
   preferred over other RfDs that have not undergone such
   review (see Section  7.2.7, Verification of RfDs).
   Similarly, acceptable intakes for subchronic exposures
   fAISsl have been superseded by the more strictly
   defined subchronic RfD values. Therefore, the former
   terminology (ADI, AIC, AIS) should no longer be used
   in Superfund program  risk assessments.
     More recently, EPA has begun developing
subchronic RfDs fRfDsl which are useful for
characterizing potential noncarcinogenic effects
associated with shorter-term exposures, and
developmental RfDs  (RfD.,,s).  which are useful
specifically for assessing potential developmental
effects resulting from exposure to a compound.
As a guideline  for  Superfund program risk
assessments,  subchronic RfDs should be used to
evaluate the potential noncarcinogenic effects of
exposure periods between two  weeks and seven
years. Such short-term exposures can result when
a particular activity is  performed for a limited
number of years or when a chemical with a short
half-life degrades to negligible concentrations
within several months. Developmental RfDs are
used to evaluate the  potential effects on  a
developing organism following  a single  exposure
event.
7.2.1 CONCEPT OF THRESHOLD

    For many noncarcinogenic effects, protective
mechanisms  are believed to exist that  must be
overcome before an adverse effect is manifested
For example, where a large number  of cells
perform the  same or similar function, the cell
population may have to be significantly  depleted
before an effect is seen. As a result, a  range of
exposures exists from zero to some finite value
that can be  tolerated  by the organism  with
essentially no chance of expression of adverse
effects.    In developing a toxicity value for
evaluating noncarcinogenic effects (i.e., an RfD),
the approach is to identify the upper bound of
this tolerance range  (i.e.,  the maximum
subthreshold  level). Because variability  exists in
the human population, attempts are made to
identify a subthreshold level protective of sensitive
individuals in the population. For most chemicals,
this level can  only be estimated; the  RfD
incorporates  uncertainty factors  indicating the
degree or extrapolation  used  to derive the
estimated value. RfD summaries in IRIS also
contain  a statement  expressing  the overall
confidence that the evaluators have in  the RtD
(high, medium, or low). The RfD is generally
considered to have uncertainty spanning an order
of magnitude or more, and therefore the RfD
should not be  viewed as a strict  scientific
demarcation between what level is toxic and
nontoxic.

7.2.2 DERIVATION OF AN ORAL RfD (RfDJ

    Identifying the critical study and determining
the NOAEL.  In the development of oral RfDs, all
available studies examining the toxicity of a
chemical  following exposure by the oral route are
gathered and judged  for  scientific merit.
Occasionally, studies based  on other  exposure
routes (e.g., inhalation) are considered, and the
data are adjusted for application to the oral route.
Any differences between studies are reconciled and
an overall evaluation is reached.  If adequate
human data are available, this information is used
as the basis of the RfD. Otherwise, animal study
data  are used;  in  these cases,  a  series of
professional judgments are made that  involve,
among other considerations, an assessment of the
relevance and scientific quality of the experimental
studies. If data from several animal studies are
being evaluated, EPA first seeks to identify the

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                                                                                               7-7
animal model that is most relevant to humans
based  on a defensible biological rationale, for
instance,   using  comparative   metabolic and
pharmacokinetic data. In the absence of a species
that is clearly the most relevant, EPA assumes
that humans are at least as sensitive to the
substance as the most sensitive animal  species
tested. Therefore, as a matter of science policy,
the study on the most  sensitive species (the
species showing a toxic effect at the lowest
administered dose) is selected as the  critical study
for the basis of the RfD. The effect characterized
by   the    "lowest-observed-adverse-effect-level"
(LOAEL) after dosimetric conversions to adjust
for species differences is referred to as the critical
toxic effect.

    After the critical study and toxic effect have
been selected,  EPA identifies the experimental
exposure  level representing the highest level tested
at which  no adverse effects (including the critical
toxic effect)  were demonstrated. This highest "no-
observed-adverse-effect level" (NOAEL)  is the key
datum obtained from the  study of the dose-
response relationship. A NOAEL observed in an
animal  study  in   which  the  exposure  was
intermittent (such as five days per  week)  is
adjusted  to reflect continuous exposure.

    The NOAEL is selected based in part on the
assumption that if the critical toxic effect  is
prevented, then all toxic effects are prevented.
The NOAEL for the critical toxic effect should
not be confused  with the "no-observed-effect level"
(NOEL). The NOEL corresponds to the exposure
level at which no effect at all has been observed;
frequently,  effects are  observed that are not
considered to be of toxicological significance. In
some  studies,  only a LOAEL rather than a
NOAEL is available. The use of a LOAEL
   MULTIPLE TOXIC EFFECTS AND RfDS

  The RfD is developed from a NOAEL for the most
  sensitive, or critical, toxic effect based in part on the
   assumption that if the critical toxic effect is preventad,
  then all toxic effects are prevented. It should be
  remembered during the risk characterization step of the
  risk assessment that if exposure levels exceed the RfD,
  then adverse effects in addition to the critical toxic
  effect may begin to appear.
however, requires the  use of an additional
uncertainty factor (see below).

    Applying uncertainty factors. The RfD is
derived from the NOAEL (or LOAEL) for the
critical toxic effect by consistent application of
uncertainty factors (UFs) and a modifying factor
(MF). The uncertainty  factors generally consist of
multiples of 10 (although values less than 10 are
sometimes used), with each factor representing a
specific area of uncertainty inherent in  the
extrapolation from the  available data. The bases
for application of different uncertainty factors are
explained below.

     •    A UF of 10 is used to account for
         variation in the  general population  and
         is   intended to   protect   sensitive
         subpopulations (e.g., elderly, children).

     •    A UF of 10 is used when extrapolating
         from animals to humans.  This factor is
         intended to account for the interspecies
         variability between humans and other
         mammals.

     •    A UF of 10 is  used when a NOAEL
         derived from  a subchronic instead of a
         chronic study is used as the basis for a
         chronic  RfD.

     •    A UF of 10 is used when a LOAEL is
         used instead of a NOAEL. This factor
         is   intended  to  account for   the
         uncertainty associated with extrapolating
         from LOAELs to NOAELs.

In addition to the UFS  listed above, a modifying
factor (MF) is applied.

     •    An  MF ranging from  >0 to 10 is
         included  to  reflect  a  qualitative
         professional assessment  of additional
         uncertainties in the critical study and in
         the entire data base for the chemical not
         explicitly addressed by the preceding
         uncertainty factors. The  default value
         for the MF is I.1

To calculate the RfD, the appropriate NOAEL
(or the LOAEL if a suitable NOAEL is  not
available) is divided by the product of all of the

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 Page 7-8
applicable uncertainty factors and the modifying
factor. That is:

     RfD = NOAEL or LOAEL/(UF,x UF2.. x
           MF

Oral  RfDs typically  are  expressed as  one
significant figure in units of mg/kg-day. These
concepts are shown graphically in EPA (1989g).
To date, most RfDs developed by EPA and
included in the sources listed in Section 7.4 are
based on administered doses, not absorbed doses
(see box on page 7-10).

7.2.3  DERIVATION OF AN INHALATION
      RfD (RfD)

     The methods EPA uses in the derivation of
inhalation RfDs are  similar in  concept to those
used  for oral RfDs; however, the actual analysis
of inhalation exposures is more complex than oral
exposures due to (1) the  dynamics  of the
respiratory system and its diversity across species
and (2) differences  in the  physiochemical
properties  of contaminants.      Additional
information  can be found in EPA's Interim
Methods for Development of Inhalation Reference
Doses (EPA 1989d).

     Identifying the critical study and determining
the NOAEL. Although in theory the identification
of the critical study and the determination of the
NOAEL  is  similar for  oral and  inhalation
exposures, several important differences should be
noted. In selecting the most appropriate study,
EPA, considers  differences in respiratory anatomy
and physiology,  as  well  as differences in the
physiochemical  characteristics of the contaminant.
Differences in respiratory anatomy and physiology
may affect the pattern of contaminant deposition
in the respiratory tract, and the clearance and
redistribution of the agent. Consequently, the
different species may  not receive the same dose of
the contaminant at the same locations within the
respiratory tract even though both species were
exposed to the same particle or gas concentration.
Differences in the physiochemical characteristics
of the contaminants, such as the size and shape of
a particle  or whether the  contaminant is an
aerosol or a gas, also influence  deposition,
clearance, and redistribution.
     In inhalation exposures, the target tissue may
be a portion of the respiratort tract or, if the
contaminant can be absorbed and distributed
through the body, some extra respiratory organ.
Because the pattern of deposition may influence
concentrations at the alveolar exchange boundary
or different tissues  of the lung, the toxic health
effect observed may be more directly related to
the pattern of deposition than to the exposure
concentration.  Consequently, EPA  considers the
deposition,  clearance  mechanisms, and the
physiochemical properties of the inhaled agent in
determining the effective dose delivered to the
target organ.

     Doses calculated in  animals are converted to
equivalent doses  in humans on  the basis of
comparative physiological considerations  (e.g.,
ventilator parameters,  regional  lung surface
areas). Additionally, if the exposure period was
discontinuous, it is adjusted to reflect continuous
exposure.

     Applying uncertainty factors. The inhalation
RfD is derived from the NOAEL by applying
uncertainty factors similar to those listed above
for oral RfDs.   The UF of 10 is used when
extrapolating from animals to humans, in addition
to calculation of the human equivalent dose, to
account for interspecific variability in sensitivity to
the toxicant.   The resulting RfD value for
inhalation exposure is generally reported as a
concentration in air (in mg/m3 for continuous, 24
hour/day exposure), although it may be reported
as a corresponding inhaled intake (in mg/kg-day).
A human body weight of 70 kg and  an inhalation
rate  of 20  mVday are used to convert between an
inhaled intake expressed in units of mg/kg-day and
a concentration in air expressed in mg/m3.

7.2.4 DERIVATION OF  A SUBCHRONIC RfD
    The chronic RfDs described above pertain to
lifetime or other long-term exposures and may be
overly protective if used to evaluate the potential
for adverse  health  effects  resulting  from
substantially less-than-lifetime exposures.    For
such situations, EPA has begun calculating toxicity
values  specifically for  subchronic exposure
durations, using a method similar to that outlined
above for chronic RfDs, EPA's Environmental
Criteria  and Assessment   Office develops

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                                                                                         Page 7-9
subchronic RfDs and, although they have been
peer-reviewed by Agency and outside reviewers,
RfDs values have not undergone verification by an
intra-Agency workgroup (see Section 7.2.7). As
a result, subchronic RfDs are considered interim
rather than verified toxicity values and are not
placed in IRIS.

    Development of subchronic reference doses
parallels the  development of chronic reference
doses in concept; the distinction is one of
exposure duration.    Appropriate studies are
evaluated and a subchronic NOAEL is identified.
The RfDsis derived from the NOAEL by the
application of UFs and MF as  outlined above.
When experimental data are available only for
shorter  exposure durations than desired, an
additional uncertainty factor is  applied. This is
similar to the application of the uncertainty  factor
for duration differences when a chronic RfD is
estimated from subchronic animal data. On the
other hand, if subchronic data are missing and a
chronic oral RfD derived from chronic data exists,
the chronic  oral RfD is adopted as the subchronic
oral RfD.    There is  no application  of an
uncertainty factor to account for differences in
exposure duration in this instance.

7.2.5 DERIVATION OF A DEVELOPMENTAL
     TOXICANT RfD (RfDJ

    In developing an RfD^,, evidence is gathered
regarding the potential of a substance to cause
adverse effects in a developing organism as a
result of exposure prior to conception (either
parent), during prenatal  development,  or
postnatally to the time of sexual maturation.
Adverse effects can include death, structural
abnormality, altered  growth,  and functional
deficiencies. Maternal toxicity also  is considered.
The evidence is assessed, and the substance is
assigned a   weight-of-evidence   designation
according  to the scheme outlined below and
summarized in the box in the opposite column.
In this scheme, three levels are  used to indicate
the assessor's degree of confidence in the data:
definitive  evidence, adequate evidence, and
inadequate evidence. The definitive and adequate
evidence categories are subdivided as to whether
the evidence  demonstrates the occurrence or the
absence  of adverse effects.
   WEIGHT-OF-EVIDENCE SCHEME  FOR
        DEVELOPMENTAL TOXICITY

   • Definitive Evidence for:

    - Human Developmental Toxicity

    - No Apparent Human Developmental Toxicity

   • ^Adequate Evidence for

    - Potential Human Developmental Toxicity

    - No Apparent Potential Human Developmental
      Toxicity

   • Inadequate Evidence for Determining Potential
    Human Developmental Toxicity
    After the weight-of-evidence designation is
assigned, a study is selected for the identification
of a NOAEL. The NOAEL is converted to an
equivalent human dose, if necessary, and divided
by uncertainty factors similar to those used in the
development of an oral RfD.    It should be
remembered that the RfDdtis based on a short
duration of exposure because even a single
exposure at a critical time (e.g., during gestation)
may   be  sufficient  to   produce adverse
developmental effects  and that chronic exposure
is not a prerequisite for developmental toxicity to
be manifested.    Therefore, RfDdt values  are
appropriate for evaluating single event exposures,
which usually  are not adjusted based  on the
duration of exposure. Additional information on
the derivation  of RfDdt values is available in
EPA's Proposed Amendments to the Guidelines for
the Health Assessment of Suspect Developmental
Toxicants (EPA 1989e).

7.2.6 ONE-DAY AND TEN-DAY HEALTH
      ADVISORIES

    Reference values that may be useful for
evaluating potential adverse effects associated with
oral exposures of shorter duration have been
developed by the Office of Drinking Water.
These values are known as One-day and Ten-day
Health Advisories,   which  are  issued as
nonregulatory guidance. Health Advisory values
are concentrations  of contaminants in drinking
water  at which adverse  health effects would not be
expected to occur for an exposure of the specified

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     7-10
 duration. The Health Advisory values are based
 on data describing noncarcinogenic effects  and are
 derived by dividing a NOAEL or LOAEL by the
 appropriate uncertainty and modifying factors.
 They are based on a 10-kg child assumed to drink
 1  liter of water per day, and a margin of safety is
 included to protect sensitive members of the
 population.     One-day and Ten-day Health
 Advisories do not consider any carcinogenic risk
 associated with the exposure even if the compound
 is a  potential carcinogen.    For additional
 information on the derivation of Health Advisory
 values, refer to the Agency's guidance document
(EPA 1989c).

 7.2.7 VERIFICATION OF RfDS

     EPA  has formed  an  RfD Workgroup
 composed of members from many EPA offices to
 verify existing Agency RfDs and  to resolve
 conflicting toxicity assessments and toxicity values
 within the Agency.  The Workgroup reviews the
 information regarding the derivation of an RfD
 for a substance and summarizes its evaluations,
 conclusions, and reservations regarding the RfD
 in a standardized summary form from  one to
 several pages in length.   This form contains
 information regarding the development  of the
 RfD,  such as the chosen effect  levels and
 uncertainty factors, as well as a statement on the
 confidence that the evaluators have in the RfD
 itself, the critical study, and the overall data base
 (high, medium, or low). Once verified, these data
           ABSORBED VERSUS
        ADMINISTERED  DOSE

    Toxicity values - for both noncarcinogenic and
   carcinogenic effects - are generally calculated from
   critical effect levels baaed on administered rather than
   absorbed doses. It is important, therefore, to compare
   such toxicity values to exposure estimates expressed as
   intakes (corresponding to administered doses), not as
   absorbed doses. For the few toxicity values that have
   been based on absorbed doses, either the exposure
   estimate  or the toxicity value should be adjusted to
   make the values comparable (i.e., compare exposures
   estimated as absorbed dosesto toxicity values repressed
   as absorbed doses, and exposures estimated as intakes
   to toxicity values expressed as administered doses) See
   Appendix A for guidance on making adjustments for
   absorption efficiency.
 evaluation summaries are entered into IRIS and
 are available for public access.

     Workgroup-approved RfDs are referred to as
 verified RfDs. Those RfDs awaiting workgroup
 approval are referred to as interim RfDs. At the
 time of this manual's publication, only chronic
 RfDs are being verified. No workgroup has been
 established to verify  subchronic  RfDs  or
 developmental RfDs.
 7.3 TOXICITY ASSESSMENT FOR
     CARCINOGENIC EFFECTS

     This section describes how the types of
 toxicity information presented in Section 7.1 are
 considered  in  the  toxicity  assessment for
 carcinogenic  effects.   A  slope factor and the
 accompanying weight-of-evidence determination
 are the toxicity data most commonly used to
 evaluate potential human carcinogenic risks. The
 methods EPA uses to derive these values are
 outlined below. Additional information  can be
 obtained by consulting EPA's Guidelines for
 Carcinogen Risk Assessment (EPA 1986a) and
 Appendix B to IRIS (EPA 1989a).

 7.3.1 CONCEPT OF NONTHRESHOLD
      EFFECTS

     Carcinogenesis, unlike many noncarcinogenic
 health effects,  is  generally thought to be  a
 phenomenon for which risk evaluation based on
 presumption of a threshold is inappropriate. For
 carcinogens, EPA assumes that a small number of
 molecular events can  evoke changes in a single
 cell that can  lead to uncontrolled cellular
 proliferation and eventually to a clinical state of
 disease.     This hypothesized mechanism for
 carcinogenesis is referred to as "nonthreshold"
because there is believed to be essentially no level
 of exposure to such a chemical that does not  pose
 a finite probability, however small, of generating
a carcinogenic response.  That is, no dose is
thought to be risk-free. Therefore, in evaluating
cancer risks, an effect threshold cannot be
estimated. For carcinogenic  effects,  EPA  uses  a
two-part evaluation in which  the  substance  first is
assigned a weight-of-evidence classification, and
then a slope factor is calculated.

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                                                                                         Page 7-11
 7.3.2 ASSIGNING A WEIGHT OF EVIDENCE

     In the first  step  of the  evaluation,  the
 available data are evaluated to determine the
 likelihood that the agent is a human carcinogen.
The evidence is characterized separately for human
studies and animal studies as sufficient, limited,
 inadequate, no data, or evidence of no effect. The
 characterizations of these two types of data are
 combined, and based on the extent to which the
 agent has been shown to be a carcinogen in
 experimental animals or humans, or both,  the
 agent is given a provisional weipht-of-evidence
 classification.    EPA scientists then adjust the
 provisional classification upward or downward,
 based  on  other supporting evidence  of
 carcinogenicity (see Section 7.1.3). For a further
 description of the role of supporting evidence,  see
 the EPA guidelines (EPA 1986a).

   The EPA classification system for weight of
 evidence is shown in the box in the opposite
 column.    This system is adapted  from the
 approach taken by the International Agency  for
 Research on Cancer (IARC 1982).

 7.3.3 GENERATING A  SLOPE FACTOR2

     In the second part  of the evaluation, based
 on the evaluation that the chemical is a known or
 probable human carcinogen, a toxicity value that
 defines quantitatively the relationship between
 dose and response (i.e., the slope factor)  is
 calculated. Slope factors are typically calculated
 for potential carcinogens in classes A, Bl, and B2.
 Quantitative estimation of slope factors for the
 chemicals in class  C proceeds on a case-by-case
 basis.

     Generally, the slope factor is a plausible
 upper-bound estimate  of the probability of a
 response per unit intake of a chemical over a
 lifetime.    The slope factor  is used in risk
 assessments to estimate  an upper-bound lifetime
probability of an individual developing cancer  as
a result of exposure to a particular level of a
potential carcinogen. Slope factors should always
be accompanied  by the weight-of-evidence
classification to  indicate  the strength of the
evidence that the agent is a human carcinogen.

     Identifying the appropriate  data set. In
deriving slope factors, the available information
        EPA WEIGHT-OF-EVIDENCE
      CLASSIFICATION SYSTEM FOR
            CARCINOGENICITY
   Group
Description
     A      Human carcinogen

     Bl or   Probable human carcinogen
     82
            Bl indicates that limited human data are
            available.

            B2 indicates sufficient evidence in
            animals and inadequate or no evidence in
            humans.

     C      Possible human carcinogen

     D      Not classifiable as to human
            carcinogenicity

     E      Evidence of noncarcinogenicity for
            I'timans
about a chemical is evaluated and an appropriate
data set is selected. In choosing appropriate data
sets, human data of high quality are preferable to
animal data. If animal data are used, the species
that responds most similarly to humans (with
respect to factors such as metabolism, physiology,
and pharmacokinetics) is preferred.   When no
clear choice is possible, the most sensitive species
is given the greatest emphasis.  Occasionally, in
situations where no single study is judged most
appropriate,  yet several studies collectively support
the estimate, the geometric mean of estimates
from all studies may be adopted as the slope.
This practice  ensures the inclusion of all relevant
data.

    Extrapolating to lower doses. Because risk
at low exposure levels is difficult to measure
directly either by animal experiments or by
epidemiologic studies, the development of a slope
factor generally entails applying a model to the
available  data set and using  the  model  to
extrapolate from the  relatively  high  doses
administered to experimental animals (or the
exposures noted in epidemiologic studies) to the
lower exposure levels expected for human contact
in the environment.

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 Page 7-12
     A  number of mathematical models and
 procedures have been developed to extrapolate
 from carcinogenic responses observed at high
 doses to responses  expected  at low doses.
 Different extrapolation methods may  provide a
 reasonable fit to the observed data but may lead
 to large differences in the projected risk at low
 doses.   In keeping with EPA's Guidelines for
 Carcinogen Risk Assessment (EPA 1986a) and the
 principles outlined in  Chemical Carcinogens: A
Review of the Science and Its Associated Principles
 (OSTP  1985), the  choice of a  low-dose
 extrapolation model is governed by  consistent
 with current  understanding of the mechanism of
 carcinogenesis, and not solely on goodness-of-fit
 to the observed tumor data.   When data are
 limited and when uncertainty exists regarding the
mechanisms of carcinogenic action, the EPA
 guidelines and OSTP principles suggest that
 models  or procedures that incorporate low-dose
 linearity are preferred when compatible with the
 limited  information available. EPA's guidelines
recommend that the linearized multistage model
 be  employed  in   the absence of  adequate
 information  to the contrary. Among  the other
 models  available are the Weibull, probit,  logit,
 one-hit, and gamma multihit models, as well as
various  time-to-tumor models.   Most of these
 models  are less conservative (i.e., predict lower
cancer potency) than the linearized multistage
model.  These concepts and models are shown
graphically in EPA (1989g) and OTA (1981).

    In  general, after the data are  fit to the
appropriate  model,  the upper 95th percent
confidence limit of the  slope of the resulting  dose-
response curve is calculated. This value is known
as the slope factor  and represents an upper 95th
percent confidence limit on the probability of a
response per unit  intake of a chemical over a
lifetime (i.e.,  there is only a 5 percent chance that
the probability of a  response could be greater than
the estimated  value on the  basis of the
experimental data and model used). In some
cases, slope factors based on human dose-response
data are based on the  "best" estimate instead of
the upper 95th percent confidence limits. Because
the dose-response curve generally is linear only in
the low-dose region, the slope factor estimate only
holds true for low doses. Information concerning
the limitations on use of slope factors can be
found in IRIS.
     Determining equivalent human doses. When
 animal data are used as a basis for extrapolation,
 the human dose that is equivalent to the dose in
 the  animal study  is  calculated using the
 assumption that different species are equally
 sensitive to the effects of a toxicant if they absorb
 the same amount of the agent (in milligrams) per
 unit of body surface area. This assumption is
 made only in the absence of specific information
 about the equivalent doses for the chemical in
 question. Because surface area is approximately
 proportional to the 2/3 power of body weight, the
 equivalent human dose (in mg/day, or other units
 of mass per unit time) is calculated by multiplying
 the animal dose (in identical units) by the ratio of
 human to animal body weights raised to the 2/3
 power. (For  animal doses expressed as mg/kgday,
 the equivalent human dose, in the  same units, is
 calculated by multiplying the animal dose by the
 ratio of animal to human body weights raised to
 the 1/3 power.)

    When using animal inhalation experiments to
 estimate lifetime  human risks for partially soluble
 vapors or gases, the  air concentration (ppm) is
 generally considered to be the equivalent dose
 between species based on equivalent  exposure
 times (measured as fractions of a lifetime). For
 inhalation of particulate or completely absorbed
 gases, the amount absorbed per unit of body
 surface area is considered to be the equivalent
 dose between species.

    Summary of dose-response parameters.
 Toxicity values for carcinogenic effects can be
 expressed in several ways. The slope factor is
 usually, but not  always, the upper 95th percent
 confidence limit of the slope of the  dose-response
 curve and is expressed  as (mg/kg-day)"1. If the
 extrapolation model selected is the linearized
multistage model, this value is also known as the
 q*   That is:

    Slope factor = risk per unit dose
                = risk per mg/kg-day

Where data  permit, slope factors listed in IRIS
are based on absorbed doses, although to date
many of them have been based on administered
doses. (The qualifiers related to absorbed versus
administered dose given in the box on page  7-10
apply to assessment of cancer risk as well as to
assessment of potential noncarcinogenic effects.)

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                                                                                       Page 7-13
     Toxicity values for carcinogenic effects also
 can be expressed  in terms of risk  per unit
 concentration of the substance in the medium
 where human contact occurs. These measures,
 called unit risks, are calculated  by dividing the
 slope factor by 70  kg and multiplying by the
 inhalation  rate  (20 rnVday) or  the water
 consumption rate (2 liters/day), respectively, for
 risk associated with unit concentration in  air or
 water. Where an absorption fraction less than 1.0
 has been applied in deriving the  slope factor, an
 additional conversion factor is necessary in the
 calculation of unit risk so that the unit risk will
 be on an  administered dose basis.   The
 standardized duration assumption for unit risks is
 understood to be continuous lifetime exposure.
 Hence, when there is no absorption conversion
 required:

     air unit risk =   risk per ug/m3
                = slope factor x 1/70 kg x
                    20 in/day x 10"3

    water unit risk = risk per ug/L
                  = slope factor x 1/70 kg x
                     2 L/day x 10"3

 The multiplication by 10"3is necessary to convert
 from mg (the slope factor, or q1*, is given in
 (mg/k-day)"1) to ug (the unit risk is given in
 (ug/m3)4or (ug/L)4).

 7.3.4 VERIFICATION OF SLOPE FACTORS

     EPA formed the Carcinogen Risk Assessment
 Verification Endeavor (CRAVE) Workgroup to
validate Agency carcinogen risk assessments and
 resolve conflicting toxicity values developed by
 various program offices.  Workgroup members
 represent many different EPA offices and are
 scientists experienced in issues related to both the
 qualitative  and quantitative risk assessment  of
 carcinogenic agents. Slope factors verified by
 CRAVE have undergone extensive peer review
 and represent an Agency consensus. CRAVE-
verified review summaries (similar  to  RfD
Workgroup summaries) are entered into  the IRIS
data base.
 7.4 IDENTIFYING APPROPRIATE
     TOXICITY VALUES FOR SITE
     RISK ASSESSMENT

     Using the methods outlined above, EPA has
 performed toxicity assessments for many chemicals
 found at Superfund sites and has made the results
 available for use. This section provides step-by-
 step methods for locating appropriate toxicity
 information, including numerical toxicity values, to
 be used in Superfund risk assessments. Because
 one's confidence in toxicity values depends heavily
 on the data base and the methods of extrapolation
 used in their  development, guidance is  also
 included for identifying  the important information
 on which these values are based.

 7.4.1 GATHER TOXICITY INFORMATION
     FOR CHEMICALS BEING EVALUATED

     In the first step  of the toxicity assessment,
 information is collected regarding the toxic effects
 that occur following exposure to the chemical
 being evaluated.  Particular attention, should be
 paid to the route of exposure, the frequency and
 length of  exposure, and the doses at which the
 adverse  effects are expected to occur. Chemicals
 having potential reproductive or  developmental
 effects should be flagged. Later in the evaluation,
 special reference doses for developmental effects
 can be sought for these  chemicals.

     Several sources may provide useful toxicity
 information and references to primary literature,
 although only some of them should be used as
 sources  for slope factors and reference doses (as
 explained below).

    Integrated Risk Information System (IRIS).3
 IRIS is an EPA data  base containing up-to-date
health risk and EPA  regulatory information for
numerous chemicals. IRIS contains only those
RfDs and slope factors that have been verified by
the  RfD or   CRAVE Workgroups  and
consequently, is  considered to be the preferred
source of  toxicity information.   Information in
IRIS supersedes all  other sources.   Only if
information is  not available in IRIS for the
chemical being evaluated should the sources below
be consulted. IRIS consists of a collection of
computer files on individual chemicals. Existing
information on the  chemicals is updated as new

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Page 7-14
scientific data are reviewed. New files and new
chemicals are added as information becomes
available. These chemical files  contain descriptive
and quantitative information in the following
categories:

    •   oral and inhalation  chronic reference
         doses;

    •   oral and inhalation  slope factors and
         unit  risks  for chronic exposure  to
         carcinogens;

    •   Health Advisories from EPA's Office of
         Drinking Water;

    •   EPA regulatory action summaries; and

    •   supplemental  data  on acute  health
         hazards and physical/chemical properties.

  To  ensure  access to  the  most up-to-date
chemical information, IRIS is  only available on-
line. For information on how  to access this data
base,  call IRIS User Support at 513-569-7254 or
see the Federal Register  notice regarding the
availability of IRIS (EPA 1988a).

    Should EPA regional staff have specific
technical or  scientific questions  about any
verification workgroup's analysis of particular data
cited  in IRIS, the Agency contact for a particular
chemical (identified at the  end of each IRIS file)
should be consulted. If new data are identified
suggesting that existing IRIS information may be
outdated, or if there is concern or disagreement
about the overall findings  of particular files, the
Agency IRIS  coordinator  should be consulted.
The  IRIS  coordinator can  assist  in making
arrangements should discussions with  a verification
workgroup be needed.

    Health Effects Assessment Summary Tables
(HEAST).    Formerly "The Quarterly" and
associated references, HEAST is a tabular
presentation of toxicity information and values for
chemicals for which Health Effects Assessments
(HEAs), Health and  Environmental Effects
 Documents (HEEDs), Health and Environmental
Effects Profiles (HEEPs), Health Assessment
Documents (HADs), or Ambient' Air Quality
Criteria Documents (AAQCDs)  have been
prepared. HEAST summarizes interim (and some
verified) RfDs and slope factors as well as other
toxicity information for specific chemicals.  In
addition, HEAST directs readers to the most
current sources of supporting toxicity information
through an extensive reference  section. Therefore,
HEAST  is  especially helpful when verified
information for  a chemical  is not in IRIS.
HEAST, which is updated quarterly, also provides
a valuable pointer system for identifying current
references on chemicals that are not in IRIS.

    HEAST can be obtained upon request from
the Superfund Docket (FTS  or 202-382-3046).
The Docket will mail copies of HEAST to callers
and place requesters on a mailing list to receive
an updated version quarterly. HEAs, HEEDs,
HEEPs, HADs, and AAQCDS referenced  in
HEAST are  available through EPA's Center for
Environmental Research Information (CERI)  in
Cincinnati, OH (513-569-7562  or FTS 684-7562)
or the National Technical Information Service
(NTIS), 5285 Port Royal Road, Springfield, VA
22161 (703-487-4650 or 800-336-4700).

    EPA criteria documents. These documents
include drinking water criteria documents, drinking
water Health Advisory summaries, ambient water
quality criteria documents, and air quality criteria
documents,    and   contain   general toxicity
information  that can be used if information for a
chemical is not available through IRIS or the
HEAST references.   Criteria documents are
available through NTIS at the address given above.
Information on drinking water  criteria documents
can be obtained through the Safe Drinking Water
Hotline (800-426-4791).

    Agency for Toxic Substances and Disease
Registry (ATSDR)  toxicological profiles.  ATSDR
is developing toxicological  profiles for 275
hazardous substances found at Superfund sites.
The first 200 substances to be addressed have
been identified in Federal Register notices (EPA
1987, 1988b).   These profiles contain general
toxicity information and levels  of exposure
associated with lethality,  cancer,  genotoxicity,
neurotoxicity, developmental and reproductive
toxicity, immunotoxicity, and systemic toxicity (i.e.,
hepatic,   renal,    respiratory,    cardiovascular,
gastrointestinal, hematological, musculoskeletal,
and dermal/ocular effects).   Health effects in
humans and animals are discussed by exposure
route (i.e.,  oral,  inhalation,  and dermal) and

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                                                                                             Page 7-15
                            HIERARCHY OF TOXICITY INFORMATION

     Because toxcity information may change rapidly and quickly become outdated, care should be taken to find the most recent
   information available. IRIS is updated monthly, provides verified RfDs and slope factors, and is the Agency's preferred source
   of toxicity information.  Only if values unavailable in IRIS should  other  information  sources be consulted.

   HEAST is the second most current source of toxicity information of importance to Superfund. Unlike IRIS, HEAST provides
   information regarding interim as well as verified RfDs and slope factors. Readers are directed to supporting toxicity information
   for interim and verified values in an extensive reference section of HEAST. HEAST informatiom should only be sought for those
   chemicals not listed in IRIS..

     Toxicity information, RfDs, and slope factors also can be found in other EPA documents. Although these values were
   developed by offices within the Agency, they have not necessarily been verified by the RfD or CRAVE Workgroups. The use
   of up-to-date verified information is preferred to the use of interim information and, therefore, toxicity information should be
   obtained from other EPA references only if informatkm could not be found in IRIS or HEAST. Before using references other
   than those cited in IRIS or HEAST, check with ECAO at 513-569-7300 (FTS 684-7300) to see if more  current information is
   available.
duration (i.e., acute, intermediate, and chronic).
Also included in the profiles are chapters on
physiochemical properties, environmental fate,
potential for human exposure,  analytical methods,
and regulatory and advisory status. Contact NTIS
at the address given on the  previous page for
further information on the status or availability of
a particular profile.

     EPA's    Environmental    Criteria    and
Assessment Office (ECAO).    ECAO may be
contacted at 513-569-7300 (FTS 684-7300) for
general toxicological information as well as for
technical guidance concerning route-to-route
extrapolations,   toxicity   values  for  dermal
exposures, and the evaluation of chemicals without
toxicity values. The requestor should identify their
need for a "rapid response request" (within 48
hours) for interim guidance on Superfund health-
related issues.  Contractors must give  the name
and address of their RPM or regional  risk
assessment contact before ECAO will respond.
RPMs and regional contacts will  be sent a copy
of ECAO's response to the contractor.

     Open literature. A primary literature  search
may be valuable for determining whether new data
are available that may affect IRIS information.

7.4.2 DETERMINE TOXICITY VALUES FOR
      NONCARCTNOGENIC  EFFECTS (RfDs)

     After general toxicity information for the
chemicals of concern has been located, the next
step is to identify the appropriate  toxicity values
to be used in evaluating noncarcinogenic effects
associated with the specific exposures being
assessed.    First, by referring to the exposure
information generated in Chapter 6, the exposure
periods for which toxicity values are necessary and
the exposure route for each chemical being
evaluated should be determined. The appropriate
toxicity values for the chemical for each exposure
duration  and route of exposure can then be
identified using the sources listed above.

     For Superfund risk assessments, chronic RfDs
should be identified for evaluating exposure
periods between seven years and a  lifetime,
subchronic RfDs for exposure periods between two
weeks and seven years, and One- or Ten-day
Health Advisories for oral exposure periods of less
than two weeks. According to  EPA (1988c), One-
day Health Advisories are applicable to exposure
periods as long as five days and Ten-day Health
Advisories are applicable to exposure periods as
long as two weeks.   Developmental RfDs should
be identified for evaluating single exposure events
and other very short exposures (e.g., one day).
Note that for some substances  and  some exposure
situations, more than one of the toxicity values
listed above may be needed to adequately assess
potential  noncarcinogenic effects.

     Because carcinogens also commonly evoke
noncarcinogenic effects, RfDs should be sought for..
all chemicals  being  carried  through the risk
assessment, including carcinogens.   The RfDs
derived for carcinogens,  however, are based on
noncancer effects and should  not be assumed to

-------
 Page 7-16
 be protective against carcinogenicity. A sample
 format for summarizing RfDs and other toxicity
  values is shown in Exhibit 7-2. This information
 will be needed in the risk characterization step
 (see Exhibits 8-3 and 8-4).

 7.4.3 DETERMINE TOXICITY VALUES FOR
       CARCINOGENIC EFFECTS (SLOPE
       FACTORS)

     In this  step  of the toxicity assessment,
 appropriate toxicity values for evaluating the
 carcinogenic risks associated with exposure are
 identified.    First, by referring to the exposure
 information generated in Chapter 6, the route of
 exposure for the potential  carcinogens being
 evaluated should be identified. Slope factors for
 these  chemicals can then be  identified using the
 hierarchy of sources listed in the box on page
 7-15.  Slope factors for all potential carcinogens
 having a weight-of-evidence classification of A, B,
 or C should be sought. A notation of the EPA
 weight-of-evidence classification should always be
 included with the slope factor. A sample format
 for summarizing the required toxicity values is
 shown in Exhibit 7-3.  This information will  be
 needed in the  risk characterization step  (see
 Exhibit 8-2).
 7.5 EVALUATING CHEMICALS
     FOR WHICH NO TOXICITY
     VALUES ARE AVAILABLE

     If EPA-derived RfDs and slope factors are
 available for the chemicals being examined, these
 values should always  be used  in  the risk
 assessment. Use of EPA-derived toxicity values
 prevents duplication of effort  and ensures
 consistency among risk  assessments.   If EPA-
 derived toxicity values are not available, the
 following measures  are recommended.

 7.5.1 ROUTE-TO-ROUTE EXTRAPOLATION

     For cases in which EPA-derived toxicity
values are not available for the route of exposure
 being  considered but are available for another
 route,  EPA recommends contacting ECAO for
 guidance on route-to-route extrapolation. If
 toxicity information is not available from ECAO,
 a qualitative rather than quantitative evaluation of
the chemical is recommended. The implications
of the absence of this chemical from the risk
estimate should be discussed in the uncertainty
section.

7.5.2 DERMAL EXPOSURE

    No RfDs  or slope factors are available for
the dermal route of exposure. In some cases,
however, noncarcinogenic or carcinogenic risks
associated with dermal exposure  can be evaluated
using  an  oral  RfD  or  oral slope factor,
respectively. EPA recommends contacting ECAO
for guidance on  appropriate  methods for
evaluating dermal exposure for specific chemicals;
some general guidance for calculating intakes via
the dermal route  and  making appropriate
comparisons with oral RfD values is given in
Appendix A. In brief, exposures via the dermal
route generally are calculated and expressed as
absorbed doses.    These absorbed doses are
compared to an oral  toxicity value that has been
adjusted, if necessary, so that it too is expressed
as an absorbed dose.

    It is inappropriate  to use the oral  slope
factor to evaluate  the risks associated  with dermal
exposure to carcinogens  such as benz(a)pyrene,
which cause skin cancer through  a direct action at
the point of application. These types of skin
carcinogens and other locally active  compounds
must be evaluated separately from the above
method; consult ECAO for guidance. Generally
only a qualitative  assessment of risks from dermal
exposure to  these  chemicals is  possible. This does
not apply to carcinogens  such as arsenic, which
are believed to  cause skin cancer through a
systemic rather than local action.

    If information is not available from ECAO,
the assessor should describe the effects of the
chemical qualitatively and discuss the implications
of the absence of the chemical from  the risk
estimate in the uncertainty section of the risk
assessment.

7.5.3 GENERATION OF TOXICITY VALUES

    If EPA-derived toxicity values are unavailable
but adequate toxicity studies  are available, one
may derive toxicity  values  using  Agency
methodology. Any such derivation should be done

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                                                   EXHIBIT 7-2

                                     EXAMPLE OF  TABLE FORMAT FOR
                   TOXICITY  VALUES:  POTENTIAL  NONCARCINOGENIC  EFFECTS
Chronic RID" Confidence Critical RfD Basis/
Chemical (mg/kg-day) Level* Effect RfD Source
Oral Route
Phenol 0.6* Medium Kidney and Wates*/
liver effect* IRIS
Nitrobenzene 0.0005* Medium Hematologic. Water*/
adrenal, kidney. IRIS
and liver effects
Inhalation Route
Uncertainty and
Modifying Factors

UF = 1.000* for
HAAL
MF - 1
UF - 10,000 for
H.A&L
MF- 1
—
• Values for illustration only.

* Similarly formatted tables abo could be used for subchronic and shorter-term ttnddty values.

* Confidence level from IRIS, either high, medium, or low.

c RfD expressed as administered dose in drinking water, with assumed absorption fraction of 1.0.

* Uncertainty adjustment of 1,000 used to represent combined H, A, S, and L extrapolations.

   Uncertainty adjustments:  H = variation in human sensitivity;
                      A - animal to human extrapolation;
                      S » extrapolation from subchronic to chronic NOAEL;
                      L " extrapolation from LOAEL to NOAEU

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Page 7-18
                                EXHIBIT 7-3

                    EXAMPLE OF TABLE FORMAT FOR
        TOXICITY VALUES: POTENTIAL CARCINOGENIC EFFECTS
Slope Factor (SF) Weight-of -Evidence Type of
Chemical (mg/kg-day)"1 Classification Cancer1
Oral Route
Benzene 0.029* A* Leukemia

Chlordane L3* B2*

Inhalation Route
SF Basis/
SF Source

Water'/
IRIS
Water'/
IRIS

    * Values for illustration only.

    "Identify type(s) of cancer in this table for Class A carcinogens only.

    b Slope factor based on administered dose in drinking water and assumed absorption fraction of 1.0.

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                                                                                       Page 7-19
in conjunction with the regional risk assessment
contact, who will submit the derivation to ECAO
for  approval.  Contact with ECAO should be
established early in the process to eliminate any
duplication of effort because ECAO may  have
information on the chemical being evaluated.
7.6  UNCERTAINTIES  RELATED
     TO TOXICITY INFORMATION

     Toxicity  information  for  many  of the
chemicals  found at Superfund sites is often
limited. Consequently, there are varying degrees
of uncertainty associated with the toxicity values
calculated. Sources of uncertainty associated with
toxicity values may include

     •    using dose-response information from
         effects observed at high doses to predict
         the adverse health effects that may occur
         following exposure to the low levels
         expected from human contact with the
         agent in the environment

     •    using dose-response information from
         short-term exposure studies to  predict
         the effects of long-term exposures, and
         vice-versa;

     •    using dose-response information from
         animal  studies to  predict  effects in
         humans; and

     •    using dose-response information from
         homogeneous animal populations or
         healthy human populations to predict the
         effects likely to be  observed in the
         general  population consisting  of
         individuals with  a  wide range of
         sensitivities.

     An understanding   of  the  degree  of
uncertainty associated with toxicity values is an
important part of interpreting and using those
values.    Therefore, as part  of the toxicity
assessment for Superfund sites, a discussion of the
strength of the evidence of the entire range of
principal and supporting  studies should be
included. The  degree of confidence ascribed to
a toxicity value is a function of both the quality
of the individual study from which it was  derived
and the completeness of the supporting data
base.  EPA-verified RfDs found in IRIS are
accompanied by a statement of the confidence that
the evaluators have in the RfD itself, the critical
study, and the overall data base. All EPA-verified
slope factors are accompanied by a weight-of-
evidence classification, which  indicates the
likelihood that the agent is a human carcinogen.
The weight-of-evidence classification is based on
the completeness of the  evidence that the agent
causes cancer in  experimental animals  and
humans.  These designations should be used as
one basis for the discussion of uncertainty.

    The discussion of uncertainty also should
include an indication of the extent to which an
analysis of the  results from different studies give
a consistent, plausible picture of toxicity.  The
greater the strength of the evidence, the greater
one's confidence in the conclusions drawn.  The
following factors  add to the strength of the
evidence that the chemical poses a hazard to
humans and should be considered:

     •   similar effects across species, strains, sex,
         and routes of exposure;

     •   clear evidence of a  dose-response
         relationship;

     •   a plausible relationship among data on
         metabolism,  postulated  mechanism of
         action, and the effect of concern  (see
         Section 7.1.3);

     •   similar toxicity  exhibited by structurally
         related compounds (see Section 7.1.3]
         and

     •   some link between the chemical and
         evidence of the effect  of concern in
         humans (see Section 7.1.1).

     High uncertainty  (low  confidence;  low
strength  of evidence)  indicates that the toxicity
value might change if additional chronic toxicity
data become available.  Low uncertainty (high
confidence) is an indication that  a value is less
likely to change as more data become available,
because there is consistent among the toxic
responses observed in different species, sexes,
study designs, or in dose-response relationships.
The  lower the uncertainty about toxicity values,

-------
Page 7-20
the more confidence a decision-maker can have in
the risk assessment results.     Often,  high
confidence is associated with values that are based
on human data for the exposure route of concern.
7.7  SUMMARIZATION  AND
    PRESENTATION  OF  THE
    TOXICITY  INFORMATION

    This section discusses methods for presenting
toxicity information  in the risk assessment
document for the chemicals being evaluated.

7.7.1 TOXICITY INFORMATION FOR THE
      MAIN BODY OF THE TEXT

    A short description of the toxic effects of
each chemical carried through the assessment in
non-technical  language should  be prepared for
inclusion in the main body of the risk assessment.
Included in this description should be information
on the effects associated with exposure to the
chemical and the concentrations at which the
adverse effects are  expected to occur in humans.
Toxicity values should be accompanied by a brief
description of the overall data base and the
particular study from which the value was derived.
In addition, a notation should be made of the
critical effect and any uncertainty factors used in
the calculation. For any RfD value obtained from
IRIS, a notation of the degree of confidence
associated with the determination should also be
included. To aid in the risk characterization, it
should be indicated if absorption efficiency was
considered and also what exposure averaging
periods are appropriate for comparison with the
value.

     Summary tables of toxicity values for all
chemicals should be prepared for inclusion in the
main body of the risk assessment report. RfDs in
the  table should be accompanied with the
uncertainty factors used in their derivation, the
confidence rating given in IRIS (if applicable), and
a notation of the critical effect. Slope factors
should always be accompanied by EPA's weight-
of-evidence classification.

7.7.2 TOXICITY INFORMATION FOR
      INCLUSION IN AN APPENDIX

     If toxicity values were derived in conjunction
with the regional risk assessment contact and
ECAO for chemicals lacking EPA-derived values,
a technical  documentation/justification  of the
method of derivation should be prepared and
included in the appendix of the risk assessment
report. Included in this explanation should be  a
description of the toxic  effects of the chemical
such as information regarding the noncarcinogenic,
carcinogenic,   mutagenic,   reproductive,   and
developmental  effects of the compound.  Also
presented should be brief descriptions (species,
route of administration, dosages, frequency of
exposure, length of exposure, and critical effect)
of the studies from which the values  were derived
as well as the actual method of derivation.
References for the studies cited in the discussion
should be included.

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                                                                                                       Page 7-21


                                  ENDNOTES FOR CHAPTER  7



1. The MF is set less than one for a and number of subatances to account for nutritional essentiality.

2. The slope factor is occasionally referred to as a cancer potency factor; however, use of this terminology is not recommended.

3. The quantitative risk values and supporting information found in IRIS representa consensus judgement of EPA's Reference Dose
Workgroup or Carcinogen Risk Assessment Verification Endeavor (CRAVE) Workgroup. These workgroups are composed of scientists
from EPA's program offices and the Office of Research and Development. The concept of Agency-wide consensus is one of the moat
valuable aspects of IRIS.

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Page 7-22


                                 REFERENCES FOR CHAPTER 7
Environmental Protection Agency (EPA). 1986a. Guidelines for Carcinogen Risk Assessment. 51 Federal Register 33992 (September
     24, 1986).

Environmental Protection Agency (EPA). 1986b. Guidelines for the Health Assessment of Suspect Developmental Toxicants. 51
     Federal Register 34028 (September 24, """
Environmental Protection Agency (EPA). 1987. First Priority List of Hazardous Substances That Will Be the Subject of Toxicological
     Profiles. 52 Federal Register 12866 (April  17, 1987).

Environmental Protection Agency (EPA). 1988a. Availability of the Integrated Risk Information System (IRIS). 53 Federal Register
     20162 (June 2, 1988).

Environmental Protection Agency (EPA). 1988b. Hazardous Substances List, Toxicological List, Toxicological Profiles; Second List. 53 Federal
     Register 41280 (October 20, 1988)

Environmental Protection Agency (EPA). 1988c. Office of Drinking Water Health Advisories.  Reviews of Environmental
     Contamination and Toxicology 104.

Environmental Protection Agency (EPA). 1989a. EPA Approach for Assessing the Risk Associated with Exposure to Environmental
     Carcinogens. Appendix B to the Integrated Risk Information System (IRIS).

Environmental Protection Agency (EPA).  1989b. General Quantitative Risk Assessment Guidelines for NonCancer Health Effects.
     External Review Draft. Risk Assessment Forum Technical Panel on Risk Assessment Guidelines for Noncancer Health Effects.
     ECAO-CIN-538.

Environmental Protection Agency (EPA). 1989c. Guidelinces for Authors of EPA Office of Water Health Advisories for Drinking Water
     Contaminants. Office of Drinking Water.

Environmental Protection Agency (EPA). 1989d. Interim Methods for Development of Inhalation Reference Doses.  Environmental
     Criteria and Assessment Office. EPA/600/8-88/066F.

Environmental Protection Agency (EPA). 1989e. Proposed Amendments to the Guidelines for the Health Assessment of Suspect
     Developmental Toxicants. 54 Federal Register 9386 (March 6, 1989).

Envionmental Protection Agency (EPA). 1989f.  Reference  Dose  (RfDl: Description and Use in Health Risk Assessments. Appendix
     A to the Integrated Risk  Information System (IRIS).

Environmental Protection Agency (EPA). 1989g. Guidance Manual for  Assessing Human Health Risks from Chemically Contaminated
     Fish and Shellfish. Office of Marine and Estuarine Protection. EPA/503/8-89/002

International Agency for Research on Cancer (IARC). 1982. TARC Monographs on the Evaluation of the Carcinogenic Risk of
     Chemicals to Humans. Supplement 4. Lyon, France.

National Academy of Sciences (NAS). 1983. Risk Assessment in the Federal  Government: Managing the Process. National Academy
     Press. Washington, D.C

Office of Science and Technology Policy (OSTP). 1985. Chemical Carcinogens A Preview of the Science and Its Associated Principles.
     50 Federal Register 10372 (March 14,  1985).

Office of Technology Assessment (OTA). 1981.  Assessment of Technologies for Determining Cancer Risks from the Environment.
     Congress of the United  States.  Washington, D.C

-------
              CHAPTER 8

RISK  CHARACTERIZATION
/FROM:
 •Site discovery
 • Preliminary
  assessment
 •Site inspection
\»NPL listing ^
                       Toxicity
                      Assessment
  Data   i    Data
Collection \  Evaluation
    Risk
Characterization
                       Exposure
                      Assessment
             RISK CHARACTERIZATION

            > Review outputs from toxicity and
             exposure assessments

            Quantify risks from individual
            chemicals

            1 Quantify risks from multiple
            chemicals

            1 Combine risks across exposure
             pathways

            1 Assess and present uncertainty

            1 Consider site-specific human
            studies
•Selection of
 remedy
• Remedial
 design
• Remedial
 action

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                                   CHAPTER  8
                   RISK   CHARACTERIZATION
   This chapter describes the final step of the
baseline health risk assessment process, risk
characterization.   In this step, the toxicity and
exposure  assessments are summarized and
integrated into quantitative and qualitative
expressions of risk.   To characterize potential
noncarcinogenic effects, comparisons are  made
between projected  intakes of substances and
toxicity   values; to   characterize   potential
carcinogenic   effects,   probabilities that an
individual will develop  cancer over a lifetime of
exposure are estimated from projected intakes and
chemical-specific   dose-response    information.
Major assumptions,  scientific judgments, and to
the extent possible, estimates of the uncertainties
embodied in the assessment are also presented.

   Risk characterization also serves as the bridge
between risk assessment  and risk management and
is  therefore a  key step in the ultimate site
decision-making process. This step assimilates risk
assessment information for the risk manager
(RPM or regional upper management involved in
site decision-making) to be considered alongside
other factors important for decision-making such
as  economics, technical feasibility, and regulatory
context.    The risk characterization methods
described in this chapter are consistent with EPA's
published risk assessment guidelines. Exhibit 8-1
is  an overview of  risk characterization, and
illustrates how it relates to the preceding toxicity
and exposure assessments and to the refinement
of preliminary remediation goals.

   In   the  following  sections,  the   risk
characterization methodology is described. There
are separate discussions for carcinogenic and
noncarcinogenic effects because the methodology
differs for these two modes of chemical toxicity.
In addition to giving instructions for calculating
numerical estimates of risk, this  chapter provides
guidance for   interpreting, presenting,  and
qualifying the results.   A risk characterization
cannot  be  considered complete unless  the
numerical expressions of risk are accompanied by
explanatory  text interpreting and qualifying the
results
8.1  REVIEW OF  OUTPUTS FROM
      THE TOXICITY AND
      EXPOSURE  ASSESSMENTS

   Most sites being assessed will involve the
evaluation of more than one chemical of concern
and  might   include both carcinogenic   and
noncarcinogenic substances. The first step in risk
characterization is to gather, review, compare, and
organize the results of the exposure assessment
(e.g., intakes for all exposure pathways and land-
uses  and for all relevant substances) and toxicity
assessment (e.g., toxicity values  for all exposure
       ACRONYMS FOR CHAPTER 8
 ARAR «

 ATSDR=

   CDI *
 ECAO =

     E =
    HI =
   IRIS =
LOAEL =
NOAEL =
  NRC =
   RfD <*
  R1DS
  RJ/FS
  RME <
   SDI
    SF
           Applicable or Relevant and Appropriate
           Requirement
           Agency for Toxic Substances and Disease
           Registry
           Chronic Daily Intake
           Environmental Criteria and Assessment
           Office
           Exposure Level
           Hazard Index
           Integrated Risk Information System
           Lowest-Observed-Adverse-Bffect-Level
           No-Observed-Adverse-Effect-Level
           Nuclear Regulatory Commission
           Reference Dose {when used without
           other modifiers, RfD generally refers to
           chronic reference dose)
           Developmental Reference Dose
           Subchronic Reference Dose
           Remedial Investigation/Feasibility Study
           Reasonable Maximum Exposure
           Subchronic Daily Intake
           Slope Factor

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Page 8-2
                                         DEFINITIONS FOB CHAPTER 8

    Absorbed Pose.  The amount of a substance penetrating the exchange boundaries of an organism after contact. Absorbed dose •
        is calculated from the intake and the absorption efficiency.  It usually is expressed as mass of a substance absorbed into
        the body per unit body weight per unit time (e,g., mg/kg-day).

                 , Dose.   The mas* of substance  given  to an  organism and  to contact with  an exchange  boundary  (*.g.,
        gastrointestinal tract) per suit body weight per unit time 
-------
                             EXHIBIT 8-1
               STEPS IN RISK CHARACTERIZATION
                                                                              Page 8-3
    Step 1: Organize Outputs of
Exposure and Toxicity Assessments
     •   Exposure Duration
     •   Absorption Adjustments
     *   Consistency Check
.   Exposure Assessment   ,
'      Intake Estimates
|	|

    Toxicity Assessment   '
|      Toxicity Values      I
i	j
  Step 2: Quantify Pathway Risks
  For Each Substance, Estimate:
     •  Cancer Risk
     •  Noncancer Hazard Quotient
  For Each Pathway, Calculate:
     •  Total Cancer Risk
     •  Noncancer Hazard Index
                    Step 3: Combine Risks Across Pathways
                    that affect the same individual(s) over
                    the same time periods
                          •  Sum Cancer Risks
                          •  Sum Hazard Indices
                         Step 4: Assess and Present
                         Uncertainty
                           •  Site-specific Factors
                           •  Toxicity Assessment
                              Factors
  Step 5: Consider Site-Specific
  Health or Exposure Studies
      •  Compare Adequate
         Studies with Results of
         Risk Assessment
       Identify ARARs
                                                           T
  Step 6: Summarize Results of the
  Baseline Risk Assessment
     Refine Preliminary
     Remediation Goals

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Page 8-4
routes and relevant substance). The following
two subsections describe how to organize the
outputs from the exposure and toxicity assessments
and how to check for the consistency and validity
of the information from the preceding exposure
and toxicity assessments.

8.1.1  GATHER AND ORGANIZE
       INFORMATION

   For each exposure pathway and land use
evaluated in the exposure assessment,  check that
all information needed to characterize risk is
available. The necessary exposure information is
outlined in the  box below.
    EXPOSURE INFORMATION NEEDED
      FOR RISK CHARACTERIZATION

    *  Estimated  intakes  (chronic,  subchronic,  and
       Shorter-term, as appropriate) for chemicals.

    •  important   exposure  modeling  assumptions,
       including:

        * chemical concentration at the exposure
         points;

        - frequency and duration of exposure;

        - absorption assumptions; and

        - characterization of uncertainties.

    •  List of Which exposure pathways can reasonably
       contribute to the exposure of the same individuals
       over the tame lime period.
   For each chemical or substance evaluated in
the toxicity assessment, use the checklist provided
in the next box to ensure that all information
needed to characterize risk is available.

8.1.2 MAKE FINAL CONSISTENCY AND
       VALIDITY CHECK

   Check the consistency and validity of key
assumptions common to the exposure outputs and
the toxicity outputs for each contaminant and
exposure pathway of concern. These assumptions
include the averaging period for exposure, the
exposure route, and the  absorption adjustments.
The basic principle is to ensure that the exposure
     TOXICriY INFORMATION NEEDED
      FOR RISK CHARACTERIZATION

   *  Slope factors for all carcinogenic chemicals.

   *  Discussion of weight of evidence and classification*
      for alt carcinogenic chemicals.

   •  Type of cancer for Class A carcinogens.

   *  Chronic and subchronic RfDs and shorter-term
      toxicity values (if appropriate) for all chemicals
      (including  carcinogens   and   developmental
      toxicants).

   »  Critics! effect associated with each RfD.
               of uncertainties, ttncertaiaty factors,
       and modifying factor used in deriving each RfD
       and "degree  of confidence" in RfD 
-------
                                                                                         Page 8-5
shorter-term effects). A toxicologist should review
the comparisons.   In the absence of short-term
toxicity values, the chronic RfD may be used as an
initial  screening value; i.e., if the ratio of the
short-term exposure value to the chronic RtD is
less than one, concern for potential  adverse health
effects  is low. If this ratio exceeds unity, however,
more appropriate short-term toxicity values are
needed to confirm the existence of a significant
health  threat.   ECAO may be consulted for
assistance in finding short-term toxicity values.
     EPA ENVIRONMENTAL CRITERIA
 i    AND ASSESSMENT OFFICE (ECAO)
         TECHNICAL ASSISTANCE

 t              FTS 6&*-7300

                513-569-7300
   Exposure route. Check that all toxicity values
used for each exposure pathway being evaluated
at the site  are  consistent with  the route of
exposure (e.g.,  oral  to oral,  inhalation  to
inhalation).   It  is not possible to extrapolate
between exposure routes for some substances that
produce localized effects dependent upon the
route of exposure.  For example, a toxicity value
based on localized lung tumors that result only
from inhalation exposure to a substance would not
be appropriate for estimating risk associated with
dermal exposure to the substance. At this time,
EPA considers it appropriate only to extrapolate
dermal toxicitv values from values derived for oral
exposure. It is not recommended  that oral toxicity
reference values be extrapolated casually from
inhalation  toxicity  values,  although  this
extrapolation may be performed on a case-by-case
basis in consultation with ECAO. In general,
inhalation values  should not be extrapolated  from
oral values. (Also,  see Section 7.5.1.)

   Inhalation Rfl} values obtained from IRIS
will  usually  be  expressed as  ambient air
concentrations  (i.e.,  mg/m3), instead of as
administered doses (i.e., mg/kg-day). It may be
necessary, therefore, to calculate the RfDjin units
of mg/kg-day for comparison  with the intake
estimated in the  exposure assessment. The  RfD;
expressed in mg/kg-day would be equal to the
       mg/m3 multiplied by 20 m3air inhaled
per person per day divided by 70 kg per person.

   Absorption adjustment.    Check that the
exposure estimates and the toxicity values are
either both expressed as absorbed doses or both
expressed as intakes (i.e., administered doses).
Except for the dermal route of exposure, the
exposure estimates developed using the methods
provided in Chapter 6  should be in the form of
intakes, with no adjustments made for absorption.
However, there are three types of absorption
adjustments  that might be necessary  or
appropriate depending  on the available toxicity
information. These are  described below. Sample
calculations for these absorption adjustments are
provided in Appendix A

   (1} Dermal exposures. The output of the
      exposure assessment for dermal exposure
      is expressed as the amount of substance
      absorbed per kg body weight per day. It
      therefore may be necessary to derive an
      absorbed dose toxicity value from an
      adntinistered dose toxicity value to compare
      with the exposure estimate.  See Appendix
      A for sample calculations.

   (2) Absorbed-dose toxicitv value. For the
      substances for which the toxicity value is
      expressed  as an absorbed rather  than
      administered dose (e.g., inhalation slope
      factor in IRIS for trichloroethylene and
      several other substances), one should
      express exposure as an absorbed  dose
      rather than as an intake.  See Appendix A-

   (3) Adjustment for medium  of exposure.
      Adjusting for different relative absorption
      efficiencies  based on  the medium  of
      exposure (e.g., food, soil, or water for oral
      exposure, vapor  or  particulate  for
      inhalation    exposure)   is occasionally
      appropriate,    but   not   generally
      recommended unless  there are strong
      arguments for doing so.  Many oral RfD
      and slope factor values assume ingestion in
      water even when based on studies that
      employed administration in corn oil by
      gavage or in feed. Thus, in most cases, the
      unadjusted toxicity value will provide a
      reasonable or conservative estimate of risk.
      See Appendix A.

-------
 8.2 QUANTIFYING RISKS

    This section deacribes steps for quantifying risk
 or hazard indices for both carcinogenic and
 noncarcinogenic effects to be applied to each
 exposure pathway analyzed. The first subsection
 covers promdures for individual substances,  and
 is followed by a subsection on procedures for
 quantifying risks associated  with simultaneous
 exposures to several substances. Sample table
 formats for  recording the  results of these
 calculations as  well  as recording associated
 information related to uncertainty and absorption
 adjustments are provided in Exhibits 8-2 through
 8-4.

 8.2.1 CALCULATE RISKS FOR INDIVIDUAL
       SUBSTANCES

    Carcinogenic effects. For carcinogens, risks
 are estimated as the incremental probability of an
 individual developing cancer over a lifetime as a
 result of exposure to the potential carcinogen
 (i.e., incremental or excess individual lifetime
 cancer risk).   The guidelines provided in this
 section are  consistent with EPA's (1986a)
 Guidelines for Caarcinogen Risk Assessment. For
 some  carcinogens, there may  be  sufficient
 information on  mechanism  of action  that  a
 modification of the approach outlined below is
 warranted.     Alternative approaches may be
 considered in consultation with ECAO on  a case-
 by-case basis.

    The slope factor (SF) converts estimated daily
 intakes averaged over a lifetime of exposure
 directly to incremental risk of an individual
 developing cancer. Because relatively low intakes
 (compared to those experienced by teat animals)
 are most likely from environmental exposures at
 Superfund sites, it generally can be assumed that
 the dose-response  relationship will be linear in the
 low-dose portion of the multistage model dose-
 response curve. (See the Background Document
 2 of IRIS  for a  discussion of the  multistage
 model.) Under this assumption, the slope factor
 is a constant, and risk will be directly related to
intake. Thus, the linear form of the carcinogenic
 risk equation is usually applicable for estimating
 Superfund site risks.    This linear low-dose
 equation is described in the next box.
        LINTi\R LOW-DOSE CANCER
              RISK EQUATION
            Risk = CD1 x SF
   where:
      Risk w a nnitless probability (e.g.,  2 x
             HT5) of am individual developing
             cancer,

      CDI *» chronic daily Intake averaged ov«r
             70 years (ing/kg-day); and

      SF   » slope &ctor,e3tpressed in (mg/kg-
             day}'1.
   l&e CDI it identified to Exhibit* 6-11 tknoogb 6-19 and
   <^ and tot SF ia identified in Exhibit 74.
    However, this linear equation is valid only at
low risk levels (i.e., below estimated risks of 0.01).
For sites where chemical intakes might be high
(i.e.,  risk above 0.01), an alternate calculation
equation should be used, The one-hit equation,
which is consistent with the linear low-dose model
given above and described in the box on page
8-11, should be used instead.

    Because the slope factor is often an upper
95th percentile confidence limit of the probability
of response based on experimental animal data
used in the multistage model the carcinogenic risk
estimate  will generally be an uooer-bound
estimate.  This means that EPA is reasonably
confident that the "true risk" will not exceed the
risk estimate  derived through use of this model
and is likely to be less than that predicted

    Noncarcinogenic effects. The measure used to
describe the potential for noncarcinogenic toxicity
to occur in an individual is not expressed as the
probability of an individual suffering an adverse
effect. EPA does not at the present time use a
probabilistic approach to estimating the potential
for  noncarcinogenic health effects. Instead, the

-------
                                                          EXHIBIT 3-2
                     EXAMPLE  OF TABLE FORMAT FOR CANCER RISK ESTIMATES
      Chemical
            GDI
    GDI   Adj. for
(mg/kg-day)  Absorp.
    SF        Weight of   Type of
(mg/kg-day)''    Evidence    Cancer"
 SF     SF Basis
Source    (Vehicle)
                                                                                                     Chemical-   Total     Total
                                                                                                     specific    Pathway    Exposure
                                                                                                     Risk*     Risk*      Risk*
Exposure Pathway: Ingestion of Contaminated Private Well Water
Benzene 0.00023* No 0.029* A* Leukemia HEA Water'
Chtordane 0.00015* No 1.3* B2* IRIS Water*
Txlff*
2x10-*
2XKT*
Exposure Pathway: Ingestion of Contaminated Fish
      Chlordane
                       0.00008*
            No
  1.3*
                                                            B2*
                                                                                IRIS
                                                                    Water*
                                                                                                      uirr*
                                                                                                                IxKT*
Nearby Residential Population in Area Y - Total Cancer Risk (weight of evidence predominantly B2)'
                                                                                                    3x10-*
 * Values for illustration only.
 "Identify type of cancer in this table for Class A carcinogens only.
 'All cancer risks should be expressed as one significant figure only.
 c Slope factor based on dose administered in drinking water and resumed absorption fraction of 1.0.
 'Summarize weight of evidence for carcinogens contributing most to the total cancer risk estimate.
                                                                               SF = Slope Factor
                                                                               GDI = Chronic Daily Intake
                                                                                                                                             I
                                                                                                                                              •S"

-------
                                                               EXHIBIT   8-3
                EXAMPLE OF TABLE FORMAT FOR CHRONIC HAZARD  INDEX ESTIMATES
                                  GDI                                                                                         Tottl
                                 Adjusted                                                  RfD                        Pathway Exposure
                         GDI       for        RfD    Confidence  Critical   RfD  RfD Basis Uncertainty   Modifying  Hazard    Hazard  Hazard
      Chemical         (mg/kg-day)  Absorption (mg/kg-day)    Level     Effect  Source (Vehicle)  Adjustments  Factor    Quotient"  Index*   Index*
Exposure Pathway:
Phenol
Nitrobenzene
Cyanide
Exposure Pathway.
Ingestion of Contaminated Private Well Water
0.1* No 0.6' M
0.0001* No 0.0005* M
0.0003* No 0.02* M
Ingestion of Contaminated Pbh

Kidney, IRIS Water* HA&L** 1* 0.2
liver
Several IRIS Water5 HASJU* 1* 0.2
Thyroid IRIS Water* HA* 5* 0.02
(M*

      Phenol
      MEK
0.08*
0.005*
Yes
Yes
0.6*
0.05*
M       Kidney,  IRIS   Water*
         liver
M      CNS,   IRIS   Water*    HAS*
        fetotox
0.1


0.1
                                                                                                                      02*
Nearby Residential Population in Area Y - Total Chronic Hazard Index
                                                                                                         0.6*
 * Values for illustration only.

 "All hazard indices and hazard quotients should
  be expressed as one significant figure only.
 'If the hazard index is greater than 1.0, see
  section 8.2.2 for guidance on possible
  segregation of hazard index by endpoint.
 cRfD expressed as administered dose.
 'Uncertainty adjustment of 1,000 used to
  represent combined H, A, S, & L extrapolationa.
                        Abbreviations for Uncertainty Adjustments:
                          Factor of 10 used for each adjustment
                          unless indicated otherwise.

                        H = variation in human sensitivity
                        A = animal to human extrapolation
                        S  = extrapolation from subchronic to chronic NOAEL
                        L = extrapolation from LOAEL to NOAEL

                        Confidence Level: L = low, M = medium, H = high.
                                                                ME = Modifying factor for EPA verified
                                                                      RfDs. This factor represents profes-
                                                                      sional judgment on overall data base
                                                                      not specifically addressed by
                                                                      uncertainty adjustments.

                                                               GDI = Chronic Daily Intake
                                                               RfD = Chronic Reference Dose

-------
                                                        EXHIBIT 8-4

         EXAMPLE OF TABLE FORMAT FOR SUBCHRONIC HAZARD INDEX ESTIMATES

Chemical
Exposure Pathway.
Manganese

Selenium
Mercury
Tin


SDI
(rag/kg-day)

SDI
Adjusted for
Absorption

RfD,
(mg/kd-day)

Critical
Effect
Total
RfD, Pathway Exposure
RfD, RID, Basis Uncertainty Modifying Hazard Hazard Hazard
Source (Vehicle) Adjustments Factor Quotient" Index0 Index0
Ingestion of Contaminated Schoolyard Soil/Six Years
0.02*

0.0008*
0.00001*
0.006*

Nearby Elementary Schoolyard - Total
Yes

Yes
Yes
No

0.5*

0.004*
0.0003*
0.6*

CNS,
repro.
Several
CNS
Liver,
kidney
Subchronic Hazard Index
HEA Water* H, A* 1* 0.04

HEA Water* H, A* 1.5* 0.2
HEA Water0 H* 1* 0.03
HEA Food0 H, A* 1* 0.01
0.3*
0.3*
* Values for illustration only.

"All hazard indices and hazard quotients should
  be expressed as one significant figure only.
b If hazard index is greater than 1.0, see
  Section 8.22 for guidance on possible
  segregation of hazard index by endpoint.
'RfDs expressed as administered dose.
Abbreviations for Uncertainty Adjustments:
 Factor of 10 used for each adjustment,
 unless indicated otherwise.

H = variation in human sensitivity
A = animal to human extrapolation
L = extrapolation from LOAEL to NOAEL
 MF = Modifying factor for EPA RtD.s.
      This factor represents professional
      judgment on overall data base not
      specifically addressed by uncertainty
      adjustments.

 SDI = Subchronic Daily Intake
RfD = Subchronic Reference Dose

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Page  8-10
                                  EXPLANATION OF SAMPLE TABLE FORMAT
                                         FOR CANCER RISK ESTIMATES

         A Sample table format for summarizing cancer risk estimates is provided in Exhibit 8-2,  For each baseline risk assessment,
     at least two summary tables generally would be required;  one for current land uses and one for future land uses,  in the
     example provided ta Exhibit 8-2, two exposure pathways were determined to contribute to exposure of a nearby residential
     population under current land use:  ingestion of private well water contaminated with benzene and chlontane and ingestion of
     fish contaminated with chlordane.  Moreover, a subset of the population ia Area Y was exposed to the maximal well Water
     contamination aad consumed more Jocally caught fish than the remainder of the nearby population.

         Values for the chronic daily intake (GDI), averaged over a lifetime, ot each contaminant by each exposure pathway would
     be obtained from a table such as that shown hi Exhibit 6-22. The CD1 via well water was not adjusted for relative absorption
     efficiency because the slope factors for these substances assume ingestion in water and an absorption fraction of 1.0. The GDI
     for chlordane in fish was not adjusted for vehicle of exposure (i.e., food versus water) because absorption efficiency data were
     limited, and a relative absorption fraction of 1.0 was used as « conservative assumption.  If, tor example, available data had
     indicated that only 10 percent of chlordane ingested with fish is absorbed, toe CD! could have been adjusted downward to
     0.000008 mg/kg-day (le., 0.00008 mg/kg-day x 040 relative absorption fraction),

         Values for the slope factors (SF), wetght-of-evideace classification, type of cancer (for Class A carcinogens), reference
     source of the SF, and basis of the SF (vehicle of administration and absorption efficiency) would be obtained from a table such
     as that shown in Exhibit 7-3, The chemical-specific risks were calculated from the GDI aad SF using the linear few-dose cancer
     risk equation (risk = CD! x SF). The total pathway risk for ingestion of private well water is the sum of the two chemical-
     specific risks for that pathway. The total risk estimate for the nearby residential population in area Y is the sum of the cancer
     risks for the two pathways. Note that it is important to summarize the weight of evidence for the carcinogens contributing most
     to the tool cancer risk estimate; in this example, chlordane, a Class B2 carcinogen, accounted  for most of the risk.
                                 EXPLANATION OF SAMPLE TABLE FORMAT
                                 FOR CHRONIC HAZARD INDEX ESTIMATES

       A sample table format for summarizing chronic hazard index estimates is provided in Exhibit 8*3. For each baseline risk
     assessment, at least two summary tables generally would be required: one for current land uses and one for future land uses.
     In the example provided in Exhibit 8-3, two exposure {pathways were determined to contribute to exposure ot a nearby residential
     population under current land use:  ingestion of private well water contaminated with phenol, nitrobenzene, and cyanide and
     ingestion of fish contaminated with phenol and methyl ethyi ketone (MEK). Moreover, a subset of the population in Area Y
     was exposed to the maximal well water contamination and consumed more locally caught fish than the remainder of the nearby
     population.

       Values for  the chronic daily intake (CD1), averaged over the period of exposure, of each contaminant by each exposure
     pathway would be obtained from a table  such as that shown in Exhibit 6-22.  The GDI via well water was not  adjusted for
     relative absorption efficiency because the RfDs for these substances are based on ingestion in water and an absorption fraction
     of l.O.  The CDI for  phenol and MEK  hi fish was not adjusted for vehicle of exposure (i.e., food versus water) because
     absorption efficiency data were limited, and a relative absorption fraction of 1.0 was osed as a conservative assumption. If, for
     example, available data had indicated that only 20 percent of MEK ingested with fish is absorbed, the CDI for MEK could have
     been adjusted downward to 0.001 mg/kg-day (Lei, 0.005 mg/kg-day x 0.20 relative absorption efficiency).

       Values for  the RfDs, confidence level  in the RID, critical effect, source of the value, and  basis of the RfO (vehicle Of
     administration and absorption efficiency) would be obtained from a table such as that shown in Exhibit 7-2.  The chemical-
     specific hazard quotients are equal to the CDI divided by the RfD. The total pathway hazard index for ingestion of private well
     water is the sum of the three chemical-specific hazard quotients for that pathway. The total hazard index estimate for the nearby
     residential  population in area Y is the sum of toe hazard indices for the two exposure pathways.

       Note that it is important to include the  noncaranogenic effects of carcinogenic substances when appropriate reference doses
     are available.   For example,  in an actual risk assessment of the chemicals summarized  in Exhibit 6-22, the  potential
     noncarcinogenic effects of chlordane should be evaluated and appropriate entries made in tables such as those shown in Exhibits
     7-2 and 8-3,

-------
                                                                                        Page 8-11
      ONE-HIT EQUATION FOR HIGH
       CARCINOGENIC RISK LEVELS

         Risk =  1  . exp(-CDI x SF)

   where:

     Risk « a unitless probability (e.g., 2 x
             10"5) of an individual
             developing cancer;

     exp = the exponential;

 '    GDI — chronic daily intake averaged
             over 70 years (mg/kg-day); and

  •   SF  = slope factor, in
potential for noncarcinogenic effects is evaluated
bycomparing an exposure level over a specified
time period (e.g., lifetime) with a reference dose
derived for a similar exposure period. This ratio
of exposure to toxicity is called a hazard quotient
and is  described in the box in the opposite
column.

    The noncancer hazard quotient assumes that
there is a level of exposure (i.e., RfD) below
which it is unlikely for even sensitive populations
to experience adverse health effects.   If the
exposure level (E) exceeds this threshold (i.e., if
E/RfD exceeds  unity), there may  be concern for
potential noncancer effects. As a rule,  the greater
the  value of E/RfD  above unity,  the greater the
level of concern.   Be sure, however, not to
interpret  ratios   of  E/RfD  as  statistical
probabilities: a ratio  of 0.001 does not mean that
there is a one  in one thousand  chance of the
effect occurring.  Further,  it is  important to
emphasize that the level of concern does not
increase linearly as the RfD is approached or
exceeded because   RfDs  do not have  equal
accuracy or  precision and are not based on the
same severity of toxic effects. Thus, the slopes of
the  dose-response curve in excess  of the RfD can
range widely depending on the substance.

    Three exposure durations that  will need
separate consideration for the  possibility  of
adverse noncarcinogenic health effects are chronic,
      NONCANCER HAZARD QUOTIENT

     Nottcancer Hazard Quotient «= E/RfD

   where:

     E   = exposure level (or intake);

     RfD= reference dose; and

     E and RfD are expressed in the same
     units and represent the same exposure
     period (i.e., chronic, subchronic, or
     shorter-term).
subchronic, and shorter-term exposures. As
guidance for Superfund, chronic exposures for
humans range  in duration from seven years to a
lifetime; such long-term exposures are almost
always of concern for Superfund sites (e.g.,
inhabitants of nearby residences, year-round users
of specified drinking water sources). Subchronic
human exposures range in duration from two
weeks to seven years  (as a Superfund program
guideline) and are often of concern at Superfund
sites. For example, children might attend a junior
high school near the site for no more than two or
three years. Exposures less than two weeks in
duration are occasionally of concern  at Superfund
sites. For example, if chemicals known to be
developmental toxicants are present at a site,
short-term exposures of only a day or two can be
of concern.

8.2.2 AGGREGATE RISKS FOR MULTIPLE
      SUBSTANCES

   At most Superfund sites, one must assess
potential health effects  of more than one chemical
(both  carcinogens  and  other  toxicants).
Estimating risk or hazard potential by considering
one  chemical at  a time might significantly
underestimate   the  risks    associated with
simultaneous exposures to several substances. To
assess the overall potential  for  cancer and
noncancer effects posed by multiple chemicals,
EPA (1986b) has developed  Guidelines for the
Health Risk Assessment of Chemical Mixtures that
can also be applied to the case of simultaneous
exposures to several chemicals from a variety of

-------
 Page 8-12
 sources by more than one exposure pathway.
 Although the calculation procedures differ for
 carcinogenic and noncarcinogenic effects, both sets
 of procedures assume dose additivity in the
 absence of information on specific mixtures.

    Information on specific  mixtures found at
 Superfund sites is rarely available. Even if such
 data  exist, they are often  difficult to  use.
 Monitoring for  "mixtures"  or modeling the
 movement of mixtures across space and time
 present technical problems given the likelihood
 that individual components will behave differently
 in the environment (i.e., fate and transport).  If
 data are available on the mixtures present at the
 site,  but  are  not  adequate  to support  a
 quantitative evaluation, note  the information  in
 the "assumptions" documentation.

    Carcinogenic effects. The cancer risk equation
 described  in the box below estimates the
 incremental individual lifetime cancer risk for
 simultaneous exposure to several carcinogens and
 is based on EPA's (1986a,b) risk assessment
 guidelines.     This  equation represents an
 approximation  of  the precise  equation for
 combining risks which accounts for the joint
 probabilities of the same individual developing
 cancer as a consequence of exposure to two or
 more  carcinogens.   The difference between the
precise equation and the approximation described
 in the box is negligible for total cancer risks less
than 0.1. Thus, the simple  additive equation  is
appropriate for most Superfund risk assessments.
      CANCER RISK EQUATION FOR
          MULTIPLE SUBSTANCES
  where:
Risk,- =
                    = S Risk,
             th6 total cancer risk, expressed
             as a unitless probability, and

             the risk estimate for the I*
             substance.
    The risk summation techniques described in
 the box on this page and in the footnote assume
 that intakes of individual substances are small.
 They also assume independence of action by the
 compounds involved (i.e., that there are no
 synergistic or antagonistic chemical interactions
 and that all chemicals produce the same effect,
 i.e., cancer). If these assumptions are incorrect,
 over- or under-estimation of the actual multiple-
 substance risk could result.

    Calculate a separate total cancer risk for each
 exposure pathway by  summing the substance-
 specific cancer risks.    Resulting cancer risk
 estimates should be expressed using one significant
 figure only.  Obviously, the total cancer risk for
 each pathway should not exceed 1. Exhibit 8-2
 provides a sample table format for presenting
 estimated cancer risks for specified exposure
 pathways in the "Total  Pathway Risk" column.

    There are several limitations to this approach
 that must be acknowledged. First, because each
 slope factor is an upper 95th percentile estimate
 of potency,  and because upper 95th percentiles of
 probability distributions are not strictly additive,
 the total cancer  risk estimate might become
 artificially more conservative as risks from a
 number of different carcinogens are summed. If
 one or two carcinogens drive the risk, however,
 this problem is not of concern. Second, it often
 will be the case that substances with different
 weights of evidence for human carcinogeniciry are
 included. The cancer risk equation for multiple
 substances sums all carcinogens equally, giving as
 much  weight to class B or C as to class A
 carcinogens. In addition, slope factors derived
 from animal data will be given the same weight as
 slope factors derived from human data. Finally,
 the action of two different carcinogens might not
 be  independent.    New tools for assessing
 carcinogen interactions are becoming available
 (e.g., Arcos etal. 1988), and should be considered
 in consultation  with the RPM. The significance
 of these concerns given the circumstances at a
 particular site should be discussed and presented
with the other information described in Section
 8.6.

   Noncarcinogenic effects. To assess the overall
potential for noncarcinogenic effects posed by
more than one chemical, a hazard index (HI)
approach has been developed  based on  EPA's

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                                                                                        Page 8-13
 (1986b) Guidelines for Health Risk Assessment of
 Chemical Mixtures. This approach assumes that
 simultaneous subthreshold exposures to several
 chemicals could result in an adverse health effect.
 It also assumes that the magnitude of the adverse
 effect will be proportional to the sum of the ratios
 of the subthreshold exposures to acceptable
 exposures.  The hazard index is equal to the sum
 of the hazard quotients, as described in the box
 below, where E and the RfD represent the same
 exposure period (e.g., subchronic, chronic, or
 shorter-term).   When the hazard index exceeds
 unity, there may be concern for potential health
effects.   While any single chemical  with an
exposure level greater than the toxicity value will
 cause  the  hazard index to exceed unity, for
 multiple chemical exposures, the hazard index can
 also exceed unity even if no single chemical
 exposure exceeds its RfD.
       NONCANCER HAZARD INDEX
Hazard Index « E//Rfl>j -f
               -t-
                                     + ,„
  Rfl>;
           =5 exposure level (or Intake) for
              the i* toxicant;

           « reference dose for the i*
              toxicant; and
     B and RfD are expressed in the same
     units  and represent the same exposure
     period (i.e.» chronic, subchronfc, or
     sJiorteMerm).
   It is important to calculate the hazard index
separately for chronic, subchronic, and shorter-
term exposure periods as described below. It is
also important to remember to include RfDs for
the noncancer effects of carcinogenic substances.

  (1)  Noncarcinogenic   effects  —   chronic
      exposures.    For each chronic exposure
      pathway (i.e.,  seven year to  lifetime
      exposure), calculate a separate chronic
      hazard index  from the  ratios of the chronic
      daily intake (GDI) to the chronic reference
                                                       dose (RfD) for individual chemicals as
                                                       described in the box below.  Exhibit 8-3
                                                       provides a  sample table  format for
                                                       recording these results in the "Pathway
                                                       Hazard Index" column.
                                                      €HRO!«C NONCANC1R HAZARD
                                                                   INDEX
                                                   Chronic
                                                   Hazard Index ** d>Ij/Rfl>/  •*•
                                                   wheie:
                                                          = chronic daily intake for the i
                                                             toxicant in mg/kg-day, and
                                                        Rf£>; = chronic reference dose for the
                                                               Ith toxicant in mg/fcg-day.
The CDI is identified in Exhibits £-11 through 6*19
and 6-22 and the RfD B identified in Exhibit 7-2,
 (2) Noncarcinogenic effects — subchronic
    exposures. For each subchronic exposure
    pathway (i.e., two week to seven year
    exposure), calculate a separate subchronic
    hazard  index from the ratios  of the
    subchronic daily intake (SDI)  to the
    subchronic reference dose (RfDs) for
    individual chemicals as described in  the box
    on the next page. Exhibit 8-4 provides a
    sample table format for  recording these
    results in the "Pathway Hazard Index"
    column.      Add  only  those  ratios
    corresponding to subchronic exposures that
    will be  occurring simultaneously.

 (3) Noncarcinogenic effects — less than two
    week exposures. The same procedure may
    be applied for simultaneous  shorter-term
    exposures to several chemicals.     For
    drinking water exposures, 1- and  10-day
    Health Advisories can be used as reference
    toxicity values. Depending  on  available
    data, a separate hazard index might  also be
    calculated for developmental toxicants
    (using RfD^s), which might cause adverse

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Page 8-14
        SUBCHRONIC NQNCANCER
              HAZARD INDEX
   Snbcbroitfc
   Hazard Index
   wliere:
           * subchronic daily intake for the
             fi toxicant ia mg/kg-day, and

           
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                                                                                          Page 8-15
   PROCEDURE FOR  SEGREGATION OF
       HAZARD INDICES BY EFFECT

    Segregation of hazard indices requires identification
  of the major effects of each chemical, including those
  seen at higher doses than the critical effect (e.g., the
  chemical may cause liver damage at a dose of 100
  mg/kg-day and neurotoxicity at a dose of 250 mg/kg-
  day). Major effect categories include neurotoxicity,
  developmental toxicity,  reproductive  toxicity,
  immunotoxicity, and adverse effects by target organ (i.e.,
  hepatic,   renal,  respiratory,   cardiovascular,
  gastrointestinal, hematological, musculoskekal, and
  dermal/ocular effects). Although higher exposure levels
  may be required to produce adverse  health effects other
  than the critical effect, the RfD can be used as the
  toxicity value for each effect category as a conservative
  and simplifying step.
       INFORMATION SOURCES FOR
  SEGREGATION OF HAZARD  INDICES


     Of the available information sources, the ATSDR
   Toxicological Profiles are well suited in format and
   content to allow a rapid determination of additional
   health effects that may occur at exposure levels higher
  than those that produce the critical effect. Readers
   should  be  aware that the ATSDR definitions  of
   exposure durations are somewhat different than EPA's
   and are indepedent of species; acute - up to 14 days;
   intermediate — more than 14 days to 1 year; chronic
   — greater than one year. IRIS contains only limited
   information on health effects beyond the critical effect,
   and EPA criteria documents and HEAs, HEEPs, and
   HEEDs may not systematically cover all health effects
   observed at doses higher those associated with the most
   sensitive effects.
8.3  COMBINING RISKS ACROSS
       EXPOSURE PATHWAYS

   This section gives directions for combining the
multi-chemical risk estimates  across  exposure
pathways and provides guidance for determining
when such aggregation is appropriate.

   In some  Superfund  site  situations, an
individual might be exposed to a substance or
combination   of substances  through several
pathways. For  example, a single individual might
be exposed to substance(s) from a hazardous waste
site by consuming contaminated drinking water
from a well, eating contaminated fish caught near
the site, and through inhalation of dust originating
from the site.  The total exposure to various
chemicals will equal the sum of the exposures by
all pathways. One should not automatically sum
risks from all exposure pathways evaluated for a
site, however. The following subsections describe
how to identify  exposure  pathways that should be
combined and, for these, how to sum cancer risks
and noncancer hazard indices across multiple
exposure pathways.

8.3.1 IDENTIFY REASONABLE EXPOSURE
      PATHWAY COMBINATIONS

    There are two steps required to  determine
whether risks or hazard indices for two or more
pathways should he combined for a single exposed
individual or group of individuals. The first is to
identify    reasonable    exposure    pathway
combinations. The second is to examine whether
it  is likely that the same individuals  would
consistently   face the   "reasonable  maximum
exposure" (RME) by more than one pathway.

    Identify exposure pathways that have the
potential to expose the same individual or
subpopulation at the key exposure areas evaluated
in the exposure assessment,  making sure to
consider  areas of highest exposure for each
pathway for both current and future land uses
(e.g., nearest downgradient well, nearest downwind
receptor). For each pathway, the risk estimates
and hazard indices have been developed for a
particular exposure area and time period; they do
not necessarily apply to other locations or time
periods. Hence, if two pathways do not affect the
same   individual or  subpopulation,   neither
pathway's individual risk  estimate or hazard index
affects  the other, and risks should not  be
combined.

    Once    reasonable   exposure   pathway
combinations have been identified, it is necessary
to examine whether it is likely that the same
individuals would consistently face the RME as
estimated by the methods described in Chapter 6.
Remember that  the RME estimate for each
exposure pathway includes many conservative and
upper-bound parameter values and assumptions
(e.g., upper 95th confidence limit on amount of
water ingested, upper-bound duration of occupancy

-------
 Page 8-16
 of a single residence). Also, some of the exposure
 parameters are not predictable in either space or
 time (e.g., maximum  downwind concentration may
 shift compass direction, maximum ground-water
 plume concentration may move past a well).  For
 real world situations  in  which  contaminant
 concentrations vary over time and space, the same
 individual may or may not experience the RME
 for more than one pathway over the same period
 of time. One individual might face the RME
 through one pathway, and a different individual
 face the RME through a different pathway. Only
 if you can explain why the key RME assumptions
 for more than one pathway apply to the same
 individual or subpopulation should the RME risks
for more than one pathway be combined.

    In some situations, it may be appropriate to
 combine one pathway's RME risks with other
 pathways' risk estimates that have been derived
 born more typical exposure parameter values. In
 this way, resulting estimates of combined pathway
 risks may better relate to RME conditions.

    If it is deemed appropriate to sum risks and
 hazard indices across pathways, the risk assessor
 should clearly identify those exposure pathway
 combinations for which a total risk estimate or
 hazard index is being developed. The rationale
 supporting such combinations should also be
 clearly stated. Then, using the methods described
 in Sections 8.3.2 and 8.3.3, total cancer risk
 estimates and hazard  indices  should be developed
 for the  relevant exposure areas and individuals (or
 subpopulations).  For example, Exhibits 8-2 and
 8-3  illustrate the combination of cancer risk
 estimates and chronic noncancer hazard indices,
 respectively, for a hypothetical nearby residential
 population exposed to contaminants  from a  site
 by two exposure pathways: drinking contaminated
 ground water from private wells and ingestion of
 contaminated fish caught in the local river. In
 this hypothetical  example, it is "known" that the
 few families living next to the site consume more
 locally  caught fish than the remaining community
 and have  the most highly contaminated wells of
 the area.

    The following two subsections describe how to
 sum risks  and hazard  indices for multiple exposure
 pathways for carcinogenic  and noncarcinogenic
 substances, respectively.
8.3.2  SUM  CANCER  RISKS

   First, sum the cancer risks for each exposure
pathway contributing to exposure of the same
individual or subpopulation. For Superfund risk
assessments, cancer risks from various exposure
pathways are assumed to be additive, as long as
the risks are for the same individuals and time
period (i.e., less-than-lifetime exposures have  all
been converted to equivalent lifetime exposures).
This summation is described in the box below.
The sample table format given in Exhibit 8-2
provides a place to record the total cancer risk
estimate.
       CANCER RISK EQUATION FOR
           MULTIPLE PATHWAYS

        Total Exposure Cancer Risk =*

        Risk(exposure pathway;) +
        Risk(exposure pathway2) +  	
        Risk(exposure pathway/)
   As described in Section 8.2.2, although the
exact equation for combining risk probabilities
includes terms for joint risks, the difference
between the exact equation and the approximation
described above is negligible for total cancer risks
of less than 0.1.

8.3.3 SUM NONCANCER HAZARD INDICES

   To   assess   the  overall   potential  for
noncarcinogenic effects posed by several exposure
pathways, the total hazard index for each exposure
duration fi.e.. chronic, subchronic. and shorter-
term) should be calculated separately.    This
equation is described in the box on the next page.
The sample table format given in Exhibit 8-3
provides a place to record the total exposure
hazard index for chronic exposure durations.

   When the total hazard index for an exposed
individual or group of individuals exceeds unity,
there may be concern for potential noncancer
health effects. For multiple exposure pathways,
the hazard index can exceed unity even if no
single exposure pathway hazard index exceeds
unity. If the total hazard index exceeds unity and

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                                                                                        Page 8-17
      HAZARD INDEX EQUATION FOR
           MULTIPLE PATHWAYS

   Total Exposure Hazard Index =

   Hazard Index(exposure pathway^)  +
   Hazard Index(exposure pathway^)  +	
   Hazard Index(exposure pathway,-)
   where:
      Total   Exposure  Hazard   Index   is
      calculated   separately   for  chronic,
      subchronic, and  shorter-term exposure
      periods.
if combining exposure pathways has resulted in
combining hazard indices based on different
chemicals, one may need to consider segregating
the contributions of the different chemicals
according to major effect (see Section 8.2.2.).
8.4    ASSESSMENT  AND
       PRESENTATION OF
       UNCERTAINTY

   This section discusses practical approaches to
assessing uncertainty in  Superfund site risk
assessments and describes ways to present key
information bearing on the level of confidence in
quantitative risk estimates for a site. The risk
measures used in Superfund site risk assessments
usually are not fully probabilistic estimates of risk
but conditional estimates given a considerable
number of assumptions about exposure and
toxicity (e.g., risk given a particular future land
use). Thus, it is important to fully specify the
assumptions and uncertainties inherent in the risk
assessment to place the risk  estimates in proper
perspective.     Another use  of  uncertainty
characterization can be to identify areas where a
moderate  amount of additional data collection
might significantly improve the basis for selection
of a remedial alternative.

   Highly quantitative statistical  uncertainty
analysis is usually not practical or necessary for
Superfund site risk assessments for a number of
reasons, not the least of which are the resource
requirements to collect and analyze site data in
such a way that the results can be presented as
valid  probability distributions.      As  in all
environmental risk assessments, it already is
known that uncertainty about the numerical
results is generally large (i.e., on the range of at
least  an  order  of  magnitude  or greater).
Consequently, it is more important to identify the
key site-related variables and assumptions that
contribute most to  the uncertainty than  to
precisely quantify  the degree of uncertainty in the
risk assessment. Thus, the focus of this section is
on qualitative/semi-quantitative approaches that
can yield useful information to decision-makers for
a limited resource investment.

   There are several  categories of uncertainties
associated with site risk assessments. One is the
initial selection of substances used to characterize
exposures and risk on the basis of the sampling
data and available toxicity information.  Other
sources of uncertainty are inherent in the toxicity
values for each substance used to characterize risk.
Additional uncertainties  are inherent in the
exposure assessment for individual substances and
individual  exposures.   These uncertainties are
usually driven by uncertainty in the chemical
monitoring data and the models used to estimate
exposure  concentrations  in the absence  of
monitoring data,  but can also  be driven by
population intake  parameters. Finally, additional
uncertainties  are incorporated  in the risk
assessment when exposures to several substances
across multiple pathways  are  summed.

   The following subsections describe how to
summarize and discuss  important site-specific
exposure uncertainties  and the  more  general
toxicity assessment uncertainties.

8.4.1 IDENTIFY AND EVALUATE
      IMPORTANT SITE-SPECIFIC
      UNCERTAINTY FACTORS

   Uncertainties in the exposure assessment
typically include  most of  the  site-specific
uncertainties  inherent in risk characterization, and
thus are particularly important to  summarize for
each site. In risk assessments in general, and in
the exposure assessment in particular, several
sources of uncertainty need to be addressed: (1)
definition of the physical setting, (2) model

-------
Page 8-18
applicability and assumptions, (3) transport, fate,
and exposure parameter values, and (4) tracking
uncertainty, or how uncertainties are magnified
through the various  steps  of the  assessment.
Some of these sources of uncertainty can be
quantified  while  others are best  addressed
qualitatively.

    Definition of the physical setting. The initial
characterization of the physical setting that defines
the risk assessment for a Superfund site involves
many professional judgments and assumptions.
These include definition of the current and future
land uses, identification of possible exposure
pathways now and in the future, and selection of
substances  detected at the site to include in the
quantitative risk assessment. In Superfund risk
assessments, particular attention should be given
to the following aspects of the definition of the
physical  setting.

    •   Likelihood of exposure pathways and land
       uses actually occurring.  A large part of the
       risk  assessment is the estimation of cancer
       risks or hazard  indices that are conditional
       on the existence of the exposure conditions
       analyzed; e.g., if a residential development
       is built on the site 10 years from now, the
       health risks associated with contaminants
       from the site would be X. It is important
       to provide the RPM or other risk manager
       with information related to the likelihood
       that the assumed conditions will occur to
       allow interpretation of a conditional risk
       estimate  in the  proper context.    For
       example, if the probability that a residential
       development would be built on the site 10
       or 50 years from now  is  very small,
       different risk management decisions might
       be made than if the probability is high.
       Present the information collected during
       scoping and for the exposure assessment
       that will help  the RPM to  identify the
       relative likelihood of occurrence of each
       exposure pathway and land use, at least
       qualitatively (e.g., institutional land-use
       controls,  zoning, regional development
       plans).

    •   The chemicals  not included in the
       quantitative risk estimate as a consequence
       of missing information on health effects  or
       lack  of quantitation  in  the chemical
       analysis may represent a significant source
       of uncertainty in the final risk estimates.
       If chemicals with known health effects were
       eliminated from the risk assessment on the
       basis of concentration or frequency of
       detection, one should now review and
       confirm whether or  not  any  of the
       chemicals  previously eliminated should
       actually  be included.    For substances
       detected at the site, but not included in the
       quantitative risk assessment because of data
       limitations, discuss possible consequences
       of the exclusion on the risk assessment.

A checklist of uncertainty factors related to the
definition of the physical setting is described in
the box below.
   LIST PHYSICAL SETTING DEFINITION
              ONCEaRTAINTTES

   •   Pw chemicals npl, included in the quaatttatJve risk
       assessment, describe briefly:
       -  reason for exclusion (e.g., quality control), and
       -  possible consequences  of exclusion on risk
         assessment  (e.g.,   because  of widespread
         contamination, underestimate of risk).

   •   For the current land uses describe:
       -  sources and quality of information, and
       -  qualitative confidence level.

   •   For the future land uses describe:
       -  sources and quality of information, and
       •  information related to the likelihood  of
         occurrence.

   •   For each, exposure pathway, describe why pathway
       was selected or not selected for evaluation (i.e.,
       sample table format from Exhibit 6-8).

   »   For each combination of pathways, describe any
       qualifications regarding ihe selection of exposure
       pathways considered to contribute to exposure of
       (he same individual or group of individuals over
       (he same period of time.
   Model applicability and  assumptions. There
is always some doubt as to how well an exposure
model or  its mathematical expression (e.g.,
ground-water transport model) approximates the
true    relationships    between    site-specific
environmental conditions.  Ideally, one would like
to use a fully validated model that accounts for all
the  known complexities  in the  parameter

-------
                                                                                          Page 8-19
 interrelationships for each assessment. At present,
 however, only simple, partially validated models
 are  available and  commonly  used.  As  a
 consequence, it is important to identify key  model
 assumptions (e.g., linearity, homogeneity, steady-
 state conditions, equilibrium) and their potential
 impact on the risk  estimates. In the absence of
 field data for model validation, one could perform
 a limited sensitivity analysis (i.e., vary assumptions
 about functional relationships) to indicate the
 magnitude of uncertainty  that might be associated
 with model form. At a minimum, one should list
 key  model assumptions and indicate the potential
 impact of each on risk with respect to both
 direction and magnitude, as shown in the box
 below. A sample table  format is presented in
 Exhibit 6-21 of Chapter 6.
           CHARACTERIZE MODEL
              UNCERTAINTIES

   *   Ustysummarize the key model assumptions.

   *   Indicate the potential impact of each on risfc

       - direction (i.e., may over- or underestimate
        risk); and

       - magnitude (e.g., order of magnitude).
    Parameter value uncertainty.   During the
course of a risk assessment, numerous parameter
values are included in the calculations of chemical
fate and transport and human intake. A first step
in characterizing parameter value uncertainty in
the baseline risk assessment is to identify the key
parameters influencing risk.  This usually can be
accomplished by expert opinion or by an explicit
sensitivity analysis.  In a sensitivity  analysis, the
values of parameters suspected of driving the risks
are varied and the degree to which changes in the
input variables result in changes in the risk
estimates are summarized and compared (e.g., the
ratio of the change in output to the change in
input).    It is important to  summarize the
uncertainty  associated with  key parameters,  as
described below.

    • Significant site  data  gaps might have
       required that certain parameter values  be
       assumed for the risk assessment. For
       example, no information on the frequency
       with which individuals swim in a nearby
       stream might be available for a site, and an
       assumed  frequency and duration  of
       swimming events based on a national
       average could have driven the exposure
       estimate for this pathway.

    •   Significant data uncertainties might exist
       for other parameters, for example, whether
       or not the available soil  concentration
       measurements are representative of the
       true  distribution of soil contaminant
       concentrations.

    Tracking uncertainty. Ideally, one would like
to  carry through the  risk assessment the
uncertainty  associated with  each parameter in
order to characterize  the uncertainty associated
with the final risk estimates. A more practical
approach for Superfund risk assessments is to
describe  qualitatively how the uncertainties  might
be magnified or biased through the risk models
used. General quantitative, semi-quantitative, and
qualitative approaches to uncertainty analysis are
described below.

    Quantitative  approach.    Only on the rare
occasions that an RPM may indicate the need for
a quantitative uncertainty analysis should one  be
undertaken.    As mentioned earlier, a highly
quantitative statistical uncertainty analysis is
usually not practical or necessary for Superfund
sites.

    If a quantitative analysis is undertaken for a
site, it is necessary to  involve a statistician in the
design and interpretation of that analysis.  A
quantitative approach to characterizing uncertainty
might be appropriate if the exposure models are
simple and the values for  the key input
parameters are well  known. In this case, the first
step would  be to characterize the probability
distributions for key input  parameter values
(either using measured or assumed distributions).
The second step would be to propagate parameter
value uncertainties  through the analysis  using
analytic (e.g.,  first-order  Taylor  series
approximation) or numerical  (e.g., Monte Carlo
simulation) methods,  as appropriate.   Analytic
methods might  be  feasible if there are a few
parameters with known distributions and linear
relationships. Numerical methods (e.g., Monte

-------
Page 8-20
 Carlo simulation) can  be suitable for more
 complex relationships, but must be done on a
 computer and can be resource intensive even with
 time-saving techniques (e.g.,  Latin Hypercube
 sampling).

    Two common techniques of propagating
 uncertainty are first-order analyses  and Monte
 Carlo simulations. First-order analysis is based on
 the assumption that the total variance of a model
 output variable is a function of the variances of
 the individual model input variables  and the
 sensitivity  of the output variable to changes in
 input variables.   The sensitivity of the output
 variable is defined by the first derivative of the
 function or model,  which can be generated
 analytically or numerically.   A Monte Carlo
 simulation estimates a distribution of exposures or
 risk by repeatedly solving the model equation(s).
 The probability distribution for each variable in
 the model must be defined. The computer selects
 randomly from each distribution  every time the
 equation is solved.  From the resulting output
 distribution of exposures or risk, the assessor can
 identify the value corresponding to any specified
 percentile (e.g.,  the 95th percentile  in  the
 exposure distribution).

    These  quantitative  techniques  require
 definition  of  the distribution  of  all  input
 parameters and  knowledge of  the degree of
 dependence (i.e.,  covariance) among parameters.
 The value of first-order analyses or Monte Carlo
 simulations  in  estimating exposure  or risk
 probability  distributions diminishes sharply if one
 or more  parameter value  distributions are poorly
 defined  or must be assumed.  These techniques
 also become difficult to document and to review
 as the number of model parameters increases.
 Moreover, estimating a probability  distribution for
 exposures and risks can lead one into a false sense
 of certainty about the analysis. Even in the most
 comprehensive analyses, it will generally be true
 that not  all of the sources of uncertainty can be
 accounted  for  or  all  of  the  parameter
 codependencies recognized.  Therefore, in  addition
 to  documenting  all input distributions and
 covariances, it is very important to identify all of
 the assumptions and incomplete information that
 have not been accounted for in the quantitative
 uncertainty  analysis (e.g., likelihood that  a
 particular land use will occur) when presenting the
 results.
   References describing numerical methods of
propagating uncertainty through a risk analysis
include Burmaster and von Stackelberg (1988),
Hoffman and Gardner (1983), Iman and Helton
(1988), and NRC (1983). References describing
analytic methods of tracking uncertainty include
Hoffman and Gardner (1983), NRC (1983),
Downing et al. (1985), and Benjamin and Cornell
(1970).

   Semi-quantitative approach. Often available
data are insufficient to fully describe parameter
distributions, but are  sufficient to describe  the
potential range of values the parameters might
assume. In this situation, sensitivity analyses can
be used to identify  influential model input
variables  and to develop  bounds  on  the
distribution of exposure or risk. A sensitivity
analysis can estimate the range of exposures or
risk that result from combinations of minimum
and maximum values for some parameters and
mid-range values for others.  The uncertainty for
an assessment of this type could be characterized
by presenting the ranges of exposure or risk
generated by the  sensitivity  analysis and by
describing the limitations of the data used to
estimate plausible ranges of model  input variables
(EPA 1985).

   Qualitative approach.  Sometimes, a qualitative
approach is the most' practical approach to
describing uncertainty in Superfund site risk
assessments given the use of the information (e.g.,
identifying areas  where the results  may  be
misleading). Often the most practical approach
to characterizing parameter uncertainty will be to
develop a quantitative or qualitative description of
the uncertainty for  each parameter and to simply
indicate  the possible influence  of  these
uncertainties on the final risk estimates given
knowledge of the models used (e.g., a specific
ground-water transport  model). A checklist of
uncertainty factors related to the definition of
parameters is described in the box on page 8-22.
A sample table format is provided in Exhibit
6-21 of Chapter 6.

   Consider presentation of information on key
parameter uncertainties in graphic  form to
illustrate  clearly  to the RPM or other risk
managers the significance of various assumptions.
For example, Exhibit 8-5  plots assumptions
regarding contaminated fish ingestion and resulting

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                                                                           Page 8-21
                               EXHIBIT 8-5
EXAMPLE OF PRESENTATION OF IMPACT OF EXPOSURE ASSUMPTIONS
                       ON CANCER RISK ESTIMATE
               Ingestion of Fish Contaminated  with Chemical X
                        (30 mg X/Kg Fish Wet  Weight)
             10
20
  30        40
Grams/Person/Day
                                                      50
                      	Fillet with Skin
                          Fillet Only
      The risk of developing cancer is plotted on a log scale. A risk of 104indicates a probability
      of 1 chance in 10,000 and a  risk of 10'indicates  a probability of 1 chance in 100,000 of an
      individual developing cancer.

-------
Page 8-22
impacts on the cancer risk estimate for this
exposure pathway.   Exhibit 8-6 illustrates the
significance of these same assumptions for the
hazard index estimates for contaminated fish
consumption.      Additionally, maps showing
isopleths of risks resulting from modeled air
exposures such as emissions near the site may
assist the RPM or risk manager in visualizing the
significance of current or future site risks for a
community.
         CHARACTERIZE FATE AND
       TRANSPORT AND EXPOSURE
       PARAMETER UNCERTAINTIES

   •    List at) key exposure assessment parameters (e.g.,
       infiltration  rate,   exposure  duration,
       bioconcentration factors, body weight).

   «    List  the value used for each  parameter and
       rationale for its selection.

   •    Describe the measured or  assumed parameter
       value distributions, if possible, considering:

       -  total  range;

       -  shape of distribution, if known (e.g., log-
         normal);

       -  mean (geometric or  arithmetic)  +  standard
         deviation; and/or

       -  specific percentiles (e.g., median, 95tb).

   •    Quantify the uncertainty of statistical values used
       in the risk assessment (e.g., standard error of the
       mean) or data gaps and  qualifiers,

   »    Describe potential direction and magnitude of bias
       in risk estimate resulting from assumptions or data
       gaps (see Exhibit 6-21).
8.4.2 IDENTIFY AND EVALUATE TOXICITY
       ASSESSMENT  UNCERTAINTY
       FACTORS

   For substances that contribute most to the
estimates  of cancer risk and noncancer hazard
indices, summarize the uncertainty inherent in the
toxicity values for the durations  of exposure
assessed. Some of the information (e.g., weight of
evidence  for potential human  carcinogens,
uncertainty  adjustments  for noncancer toxicity
values) has already been recorded in the sample
table formats provided in Exhibits 8-2 through
8-4. Other information will be developed during
the toxicity assessment itself (see Chapter 7).
The box on page 8-24 provides a checklist of
uncertainties   that  apply  to most  toxicity
assessments.

    Multiple  substance exposure uncertainties.
Uncertainties associated with summing risks or
hazard indices  for several  substances  are of
particular concern in the risk characterization step.
The assumption of dose additiviry ignores possible
synergisms or antagonisms among chemicals, and
assumes similarity in mechanisms of action and
metabolism.     Unfortunately,  data to  assess
interactions quantitatively are generally lacking.
In the absence of adequate  information, EPA
guidelines indicate that carcinogenic risks should
be treated as  additive and that noncancer hazard
indices should also be treated as additive. These
assumptions  are made  to  help  prevent an
underestimation of cancer risk or potential
noncancer health effects at a site.

   Be sure  to  discuss the  availability  of
information concerning potential antagonistic or
synergistic effects of chemicals for which cancer
risks or hazard indices have been summed for the
same exposed individual or  subpopulations. On
the basis of available information concerning
target organ specificity and mechanism of action,
indicate the degree to which  treating the cancer
risks as additive may over- or  under-estimate risk.
If only qualitative  information is available
concerning potential interactions or dose-additiviry
for the noncarcinogenic substances, discuss
whether the information indicates that hazard
indices may have been over- or under-estimated.
This discussion  is particularly important if the
total hazard index for an exposure point is slightly
below or slightly above unity, or if the total
hazard index exceeds unity and the effect-specific
hazard indices are less than unity, and if the
uncertainty is likely to significantly influence the
risk management decision at the site.

8.5 CONSIDERATION OF SITE-
       SPECIFIC HUMAN STUDIES

   This section  describes how to compare the
results of the risk characterization step with

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                                                                    Page 8-23
                              EXHIBIT 8-6

   EXAMPLE OF PRESENTATION OF IMPACT OF EXPOSURE ASSUMPTIONS
                     ON HAZARD INDEX ESTIMATE
              Ingestion of Fish Contaminated with Chemical Y
                      (10 mg Y/Kg Fish Wet Weight)
2.0 -
1.5 -
0.5 H
            10
20        30        40

       Grams/Person/Day
50
60
                    —  Fillet  with  Skin   —  Fillet Only

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Page 8-24
ATSDR health assessments and other site-specific
human studies that might be available. The first
subsection outlines how to compare an ATSDR
health assessment for the site with the risk results
summarized in the previous sections (Sections 8.2,
8.3, and 8.4). The  second subsection discusses
when epidemiological  or health studies might
provide useful information for assessing exposures
and health  risks associated with contaminants
from a site.
         CHARACTERIZE TOXICITY
       ASSESSMENT UNCERTAINTIES

    For each substance carried through ihe quantitative
   risk assessment, list uncertainties related to:

   •   qualitative  hazard findings  (i.e.,  potential  for
       human toxicity);

   «   derivation of toxicity values, e.g,,

       • human or animal data,

       - duration of study (e.g., chronic study used to set
  :       subchronic RfD), and

       - any special considerations;

   •   the  potential  for synergistic Or  antagonistic
       interactions with other substances affecting  the
       same individuals; and

   •   calculation  of lifetime cancer risks on the basis of
       less-than-lifetime exposures.

    For each substance not included in the quantitative
   risk   assessment because   of  inadequate toxicity
   information, list:

   *   possible health effects; and

   «   possible consequences of exclusion on ffeal risk
       estimates.
8.5.1 COMPARE WITH ATSDR HEALTH
       ASSESSMENT

   ATSDR health assessments were defined and
compared to the  RI/FS risk assessment in Section
2.2.2. As of 1989, preliminary ATSDR health
assessments should be completed before the RI/FS
risk assessment  is initiated and therefore should
be available to the risk assessor as early as
"scoping."    The  steps for  comparing the
preliminary ATSDR health assessment with the
baseline risk assessment are outlined below.

    Review again the ATSDR health  assessment
findings and conclusions. These will be largely
qualitative in nature.    If the  ATSDR health
assessment  identifies exposure pathways  or
chemicals of concern that have not been included
in the RI/FS baseline risk assessment, describe the
information supporting the decision not to include
these parameters.  If there are differences in the
qualitative conclusions of the health  assessment
and the quantitative conclusions of the baseline
risk assessment, explain the differences, if possible,
and discuss their implications.

8.5.2 COMPARE WITH OTHER AVAILABLE
       SITE-SPECIFIC  EPIDEMIOLOGICAL
       OR HEALTH STUDIES

    For most Superfund sites, studies of human
exposure or health effects in the  surrounding
population will not be available.  However, if
controlled epidemiological or other health studies
have been conducted, perhaps as a consequence
of the preliminary ATSDR health assessment or
other community involvement, it is important to
include this information  in the baseline risk
assessment as appropriate. However, not all such
studies  provide meaningful information in the
context  of Superfund risk assessments.

    One can determine the  availability of other
epidemiological or health studies for populations
potentially exposed to contaminants  from the site
by   contacting    the   ATSDR    Regional
Representative, the Centers for  Disease Control
in Atlanta, Georgia, and state and local health
agencies as early in the risk assessment process as
possible. It is important to avoid use of anecdotal
information  or data from studies that might
include a significant bias or confounding factor,
however. Isolated reports of high body levels of
substances that are known  to be present at the
site in a few individuals living near the site are
not sufficient evidence to confirm the  hypothesis
that these individuals have received  significant
exposures from the site.  Nor can isolated reports
of disease or symptoms in a few individuals living
near the site  be used to confirm the  hypothesis
that the cause of the  health effects in these
individuals was exposure to contamination from
the site. A trained epidemiologist should review

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                                                                                        Page 8-25
 any available studies in order to identify possible
study limitations and implications for site risk
findings.    The small populations and variable
exposures predominating at most Superfund sites
will make it extremely difficult to detect site-
related effects using epidemiological techniques.

    If site-specific health or exposure  studies have
 been  identified and evaluated as adequate, one
 should incorporate the study findings into the
 overall risk characterization to strengthen the
 conclusions of the risk assessment (e.g., the risk
 assessment predicts elevated blood lead levels and
 the human exposure study documented elevated
 blood lead levels only among those  exposed  to
 ground water contaminated by the site). Because
 of the generally large and different types  of
 uncertainties associated with the risk assessment
 and actual health studies, a  qualitative, not
 quantitative, comparison between the two types  of
 studies is generally warranted.     Areas  of
 agreement and disagreement between the health
 study(ies) and the risk assessment should be
 described and factors that might contribute to any
 disagreement discussed.

 8.6 SUMMARIZATION AND
       PRESENTATION  OF THE
       BASELINE RISK
       CHARACTERIZATION
       RESULTS

    This section provides guidance on  interpreting
 and presenting the risk characterization results.
 The results of the baseline evaluation should not
 be taken as a characterization  of absolute risk.
 An important  use of the risk and hazard  index
 estimates  is to highlight potential sources of risk
 at a site so that they may be dealt with effectively
 in the remedial process. It  is the responsibility  of
 the risk assessment team to develop  conclusions
 about the  magnitude and kinds of risk at the site
 and the major uncertainties affecting the risk
 estimates. It is not the responsibility of the risk
 assessment team to evaluate the  significance  of the
 risk in a program context, or whether and how
 the risk should be addressed, which are risk
 management decisions.

    The ultimate user of the risk characterization
 results will be  the RPM or  other risk manager for
the site.   This  section therefore outlines a
presentation of material that is designed to assist
the risk manager in using risk information to
reach site-specific decisions.

8.6.1 SUMMARIZE RISK INFORMATION IN
      TEXT

   The final discussion of the risk characterization
results  is  a  key  component  of the  risk
characterization. The discussion provides a means
of placing the numerical estimates of risk and
hazard in the context of what is known and what
is not known about the site and in the context of
decisions to be made about selection of remedies.
At a minimum, the discussion should include:

   •  confidence that the  key  site-related
      contaminants were identified and discussion
      of contaminant concentrations relative to
      background concentration ranges;

   •  a description of the various types of cancer
      and other health risks present at the site
      (e.g.,  liver  toxicity,  neurotoxicity),
      distinguishing between known effects in
      humans and those that are predicted to
      occur based on animal experiments;

   •  level of confidence in the quantitative
      toxicity  information used to estimate risks
      and presentation of qualitative information
      on the toxicity of substances not included
      in the quantitative assessment

   •  level of confidence in the  exposure
      estimates for key exposure pathways and
      related exposure  parameter assumptions;

   •  the magnitude of the cancer risks and
      noncancer hazard indices relative to the
      Superfund  site remediation goals  in the
      NCP (e.g., the cancer risk range of 104to
      10'and noncancer hazard index of  1.0);

   •  the major factors driving the site risks (e.g.,
      substances,    pathways,    and  pathway
      combinations);

   •  the major factors reducing the certainty in
      the results  and the significance of these
      uncertainties (e.g., adding  risks over  several
      substances and pathways);

-------
Page 8-26
   •  exposed population characteristics, and

   •  comparison with site-specific health studies,
      when available.

   In addition, if the size of the potentially
exposed population is large, the presentation of
population numbers may be of, assistance to the
RPM, especially  in evaluating risks in the context
of current land use. Individual risk estimates
baaed on the reasonable maximum exposure
(RME) should not be presented as representative
of a broadly defined population, however.

8.6.2 SUMMARIZE RISK INFORMATION IN
      TABLES

   A tabular summary of the cancer risks and
noncancer hazard indices should  be prepared for
all exposure  pathways and land uses analyzed and
for all  substances  carried  through  the  risk
assessment. These tables must be  accompanied by
explanatory text, as described in the previous
section, and should not be allowed to stand alone
as the entire risk characterization.  The sample
table formats presented in Chapter 6 and in
Exhibits 8-2 to 8-6 provide basic summary formats.
Exhibits 8-7 and 8-8 provide examples of optional
presentations that might assist in visualization of
the risk assessment results.   These bar graphs
present the baseline cancer risk estimates and
noncancer hazard indices, respectively, by pathway
for an identified subpopulation near the site. The
stacked bars in Exhibit 8-8 allow the reader to
immediately identify the pathway(s) contributing
most to the total hazard index as well as identify
the substances driving the indices in each pathway.
Reference levels are also provided (e.g., hazard
index of 1.0). Exhibits 8-5 and 8-6 introduced in
Section 8.4.1 provide examples of figures that
could  help the RPM or  other risk manager
visualize the impact of various assumptions and
uncertainties on the final risk or hazard index
estimate. In addition, graphics relating risk level
(or magnitude of hazard index) to concentrations
of substances in environmental media and cost of
"treatment" could allow the RPM or other risk
manager to weigh the benefits of various remedial
alternatives more easily. Examples of the last type
of graphics are  presented in Part C of this
manual.

   In a few succinct concluding paragraphs,
summarize the results of the risk characterization
step. It is the responsibility of the risk assessment
team members, who are familiar with all steps in
the site risk assessment,  to highlight the major
conclusions of the risk assessment. The discussion
should summarize  both the qualitative and the
quantitative findings of cancer risks and noncancer
hazards, and properly qualify these by mention of
major assumptions and uncertainties  in the
assessment.

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                                                                                Page 8-27
                                   EXHIBIT 8-7
EXAMPLE OF PRESENTATION OF RELATIVE CONTRIBUTION OF INDIVIDUAL
CHEMICALS TO EXPOSURE PATHWAY AND TOTAL CANCER RISK ESTIMATES
T3
 0>
                            Nearby  Resident  Population
                       Excess Lifetime Cancer Risks <  3 x 10
«  10'
cc
8
(i  10
o
CD  >
    10 --^
 I  10
LU
    10"-
    lO'H
    10'
                      Public Water Supply

                  2x10'4(B2)
                                                                        Benzene

                                                                        Chlordane
Contaminated Fish

  <  1x1Q-4(B2)
                                      Exposure Pathway
       The risk of developing cancer is plotted on a log scale. A risk of 104 indicates a probability
       of 1  chance in 10,000 of an individual developing cancer. Risks of 105and  10'correspond to
       probabilities of 1 chance in 100,000 and  1 chance in 1,000,000, respectively. Values in
       parentheses  represent  EPAs  weight-of-evidence classification of the agent  as a potential
       human carcinogen: A = human carcinogen; and B2  = probable human carcinogen
       (with  sufficient evidence in animals and inadequate or no evidence in  humans).

-------
Page 8-28
                                   EXHIBIT 8-8
   EXAMPLE OF PRESENTATION OF RELATIVE CONTRIBUTION OF INDIVIDUAL
 CHEMICALS TO EXPOSURE PATHWAY AND TOTAL HAZARD INDEX ESTIMATES
   1.2


    1

   0.9
   0.8
   0.7
H 0.6
| 0.5
   0.4
   0.3
   0.2
   0.1

    0
                           Nearby  Resident Population
                            Chronic Hazard Index = 0.6
                                                                Phenol

                                                                Nitrobenzene

                                                                MEK
                  Well Water
                                   Contaminated Fish
                                                            Swimming
                                    Exposure Pathway
               The hazard index is equal to the sum of the hazard quotients (i.e., exposure
               level/RfD) for each chemical. It is not a probability; a hazard index or
               quotient of <1.0 indicates that it is unlikely for even  sensitive populations to
               experience adverse health effects.

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                                                                                                              Page 8-29


                                     ENDNOTE FOR CHAPTER 8
1. The probability of an individual developing cancer following exposure to more than one carcinogen is the probability of developing
cancer from at least one of the carcinogen. For two carcinogens, the precise equation for estimating this probability is riak,+ riak2-
probability  (risk,, risk?) where the latter term is the joint probability of the two risks occurring in the same individual. If the risk to
agent 1 is distributed in the population independently of the risk to agent 2, the latter term would equal (riak,)(risk2). This equation
can be expanded to evaluate risks from more than two substances.

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     8-30
                                  REFERENCES  FOR  CHAPTER 8
Arcos, I, Woo, Y.T., and Lai, D. 1988: Data Base on Binary Combination Effects of Chemical Carcinogens.   Environ. Carcino.
    Revs. [J. Environ. Sci. Health Pt. C] 6:1-150.

Benjamin, J.R. and C.A. Cornell. 1970. Probability. Statistics, and Decision-making for Civil Engineers. McGraw Hill. New York.

Burmaster, D.E. and K von Stackelberg. 1988. A New Method for Uncertainty and Sensitivity Analysis in Public Health Risk
    Assessments at Hazardous Waste Sites Using Monte Carlo Techniques in a Spreadsheet. Pages 550-556 in Superfund '88.
    Proceedings of the 9th National Conference. Washington, D.C. Sponsored by the Hazardous Materials Control Research Institute.

Downing, D. I, Gardner, R. H., and Hoffman, F. 0. 1985. Response Surface Methodologies for Uncertainty Analysis in Assessment
    Models. Technometrics 27:151-163.

Environmental Protection Agency (EPA). 1985. Methodology for Characterization of Uncertainty in Exposure Assessments. Prepared
    by Research Triangle Institute. NTIS: PB85-240455.

Environmental Protection Agency (EPA). 1986a. Guidelines for Carcinogen Risk Assessment. 51 Federal Register 33992 (September
    24, 1986).

EnviromentalProtection Agency  (EPA).  1986b. Guidelines  for the  Health Risk Assessment of Chemical Mixtures. 51 Federal
    Register 34014 (September 24, 1986).

Environmental Protection Agency  (EPA). 1986c. Guideline for the Health Assessment of Suspect Developmental Toxicants. 51
    Federal Register 34028 (September 24, 1986).

Environmental Protection Agency (EPA). 1989. Proposed Amendments to the Guidelines for the Health Assessment of Suspect
    Developmental Toxicants.  54 Federal Register 93S6 (March 6, 1989).

Hoffman, F. O. and R.  H. Gardner.  1983.  Evaluation of Uncertainties in Radiological Assessment Models. In Radiological
    Assessment. A Textbook on Environmental Dose Analysis. Till, J. E., and H.R. Meyer, (eds.). Prepared for Office of Nuclear
    Reactor Regulation, U.S. Nuclear Regulatory Commission.  Washington, DC. NRC FIN B0766. NUREG/CR-3332.

Iman, R. L and J. C. Helton. 1988. An Investigation of Uncertainty and Sensitivity Analysis Techniques for Computer Models.
    Risk Analysis 871-90.

IRIS. Integrated Risk  Information System (data  base).  1989. U.S. Environmental Protection Agency, Office  of Research and
    Development.

Metcalf, D.R. and J.W. Pegram. 1981. Uncertainty Propagation in Probabilistic Risk Assessment: A Comparative Study.  Transactions
    of the American Nuclear Society 38:483-484.

Nuclear Regulatoty Commission (NRC). 1983.  PRA Procedures  Guide - A Guide to  the Performance of Probabilistic  Risk
    Assessments for Nuclear Power Plants. Office of Nuclear Regulatory Research, Washington, D.C. NUREG/CR-2300. Vol. 2

Vesefy, W. E. and D. M. Rasmuson. 1984. Uncertainties in Nuclear Probabilistic  Risk Analysis Risk Analysis 4:313-322.

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                                CHAPTER  9

            DOCUMENTATION,  REVIEW,  AND
                 MANAGEMENT  TOOLS  FOR
                       THE  RISK  ASSESSOR,
                 REVIEWER,  AND MANAGER
    This  chapter  provides  tools  for  the
documentation, review, and management of the
baseline risk assessment. These tools will help
ensure completeness  and consistency throughout
the risk assessment and in the reporting of
assessment results.     Section 9.1 provides
documentation tools (for risk assessors), Section
9.2 provides review tools (for risk assessment
reviewers), and Section 9.3 provides management
tools (for remedial project managers [RPMs] and
other decision-makers concerned with the site).
9.1 DOCUMENTATION TOOLS

    Throughout Chapters 4 to 8 of this manual,
guidance is provided to the risk assessor on how
to summarize and document many beginning,
intermediate,  and  final  steps  of  the  risk
assessment.  The purpose of this section is to
consolidate that guidance, provide a final check to
ensure that all appropriate documentation has
been  completed,  and  provide additional
information that should be helpful. This section
addresses (1) basic principles of documenting a
Superfund site risk assessment (e.g., key "dos" and
don'ts", the rationale for consistency), (2) a
suggested outline and guidance for the risk
assessment report, and (3) guidance for providing
risk assessment summaries in other key reports.
9.1.1 BASIC PRINCIPLES

    There  are three basic principles
documenting a baseline risk assessment:
for
    (1)  address the main objectives of the risk
        assessment

    (2)  communicate using clear, concise, and
        relevant text, graphics, and tables; and

    (3)  use a consistent format.

    Addressing the objectives. The objectives of
the baseline risk assessment -- to help determine
whether additional response action is necessary at
the site, to provide a basis for determining
residual chemical  levels that are adequately
protective of public  health, to provide a basis for
comparing potential health impacts of various
remedial alternatives,  and to help support
selection of the  "no-action" remedial alternative
(where appropriate) — should be considered
carefully during the documentation of the, risk
assessment.  Recognizing these objectives early
and presenting the results of the risk assessment
with them in mind will assist the RPM and other
decision-makers at the site with readily obtaining
and using the necessary information to evaluate
the objectives.     Failing to  recognize the
importance of the objectives could result in a risk
assessment report that appears misdirected and/or
unnecessary.

    Communicating.    Clearly and concisely
communicating  the  relevant results of the risk
assessment can be  one of the most important
aspects of the entire RI/FS. If done correctly, a
useful instrument for mitigating public health
threats will have been developed.   If done
incorrectly,   however,    risks   could  be
underemphasized,   possibly  leading to the

-------
Page 9-2
occurrence of adverse health effects, or they could
be overemphasized, possibly  leading to the
unnecessary expenditure of limited resources. See
the  box below  for some  helpful hints on
communicating the baseline risk  assessment.
    HELPFUL HINTS: COMMUNICATING
     THE BASELINE RISK ASSESSMENT
   Try to:
         use a mix  of well written  text, illustrative
         graphics, and summary tables;

         explain the major steps and the resuJis of the
         risk assessment in terms easily understood by
         the general public (and especially by members
         of exposed or potentially exposed populations);

         define highly technical terms early (e.g., In a
         glossary); and

         use a standard quantitative system — preferably
         the metric system - throughout and units that
         are the same where possible (e.g., Dg/L for all
         water concentrations).
   Avoid:
         the use of large blocks of text unbroken by
         any headings, graphics, tables, lists, or other
         'Visual dividers";

         the   presentation  of  much   quantitative
         information within the text  (rather  than in
         tabjes); and

         the drawing of "risk management" conclusions
         (e.g,,  stating that the total or largest risk is
         insignificant).
     Many skills for communicating the baseline
risk assessment also can be learned by reviewing
the  literature on risk communication.  The
following box lists just some of the literature that
is available. Courses on the subject also exist.

     Using a consistent format. A consistent
format for all Superfund risk assessments is
strongly recommended for four important reasons:

     (1) it    encourages    consistency    and
         completeness in the assessment itself;
     RISK COMMUNICATION GUIDANCE

   Explaining Environmental Risk (EPA 1986}

   Tools   far   Environmental   Professionals
   Involved  in   Risk  Communication   At
   Hazardous Waste Facilities Undergoing Siting,
   Permitting, or Remediation (Bean 1987)

   Improving Dialogue with Communities:   A
   Short   Guide   for   Government   Risk
   Communication (NJDEP 1987)

   Seven Cardinal Rules of Risk Communication
   (EPA 1988a)
     (2)  it allows for easier review of the risk
         assessments;

     (3)  it encourages consistent use  of the
         results by RPMs and other decision-
         makers; and

     (4)  it helps demonstrate to the public and
         others    that  risk assessments  are
         conducted using the same framework (if
         not the same specific procedures).

Using other formats can lead to slower  review
times, different  interpretations of similar results,
and the  charge  that  risk assessments  are
inappropriately being conducted differently from
one site to another. The following subsections
provide guidance on the use of consistent formats.

9.1.2     BASELINE RISK ASSESSMENT
         REPORT

     The baseline risk assessment report references
and supports the RI/FS report. Depending on the
site, the risk assessment report can range  from a
small, simple document with no appendices that
can simply be added to the RI/FS report as a
chapter, to a large, complex document with many
appendices that can "stand alone." This subsection
provides general guidance on how to  organize the
baseline  risk assessment report  and  which
information should be  included in the report.
More detailed guidance, however,  is found by
following the guidance in previous chapters of this

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                                                                                          Page 9-3
manual. Careful use of that guidance will ensure
a well-documented baseline risk assessment report.

     Exhibit 9-1 provides a suggested outline for
the full baseline risk  assessment report. This
outline generally follows the flow of the risk
assessment and the organization of this manual.
The "bulleted" items are not necessarily section
headings, but rather are often items that should
be considered when writing the report. Note that,
as with the manual, not all components of the
outline are applicable to all  sites.    This is
especially true if the risk assessment report will be
a chapter in the RI/FS report.  At some sites, and
especially when the risk assessment report will be
a stand-alone document, more site-specific items
could be added to the report.

   Examples of tables  and graphics that should
be included in the report are presented as  exhibits
in previous  chapters  of this manual.    Note,
however, that additional tables and graphics may
be useful.

     This suggested outline  may be used as a
review guide by risk assessors (and risk assessment
reviewers)  to  ensure  that all appropriate
components  of the  assessment  have  been
addressed.  Section 9.2  addresses review  tools in
greater detail.
9.1.3
OTHER KEY REPORTS
     Two important reports that must include
summaries of the baseline risk assessment are (1)
the remedial investigation/feasibility study (RI/FS)
report and (2) the record of decision (ROD)
report.

     Summary for the RI/FS report. One of the
chapters of the RI/FS typically is devoted to a
summary of the baseline risk assessment. Part of
this summary should address the human health
evaluation (the other part should address the
environmental evaluation). The human health
summary should follow the same outline as the
full baseline risk assessment report, with almost
each section of the summary being a distillation
of each  full report  chapter.    The  risk
characterization chapter is an exception, however,
in that it could be included in the RI/FS report
essentially unchanged. Most tables and graphics
should be included unchanged as well. For more
                                           information, see Guidance for Conducting Remedial
                                           Investigations   and Feasibility Studies Under
                                           CERCLA (EPA 1988b).

                                               Summary for the ROD report. The ROD
                                           documents the remedial action selected for a site.
                                           It consists of three basic components: (1) a
                                           Declaration (2) a Decision Summary;, and (3) a
                                           Responsiveness Summary. The second component,
                                           a Decision Summary, provides an overview of the
                                           site-specific factors and analyses that led to the
                                           selection of  the remedy.    Included  in this
                                           component is a summary of site risks. As with
                                           the risk assessment  summary for the RI/FS report,
                                           the summary  for the ROD report should follow
                                           the same outline as the full risk assessment. This
                                           summary, however,  should be  much more
                                           abbreviated than the RI/FS summary, although
                                           care must be taken to address all of the relevant
                                           site-specific results.  For more information, see
                                           Interim Final  Guidance on Preparing Superfund
                                           Decision Documents:    The Proposed Plan,  the
                                           Record of Decision, Explanation of Significant
                                           Differences,  and the  Record of Decision Amendment
                                           (EPA  1989).
9.2 REVIEW TOOLS

    This section provides guidelines on reviewing
a risk assessment report. A checklist of many
essential  criteria that  should be  adequately
addressed in any  good risk assessment is provided
(Exhibit 9-2). The checklist touches upon issues
that are often problematic and lead to difficulty
and delay in the review of risk assessments.
Principal questions are presented in the checklist
with qualifying statements or follow-up  questions,
as well as references to appropriate chapters and
sections of this manual. The checklist is intended
as a guide to assist the preliminary reviewer by
ensuring that critical issues concerning the quality
and adequacy of information are not overlooked
at the screening level review of risk assessments.
Experience has shown that reviewers should pay
particular attention to the following concerns.

    •    Were all appropriate media sampled?

    •    Were any  site-related chemicals (e.g.,
         human carcinogens)  eliminated from
         analysis without appropriate  justification?

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Page 9-4

                                     EXHIBIT 9-1


   SUGGESTED OUTLINE FOR A BASELINE RISK ASSESSMENT REPORT



1.0 INTRODUCTION

    1.1 Oveview
        • General problem at site
        • Site-specific objectives of risk assessment

    1.2 Site Background
        •  Site description
        • Map of site
        •  General history
           ~ Ownership
           —  Operations
           -- Contamination
        • Significant site  reference points
        • Geographic location relative to offsite areas of interest
        • General  sampling locations and media

    1.3 Scope of Risk Assessment
        • Complexity of assessment and rationale
        • Overview of study design

    1.4 Organization  of Risk Assessment Report

2.0 IDENTIFICATION OF CHEMICALS OF POTENTIAL CONCERN

    2.1  General Site-specific Data Collection Considerations
        • Detailed historical information relevant to data collection
        • Preliminary identification of potential human exposure
        • Modeling parameter needs
        • Background sampling
        • Sampling locations and media
        • Sampling methods
        • QA/QC  methods
        • Special analytical services (SAS)

    2.2 General Site-specific Data Evaluation Considerations
        • Steps used  (including optional screening procedure steps, if used)
        • QA/QC methods during  evaluation
        • General  data uncertainty

    2.3 Environmental Area or Operable Unit 1 (Complete for All Media)
        • Area- and media-specific sample collection strategy (e.g., sample size, sampling locations)
        • Data from  site investigations


                                        (continued)

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                                                                                     Page 9-5

                               EXHIBIT 9-1 (continued)

   SUGGESTED OUTLINE FOR A BASELINE RISK ASSESSMENT REPORT
           Evaluation of analytical methods
           Evaluation of quantitation limits
           Evaluation of qualified and coded data
           Chemicals in blanks
           Tentatively identified compounds
           Comparison  of chemical concentrations with background
           Further limitation of number of chemicals
           Uncertainties, limitations, gaps in quality of collection or analysis

    2.4  Environmental Area  or Operable Unit 2 (Repeat for All Areas or Operable Units, As
        Appropriate)

    2.X Summary of Chemicals of Potential Concern

3.0  EXPOSURE  ASSESSMENT

    3.1  Characterization of Exposure  Setting
        •  Physical Setting
           ~ Climate
           ~ Vegetation
           ~ Soil type
           -- Surface hydrology
           -- Ground-water hydrology
        • Potentially Exposed Populations
           -  Relative  locations of populations with respect to site
           ~  Current  land use
           --  Potential alternate future land uses
           -  Subpopulations of potential concern

    3.2  Identification of Exposure Pathways
        •  Sources and receiving media
        •  Fate and transport in release media
        •  Exposure points and exposure routes
        •  Integration of sources,  releases, fate and transport mechanisms, exposure points, and exposure
           routes into complete exposure pathways
        •  Summary of exposure pathways to be quantified in this assessment

    3.3  Quantification of Exposure
        •  Exposure  concentrations
        •  Estimation of chemical intakes  for individual pathways


                                         (continued)

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Page 9-6

                                EXHIBIT  9-1 (continued)

   SUGGESTED OUTLINE FOR A BASELINE RISK ASSESSMENT REPORT
    3.4 Identification of Uncertainties
         • Current and future land-use
         • Environmental sampling and analysis
         • Exposure pathways evaluated
         • Fate and transport modeling
         • Parameter values

    3.5 Summary of Exposure Assessment

4.0 TOXIC1TY ASSESSMENT

    4.1 Toxicity  Information for NonCarcinogenic Effects
         •  Appropriate exposure periods for-toxicity values
         •  Up-to-date RfDs for all chemicals
         •  One- and ten-day health advisories for shorter-term oral exposures
         •  Overall data base and the critical study on which the toxicity value is based (including the
           critical effect and the uncertainty and modifying factors used in the calculation)
         •  Effects that may appear at doses higher than those required to elicit the critical effect
         •  Absorption efficiency considered

    4.2 Toxicity Information for Carcinogenic Effects
         •  Exposure  averaged over a  lifetime
         •  Up-to-date slope  factors  for all carcinogens
         •  Weight-of-evidence classification for all carcinogens
         •  Type of cancer for Class A carcinogens
         •  Concentration above which the dose-response curve is no longer linear

    4.3 Chemicals for Which No EPA Toxicity Values Are Available
         • Review by ECAO
         • Qualitative evaluation
         • Documentation/justification of any new toxicity values developed

    4.4 Uncertainties Related to  Toxicity Information
         •  Quality of the individual studies
         •  Completeness of the overall data  base

    4.5 Summary of Toxicity Information

5.0 RISK CHARACTERIZATION

    5.1 Current Land-use Conditions
         • Carcinogenic  risk of individual substances
         • Chronic hazard quotient calculation (individual substances)
         • Subchronic hazard quotient calculation (individual  substances)

                                         (continued)

-------
                                                                                         Psgc 9-7

                                 EXHIBIT 9-1  (continued)

SUGGESTED OUTLINE FOR A BASELINE RISK ASSESSMENT REPORT
           Shorter-term hazard quotient calculation (individual substances)
           Carcinogenic risk  (multiple  substances)
           Chronic hazard index (multiple substances)
           Subchronic  hazard index (multiple substances)
           Shorter-term hazard index calculation (multiple substances)
           Segregation of hazard indices
           Justification for combining risks across  pathways
           Noncarcinogenic hazard index  (multiple pathways)
           Carcinogenic risk  (multiple pathways)

    5.2 Future Land-use Conditions
        •  Carcinogenic risk of individual substances
        •  Chronic hazard quotient calculation (individual substances)
        •  Subchronic  hazard quotient  calculation  (individual substances)
        •  Carcinogenic risk  (multiple  substances)
        •  Chronic hazard index (multiple substances)
        •  Subchronic  hazard index (multiple substances)
        •  Segregation of hazard indices
        •  Justification for combining risks across  pathways
        •  Noncarcinogenic hazard index  (multiple pathways)
        •  Carcinogenic risk  (multiple pathways)

    5.3 Uncertainties
        • Site-specific uncertainty factors
           ~ Definition of physical setting
           ~ Model applicability and assumptions
           -  Parameter values for fate/transport and exposure calculations
        • Summary of toxicity assessment uncertainty
           ~ Identification of potential health effects
           ~ Derivation of toxicity value
           ~ Potential for synergistic or  antagonistic interactions
           ~ Uncertainty in evaluating less-than-lifetime exposures

    5.4 Comparison of Risk Characterization Results to Human Studies
        • ATSDR health assessment
        • Site-specific health studies (pilot studies or epidemiological studies)
        • Incorporation of studies into the overall risk characterization

    5.5 Summary Discussion and Tabulation of the Risk Characterization
        • Key site-related contaminants and key exposure pathways identified
        • Types of health risk of concern
        • Level of confidence in the quantitative  information used to estimate risk
        • Presentation of qualitative information  on toxicity
                                           (continued)

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Page 9-8
                              EXHIBIT 9-1 (continued)

   SUGGESTED OUTLINE FOR A BASELINE RISK ASSESSMENT REPORT
          Confidence in the key exposure estimates for the key exposure pathways
          Magnitude of the carcinogenic and noncarcinogenic risk estimates
          Major factors driving risk
          Major factors contributing to uncertainty
          Exposed population  characteristics
          Comparison with site-specific health studies
6.0  SUMMARY

    6.1  Chemicals of Potential Concern
    6.2  Exposure Assessment
    6.3  Toxicity Assessment
    6.4  Risk Characterization

-------
                                                                                         Page 9-9

                                        EXHIBIT  9-2


                                REVIEWER CHECKLIST
1.0 GENERAL CONCERNS

    •    Were the site-specific obJective(s) of the risk assessment stated? (HHEM - 1)

    •    Was the scope of the assessment described (e.g., in terms of the complexity of the assessment and
         rationale, data needs, and overview of the study design)? (HHEM -1.1.1, 3.5)

    •    Was an adequate history of site activities provided, including a chronology of land use (e.g.,
         specifying agriculture, industry, recreation, waste deposition, and residential development at the
         site)? (HHEM-2.1.4, 9.1)

    •    Was an initial qualitative overview of the nature of contamination included (e.g.,  specifying in a
         general manner the kinds of contaminants, media potentially contaminated)? (HHEM -2.1.4, 9.1)

    •    Was a general map of the site depicting boundaries and surface topography included, which
         illustrates site features, such as fences,  ponds, structures, as well as geographical relationships
         between specific potential receptors and the site? (HHEM -2.1.4, 9.1)

2.0 CONCERNS IN REVIEWING DATA COLLECTION AND EVALUATION

    2.1 Data Collection

         • Was an adequate  "conceptual model" of the site discussed? (HHEM - 4.2)

           -  a qualitative  discussion of potential  or suspected sources  of contamination, types  and
              concentrations of contaminants detected at the site, potentially contaminated media, as well
              as potential exposure pathways and receptors

         •  Was an adequate  Data Quality Objectives  (000) statement provided? (HHEM 4.1.4)

           ~ a statement specifying both the qualitative and quantitative nature  of the sampling dam
              in terms of relative quality and intent  for use, issued prior to data collection, which helps
              to ensure that the data collected will be appropriate for the intended objectives of the study

          Were kev site characteristics documented? (HHEM -4.3, 4.5)

           --  soil/sediment  parameters (e.g., particle size, redox potential, mineral class, organic carbon
              and clay content, bulk density, and porosity)

           -  hydrogeological parameters (e.g., hydraulic gradient, pH/Eh, hydraulic  conductivity,  location,
              saturated thickness,  direction, and rate of flow of aquifers, relative location of bedrock layer)
                                          (continued)

-------
9-10
                             EXHIBIT  9-2 (continued)

                             REVIEWER CHECKLIST
       --  hydrological parameters (e.g., hardness, pH, dissolved oxygen, salinity, temperature, total
          suspended solids, flow rates, and depths of rivers or streams;  estuary and embayment
          parameters such as tidal cycle, range, and area; as well as lake parameters such as area,
          volume, depth, and depth to thermocline)

       --  meteorological parameters  (e.g., direction of prevailing wind, average wind speed,
          temperature, humidity, annual average and 24 hour maximum  rainfall)

     • Were all appromiate media sampled?  (HHEM -4.4,4.5, 4.6)

       --  was there adequate justification for any omissions?

       ~  were literature estimates employed for omissions in background sampling and were they
          referenced properly?

     • Were all kev areas sampled, based on all available information (e.g., preliminary assessment,
       field screening)? (HHEM -4.4, 4.5,  4.6)

     • Did sampling include media along potential routes of migration (e.g..  between the contaminant
       source and potential future exposure points)? (HHEM -4.5, 4.6)

     • Were sampling locations consistent with nature of contamination  (e.g., at the appropriate
       depth)? (HHEM -4.5, 4.6)

     • Were sampling efforts consistent with field screening and visual observations in locating "hot
       spots"?rHHEM-4.5. 4.6^

     • Were detailed sampling  maps provided, indicating the location, type (e.g., grab, composite,
       duplicate), and numerical code of each sample? (HHEM - 5.10)

     • Did sampling include appropriate  OA/OC measures (e.g.. replicates, split samples, trip and field
       blanks)? (HHEM -4.7,  5.4)

     • Were background samples collected from appropriate areas (e.g., areas proximate to the site,
       free of potential contamination by site chemicals or anthropogenic sources, and similar to the
       site in topography, geology,  meteorology, and other physical characteristics)? (HHEM  -4.4,
       5.7)

2.2 Data  Evaluation

     • Were any site-related chemicals (e.g.. human carcinogens) eliminated from analysis without
       appropriate justification? (HHEM -  5.9)

                                       (continued)

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                                                                                     Page 9-11

                               EXHIBIT 9-2 (continued)


                               REVIEWER CHECKLIST
           -  as infrequently detected chemicals (HHEM - 5.3.3, 5.9.3)

           -  as non-detects in a specific medium without employing a "proxy" concentration (HHEM -
              5.3)

           --  as common laboratory contaminants even though sample concentrations were significantly
              higher than that found in blanks? (HHEM - 5.5)

           -  as present at a "ubiquitous level"? (HHEM - 5.7)

        •  Were inappropriate "proxy concentrations" assigned to site-related chemicals? (HHEM - 5.3)

           ~ was a value of zero or the instrument detection limit (IDL) assigned?

           -- was an erroneous sample-specific quantitation limit employed?

        •  Were appromiate analytical methods employed for collection of data upon which risk estimates
           are based? (HHEM - 5.2)

           -  were the methods consistent with the requisite level of sensitivity?

           --  were established procedures  with adequate QA/QC measures employed?

        •  Did the data meet the Data Quality Objectives (DQO)? (HHEM - 4.1.4)

           --  were the sampling methods consistent with the intended uses of data?

        •  Were appropriate data qualifiers employed?  (HHEM - 5.4)

        •  Were special analytical services (SAS) employed when appropriate? (HHEM - 5.3)

           --  was SAS employed  as an adjunct to routine analysis in cases where certain contaminants
              were suspected at low levels, as non-TCL chemicals, in non-standard matrices, or in
              situations requiring a quick turnaround time?


3.0 CONCERNS IN REVIEWING THE EXPOSURE ASSESSMENT

    •   Were  "reasonable maximum exposures"  considered (i.e., the highest exposures that are reasonably
        expected to occur)? (HHEM -6.1.2, 6.4.1, 6.6)

    •   Were current and future land uses considered? (HHEM -6.1.2, 6.2)


                                         (continued)

-------
Page 9-12

                                 EXHIBIT 9-2 (continued)


                                 REVIEWER CHECKLIST
         Was residential land use considered as an alternative future land use? (HHEM - 6.2.2)

         - if not, was a valid rationale provided?

         Were all potential sensitive subpopulations considered (e.g., elderly people, pregnant or nursing
         women, infants and children, and people with chronic illnesses)? (HHEM - 6.2.2)

         Were all significant contaminant sources considered? (HHEM - 6.3.1)

         Were all potential contaminant release mechanisms considered, such as volatilization, fugitive dust
         emission, surface runoff/overland flow, leaching to ground water, tracking by humans/anirnals, and
         soil gas generation? (HHEM - 6.3.1)

         Were all potential contaminant transport pathways considered, such as direct air transport
         downwind,  diffusion in surface water, surface water flow, ground-water flow, and soil gas migration?
         (HHEM - 6.3)

         Were all relevant cross-media transfer effects considered, such as volatilization to air, wet
         deposition, dry deposition, ground-water discharge to surface, and ground-water recharge from
         surface water? (HHEM - 6.3)

         Were all media potentially associated with exposure considered? (HHEM - 6.2, 6.3)

         Were all relevant site-speific characteristic considered, including topographical, hydrogeological,
         hydrological, and meteorological parameters? (HHEM - 6.1, 6.3)

         Were  all possible exposure pathways considered? (HHEM - 6.3)

         — was a valid rationale offered for exclusion of any potential pathways from quantitative
           evaluation?

         Were all "spatial relationships" adequately considered as factors that could affect the level of
         exposure (e.g., hot spots in an area that is frequented by children, exposure to ground water from
         two aquifers that are not hydraulically connected and that differ in the type and extent of
         contamination)? (HHEM - 6.2, 6.3)

         Were appropriate approaches employed for calculating average exposure concentrations? fHHEM
         - 6.4, 6.5)

         ~ was a valid rationale provided for using geometric or arithmetic means?

         Were appromiate or standard default values used in exposure calculations (e.g., age-specific body
         weights, appropriate exposure  frequency and duration values)? (HHEM - 6.4, 6.5, 6.6)

                                          (continued)

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                                                                                       Page 9-13

                                EXHIBIT 9-2 (continued)


                                REVIEWER CHECKLIST
4.0 CONCERNS IN REVIEWING THE TOXICITY ASSESSMENT

    •   Was the exclusion of any carcinogen from analysis adequately justified (e.g., were "weight-of-
        evidence" classifications and completeness of exposure pathways considered in this decision)?
        (HHEM - 5.9, 7.3)

    •   Were appropriate "route-to-route" extrapolations performed in cases where a toxicity value was
        applied across differing routes of exposure?  (HHEM -7.5.1, 8.1.2)

        -- were the extrapolations based on appropriate guidance?

    •   Were appropriate toxicitv values employed based on the nature of exposure? (HHEM - 7.4, 7.5)

        -- were subchronic vs. chronic RfDs applied  correctly based on the duration of exposure?

        -- were all sensitive subpopulations, such as pregnant or nursing women potentially requiring
           developmental RfDs (RfD^ts), considered in the selection of the toxicity values used?

    •   Were the toxicity values that were used consistent with the values contained within the Integrated
        Risk Information System (IRIS') or other EPA documents? (HHEM - 7.4, 7.5)


5.0 CONCERNS IN REVIEWING THE RISK CHARACTERIZATION

    •   Were exposure estimates and toxicitv values consistently expressed as either intakes or absorbed
        doses for each chemical taken through risk characterization? (HHEM - 8.1.2)

        -- was a valid rationale given for employing values based on absorbed dose?

    •   Were all site-related chemicals that were analyzed in the exposure assessment considered in risk
        characterization? (HHEM - 8.1.2)

        - were inconsistencies explained?

    •   Were risks appropriately summed only across exposure pathways  that affect the same individual
        or population subgroup, and in  which the same individual or population subgroup faces the
        "reasonable maximum exposure," based on the assumptions employed in the exposure assessment?
        (HHEM - 8.3)

    •   Were sources of uncertainty adequately characterized? (HHEM - 8.4)

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Page  9-14
     •   Were current and future land  uses
         considered?

     •   Were all significant contaminant sources
         considered?

     •   Were appropriate or  standard default
         values used in exposure calculations?

     •   Were the toxicity values that were used
         consistent with the values contained
         within the Integrated Risk Information
         System (IRIS) or other EPA documents?

 Although the checklist addresses many pertinent
 issues, it is not a complete listing of all potential
 concerns, since this objective is beyond  the scope
 of a preliminary review tool. In addition, some of
 the concerns listed are not necessarily appropriate
 for all risk assessment reports.

     The recommended steps in reviewing a risk
 assessment report  are  as follows:

     (1) compare the  risk assessment report
         outline  to the suggested outline in
         Section 9.1 of this chapter (i.e., Exhibit
         9-1);

     (2) use the checklist in this section (i.e.,
         Exhibit 9-2); and

     (3) conduct a comprehensive review.

 The outline (Exhibit  9-1) and the checklist
 (Exhibit 9-2) are intended only as tools to assist
 in a preliminary review of a risk assessment, and
 are not designed to replace the good judgment
 needed during the comprehensive review. These
 two tools should provide a framework,  however,
 for the timely screening of risk assessments by
 reviewers with a moderate level of experience in
the area. If these steps are followed in order,
then some of the major problems with a risk
assessment report (if any) can be identified before
significant resources are expended during the
comprehensive review.
9.3  MANAGEMENT  TOOLS

     This section provides a concise checklist for
the RPM to use in carrying out their role in the
risk  assessment process (see Exhibit 9-3). Other
decision-makers at the site also may find this'
checklist useful.   Specific points at which the
managers should be involved, or may be called
upon to become  involved, during  the risk
assessment are discussed in Chapters 4 through 8
of the manual. This checklist extracts information
from those chapters, and also includes pointers on
planning and involvement for the manager. The
purpose of the checklist is to involve managers in
the  direction and  development  of  the risk
assessment and thereby avoid serious mistakes or
costly misdirections in focus or level of effort.

     Although the checklist is shaped to suggest
when and how the  manager should become
involved in the risk assessment process, it is
assumed that part of the manager's involvement
will require consultation with technical resources
available in the region or state. The checklist
advises consulting the "regional risk assessment
support staff  at a  number  of points  in the
process. This contact may not be one person, but
could be a number of different technical people
in   the region,  such  as   a   toxicologist,
hydrogeologist, or other technical reviewer. The
manager should become aware of the resources
available to  him or her, and use them when
appropriate to ensure that the risk assessment
developed is useful and accurate.

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                                                                                     Page 9-15


                                      EXHIBIT 9-3


                  CHECKLIST FOR MANAGER INVOLVEMENT



1. GETTING ORGANIZED

    •   Ensure that the workplan for the risk assessment contractor support is in place (if needed).

    •   Identify EPA risk assessment support persomel (to be used throughout the risk assessment
        process).

    •   Gather relevant information, such as appropriate risk assessment guidances and site-
        specific data and reports.

    •   Identify available state, county, and other non-EPA resources.

2. BEFORE THE SCOPING MEETING

    ...»   Make  initial contact with risk assessor.

    •   Provide risk asseasor with available guidances and site data.

    •   Determine (or review) data collection needs for risk assessment, considering:
        "  modeling parameter needs;
        —  type and location of background sample,
           the preliminary identification of potential human exposure;
        "  strategies for sample collection appropriate to site/risk assessment data needs;
        -  statistical  methods;
        —  QA/QC measures of particular importance to risk assessment;
        —  special analytical services (SAS) needs;
        --  alternate  future land use and
        -  location(s) in ground water that will be used to evaluate future ground-water exposures.

3. AT THE SCOPING MEETING

    •   Present risk assessment data collection needs.

    •   Ensure that the risk assessment data collection needs will be considered in development
        of the sampling and analysis plan.

    •   Where limited resources  require that less-than-optimal sampling be conducted, discuss potential
        impacts on risk assessment results.

4. AFTER  THE SCOPING MEETING

    •   Ensure that the risk assessor reviews and approves the sampling and analysis plan.

    •   Consult with ATSDR if human monitoring is planned.

                                        (continued)

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Page 9-16


                                EXHIBIT 9-3 (continued)


                   CHECKLIST FOR MANAGER INVOLVEMENT


5.  DURING SAMPLING AND ANALYSIS

    •   Ensure that risk assessment needs are being met during sampling.

    •   Provide risk assessor with any preliminary sampling results so that he/she can determine
        if sampling should be refocused.

    •   Consult with ATSDR to obtain a status report on any human monitoring that is being conducted.
        Provide any results to risk assessor.

6.  DURING DEVELOPMENT OF RISK ASSESSMENT

    •   Meet with risk assessor to discuss basis of excluding chemicals from the risk assessment
        (and developing the list of chemicals of potential concern). Confirm appropriateness of
        excluding chemicals.

    •   Confirm determination of alternate future kind use.

    •   Confirm location(s) in ground water that will be used to evaluate  future ground-water exposures.

    •   Understand basis for selection of pathways  and potentially exposed populations.

    •   Facilitate discussions between risk assessor  and EPA risk assessment support personnel
        on the following points:

        -  the need for any major exposure, fate, and transport models (e.g., air or ground-water
           dispersion models) used;

        --  site-specific exposure assumptions;

        --  non-EPA-derived toxicity values; and

        --  appropriate level of detail for uncertainty analysis,  and the degree to which uncertainties will
           be quantified.

    •   Discuss and approve combination of pathway risks and hazard indices.

    •   Ensure that end results of risk characterization have been compared with ATSDR health
        assessments and other site-specific human studies that might be available.

7.  REVIEWING THE RISK ASSESSMENT

    •   Allow sufficient time for review and incorporation of comments.

    •   Ensure that reviewers' comments are incorporated.

                                         (continued)

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                                                                          Page 9-17





                         EXHIBIT 9-3 (continued)





             CHECKLIST FOR MANAGER INVOLVEMENT









COMMUNICATING THE  RISK ASSESSMENT




 •  Plan a briefing among technical staff to discuss significant findings and uncertainties.




 •  Discuss development of graphics, tools, and presentations to assist risk management decisions




 • Consult with other groups (e.g., community relations staff), as appropriate.




 • Brief upper management.

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Page 9-18

                                 REFERENCES  FOR  CHAPTER 9
Bean, M.C. (CH2M Hill). 1987. Tools for Environmental Professionals Involved in Risk Communication at Hazardous Waste Facilities
     Undergoing Siting. Permitting, or Remediation. Presented at the Air Pollution Control Association Annual Meeting. New York,
     June 21-26, 1987.

Environmental Protection Agency (EPA). 1986.  Explaining Environmental Risk. Office of Toxic Substances.

Environmental Protection Agency (EPA). 1988a. Seven Cardinal Rules of Risk Communication. Office of Policy Analysis.

Environmental Protection Agency (EPA). 1988b. Guidance for Conducting Remedial Investigations and Feasibiliv Studies Under
     CERCLA.  Office of Emergency and Remedial Response. (OSWER Directive 9355.3-01).

Environmental Protection Agency (EPA). 1989. Interim Final Guidance on Preparing Superfund Decision Documents The Proposed
     Plan, the Record of Decision, Explanation of Significant Differences, and the Record of Decision Amendment. Office of
     Emergency and Remedial Response. (OSWER Directive 9355.3-02).

New Jersey Department of Environmental Protection (NJDEP). 1987. Improving Dialogue with Communities A Short Guide for
     Government Risk Communication. Division of Science and Research.

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                                  CHAPTER  10

               RADIATION  RISK  ASSESSMENT
                                    GUIDANCE
     There are many sites  contaminated with
radioactive substances that  are included on the
National Priorities List (NPL), and additional sites
are expected in future NPL updates. This chapter
provides supplemental baseline risk assessment
guidance for use at these sites. This guidance is
intended as an overview of key differences in
chemical and radionuclide assessments, and not as
a  comprehensive,   stand-alone approach for
assessing the risks posed by radiation.

     The reader should be familiar with the
guidance provided in Chapters 2 through 9 before
proceeding further in Chapter 10. Although the
discussions in the  previous  chapters  focus
primarily  on chemically contaminated sites,  much
of the information presented  is also applicable to
the evaluation of radioactively contaminated
Superfund sites For consistency and completeness,
the topics discussed in each section of this chapter
parallel the topics covered in  each of the previous
chapters.

    After a brief introduction to some of the
basic principles  and  concepts of radiation
protection (Section 10.1), seven additional  areas
are addressed:

     (1)  Regulation  of  Radioactively
        Contaminated sites  (Section  10.2);

     (2)  Data Collection (Section 10.3);

     (3)  Data Evaluation (Section 10.4);

     (4)  Exposure and Dose  Assessment (Section
         10.5);
 ACRONYMS, SYMBOLS, AND UNITS
         FOR CHAPTER 10

 Aft) * Activity at Time t
  Bq = Becquerel
   C$ ** Curie
 CLP — Contract Laboratory Program
   D «* Absorbed Dose
 DCF * Dose Conversion Factor Per Unit Intake
  HE * Effective Dose Equivalent
  HX ** Dose Bqujyalen* Averaged Over Tissue or
     -  Organ T
HB 50 * Committed Effective Dose Equivalent Per
       Unit  Intake
HT;SO " Committed Dose Equivalent Averaged
       Over Tissue T
 LET = Linear Energy Transfer
 LLD w Lower Limit of Detection
 MeV « Million Electron Volts
   N = Modifying Factor in the Definition of
       Dose Equivalent
  pCi * PicoCurie (10"*2 Ci)
   Q * Quality Factor in Definition of Dose
       Equivalent
 RBE » Relative Biological Effectiveness
   SI * International System of Units
   Sv ** Sievert
   T - Tfc&w or Target Organs
  WT = Weighting Factor in the Definition of
       Effective Dose Equivalent and Committed
       Effective Dose Equivalent
 (5)  Toxicity Assessment (Section  10.6);

 (6)  Risk Characterization (Section  10.7); and

 (7)  Documentation,    Review,   and
     Management   Tools  for the  Risk
     Assessor,  Reviewer,  and  Manager
     (Section 10.8).

-------
Page 10-2
                                         DEFINITIONS FOR CHAPTER 10

     Absorbed Dose fD).  The mean energy imparted by ionizing radiation to matter per unit mass. Th« *pecia] Si unit of
           absorbed dose is the gray (Gy); the conventional unit is the rad (1 rad *s 0,01 Gy).

     Becouerel fBqV  One nuclear disintegration per second; the name for the SI unit of activity.  1 Bq •» 2.7 x 10'^ d
                ,E>pfl$, ffiufoafcifl , {ffir ;»),  The total dose equivalent (averaged over tissue 1) deposited over the 50-year
           period following the intake of a radionuclide,
     Committed Effective Dose Equivalent (Hp^n). The weighted sum of committed dose equivalents to specified organs and
           tissues, in analogy to the effective dose equivalent.

     Curie fen.  3.7 x 1010 nuclear disintegrations  per second, the name for the conventional unit of activity, 1 Q •= 3^ x
     Pecav ProducUs"). A. radionuclide or a series of radionuclides formed by the nuclear transformation of another
           radioauclide which, in this context, is referred to as the parent.
     Dose Conversion Factor fDCPk  The dose equivalent per unit intake of radionuclide.

     Dose Equivalent (H).  The product of the absorbed dose (D), the quality factor (Q), and ycy other modifying factors (N).
           The SI unit of dose equivalent is the sievert (Sv); the conventional unit is the rera  (1 rem *" maItte
-------
                                                                                        Page 10-3
     There are special hazards associated with
handling radioactive waste and EPA strongly
recommends that a health physicist experienced in
radiation  measurement and protection be
consulted prior to initiating any activities at a site
suspected of being contaminated with radioactive
substances.    EPA also recommends that the
remedial project manager (RPM) or on-scene
coordinator (OSC)  should  designate both  a
chemical risk assessor  and  a  radiation risk
assessor.  These individuals should work closely
with each other and the RPM to coordinate
remedial activities (e.g., site scoping, health and
safety planning, sampling  and analysis) and
exchange information common to both chemical
and radionuclide assessments, including data on
the physical characteristics of the site, potentially
impacted populations, pathways of concern, and
fate and transport models used. At the conclusion
of the remedial investigation/feasibility study
(RI/FS) process, the  RPM should issue a single
report that summarizes and integrates the results
from both the chemical and the radiation risk
assessments.

     A two-phase evaluation is described for the
radiation risk assessment. As discussed in Section
10.5, procedures established by the International
Commission on Radiological Protection (ICRP
1979) and adopted by EPA in Federal Guidance
Report No. 11 (EPA  1988) are used to estimate
the radiation dose equivalent to humans from
potential exposures to radionuclides through all
pertinent exposure pathways at a site. Those
estimates of dose equivalent may be used for
comparison with established radiation protection
standards and criteria. However, this methodology
was developed for regulation of occupational
radiation  exposures   for  adults  and is  not
completely applicable  for estimating health risk to
the  general  population  at  a Superfund site.
Therefore, a separate methodology is presented in
Section 10.7.2 for estimating health risk based on
the age-averaged lifetime excess cancer incidence
per unit intake (and  per unit extenal exposure)
for radionuclides of concern. Radiation risk
assessments for Superfund sites should include
estimates of both the dose equivalent computed
as described in Section 10.5, and the health risk
attributable to radionuclide exposures computed
using the approach described in Section  10.7.
     Only summary-level information is presented
in this chapter, and references are provided to a
number of supporting technical documents for
further information. In particular, the reader is
encouraged to  consult  Volume  1  of the
Background Information Document for the Draft
Environmental Impact Statement for Proposed
NESHAPS for Radionuclides (EPA 1989a) for a
more comprehensive discussion of EPA's current
risk assessment methodology for radionuclides.

    For additional radiation  risk  assessment
information  and guidance, RPMs and other
interested individuals  can  contact the Office of
Radiation  Programs  (ORP)  within EPA
headquarters  at 202-475-9630 (FTS  475-9630).
Interested individuals  also  can contact the
Regional  Radiation Program Managers within
each of the EPA regional offices for guidance and
health  physics support.
10.1 RADIATION PROTECTION
         PRINCIPLES AND
         CONCEPTS

    Radioactive atoms undergo  spontaneous
nuclear transformations and release  excess energy
in the  form  of ionizing radiation.    Such
transformations are referred to as radioactive
decay.   As a result  of the radioactive decay
process, one element is transformed into another;
the newly formed element,  called a decay product,
will possess physical and chemical properties
different from those of its parent, and may also be
radioactive. A radioactive  species of a particular
element is  referred  to as a radionuclide or
radioisotope.   The exact mode of radioactive
transformation for a particular  radionuclide
depends solely upon its nuclear characteristics, and
is independent   of  the  nuclide's  chemical
characteristics or physical state.  A fundamental
and unique characteristic of each radionuclide is
its radioactive half-life,  defined as the time
required for one half of  the atoms in a given
quantity of the radionuclide to decay. Over 1,600
different radionuclides  have been  identified to
date, with half-lives ranging from fractions of a
second to millions of years. Selected radionuclidea

-------
Page 10-4
 of potential importance at Superfund sites are
listed in Exhibit 10-1.

      Radiation emitted by radioactive substances
can transfer sufficient localized energy to atoms
to remove electrons from the electric field of their
nucleus (ionization). In living tissue this energy
transfer can destroy  cellular constituents and
produce electrically charged molecules (i.e., free
radicals). Extensive biological  damage can lead to
adverse health effects.    The type of ionizing
radiation emitted by a particular radionuclide
depends upon the exact  nature of the nuclear
transformation, and may include emission of alpha
particles, electrons (beta particles  or positrons),
and neutrons; each of these transformations may
be  accompanied by emission of photons (gamma
radiation  or x-rays).    Each type of radiation
differs in its physical  characteristics and in its
ability to inflict damage to  biological tissue. These
characteristics and effects  are summarized in the
box on this  page.
     Quantities  of radionuclides are typically
expressed in terms of activity at a given time t
(A(t)). The SI unit of activity is the becquerel
(Bq), which is defined as the quantity of a given
radionuclide in which one atom is transformed per
second  (i.e.,  one  decay  per   second).   The
conventional unit of activity is the curie (Ci),
which is defined  as the quantity of a given
radionuclide in which 3.7xl010atoms undergo
nuclear transformation each second; one curie is
approximately equivalent to the decay rate of one
gram  of Ra-226. A more convenient unit of
activity    for     expressing     environmental
concentrations of radionuclides  is the picoCurie
(pCi), which is equal to 10"12 Ci.   Occassionally,
activity is expressed incorrectly in terms of counts
per second (cps) or  counts per minute (cpm):
these refer to the number of transformations per
unit time measured by a particular radiation
detector and do not represent the true decay  rate
of the radionuclide.    To derive activity values,
count  rate  measurements are  multiplied by
radioisotope-specific  detector  calibration factors.
                             PRINCIPAL TYPES OF IONIZING RADIATION

     Alpha particles are doubly charged cations, composed of two protons aad two neutrons, which are ejected monoenergeiicafly
   from the nucleus of an atom when the neutron to proton ratio fe too low.  Because of their relatively large mass and charge,
   alpha particles tend to ionize nearby atoms quite readily, expending their energy in short distances. Alpha particles will usually
   not penetrate an ordinary sheet of paper or the outer layer of skin.  Consequently, alpha particles represent a significant hazard
   only when taken into the body, where their energy is completely absorbed by small volumes of tissues.

     Beta particles are electrons ejected at high speeds from the nucleus of an unstable atom when a neutron spontaneously
   converts to a proton and an electron. Unlike alpha particles, beta particles are not emitted with discrete energies but are ejected
   from the nucleus over a continuous energy spectrum. Beta particles are smaller than alpha particles, carry a single negative
   charge, and possess a lower specific ionization potential. Unshielded beta sources can constitute external hazards if the beta
   radiation is within a few centimeters of exposed skia surfaces and if the beta energy is greater than 70 keV. Beta sources
   shielded with certain metallic materials may produce bremsstrahlung (low energy x-ray) radiation which may also contribute to
   the external radiation exposure,  laternally, beta particles have a much greater range than alpha panicles in tissue. However,
   because tftey cause fewer toafesttans per trait patfi length, beta particles deposit much less energy to small volumes of tissue and,
   coasequemiy, indict must less damage than alpha particles.

     Positrons are identical to beta particles except that they have a positive charge. A positron is emitted from the nucleus of
   a neutron-deficient atom when a proton spontaneously transforms into A neutron. Alternatively, in cases where positron emission
   is not energetically possible, the neutron deficiency may be overcome by electron capture, whereby one of the orbital electrons
   to captured by the nucleus and united with a proton to form a neutron, or by annihilation radiation, whereby the combined mass
   of a positron and electron is converted into photon energy.   The damage inflicted by positrons to small volumes of tissue is
   similar to that of beta particles.

     Gamma radiations are photons emitted from the nucleus of a radioactive atom.  X-rays, which are extra-nuclear in origin, are
   identical in form to gamma rays, but have slightly lower energy ranges. There are three mam ways in which x- and gamma rays
   internet with matter, the photoelectric effect, the Compton effect, and pair production. At) three processes yield  electrons which
   then  ionize or excite other atoms of the substance.  Because of their high penetration ability, x- and gamma radiations are of
   most concern as external hazards.

     frfcutrons are emitted during nuclear fission reactions, along with two smaller nuclei, called fission fragments, and beta and
   gamma radiation. For radionuclides likely to be encountered at Superfund sites, the rate of spontaneous fission is minute and
   no significant neutron radiation Is expected.

-------
                                                                       Page 10-5
                                EXHIBIT  10-1
   RADIOLOGICAL CHARACTERISTICS OF SELECTED RADIONUCLIDES
                       FOUND AT SUPERFUND  SITES3
Nuclide
Am-241
Am-243
Ba-137m
C-14
Ce-144
Cm-243
Cm-244
'Co-60
Cr-51
'Cs-134
Cs-135
Cs-137
Fe-59
H-3
1-129
1-131
K-40
Mn-54
Mo-99
Nb-94
Np-237
P-32
Pb-210
Po-210
Pu-238
Pu-239
Pu-240
Pu-241
Pu-242
Ra-226
Ra-228
Ru-106
S-35
Sr-89
Sr-90
Tc-99
Tc-99m
Th-230
Th-232
U-234
U-235
U-238
Half-life c
4.32X102 y
7.38X103 y
2.55x10° h
5.73x10* y
2.84X102 d
2.85X107 y
LSlxlO7 y
5.27x10° y
2.77X107 d
2.06x10° y
2.30X106 y
S.OOxlO7 y
4.45X107 d
1.23xl(r y
1.57xl07 y
8.04x10° d
1.28X109 y
3.13X102 d
6.60X107 h
2.03x10* y
2.14x10* y
1.43x10* d
2.23X107 y
1.38X102 d
8.77X101 y
2.41x10* y
6.54x10* y
1.44x10-' y
3.76X105 y
1.60X105 y
5.75x10° y
3.68X102 d
8.74x10* d
5.05x10* d
2.91X107 y
2.13X105 y
6.02x10° h
7.70x10* y
lAlxltf0 y
2.44X105 y
7.04x10* y
4.47X109 y
Averaae
Alpha
5.57x10°
5.36x10°
__
„
„
5.89x10°
5.89x10°
~
—
..
..
—
	
..
..
..
..
„
	
..
4.85x10°
..
..
5.40x10°
5.59x10°
5.24x10°
5.24x10°
1.22x10'-
4.97x10°
4.86x10°
—
_
	
	
..
—
	
4.75x10°
4.07x10°
4.84x10°
4.47x10°
4.26x10°
Radiation Enemies (MeV/decavV
Beta, Electron
5.21xlO-2
2.17X10"2
6.37X10"2
4.95xl(T2
9.22xlO'2
1.38X10-7
8.59X10"5
9.65xlO-2
3.86xl(T5
1.64xlO-;
6.73xl(T2
1.87xlO-7
1.17X10'7
5.68xlO-5
6.38xl(T2
1.92x10-'
5.23xl(T7
4.22X10"5
3.93X10-7
1.68X10-7
7.01xlO-2
6.95xl(T7
3.80X1Q-2
8.19X10"8
1.06x10-2
6.74X10"5
1.06xlO-2
5.25xlu5
8.73xlO-J
3.59xlO'J
1.69xl02
1.00x10-2
4.88x10-2
5.83xlO-;
1.96xlO-;
1.01x10-'
1.61x10-2
1.42x10-2
1.25x10-2
1.32x10-2
4.92x10-2
1.00x10-2

x, Gamm
3.25x10-2
5.61xlO-2
5.98xlO';
„
2.07x10-2
1.35xlO-;
1.70xlO'5
2.50x10°
3.26x10-2
1.55x10°
..
..
1.19x10°
..
2.46x10-2
3.81x10-'
1.56X10'7
8.36xlQ-;
1.50x10-'
1.57x10°
3.46x10-2
	
4.8MO'5
8.51xlO-6
1.81xlO'5
8.07x10"'
1.73X10'3
2.55xiu-
1.44xlO'5
6.75X10-5
4.14xlO'p
..
	
8.45xlO-5
..
..
L26xlO-'
1.55x10-^
1.33X10'5
1.73xlO'5
1.56x10-'
1.36xlO-5
"Source: ICRP 1983 (except Ba-137m data from Kocher 1981).
b Computed as the sum of the products of the energies and yields of individual radiations.

°Half-life expressed in years (y), days (d), and hours (h).

-------
    10-6
     The  activity per unit mass  of a given
radionuclide is called the specific activity, and is
usually expressed in units of bequerels per gram
(Bq/g) or  curies per gram (Ci/g). The shorter the
half-life of the radionuclide, the greater is its
specific activity.    For example, Co-60 has a
radioactive half-life of about 5 years and a specific
activity of 4xl013Bq/g, whereas Np-237 has a
half-life of 2 million years and a specific activity
of3x!07Bq/g.

     Several terms are used by health physicists to
describe the physical interactions of different types
of radiations with biological tissue, and to define
the effects of these interactions on human health.
One of the first terms developed was radiation
exposure, which refers to the transfer of energy
from a radiation field of x- or gamma rays to a
unit mass of air. The unit for this definition of
exposure is  the roentgen  (R), expressed as
coulombs of charge per  kilogram of air (1 R =
2.58x10 4C/kg).

   The term  exposure  is also defined  as the
physical contact of the human body with radiation.
Internal exposure refers to an exposure that occurs
when human tissues are  subjected to  radiations
from radionuclides that have entered  the body via
inhalation, ingestion, injection, or other routes.
External  exposure refers to the' irradiation of
human tissues   by radiations  emitted  by
radionuclides located outside the  body either
dispersed  in the air or water, on skin surfaces, or
deposited on  ground surfaces.   All types of
radiation  may contribute to internal  exposure,
whereas only photon, beta, and neutron radiations
contribute  significantly to external exposure.

     Ionizing  radiation  can cause deleterious
effects on  biological tissues only when  the energy
released during radioactive decay is absorbed in
tissue. The absorbed dose (D) is defined as the
mean energy imparted by ionizing radiation per
unit mass  of tissue. The SI unit of absorbed dose
is the joule per kilogram, also assigned the special
name  the gray  (1 Gy = 1  joule/kg).  The
conventional unit of absorbed dose is  the rad (1
rad =100 ergs per gram = 0.01 Gy).

     For radiation protection purposes, it is
desirable  to compare doses of different types of
radiation.   The absorbed dose of any radiation
divided by the absorbed dose of a reference.
radiation (traditionally 250 kVp x-rays) that
produces the  same biological endpoint is called
the Relative Biological Effectiveness or RBE. For
regulatory purposes, an arbitrary consensus RBE
estimate called the Quality Factor or Q is often
used. The dose equivalent (H) was developed to
normalize the unequal biological effects produced
from equal absorbed doses of different types of
radiation. The dose equivalent is defined as:

                 H  =DQN

where D is the absorbed dose, Q is  a  quality
factor that accounts for the RBE of the type of
radiation emitted, and N is the product of any
additional modifying factors,   Quality factors
currently   assigned  by    the    International
Commission on Radiological Protection (ICRP)
include values of Q=20 for alpha particles, Q=10
for neutrons and protons, and Q= 1 for beta
particles, positrons, x-rays, and gamma rays (ICRP
1984).    These factors may be interpreted as
follows: on average, if an equal amount of energy
is absorbed,  an alpha particle will  inflict
approximately 20 times more damage to biological
tissue than a beta particle or gamma ray, and
twice  as much damage  as a neutron. The
modifyng factor is currently assigned a value of
unity (N=  1) for all radiations.  The SI unit of
dose equivalent is the sievert (Sv), and the
conventional unit is the rem (1 rem = 0.01 Sv).
        GENERAL HEALTH PHYSICS
               REFERENCES

   Introduction to Health Physics (Ceraber
   1983)

   Atoms, Radiation, and Radiation Protection
   (Turner  1986)

   Environmental Radioactivity (Eisenbud
   1987)

   The Health Physics and Radiological Health
   Handbook (SWeien and Terpilak 1984)

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                                                                                                   10-7
                                  EFFECTIVE DOSE EQUIVALENT

     The effective dose equivalent, HE , is a weighted wnn of dose equivalent* to all organs and tissues (ICRP1977, ICR? 197?),
   defined as:
   where Wf is the weighting factor for organ or tissue T and Hf is the mean dose equivalent to organ or tissue T. The factor
   Wf, which is normalized so that the summation of all the organ weighting factors is equal to one, corresponds to the fractional
   contribution of organ or tissue T to the total risk of stochastic health effects when the body is uniformly irradiated. Similarly,
   the committed effective dose equivalent, HJJ^Q, is defined as the weighted sum of committed dose equivalents to all irradiated
   organs and tissues, as follows:

                                          HE so  ^  $ *T HT,5o
                                                    T

   HE And HRSO tl)US reflect both the distribution of dose among the various organs and tissues of the body and their assumed
   relative sensitivities to ctochastic effects.  The organ and tissue weighting factor values w-j- are as follows: Gonads, 0.25; Breast,
 • 045;  Red Marrow, 0.12; Lungs,  042; Thyroid, 0.03; Bone Surface, 0.03; and Remainder, 0.30 (i.e., a value of WT = 0.06 is
   applicable to each of the five remaining organs or tissues receiving the highest doses).
    The dose delivered to tissues from radiations
external  to the body  occurs  only while the
radiation field is present. However, the  dose
delivered to body tissues due to radiations  from
systemically incorporated radionuclides  may
continue long after intake of the nuclide has
ceased.    Therefore, internal doses to specific
tissues and  organs are typically reported in terms
of the committed dose equivalent (HT,5(1), which
is defined as the integral of the dose equivalent in
a particular tissue  T for 50 years after intake
(corresponding to a  working lifetime).

     When  subjected to equal doses of radiation,
organs and tissues in the human body will exhibit
different cancer induction rates. To account for
these differences and to normalize radiation doses
and effects  on a whole body basis for regulation
of occupational exposure, the ICRP developed the
concept of the effective dose equivalent (HE) and
committed effective  dose equivalent (HE,50), which
are defined as weighted sums of the organ-specific
dose equivalents (i.e., S wj-Hj) and organ-specific
committed dose equivalents (i.e.,  SwjHr,50)>
respectively. Weighting factors,  WT, are based on
selected stochastic risk factors specified by the
ICRP and are  used to average organ-specific  dose
equivalents (ICRP 1977,  1979). The effective  dose
equivalent  is equal to that  dose  equivalent,
delivered at a uniform whole-body  rate,  that
corresponds to the same number (but possibly a
dissimilar distribution) of fatal stochastic health
effects as the particular combination of committed
organ dose equivalents (see the box on this page).

     A special unit, the working level (WL), is
used to describe  exposure to the short-lived
radioactive decay  products of radon (Rn-222).
Radon is a naturally occurring radionuclide that
is of particular concern because it is ubiquitous,
it is very mobile in the environment, and it decays
through a series of short-lived decay products that
can deliver a significant dose to the lung when
inhaled.  The WL is defined as any combination
of short-lived radon decay products in one liter of
air that will result in the ultimate  emission of
1.3xl05MeV of alpha energy. The working  level
month (WLM) is  defined as the exposure to 1
WL for 170 hours  (1 working month).

     Radiation protection philosophy encourages
the reduction of all radiation exposures as low as
reasonably achievable (ALARA), in consideration
of  technical,  economic,  and  social factors.
Further, no practice involving radiation exposure
should be adopted unless it provides a positive net
benefit. In addition to these general guidelines,
specific upper limits  on radiation exposures and
doses  have been established by  regulatory
authorities as described in the following section.

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Page 10-8
    Additional discussion on the measurement of
radioactivity is provided in Sections 10.3 and 10.4,
and the evaluation of radiation exposure and dose
is discussed further in Section 10.5. Discussion of
potential health impacts  from ionizing radiation
is presented in Section 10.6.
10.2 REGULATION  OF
      RADIOACTIVELY
      CONTAMINATED SITES

     Chapter 2 briefly describes the statutes,
regulations, guidance, and studies related to the
human health evaluation process  for chemical
contaminants.  The discussion  describes CERCLA
as amended by SARA and the RI/FS process.
Since radionuclides are classified  as hazardous
substances under CERCLA,  this information is
also applicable to radioactively contaminated sites.
Chapter  2 also   introduces  the  concept  of
compliance with  applicable or relevant and
appropriate requirements (ARARs) in federal and
state environmental laws as required by SARA.
Guidance on   potential   ARARs for  the
remediation of radioactively  contaminated  sites
under CERCLA is available in the CERCLA
Compliance with Other Laws Manual (EPA 1989c).
Only a brief summary of regulatory authorities is
presented here.

    The  primary  agencies with  regulatory
authority  for the  cleanup of radioactively
contaminated sites include  EPA the Nuclear
Regulatory Commission (NRC), the Department
of Energy (DOE), and state agencies.   Other
federal agencies, including the Department of
Transportation (DOT) and Department of Defense
(DOD), also have regulatory programs (but more
limited) for radioactive materials. Also, national
and international  scientific advisory organizations
provide recommendations related to radiation
protection  and radioactive waste  management, but
have no regulatory authority.  The following is a
brief description of the main functions and areas
of jurisdiction of these agencies and organizations.

     •   EPA's authority to protect public health
        and the environment from adverse effects
        of radiation exposure is derived from
        several statutes, including the  Atomic
        Energy Act, the Clean Air Act,  the
    Uranium Mill Tailings Radiation Control
    Act (UMTRCA), the Nuclear Waste
    Policy Act, the Resource Conservation
    and Recovery  Act  (RCRA), and
    CERCLA. EPA's major responsibilities
    with regard to radiation include the
    development of federal guidance and
    standards,    assessment    of  new
    technologies,   and   surveillance of
    radiation in the environment. EPA also
    has lead responsibility in the federal
    government for advising all  federal
    agencies on radiation standards. EPA's
    radiation  standards apply to many
    different types of activities involving all
    types of radioactive material (i.e., source,
    byproduct, special nuclear,  and  naturally
    occurring and accelerator produced
    radioactive material [NARM]).   For
    some    of  the    EPA    standards,
    implementation   and    enforcement
    responsibilities   are  vested in other
    agencies, such as NRC and DOE.

•   NRC licenses the possession and use of
    certain types of radioactive material at
    certain types of  facilities.  Specifically, the
    NRC is authorized to license source,
    byproduct, and  special nuclear material.
    The NRC is not authorized to license
    NARM,  although  NARM may be
    partially subject to NRC regulation when
    it is associated with material licensed by
    the NRC. Most of DOE's operations
    are exempt from NRC's licensing and
    regulatory requirements, as are certain
    DOD activities   involving    nuclear
    weapons and the use of nuclear reactors
    for  military purposes.

•   DOE is responsible  for conducting or
    overseeing   radioactive    material
    operations at numerous government-
    owned/contractor-operated     facilities.
    DOE is also responsible for managing
    several  inactive  sites that  contain
    radioactive  waste, such as sites associated
    with  the  Formerly Utilized Sites
    Remedial Action Program (FUSRAP),
    the Uranium Mill Tailings Remedial
    Action Program (UMTRAP), the Grand
    Junction Remedial Action Program
    (GJRAP), and the Surplus Facilities

-------
                                                                                           Page 10-9
                   MAJOR FEDERAL lAWS FOR RADIATION PROTECTION

» Atomic Energy Act of 1954, Public Law 83-705 - established the Atomic Energy Commission as the basic regulatory
  authority for ionizing radiation.

• Energy Reorganization Act of 1974, Public Law 93-438 - amended the Atomic Energy Act, and established the Nuclear
  Regulatory Commission to regulate nondefense nuclear activities.

• Marine Protection, Research, and Sanctuaries Act of 1972> Public Law 92-532 - established controls for ocean disposal of
  radioactive waste.

• Safe Drinking Water Act, Public Law 93-523 <• mandated regulation of radkmuclides in drinking water,

« Clean Air Act Amendments of 1977, Public Law 95-95 * extended coverage of the Act's provisions to include
  radionuclides.

• Uranium Mill Tailings Radiation Control Act of 1978, Public Law 96-415 - required stabilization and control of byproduct
  materials (primarily mill tailings) at licensed commercial uranium and thorium processing sites.

• Low-Lcvci Radioactive Waste FoUey Act of ISSO, rwroc Law w473 - Bwdc Swrtw wspOBswic for disposal 0* LLRW
  generated within their borders and encouraged formation of later-state compacts.

  XT.4*I<»»~ 117***^ IXhtt/Mr AA» Af 11&1  DlkKUyt T AM> iVT_*
  4^\AV4VWU  VTCWM* A waAVT *"»Wfc w AyFvr**, X wvuv 44dfT f f T
  high-level radioactive waste and spent nuclear fuel

» Low-Level Radioactive Waste Policy Act AmendineuiB of 1985, PabKc Law 99*240 * amended LLRWPA requiremenm and
  schedules for establishment of LLRW disposal capacity.
    Management Program (SFMP). DOE is
    authorized  to control  all  types of
    radioactive materials at sites within its
    jurisdiction.

•   Other federal agencies with regulatory
    programs applicable to radioactive waste
    include DOT and DOD.    DOT has
    issued regulations   that  set forth
    packaging, labeling, record keeping, and
    reporting requirements for the transport
    of radioactive material  (see 49 CFR
    Parts 171 through 179). Most of DOD's
    radioactive waste management activities
    are  regulated by NRC  and/or EPA
    However, DOD has its own program for
    controlling wastes generated for certain
    nuclear weapon and reactor operations
    for military purposes. Other agencies,
    such  as   the  Federal  Emergency
    Management Agency  (FEMA) and the
    Department of the Interior (DOI), may
    also play a role in radioactive waste
    cleanups in certain cases.
                                                        •    States have their own authority and
                                                             regulations for managing radioactive
                                                             material and waste.    In addition, 29
                                                             states (Agreement States) have entered
                                                             into agreements with the NRC, whereby
                                                             the Commission has relinquished to the
                                                             states its  regulatory  authority over
                                                             source, byproduct, and small quantities
                                                             of special nuclear material.    Both
                                                             Agreement States and Nonagreement
                                                             States can also regulate NARM. Such
                                                             state-implemented    regulations    are
                                                             potential ARARs.

                                                        •    The National Council on Radiation
                                                             Protection and Measurements (NCRP)
                                                             and the International Commission on
                                                             Radiological Protection (ICRP) provide
                                                             recommendations on human radiation
                                                             protection. The NCRP was chartered
                                                             by Congress to collect, analyze, develop,
                                                             and  disseminate  information  and
                                                             recommendations     about   radiation
                                                             protection and measurements.  The
                                                             ICRP'S function is basically the same,
                                                             but on an international level. Although

-------
Page  10-10
          neither the NCRP nor the ICRP have
          regulatory    authority,    their
          recommendations serve as the basis for
          many   of  the   general  (i.e.,  not
          source-specific) regulations  on radiation
          protection developed at state and federal
          levels.

      The standards, advisories,  and  guidance of
 these various groups are designed primarily to be
 consistent with each other, often overlapping in
 scope and purpose.    Nevertheless, there are
 important differences  between agencies and
programs  in  some cases. It  is important that
 these differences be well understood so that when
more than one set of standards is  potentially
 applicable to or relevant and appropriate for the
 same CERCLA  site,  RPMs will  be able to
 evaluate which standards to follow. In general,
 determination  of  an  ARAR for a  site
 contaminated with radioactive materials requires
 consideration of the radioactive constituents
 present and the  functional operations  that
 generated  the site, whose regulatory jurisdiction
 the site falls under, and which regulation is most
 protective, or if relevant  and appropriate, most
 appropriate given  site conditions.

      For  further  information on radiation
 standards,  advisories, and guidance, RPMs should
 consult the detailed ARARs guidance document
 (EPA 1989c),  as well as EPA's ORP and/or
 Regional Radiation Program Managers.
 10.3 DATA COLLECTION

     Data collection needs and procedures for sites
 contaminated with radioactive substances are very
 similar to  those described in Chapter 4 for
 chemically contaminated  sites.     There are,
 however, some basic differences that simplify data
 collection for radionuclides, including the  relative
 ease and accuracy with which natural background
 radiation and radionuclide contaminants can be
 detected in the environment when compared with
 chemical contaminants.

     The pathways  of exposure and the
 mathematical models  used to  evaluate  the
 potential health risks associated with radionuclides
 in the environment are similar to those used for
 evaluating chemical contaminants. Many of the
radionuclides found at Superfund sites behave in
the environment like trace metals. Consequently,
the types of data needed for a radiation risk
assessment are very similar to those required for
a chemical contaminant risk assessment.   For
example,  the environmental,  land use, and
demographic data needed and the procedures used
to gather the data required to model fate and
effect are virtually  identical.    The primary
differences  lie  in  the  procedures  used  to
characterize the radionuclide contaminants.  In the
sections that follow, emphasis is placed on the
procedures used to characterize the radionuclide
contaminants and not the environmental setting
that affects their fate and effects, since the latter
has been thoroughly covered in Chapter 4.

10.3.1    RADIATION DETECTION METHODS

    Field and laboratory methods used to identify
and quantify concentrations of radionuclides in the
environment are, in many cases, more exact, less
costly, and more easily  implemented than those
employed for chemical  analyses. Selection of a
radiometric method depends upon the number of
radionuclides of interest,  their  activities and types
of radiations emitted, as well  as on the level of
sensitivity required and the sample size available.
In some cases, the selection process requires prior
knowledge of the  nature  and extent  of radioactive
contamination present onsite.  See the references
provided in the box on  page  10-12 for detailed
guidance on sample  collection and preparation,
radiochemical procedures, and radiation counters
and measurement techniques.   The following
discussion provides an overview of a few of the
radiation detection techniques and instruments
currently used to characterize  sites  contaminated
with radioactive materials.

    Field  methods utilize instrumental techniques
rather than radiochemical  procedures to determine
in-situ    identities   and   concentrations   of
radionuclides, contamination profiles, and external
beta/gamma exposure rates.  Field instruments
designed for radiation detection (see Exhibit 10-
2) are portable, rugged, and relatively insensitive
to wide fluctuations in temperature and humidity.
At the same time, they  are sensitive enough  to
discriminate between variable levels of background
radiation from naturally occurring radionuclides
and excess radiation due to radioactive waste.
Because of the harsh conditions in which they are

-------
                                                                EXHIBIT  10-2
                              TYPES OF FIELD RADIATION DETECTION INSTRUMENTS
        Instruments
                                         Range of Counting Rate
                                         and Other Characteristics
                             Typical Uses
                                                                                              Remarks
Beta-Gamma Surface Monitors0

   Portable Count Rate Meter (Thin
   Walled or Thin Window G-M Counter)

Alpha Surface Monitors
   Portable Air Proportional Counter
   with Probe

   Portable Gas Flow Counter with Probe
   Portable Scintillation Counter with
   Probe

Air Monitors
   Particle Samplers
      Filter Paper (High-volume)

      Filter Paper (Low-volume)
   Electrostatic Precipitalor
    Impingcr
Tritium Monitors
    Flow ionizaiion chambers
0-1,000; 0-10,000; 0-100,000
count/min
0-100,000 count/min over
100 an2

0-100,000 count/min over
100cm2

0-100,000 count/min over
100cm2
40 ftj/min (1.1 m5/min)

0.1 to 10 frVmin
(0.003-0.3 mj/min)

3 ft-Vmin (0.09 mj/min)
20 to 40 fr*/min
(0.6-1.1 nr'/min)
                                        0.10 pCi/nr/min
Surfaces, hands, clothing    Simple, reliable, battery powered
Surfaces, hands, clothing
Surfaces, hands, clothing
Surfaces, hands, clothing
Not accurate in high humidity; battery powered;
fragile wiadcw

Not affected by the humidity, battery powered;
fragile window

Not affected by the humidity, battery powered;
fragile window
For quick grab samples     Used intermittently, requires separate coutner

For continuous room air    Used continuously, requires separate counter
breathing zone monitoring

For continuous monitoring  Sample deposited on cylindrical shell; requires
                         separate counter
Alpha contamination
Special uses; requires separate counter
                             Continuous monitoring      May be sensitive to other sources of ionizatkra
"None of these surface monitors is suitable for tritium detection.

Source NCRP Report No. 57 (NCRP 1978).

-------
 Page 10-12
      RADIONUCLTOE MEASUREMENT
               PROCEDURES

   Environmental Radiation Measurements
   (NCRP 1976)

   Instrumentation and Monitoring Methods for
   Radiation Protection {NCRP 1978)

   Radiochemical Analytical Procedures for
   Analysis of Environmental Samples (EPA
   1979a)

   Eastern Environmental Radiation Facility
   Radiochemistry Procedures Manual (EPA
   19843)

   A Handbook of Radioactivity Measurement
   Procedures (NCRP 1985a)
sometimes operated, and because their detection
efficiency  varies with photon energy, all field
instruments should be properly calibrated in the
laboratory  against National Bureau of Standards
(NBS) radionuclide sources prior to use in the
field. Detector response should also be tested
periodically in the field against NBS  check-sources
of known activity.

     Commonly used gamma-ray survey meters
include Geiger-Muller  (G-M) probes, sodium
iodide   (Nal(Tl))  crystals,  and  solid-state
germanium diodes (Ge(Li)) coupled to ratemeters,
sealers, or multichannel analyzers (MCAs). These
instruments provide measurements  of overall
exposure  rates in counts per  minute, or
microRoentgens or microrem per hour. However,
only Nal and Ge(Li)  detectors with MCAs provide
energy spectra of the gamma rays detected and
can therefore  verify the identity of specific
radionuclides.  Thin  window G-M detectors and
Pancake (ionization) probes are used to  detect
beta particles. Alpha-particle surface monitors
include portable air proportional, gas proportional,
and zinc sulfide (ZnS) scintillation detectors,
which all have very thin and fragile windows. The
references  in the box on this  page  provide
additional information on several other survey
techniques and instruments, such as aerial gamma
 surveillance used to map gamma exposure rate
 contours over large areas.

     Laboratory methods involve both chemical
 and instrumental techniques to quantify low-levels
 of radionuclides  in  sample  media.  The
 preparation of samples prior to counting is an
 important consideration, especially for samples
 containing alpha- and beta-emitting radionuclides
 that either  do not emit gamma rays or emit
 gamma rays  of low  abundance.      Sample
 preparation is a multistep process that achieves
 the following three objectives:  (1) the destruction
 of the sample matrix (primarily organic material)
 to reduce alpha- and beta-particle self-absorption
 (2)  the separation   and concentration of
 radionuclides of interest to increase resolution and
 sensitivity and (3) the preparation of the  sample
 in a suitable form for  counting. Appropriate
 radioactive    tracers   (i.e.,   isotopes  of  the
 radionuclides of interest that are not present in
 the sample initially, but are added to the  sample
 to serve as yield determinants) must be selected
 and added to the sample before a radiochemical
 procedure is initiated.

     For alpha counting, samples are prepared as
 thin-layer (low mass) sources on membrane filters
 by coprecipitation with stable carriers or on metal
 discs by electrodeposition. These sample filters and
 discs are then loaded  into gas  proportional
 counters,   scintillation detectors,  or   alpha
 spectrometry systems for measurement (see  Exhibit
 10-3).  In a  proportional counter, the sample is
 immersed in a counting gas, usually methane and
 argon, and subjected to a high voltage  field: alpha
 emissions dissociate the  counting gas creating an
 ionization current proportional to the  source
 strength, which is then measured by the  system
 electronics. In a scintillation detector, the  sample
 is placed in  contact with a ZnS phosphor  against
 the window of a photomultiplier (PM) tube: alpha
 particles induce flashes  of light in the phosphor
 that are converted to an electrical current in the
 PM tube and measured. Using alpha spectrometry,
 the sample is placed in a holder in an evacuated
 chamber facing a solid-state, surface-barrier
 detector: alpha particles strike the detector  and
 cause electrical impulses,  which are sorted by
 strength into electronic bins and counted.  All
 three systems yield results in counts per minute,
which are then converted into activity units using
 detector- and radionuclide-specific  calibration

-------
                                                             EXHIBIT  10-3
                       TYPES  OF LABORATORY RADIATION  DETECTION INSTRUMENTS3
   Type of Instrument
Typical Activity
 Range (mQ)
    Typical Sample Form
 Data Acquisition and Display
Gas Proportional Counters

Liquid-Scintillation Counters


Nal (Tl) Cylindrical or Well Crystals
lonization Chambers
Solid-state Detectors
 10'to  103

 10'to  103


 10'to  103
                                     102to  103
                                     102to 10
Film disc mount, gas

Up to 20 ml of liquid gel
Liquid, solid, or comtained gas,
<4ml
                Liquid, solid, or contained gas
                (can be large in size)

                Various
Ratemeter or sealer

Accessories for for background subtraction, quench correction,
internal standard sample comparison

Ratemeter

Discriminators for measuring various energy regions

Multichannel analyzer, or computer plus analog-to-digital
converter

Computational accessories for full-energy-peak identification,
quantification, and spectrum stripping

lonization-current measurement;
digital (mCi) readout, as in dose calibrators

Multichannel analyzer or computer with various readout
options
   'Source: NCRP Report No. 58 (NCRP 1985a).

-------
Page 10-14
values. Alpha spectrometry is the only system,
however, that can be used to identify specific
alpha-emitting  radionuclides.

     For beta counting, samples are prepared both
as thin-sources and as solutions mixed with
scintillation fluid, similar  in  function to a
phosphor. Beta-emitting sources are counted in
gas proportional counters at higher voltages than
those applied for alpha counting or in scintillation
detectors using phosphors specifically constructed
for beta-particle detection. Beta-emitters mixed
with scintillation fluid are counted in 20 ml vials
in  beta-scintillation counters:    beta-particle
interactions with the fluid produce detectable light
flashes.    Like alpha detectors, beta detectors
provide measurements in counts per minute, which
are converted to activity units using calibration
factors. It should be noted, however, that few
detection systems are available for determining the
identity  of individual beta-emitting radionuclides,
because beta particles are emitted as a continuous
spectrum of energy that is difficult to characterize
qnd ascribe to any specific nuclide.

     It is advisable to count all samples intact in
a known geometry on a Nal or Ge(Li) detector
system prior to radiochemical analysis, because
many radionuclides that emit gamma rays in
sufficient abundanw and energy can be detected
and measured by this process.   Even complex
gamma-ray spectra emitted  by  multiple
radionuclide sources can be  resolved using Ge(Li)
detectors, MCAs, and software packages, and
specific  radionuclide  concentrations can. be
determined. If the sample activity is low or if
gamma rays are feeble, then more rigorous alpha
or beta analyses are advised.

10.3.2    REVIEWING AVAILABLE SITE
         INFORMATION

     In Chapter 4, reference is made to reviewing
the  site data for chemical  contaminants  in
accordance with Stage 1  of the Data Quality
Objectives (DQO) process (see box on Page 4-4).
This process also applies to radionuclides. For
further guidance on the applicability of DQOS to
radioactively contaminated sites, consult EPA's
Office of Radiation Programs.
10.3.3    ADDRESSING MODELING
         PARAMETER  NEEDS

    Exhibits 4-1 and 4-2 describe the elements of
a conceptual model and the types of information
that may be obtained during a site sampling
investigation. These exhibits apply to radioactively
contaminated sites with  only minor modifications.
For example, additional exposure pathways  for
direct  external exposure from immersion in
contaminated air or water  or from contaminated
ground surfaces may need to  be addressed  for
certain  radionuclides; these  exposure pathways  are
discussed further in subsequent sections.  In
addition, several of the parameters identified in
these exhibits are not as important or necessary
for radiological  surveys.    For example, the
parameters  that are related primarily to the
modeling of organic contaminants, such as the
lipid content of organisms, are typically not
needed for radiological  assessments.

10.3.4    DEFINING BACKGROUND
         RADIATION SAMPLING NEEDS

    As is the case with a chemically contaminated
site,   the background  characteristics of a
radioactively contaminated site must be defined
reliably in order to distinguish natural background
radiation and fallout from the  onsite sources of
radioactive waste. With the possible exception of
indoor  sources of Rn-222,  it is often possible to
make these distinctions because the radiation
detection equipment and  analytical techniques
used are very precise and  sensitive.    At a
chemically contaminated site, there can be many
potential and difficult-to-pinpoint offsite sources
for the contamination found onsite, confounding
the interpretation of field measurements. With a
radioactively contaminated site, however, this is
not usually  a problem  because sources  of
radionuclides are, in general,  easier to isolate and
identify.   In fact, some radionuclides are  so
specifically associated with particular industries
that the presence of a  certain radioactive
contaminant sometimes acts as  a "fingerprint" to
identify its source. Additional information on the
sources of natural background and man-made
radiation in the environment may be found in the
references listed in the  box on the next page.

-------
                                                                                      Page 10-15
   NATURAL BACKGROUND RADIATION

   Tritium in the Environment (NCRP 1979)

   Ionizing Radiation: Sources and Effects
   (UNSCEAR  1982)

   Exposure pom the Uranium Series with
   Emphasis on  Radon and its Daughters
   (NCRP I984b)

   Carbon-14 at  the Environment (NCRP
   1985c)

   Environmental Radioactivity (Eisenbud
   1987)
 !
   Population Exposure to External Natural
   Radiation Background in the United States
  '(EPA1987a)

   Ionizing Radiation Exposure of the     •..-. '\
   Population of the United States (NCRP
   1987a)

   Exposure of the Population of the United
   States and Canada from Natural
   Back&owd Radiation (NCRP 1987b)
10.3.5   PRELIMINARY  IDENTIFICATION
        OF POTENTIAL EXPOSURE

    Identification of environmental media of
concern, the types of radionuclides expected at a
site, areas of concern (sampling locations), and
potential routes of radionuclide transport through
the environment is an  important  part of the
radiological risk assessment process.   Potential
media of concern include soil, ground water,
surface water, air, and biota, as discussed in
Chapter 4.     Additional considerations for
radioactively contaminated sites are listed below.

    •   Usually a very  limited  number of
        radionuclides  at  a site  contribute
        significantly to the risk. During the site
        scoping meeting,  it is appropriate to
        consult with a health physicist not only
        to develop a conceptual model of the
        facility, but also to  identify  the
         anticipated  critical radionuclides and
         pathways.

     •    In addition to the environmental media
         identified for chemically contaminated
         sites, radioactively contaminated sites
         should be examined for the potential
         presence  of external  radiation  fields.
         Many radionuclides emit both beta and
         gamma radiation,  which can  create
         significant external exposures.

     •    There are other components  in the
         environment that may or may  not be
         critical exposure pathways for the  public,
         but that are very useful indicators of the
         extent and type of contamination at a
         site.     These components include
         sediment,  aquatic plants, and fish, which
         may concentrate and integrate the
         radionuclide contaminants that may be
         (or have  been) present in the aquatic
         environment at a site.   Accordingly,
         though  some  components   of  the
         environment  may or may not  be
         important direct routes of exposure to
         man, they can serve  as indicators of
         contamination.

10.3.6  DEVELOPING A STRATEGY FOR
         SAMPLE  COLLECTION

     The discussions in Chapter 4 regarding
sample location, size, type, and frequency apply as
well to radioactively contaminated sites with the
following additions and qualifications. First, the
resolution and sensitivity of radioanalytical
techniques permit detection  in the environment of
most radionuclides at levels that are well  below
those that are considered  potentially harmful.
Analytical techniques for nonradioactive  chemicals
are usually not this sensitive.

     For radionuclides, continuous monitoring of
the site environment is important, in addition to
the sampling and monitoring programs  described
in Chapter 4. Many field devices that measure
external gamma radiation, such as continuous
radon  monitors and  high  pressure ionization
chambers, provide a real time continuous record
of radiation  exposure levels and radionuclide
concentrations.   Such devices are useful for
determining  the temporal variation of radiation

-------
Page 10-16
levels at a contaminated site and for comparing
these results  to  the  variability  observed  at
background locations. Continuous measure-merits
provide an  added level of resolution for
quantifying and characterizing radiological risk.

    Additional factors that affect the frequency of
sampling for radionuclides, besides those discussed
in Chapter 4, include the half-lives  and the decay
products of the radionuclides. Radionuclides with
short half-lives, such as Fe-59 (half-life = 44.5
days), have to be sampled more frequently because
relatively high levels of contamination can be
missed between longer sampling intervals. The
decay products of the radionuclides must also be
considered, because their presence can interfere
with the detection of the parent nuclides  of
interest, and because they also may be important
contributors to risks.

10.3.7 QUALITY ASSURANCE AND
         QUALITY CONTROL (QA/QC)
         MEASURES

     The QA/QC  concepts described in Chapter
4 also apply to sampling and analysis programs for
radionuclides, although the procedures differ.
Guidance regarding sampling and measurement of
radionuclides and QA/QC protocols for their
analyses are provided in the publications listed in
the box on this page.

     The QA/QC protocols used for radionuclide
analysis were not developed to meet the evidential
needs of the  Superfund program,  however, it is
likely that many of the  current radiological
QA/QC guidance  would meet  the intent of
Superfund requirements.   Some areas where
radiological QA/QC guidance may not meet the
intent of Superfund are listed below.

     •   The degree   of standardization for
         radiochemical procedures may be less
         rigorous in the QA/QC protocols than
         that required for chemical labs under
         the  Contract Laboratory Program (CLP).
         In radiochemical laboratories, several
         different techniques may be used to
         analyze  for a specific radionuclide in a
         given matrix with comparable results.
         The CLP requires  all  participating
         chemical laboratories to use standardized
         techniques.
    •   The required number and type of QC
        blanks  are fewer  for radionuclide
        samples. For example, a "trip" blank is
        not generally used because radionuclide
        samples   are   less  likely  to   be
        contaminated from direct exposure to air
        than are samples of volatile organics.

    Limited guidance is available that specifies
field QA/QC procedures (see the box on this
page). These and other issues related to QA/QC
guidance for radiological analyses are discussed
further in the Section 10.4.
      RADIONUCLIDE MEASUREMENT
           QA/QC PROCEDURES

   Quality Control for Environmental
   Measurements Using Gamma-Ray
   Spectrometry (EPA 1977b)

   Quality Assurance Monitoring Programs
   (Normal Operation)  - Effluent Streams and
   the Environment (NRC 1979)

   Upgrading Environmental Radiation Data
   (EPA 1980)

   Handbook of Analytical Quality Control in
   Radioanafytical Laboratories (EPA 1987b)

   QA Procedures for Health Labs
   Radiochemistry  (American Public Health
   Association 1987)
 10.4 DATA EVALUATION

     Chapter 5  describes the procedures  for
 organizing and evaluating data collected during a
 site sampling investigation for use  in risk
 assessment.   The ten-step process outlined for
 chemical data evaluation is generally applicable to
 the evaluation  of radioactive contaminants,
 although many of the details must be modified to
 accommodate differences  in sampling and
 analytical methods.

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                                                                                        Page 10-17
10.4.1    COMBINING DATA FROM
         AVAILABLE SITE INVESTIGATIONS

     All available data for the site should be
gathered   for  evaluation  and   sorted  by
environmental    medium  sampled,   analytical
 methods, and sampling periods. Decisions should
be made, using the process described in Section
5.1, to combine, evaluate individually, or eliminate
specific data for use  in the quantitative risk
assessment.

10.4.2    EVALUATING ANALYTICAL
         METHODS

     As with chemical data, radiological data
should  be grouped according to the types of
analyses performed to determine which data are
appropriate for use in quantitative risk assessment.
Analytical  methods for measuring radioactive
contaminants differ from those for measuring
organic and inorganic chemicals.    Standard
laboratory procedures for radionuclide analyses are
presented in references,  such as those listed in the
box  on  page 10-12.  Analytical methods include
alpha, beta, and gamma spectrometry, liquid
scintillation counting, proportional  counting,  and
chemical separation followed by spectrometry,
depending on the specific radionuclides of interest.

     Laboratory accreditation procedures for the
analysis  of radionuclides also differ.  Radionuclide
analyses are not currently conducted as part of the
Routine Analytical Services (RAS) under the
Superfund CLP. However, these analyses may be
included under Special Analytical Service-s (SAS).
The    EPA    Environmental    Radioactivity
Intercomparison Program, coordinated  by the
Nuclear Radiation Assessment Division of the
Environmental Monitoring Systems Laboratory in
Las Vegas (EMSL-LV),  provides quality assurance
oversight for participating radiation  measurement
laboratories (EPA 1989b). Over 300 federal, state,
and private laboratories  participate in some phase
of the program, which includes analyses for a
variety of radionuclides in media (e.g., water, air,
milk, and food) with activity concentrations that
approximate levels that may be encountered in the
environment.   Similar intercomparison programs
for analysis of thermoluminescent dosimeters
(TLDs) for external radiation exposure rate
measurements are conducted  by  the  DOE
Environmental  Measurements Laboratory  (EML)
and the DOE Radiological and Environmental
Services Laboratory (RESL).

    In both cases,   these intercomparison
programs are  less comprehensive than the CLP in
terms of facility requirements other than analysis
of performance evaluation samples,  such as
laboratory  space and procedural requirements,
instrumentation, training, and  quality  control.
However,  until  such  time  as radiation
measurements become fully incorporated in the
CLP,  use  of laboratories that successfully
participate in these intercomparison studies may
be the best available alternative for ensuring
high-quality  analytical data.     Regardless of
laboratory accreditation, all  analytical results
should be carefully scrutinized and not accepted
at face value.

    As discussed in Chapter  5 for chemical
analyses, radioanalytical results that are not
specific for a particular radionuclide (e.g., gross
alpha, gross beta) may have limited usefulness for
quantitative risk assessment. They can be useful
as a screening tool, however.   External gamma
exposure rate data,  although thought of as a
screening measurement, can be directly applied as
input data for a quantitative risk assessment.

10.4.3    EVALUATING QUANTITATION
         LIMITS

    Lower  limits  of detection  (LLDs),  or
quantitation limits, for standard techniques for
most radionuclide analyses are  sufficiently low to
ensure the detection  of nuclides at  activity
concentrations well below levels of concern.
There are  exceptions,    however:      some
radionuclides with very low specific activities, long
half-lives, and/or low-energy decay emissions (e.g.,
1-129, C-14) are difficult to detect precisely using
standard techniques.  To achieve lower LLDs, a
laboratory may     (1)  use  more  sensitive
measurement    techniques   and/or   chemical
extraction procedures; (2) analyze larger sample
sizes; or (3)  increase the counting time of the
sample. A laboratory may also choose to apply
all three options to increase detection capabilities.
Exhibit 10-4 presents examples of typical LLDs
using  standard analytical techniques.

    The same special  considerations noted for
chemical    analyses would also  apply  for

-------
  Page 10-18
                          EXHIBIT 10-4

          EXAMPLES OF LOWER LIMITS OF DETECTION (LLD)
FOR SELECTED RADIONUCLIDES USING STANDARD ANALYTICAL METHOD3
                            LLD
Isotope
CO-60



Sr-90
Cs-137






Pb-210



Ra-226





Th-232



U-234
U-235
U-238

Sample Mediab
-Water
-Soil (dry wt.)
-Biota (wet wt.)c
-Aird
-Water
-Water

-Soil (dry wt.)

-Biota (wetwt.)

-Air
-Water
-Soil (dry wt.)
-Biota (wetwt.)
-Air
-Water


-Soil (dry wt.)
-Biota (wet wt.)
-Air
-Water
-Soil (dry wt.)
-Biota (wetwt.)
-Air
-Water
-Soil (dry wt.)
-Biota (wetwt.)
-Air
pCi
10
0.1
0.1
25
1
10
0.3
1
0.3
1
0.3
30
0.2
0.2
0.2
5
100
0.1
0.1
0.1
0.1
1
0.02
0.2
0.02
0.3
0.02
0.1
0.01
0.2
Bq
0.4
0.004
0.004
0.9
0.04
0.4
0.01
0.04
0.01
0.04
0.01
1
0.007
0.007
0.007
0.2
4
0.004
0.004
0.004
0.004
0.04
0.0007
0.007
0.0007
0.01
0.0007
0.004
0.0004
0.007
Methodology
Gamma Spectrometry
Gamma Spectrometry
Gamma Spectrometry
Gamma Spectrometry
Radiochemistry
Gamma Spectrometry
Radiochemistry
Gamma Spectrometry
Radiochemistry
Gamma Spectrometry
Radiochemistry
Gamma Spectrometry
Radiochemistry
Radiochemistry
Radiochemistry
Radiochemistry
Gamma Spectrometry
Radiochemistry
Radon Daughter Emanation
Radon Daughter Emanation
Radon Daughter Emanation
Alpha Spectrometry
Alpha Spectrometry
Radiochemistry
Alpha Spectrometry
Alpha Proportional Counter
Alpha Spectrometry
Alpha Spectrometry
Alpha Spectrometry
Alpha Spectrometry
                            (continued)

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                                                                                           10-19
                                  EXHIBIT 10-4 (continued)

               EXAMPLES OF LOWER LIMITS OF DETECTION (LLD)
FOR SELECTED RADIONUCLIDES USING STANDARD ANALYTICAL METHODS8
                                           LLD
Isotope
PU-238
PU-239
PU-240

Sample Media11
-Water
-Soil (dry wt.)
-Biota (wet wt.)
-Air
pCi
0.02
0.1
0.01
0.2
Bq
0.0007
0.004
0.0004
0.007
Methodology
Alpha Spectrometry
Alpha Spectrometry
Alpha Spectrometry
Alpha Spectrometry
   a  Source: U.S. Environmental Protection Agency Eastern Environmental Radiation Facility (EPA-EERF), Department of Energy
      Environmental Measurements Laboratory (DOE-EML), and commercial laboratories. Note that LLDs are radionudide-, media-,
      sample size-, and laboratory-specific higher and lower LLDs than those reported above arc possible. The risk assessor should
      request and report the LLDs  supplied by the laboratory performing the_

   ™  Nominal sample sizes water (1 liter), soil (1 kg dry wt.), biota (1 kg wet wt.) and air (1 filter sample).

   c  Biota includes vegetation, fish, and meat.

   "  Air refers to a sample of 300 m of air collected on a filter, which is analyzed for the radionudide of interest.

-------
Page 10-20
radionuclides that are not detected in any samples
from a particular medium, but are suspected to be
present at a site. In these cases,  three options may
be applied: (1) re-analyze the sample using more
sensitive methods; (2) use the LLD  value as a
 "proxy" concentration to evaluate the potential
 risks at the detection limit; or (3) evaluate the
possible risk implication of the radionuclide
qualitatively. An experienced health physicist
should decide which of these three options would
be most appropriate.

    When multiple radionuclides are present in
a sample, various interferences can occur that may
reduce the analytical sensitivity for a particular
radionuclide.    Also,  in  some areas of high
background radioactivity from naturally occurring
radionuclides, it may be difficult to differentiate
background contributions  from incremental site
contamination.   It may be possible to eliminate
such interferences by radiochemical separation or
special instrumental techniques.

   A sample with activity that is nondetectable
should be reported as less than the appropriate
sample and radionuclide-specific LLD value.
However, particular caution should be exercised
when applying this approach to  radionuclides that
are difficult to measure and possess unusually high
detection limits, as discussed previously. In most
cases where a potentially important radionuclide
contaminant is suspected, but not detected, in a
sample, the sample should be  reanalyzed using
more rigorous radiochemical procedures and more
sophisticated detection  techniques.

    If radionuclide sample data for a site are
reported without sample-specific  radionuclide
quantitation limits, the laboratory conducting the
analyses  should be contacted  to determine the
appropriate LLD values for the  analytical
techniques and sample media.

10.4.4    EVALUATING QUALIFIED  AND
         CODED DATA

    Various data qualifiers and codes may be
attached to problem data from inorganic and
organic chemical analyses conducted under the
CLP as shown in Exhibits 5-4 and 5-5. These
include laboratory qualifiers  assigned by the
laboratory conducting the analysis and data
validation qualifiers assigned by  personnel involved
in data validation.   These qualifiers pertain to
QA/QC problems and generally indicate questions
concerning    chemical    identity,    chemical
concentration, or both. No corresponding system
of qualifiers has been developed for radioanalytical
data, although certain of the CLP  data qualifiers
might  be  adopted   for use  in  reporting
radioanalytical data.  The health physicist should
define and evaluate any qualifiers attached to data
for radionuclide analyses. Based on  the discussions
in Chapter 5, the references on methods listed
above,  and professional judgment, the health
physicist should eliminate inappropriate data from
use in the risk assessment.

10.4.5    COMPARING  CONCENTRATIONS
         DETECTED IN BLANKS WITH
         CONCENTRATIONS DETECTED IN
         SAMPLES

    The analysis of blank samples (e.g., laboratory
or reagent blanks, field blanks, calibration blanks)
is an   important  component  of a proper
radioanalytical program.    Analysis of blanks
provides a measure  of contamination introduced
into a  sample during sampling or analysis
activities.

    The CLP provides guidance for inorganic and
organic  chemicals that are not common laboratory
contaminants. According to this guidance, if a
blank contains detectable levels  of any uncommon
laboratory chemical,  site  sample results should be
considered positive  only   if the measured
concentration  in the sample exceeds five times the
maximum amount detected in any blank. Samples
containing less  than  five times the blank
concentration should be classified  as nondetects,
and the maximum  blank-related  concentration
should be specified as the quantitation limit for
that chemical in the sample.   Though they are
not  considered  to be common  laboratory
contaminants,     radionuclides should not  be
classified as  nondetects using the above  CLP
guidance. Instead, the health  physicist should
evaluate all  active sample  preparation and
analytical procedures  for  possible sources of
contamination.

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                                                                                      Page 10-21
 10.4.6    EVALUATING TENTATIVELY
         IDENTIFIED  RADIONUCLIDES

     Because radionuclides are not included on the
 Target Compound List (TCL), they may be
 classified as tentatively identified compounds
 (TICs) under CLP protocols. In reality, however,
 radioanalytical techniques are  sufficiently sensitive
 that the identity and quantity of radionuclides of
 potential concern at a site can be determined with
 a high degree of confidence.   In some cases,
 spectral  or matrix interferences may introduce
 uncertainties, but these problems usually  can be
 overcome using special  radiochemical  and/or
 instrumental methods.    In  cases where a
 radionuclide's   identity  is    not   sufficiently
 well-defined by the available  data set: (1) further
 analyses may be performed using more sensitive
 methods,  or  (2)  the tentatively identified
 radionuclide  may be  included  in the  risk
 assessment as a contaminant of potential concern
 with notation of the uncertainty in its identity and
 concentration.

 10.4.7    COMPARING SAMPLES WITH
         BACKGROUND

     It is imperative to select,  collect, and analyze
 an appropriate number of background samples to
 be able to distinguish between onsite sources of
 radionuclide contaminants from radionuclides
 expected   normally in   the   environment.
 Background  measurements of  direct radiation and
 radionuclide concentrations in all media of
 concern should be determined at sampling
 locations geologically similar to the site, but
 beyond the influence of the site.   Screening
 measurements (e.g., gross alpha, beta, and gamma)
 should be used to determine whether more
 sensitive   radionuclide-specific    analyses   are
 warranted. Professional judgment should be  used
 by the health physicist to select  appropriate
 background sampling locations and analytical
 techniques.    The health physicist should  also
 determine which naturally occurring radionuclides
 (e.g., uranium, radium, or thorium) detected onsite
 should be eliminated from the  quantitative risk
assessment. All man-made radionuclides detected
 in samples collected should, however, be retained
 for further consideration.
 10.4.8    DEVELOPING A SET OF
         RADIONUCLIDE DATA AND
         INFORMATION FOR USE IN A
         RISK ASSESSMENT

     The process described in Section 5.8 for
 selection of chemical data for inclusion in the
 quantitative risk assessment generally applies for
 radionuclides as well. One exception is the lack
 of CLP qualifiers for radionuclides, as discussed
 previously.    Radionuclides  of concern  should
 include those that are positively detected in at
 least one sample in a given medium, at levels
 significantly above  levels detected in blank samples
 and significantly above local background levels.
 As discussed previously, the decision to include
 radionuclides not detected in samples from any
 medium but  suspected  at the site based on
 historical information should be made by a
 qualified health physicist.

 10.4.9    GROUPING RADIONUCLIDES BY
         CLASS

     Grouping radionuclides for consideration in
 the quantitative risk assessment is generally
 unnecessary and inappropriate. Radiation dose
 and resulting health risk is highly dependent on
 the specific properties of each radionuclide. In
 some cases, however, it may be acceptable to
 group different radioisotopes of the same element
 that have similar radiological characteristics (e.g.,
 Pu-238/239/240, U-235/238) or belong to the same
 decay series. Such groupings should be determined
very selectively and seldom offer any significant
 advantage.

 10.4.10 FURTHER REDUCTION IN THE
        NUMBER OF RADIONUCLIDES

    For  sites  with  a   large  number  of
 radionuclides detected in samples from one or
more media, the risk assessment should focus on
 a select group of radionuclides that dominate the
radiation dose and health risk to the critical
receptors.    For  example, when considering
transport through ground  water  to  distant
receptors,  transit  times  may be very  long
consequently,  only   radionuclides with long
half-lives or radioactive progeny that are formed
during transport may be of concern for that
exposure pathway. For direct external exposures,
high-energy gamma emitters are of principal

-------
Page 10-22
concern, whereas alpha-emitters may dominate
doses from the inhalation and ingestion pathways.
The important radionuclides may differ for each
exposure pathway and must be determined on
their    relative    concentrations,     half-lives,
environmental mobility, and dose conversion
factors (see Section 10.5 for discussion of dose
conversion factors) for each exposure pathway of
interest.

    The total activity inventory and individual
concentrations of radionuclides at a Superfund site
will change with time as some nuclides decay
away and  others "grow in"  as  a  result of
radioactive decay processes. Consequently, it may
be important to evaluate different time scales in
the risk  assessment. For example, at a site where
Ra-226 (half-life =   1600 years) is the  only
contaminant of concern in soil at some initial
time, the Pb-210 (half-life = 22.3 years) and
Po-210  (half-life = 138 days) progeny will also
become dominant contributors to the activity
onsite over a period of several hundred years.

10.4.11  SUMMARIZING AND PRESENTING
         DATA

    Presentation of results of the data collection
and evaluation process will be generally the  same
for radionuclides  and  chemical contaminants. The
sample table formats presented in Exhibits 5-6 and
5-7 are  equally applicable to radionuclide data,
except that direct radiation measurement data
should  be  added,  if appropriate  for  the
radionuclides and exposure pathways identified at
the site.
10.5    EXPOSURE AND DOSE
         ASSESSMENT

     This section describes a methodology for
estimating the radiation  dose equivalent to
humans from potential exposures to radionuclides
through all pertinent exposure pathways at a
remedial site. These estimates of dose equivalent
may be used for comparison with radiation
protection standards and criteria. However, this
methodology has been developed for regulation of
occupational radiation exposures  for adults and is
not completely applicable for estimating health
risk to  the general population.  Section 10.7.2,
therefore, describes a separate methodology for
estimating health risk.

     Chapter 6 describes the procedures for
conducting an exposure assessment for chemical
contaminants as  part  of the  baseline risk
assessment for Superfund sites.  Though many
aspects of the discussion apply to radionuclides,
the term "exposure" is used in a fundamentally
different way for radionuclides as  compared to
chemicals.   For chemicals, exposure generally
refers to the  intake (e.g., inhalation, ingestion,
dermal exposure) of the toxic chemical, expressed
in units of mg/kg-day. These units are convenient
because the toxicity values for  chemicals are
generally expressed in these terms. For example,
the toxicity value used to assess carcinogenic
effects is the slope factor, expressed in units of
risk of lifetime excess cancers per mg/kg-day. As
a result, the product  of the intake estimate with
the slope factor yields the risk of  cancer (with
proper  adjustments made for  absorption, if
necessary.

     Intakes  by  inhalation,  ingestion, and
absorption are also potentially important exposure
pathways for  radionuclides, although radionuclide
intake is typically expressed in units of activity
(i.e., Bq or Ci) rather than mass.  Radionuclides
that enter through these internal exposure
pathways may become systemically incorporated
and emit alpha, beta, or gamma radiation within
tissues or organs. Unlike  chemical  assessments,
an   exposure   assessment    for    radioactive
contaminants  can include an explicit estimation of
the radiation dose equivalent.   As discussed
previously in  Section 10.1, the dose  equivalent is
an expression that takes into consideration both
the amount of energy deposited in a unit mass of
a specific organ or tissue as a result of the
radioactive decay of a specific radionuclide, as
well as the  relative biological effectiveness of the
radiations emitted by that nuclide. (Note that the
term dose  has  a  different  meaning  for
radionuclides  [dose = energy imparted to a unit
mass of tissue] than that used in Chapter 6 for
chemicals [dose,   or absorbed  dose = mass
penetrating into an organism].)

     Unlike chemicals, radionuclides can have
deleterious effects  on  humans without being taken
into or brought in contact with the body.  This is
because high energy beta particles  and photons

-------
                                                                                        Page  10-23
from radionuclides in contaminated air, water, or
soil can travel long distances with only minimum
attenuation in these media before depositing their
 energy in human tissues.   External radiation
exposures can result from either exposure to
radionuclides at the site area or to radionuclides
that have been transported from the site to other
locations in the environment. Gamma and x-rays
are the most penetrating of the emitted radiations,
and comprise the primary contribution to the
radiation dose  from external exposures.  Alpha
particles are not sufficiently energetic to penetrate
the outer layer of skin and do not  contribute
significantly to the external dose.    External
exposure to beta particles primarily imparts a dose
to the outer layer skin cells, although high-energy
beta radiation can penetrate into the human body.

  The quantification of the amount of energy
deposited in living tissue due to internal and
external exposures to radiation is termed radiation
dosimetry. The amount of energy deposited in
living tissue is  of concern because the potential
adverse effects of radiation are proportional to
energy deposition. The energy deposited in  tissues
is proportional to the decay rate of a radionuclide,
and  not its  mass.    Therefore, radionuclide
quantities and  concentrations  are  expressed in
units  of activity (e.g., Bq or Ci),  rather than in
units of mass.

    Despite the fundamental difference between
the way exposures are expressed for radionuclides
and  chemicals,  the  approach  to  exposure
assessment presented in Chapter 6 for chemical
contaminants largely  applies to radionuclide
contaminants. Specifically, the three  steps of an
exposure assessment for chemicals also apply to
radionuclides: (1) characterization of the exposure
setting;  (2)  identification of the  exposure
pathways; and (3) quantification  of exposure.
However, some of the  methods by which these
three steps  are carried out are different  for
radionuclides.

10.5.1    CHARACTERIZING THE EXPOSURE
         SETTING

    Initial characterization of the exposure  setting
for radioactively contaminated sites  is virtually
identical to that described in Chapter 6. One
additional consideration is that, at sites suspected
of having radionuclide contamination, a  survey
should be conducted to  determine  external
radiation fields using any one of a number of field
survey instruments (preferably, G-M tubes and
Nal(Tl) field detectors) (see Exhibit 10-2). Health
and safety plans should be implemented to reduce
the possibility of radiation exposures that are in
excess of allowable limits.
        REFERENCES ON EXPOSURE
    ASSESSMENT FOR RADIONUCLIDES

   Calculation of Annual Doses to Man from
   Routine Releases of Reactor Effluents
   (NRC 1977)

   Radiological Assessment; A Textbook on
   Environmental Dose Analysis (Till and
   Meyer 1983)

   Models and Parameters for Environmental
   Radiological Assessments  (Miller 1984)

   Radiological Assessment: Predicting the
   Transport, Bioaccumulation, and Uptake by
   Man of Radionuclides Released to the
   Environment (NCRP 1984a)

   Background Information Document, Draft
   EIS for Proposed NESHAPS for
   Radionuclides, Volume I, Risk Assessment
   Methodology  (EPA 1989a)

   Screening Techniques for Determining
   Compliance with Environmental Standards
   (NCRP 1989)
10.5.2    IDENTIFYING EXPOSURE
         PATHWAYS

    The identification of exposure pathways for
radioactively contaminated sites is very similar to
that described in Chapter 6 for  chemically
contaminated sites, with the following additional
guidance.

    •    In addition to the various ingestion,
         inhalation, and direct contact pathways
         described in Chapter 6, external exposure
         to penetrating radiation should also be
         considered. Potential external exposure

-------
Page 10-24
        pathways  to  be considered  include
        immersion in    contaminated    air,
        immersion in contaminated water, and
        radiation exposure from ground surfaces
        contaminated  with beta- and  photon-
        emitting  radionuclides.

    •   A  with nonradioactive chemicals,
        environmentally dispersed radionuclides
        are  subject to   the same chemical
        processes that  may accelerate or retard
        their transfer rates and may increase or
        decrease    their    bioaccumulation
        potentials.    These    transformation
        processes   must  be   taken  into
        consideration during the  exposure
        assessment.

    •   Radionuclides undergo radioactive  decay
        that, in some respects, is  similar to the
        chemical or biological degradation of
        organic compounds.   Both processes
        reduce the quantity of the hazardous
        substance  in  the environment and
        produce  other substances.     (Note,
        however, that biological  and chemical
        transformations can never alter, i.e.,
        either   increase or   decrease, the
        radioactivity  of  a    radionuclide.)
        Radioactive decay products can also
        contribute significantly to the radiation
        exposure and must be considered in the
        assessment.

    •   Chapter 6 presents a series of equations
        (Exhibits  6-11   through  6-19) for
        quantification  of chemical exposures.
        These  equations and suggested default
        variable values  may be used to estimate
        radionuclide   intakes    as   a   first
        approximation,  if the equations are
        modified by deleting the body weight and
        averaging time from the  denominator.
        However,    depending   upon   the
        characteristics of the radionuclides  of
        concern, consideration of radioactive
        decay and ingrowth of radioactive decay
        products may be important additions,  as
        well as the  external exposure pathways.

    •   Chapter 6  also refers to  a number  of
        computer models that are used to predict
        the behavior and fate of chemicals in the
         environment. While those models may
         be suitable for evaluations of radioactive
         contaminants in some cases, numerous
         models have been developed specifically
         for  evaluating  the  transport  of
         radionuclides in the environment and
         predicting the doses and risks to exposed
         individuals,      In  general,  models
         developed specifically for radiological
         assessments should be used.    Such
         models include, for example, explicit
         consideration of radioactive decay and
         ingrowth of radioactive decay products.
         (Contact ORP for additional guidance on
         the  fate   and   transport   models
         recommended by EPA.)

10.5.3 QUANTIFYING EXPOSURE:
         GENERAL  CONSIDERATIONS

     One of the primary objectives of an exposure
assessment is to make a reasonable estimate of
the maximum exposure to individuals and critical
population groups.  The equation presented in
Exhibit 6-9 to calculate intake for chemicals may
be considered,  to be applicable to exposure
assessment for radionuclides, except that the body
weight and averaging time terms in  the
denominator should  be omitted. However, as
discussed previously, exposures to radionuclides
include both internal and external exposure
pathways.    In  addition, radiation exposure
assessments do not end with the calculation of
intake, but take the calculation an additional step
in order to estimate radiation dose equivalent.

     The radiation dose equivalent to specified
organs and the effective dose equivalent due to
intakes of radionuclides by inhalation or ingestion
are estimated by  multiplying the amount of each
radionuclide inhaled or ingested times appropriate
dose conversion factors (DCFs), which represent
the dose equivalent per unit intake. As noted
previously, the  effective dose equivalent is a
weighted sum of the dose equivalents to all
irradiated organs and tissues,  and represents a
measure of the overall detriment.    Federal
Guidance Report No.  11 (EPA 1988) provides
DCFs for each of over 700 radionuclides for both
inhalation and ingestion exposures.     It  is
important to note, however, that these DCFs were
developed for regulation of occupational exposures

-------
                                                                                       Page 10-2S
to radiation and may not be appropriate for the
general population.

    Radionuclide  intake  by inhalation and
ingestion is calculated in the same manner as
chemical intake except that it is not divided by
body weight or averaging time. For radionuclides,
a reference body weight is already incorporated
into the DCFs, and the dose is an expression of
energy deposited per gram of tissue.

    If intake of a radionuclide is defined for a
specific time period (e.g.,  Bq/year), the dose
equivalent  will be expressed in  corresponding
limits (e.g., Sv/year).    Because systemically
incorporated radionuclides can remain within the
body for long periods of time, internal dose is
best expressed in terms of the committed effective
dose equivalent, which is equal to the effective
dose equivalent over the 50-year period following
intake.

    External exposures  may be determined by
monitoring and sampling of the radionuclide
concentrations in environmental  media, direct
measurement of radiation fields using portable
instrumentation, or by mathematical modeling.
Portable survey  instruments that  have been
properly calibrated can display dose rates (e.g.,
Sv/hr), and dose equivalents can be estimated by
multiplying by the duration of exposure to the
radiation field.    Alternatively,   measured or
predicted concentrations in environmental media
may be multiplied by  DCFs,   which relate
radionuclide concentrations on the ground, in air,
or in water to external dose rates (e.g., Sv/hr per
Bq/m2for ground contamination or Sv/hr per
Bq/m3for air or water immersion).

    The dose equivalents associated with external
and internal exposures are expressed in identical
units (e.g., Sv), so that  contributions from all
pathways  can be  summed to estimate the  total
effective dose equivalent value and prioritize risk
from different sources.

    In general, radiation exposure assessments
need not consider acute toxicity  effects. Acute
exposures are of less concern for radionuclides
than for chemicals because the  quantities of
radionuclides required to cause adverse effects
from acute exposure  are extremely large and such
levels are not normally encountered at Superfund
sites. Toxic effects from acute radiation exposures
are possible when   humans are exposed to the
radiation from large amounts of radioactive
materials released during a major nuclear plant
accident,    such as  Chernobyl,    or  during
above-ground weapons detonations.  Consequently,
the exposure and risk assessment guidance for
radionuclides presented in this chapter is limited
to situations  causing chronic  exposures to low
levels of radioactive contaminants.

10.5.4    QUANTIFYING EXPOSURE
         DETERMINING EXPOSURE POINT
         CONCENTRATIONS

    The preferred  method for estimating the
concentration    of  chemical  or   radioactive
contaminants at those places where members of
the public may come into contact with them is by
direct measurement. However, this will not be
possible  in many circumstances and it  may be
necessary, therefore, to use environmental  fate and
transport   models to   predict   contaminant
concentrations.     Such  modeling would be
necessary, for example: (1) when it is not possible
to  obtain    representative samples   for  all
radionuclides of concern;    (2)  when  the
contaminant has not yet reached the potential
exposure points; and (3) when the contaminants
are below the limits of detection but, if present,
can still represent a significant risk to the public.

    Numerous fate and transport models have
been developed  to estimate  contaminant
concentrations in ground water, soil, air, surface
water, sediments, and food chains.    Models
developed for chemical contaminants,  such as
those discussed in Chapter 6, may also be applied
to radionuclides with allowance for radioactive
decay and ingrowth of decay products. There are
also a  number of models  that have  been
developed specifically for radionuclides. These
models are similar to the models used for toxic
chemicals  but have features that make them
convenient to use  for radionuclide pathway
analysis,  such as  explicit consideration of
radioactive  decay  and daughter ingrowth.
Available  models  for  use in radiation  risk
assessments range in complexity from a  series of
hand calculations to major computer codes.  For
example, NRC Regulatory  Guide  1.109  presents
a methodology that may be used to manually
estimate dose equivalents from a variety of

-------
    10-26
exposure pathways (NRC 1977). Examples of
computerized  radiological  assessment models
include  the  AIRDOS-EPA  code  and  the
EPA-PRESTO family of codes, which are used
extensively by EPA to estimate exposures  and
doses to populations  following atmospheric
releases of radionuclides and releases from a
low-level waste disposal facility, respectively.
Guidance on selection and use of the various
models can be obtained from the EPA Office of
Radiation Programs.

    Exhibit 6-10, Example of Table Format for
Summarizing Exposure Concentrations, may be
used for radionuclide contaminants,  except  that
radionuclide concentrations are  expressed in terms
of activity per  unit mass or  volume  of the
environmental medium (e.g., Bq/kg, Bq/L) rather
than mass.

10.5.5 QUANTIFYING EXPOSURE:
        ESTIMATING INTAKE AND DOSE
        EQUIVALENT

    Section 6.6 presents a description of the
methods used  to  estimate intake  rates  of
contaminants from the various exposure pathways.
Exhibits 6-11 to 6-19 present  the equations  and
input assumptions recommended for use in intake
calculations. In concept, those equations and
assumptions also  apply generally  to radionuclides,
except that the body weight and averaging time
terms in the denominators should be omitted.
However, as discussed previously, the product of
these calculations for radionuclides is  an estimate
of the radionuclide intake, expressed in units of
activity (e.g., Bq), as opposed to mg/kg-day. In
addition, the endpoint of a radiation exposure
assessment is radiation dose, which is calculated
using DCFs as explained below. AS explained
previously, dose equivalents  calculated in the
following manner should be used to compare with
radiation protection standards and criteria, not to
estimate risk.

    Internal Exposure. Exhibits  6-11,6-12,6-14,
6-17, 6-18, and 6-19 present simplified models for
 the ingestion of water, food, and soil as pathways
for the intake of environmental contaminants.
The recommended assumptions for ingestion rates
and exposure   durations  are  applicable  to
radionuclide exposures and may be used to
estimate the intake rates of radionuclides by these
pathways. As noted previously, however, these
intake estimates for radionuclides should not be
divided by the body  weight or averaging time.
These intake rates  must be multiplied  by
appropriate DCF values in  order  to  obtain
committed effective dose equivalent values. The
more rigorous and complex radionuclide pathway
models noted previously typically require much
more extensive input data and may include default
parameter values that differ somewhat from the
values recommended in these exhibits.

    Exhibit 6-16 presents the equation and
assumptions used to estimate the  contaminant
intake from air. For radionuclides, the dose from
inhalation of contaminated air is determined as
the product of the radionuclide concentration in
air (Bq/m3), the breathing rate (m3per day or
year), exposure duration (day or year), and the
inhalation DCF (Sv per Bq inhaled).  The result
of this calculation is the committed effective dose
equivalent, in units of Sv.

    Chapter 6 points out that dermal  absorption
of airborne chemicals is not an important route
of uptake.   This point is also true for most
radionuclides, except airborne tritiated water
vapor, which is efficiently taken into the body
through dermal absorption. In order to account
for this route of uptake, the inhalation DCF for
tritium includes an adjustment factor to account
for dermal absorption.

    External Exposure.    Immersion   in air
containing   certain    beta-emitting    and/or
photon-emitting radioactive contaminants can also
result in external exposures.   Effective dose
equivalents from external exposure are calculated
as the product of the airborne radionuclide
concentration (Bq/m3), the external DCF for air
immersion (Sv/hr per Bq/m3), and the duration of
exposure  (hours).

    Exhibits 6-13 and 6-15 illustrate the dermal
uptake of contaminants  resulting from  immersion
in water or contact with soil.   This route of
uptake  can be important for many organic
chemicals; however, dermal uptake is  generally not
an important route of uptake for radionuclides,
which have small dermal permeability constants.
External radiation exposure due to submersion in
water contaminated with radionuclides  is possible
and is similar to external exposure due  to

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                                                                                     Page 10-27
immersion in air.    However, because of the
shielding effects of water and the generally short
durations of such exposures, immersion in water
is typically of lesser significance. The product of
the radionuclide concentration in water (Bq/m3),
the relevant DCF (Sv/hr per Bq/m3), and the
duration of exposure  (hours) yields effective  dose
equivalent.

     The third external exposure pathway of
potential   significance is   irradiation  from
radionuclides deposited on the ground surface.
Effective  dose equivalents  resulting from this
pathway may be estimated as the product of the
soil    surface    concentration    (Bq/m2) of
photon-emitting radionuclides  of concern, the
external DCF for ground surface exposure (Sv/hr
per Bq/m2), and the duration of exposure (hours).

10.5.6    COMBINING INTAKES AND DOSES
        ACROSS PATHWAYS

     The calculations described previously result
in  estimates  of committed  effective  dose
equivalents (Sv) from individual radionuclides via
a large number of possible exposure pathways.
Because a given population may be subject to
multiple exposure pathways, the results of the
exposure assessment should be organized by
grouping all applicable exposure pathways for each
exposed population. Risks  from various  exposure
pathways and contaminants then can be integrated
during the risk characterization step (see Section
10.7).

10.5.7    EVALUATING UNCERTAINTY

     The radiation exposure assessment should
include a discussion of uncertainty, that, at a
minimum, should include: (1) a tabular summary
of the values used to estimate exposures and doses
and the range of these values; and (2) a summary
of the major  assumptions of the exposure
assessment, including the uncertainty associated
with each assumption and how it might affect the
exposure and  dose estimates.    Sources of
uncertainty that must be addressed include: (1)
how well the monitoring data represent actual site
conditions; (2)  the exposure models, assumptions,
and. input variables used to estimate exposure
point concentrations; and (3) the values of the
variables used to  estimate intakes and external
exposures. More comprehensive discussions of
uncertainty associated with radiological risk
assessment are provided in the  Background
Information Document for the Draft ElS for
Proposed NESHAPSfor Radionuclides (EPA
1989a), Radiological Assessment (Till and Meyer
1983), andNCRP Report No. 76 (NCR? 1984a).

10.5.8    SUMMARIZING AND PRESENTING
         EXPOSURE ASSESSMENT RESULTS

    Exhibit 6-22 presents a sample format for
summarizing the  results of  the exposure
assessment. The format may also be used for
radionuclide contaminants except  that the  entries
should be specified as committed effective dose
equivalents  (Sv) and the annual estimated intakes
(Bq)  for each radionuclide of concern. The
intakes and dose estimates should be tabulated
for each exposure  pathway so that the most
important radionuclides and pathways contributing
to the total  health risk may be identified.

    The information should be organized by
exposure pathway, population exposed,  and  current
and future  use assumptions. For radionuclides,
however, it may  not be necessary to  summarize
short-term and long-term exposures separately as
specified for chemical contaminants.
 10.6 TOXICITY ASSESSMENT

    Chapter 7 describes the two-step process
employed to assess the potential toxicity of a given
chemical contaminant.   The first step, hazard
identification, is    used to determine whether
exposure to  a contaminant can increase the
incidence of an adverse health effect. The second
step,  dose-response assessment,  is used to
quantitatively evaluate  the toxicity information and
characterize the relationship between the dose of
the contaminant administered or received and the
incidence of adverse health effects in the exposed
population.

    There are certain fundamental differences
between radionuclides  and  chemicals  that
somewhat  simplify toxicity  assessment for
radionuclides. As discussed in the previous
sections, the adverse effects  of exposure to
radiation are due to the energy deposited in
sensitive tissue,  which  is referred to as the

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Page 10-28
radiation dose. In theory, any dose of radiation
has the potential to produce an adverse effect.
Accordingly, exposure  to  my  radioactive
substances is, by definition, hazardous.

    Dose-response assessment for radionuclides
is also more straightforward. The type of effects
and the likelihood of occurrence of any one of a
number of possible adverse effects from radiation
exposure depends on the radiation dose. The
relationship between dose and effect is relatively
well characterized (at high doses) for most types
of radiations. As a result, the toxicity assessment,
within the context that it is used in this manual,
need  not be explicitly addressed in detail for
individual radionuclides at each contaminated site.

    The sections  that follow  provide  a brief
summary of the human and experimental animal
studies that establish the hazard and dose-response
relationship for radiation exposure. More detailed
discussions of radiation toxicity are provided in
publications of the National Academy of Sciences
committee on Biological  Effects of Ionizing
Radiation (BEIR),  the United Nations Scientific
Committee  on Effects of Atomic Radiation
(UNSCEAR), NRC, NCRP, and ICRP listed in
the box on this page.

10.6.1    HAZARD IDENTIFICATION

    The principal adverse biological  effects
associated with ionizing radiation exposures from
radioactive substances in the environment are
carcinogenicity, mutagenicity,  and teratogenicity.
Carcinogenicity is  the ability to produce  cancer.
Mutagenicity is the property of being able to
induce genetic mutation, which may be in the
nucleus  of either somatic  (body)  or germ
(reproductive) cells. Mutations in germ cells lead
to genetic or inherited defects. Teratogenicity
refers to the ability of an agent to induce or
increase the incidence of congenital malformations
as a result of permanent structural or functional
deviations produced during the  growth and
development of an embryo (more commonly
referred to  as  birth defects).  Radiation  may
induce other deleterious effects at acute doses
above about 1 Sv, but doses of this magnitude are
not   normally   associated with   radioactive
contamination in the environment.
    REFERENCES ON HEALTH EFFECTS
        OF RADIATION EXPOSURE

  Recommendations of the ICRP (ICRP
  197?)

  Unfits for Intake of Radionuclides by
  Workers (ICRP 1979)

  Influence of Dose and Its Distribution in
  Time on Dose-Response Relationships for
  Low-LET Radiations (NCRP 1980)

  The Effects on Populations of Exposure to
  Law Levels aflonMng Radiation (NAS
  1980)

  Induction of TftyroM Cancer by Ionizing
  Radiation (NCRP I985b)

  Lung Cancer Risk from Indoor Exposures to
  Radon Daughters (ICRP 1987}

  Health Risks of Radon and Other Intemalfy
  Deposited Alpha-Emitters (National
  Academy  of Sciences 1988)

  Ionizing Radiation: Sources, Effects, and
  Risks (UNSCEAR 1988)

  Health Effects Models for Nuclear Power
  Plant Accident Consequence Analysis,-
  Low-LET Radiation (NRC 1989)
    As discussed in  Section 10.1,  ionizing
radiation causes injury by breaking molecules into
electrically charged fragments (i.e., free radicals),
thereby producing chemical rearrangements that
may lead to permanent cellular damage. The
degree of biological damage caused by various
types of radiation varies according to how spatially
close together the ionizations occur.    Some
ionizing radiations (e.g., alpha particles) produce
high density regions of ionization.    For this
reason, they are  called high-LET (linear energy
transfer) particles.  Other types of radiation (e.g.,
x-rays, gamma rays, and beta particles) are called
low-LET radiations because of the low density
pattern of ionization they produce.  In  equal
doses,  the carcinogenicity and mutagenicity of

-------
                                                                                       Page 10-29
high-LET radiations may  be  an  order of
magnitude or more greater than those of low-LET
radiations, depending on the endpoint being
evaluated.     The variability  in biological
effectiveness is accounted for by the quality factor
used to calculate the dose equivalent (see  Section
10.1).

     Carcinogenesis.    An extensive body of
literature  exists on radiation carcinogenesis in man
and  animals.  This literature has been reviewed
most recently by the United Nations Scientific
Committee on the Effects of Atomic Radiation
(UNSCEAR) and the National  Academy of
Sciences Advisory Committee on the Biological
Effects of Ionizing  Radiations  (NAS-BEIR
Committee) (UNSCEAR  1977, 1982, 1988; NAS
1972, 1980, 1988). Estimates of the average risk
of fatal cancer from low-LET radiation from these
studies range from approximately  0.007  to 0.07
fatal cancers per sievert.

     An increase in cancer incidence or mortality
with increasing  radiation  dose has been
demonstrated for many types of cancer  in both
human  populations   and laboratory animals
(UNSCEAR 1982, 1988; NAS  1980,  1988).
Studies of humans exposed to internal or external
sources of ionizing radiation have shown that the
incidence of cancer increases with increased
radiation exposure.    This increased incidence,
however, is usually associated with appreciably
greater doses and exposure frequencies than those
encountered in the environment. Therefore,  risk
estimates from small  doses obtained over long
periods of time are determined by extrapolating
the  effects observed at high,  acute  doses.
Malignant tumors in various organs most often
appear long after the radiation exposure,  usually
10 to 35 years later (NAS 1980, 1988; UNSCEAR
1982, 1988). Radionuclide metabolism can result
in the selective deposition of certain radionuclides
in specific organs or tissues, which, in turn, can
result   in   larger   radiation    doses    and
higher-than-normal cancer risk in these organs.

     Ionizing   radiation can be  considered
pancarcinogenic, i.e.,  it acts as  a complete
carcinogen in that it serves as both initiator and
promoter, and it can induce cancers in nearly any
tissue or organ.  Radiation-induced cancers in
humans have been reported in the thyroid, female
breast, lung, bone marrow (leukemia), stomach,
liver, large intestine, brain, salivary  glands, bone,
esophagus, small intestine, urinary bladder,
pancreas, rectum, lymphatic tissues, skin, pharynx,
uterus, ovary, mucosa of cranial sinuses, and
kidney (UNSCEAR 1977,  1982, 1988; NAS 1972,
1980, 1988). These data are taken primarily from
studies of human populations exposed to high
levels of radiation, including  atomic bomb
survivors,   underground  miners, radium dial
painters,  patients injected  with thorotrast or
radium, and patients who received high x-ray doses
during various treatment programs.  Extrapolation
of these data to much lower doses is the major
source of uncertainty in  determining low-level
radiation risks (see EPA 1989a). It is assumed
that no lower threshold exists for radiation
careinogenesis.

     On average, approximately 50 percent of all
of the cancers induced by radiation are lethal.
The fraction of fatal cancers is different for each
type of cancer, ranging from  about 10 percent in
the case of thyroid cancer to 100 percent in the
case of liver cancer (NAS 1980, 1988). Females
have approximately 2 times as many total  cancers
as fatal cancers following  radiation exposure, and
males have approximately 1.5 times as many (NAS
1980).

     Mutagenesis. Very few quantitative data are
available  on  radiogenic  mutations in humans,
particularly from low-dose exposures.    Some
mutations are so mild they  are not noticeable,
while other mutagenic effects that do occur are
similar to nonmutagenic effects and are therefore
not necessarily recorded as mutations.  The bulk
of data supporting the mutagenic character of
ionizing radiation comes from extensive studies of
experimental animals (UNSCEAR 1977, 1982,
1988; NAS 1972, 1980, 1988). These studies have
demonstrated all forms of radiation mutagenesis,
including    lethal  mutations,   translocations,
inversions, nondisjunction, and point mutations.
Mutation rates calculated from these studies are
extrapolated to humans and form the basis for
estimating the genetic impact of ionizing radiation
on humans (NAS 1980, 1988 UNSCEAR 1982
1988). The vast majority of the demonstrated
mutations in human germ  cells contribute  to both
increased mortality and illness (NAS 1980;
UNSCEAR 1982).   Moreover, the radiation
protection community is generally in agreement
that the probability of inducing genetic changes

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Page 10-30
increases  linearly  with dose and that  no
"threshold" dose is required to initiate heritable
damage to germ cells.

     The incidence of serious genetic disease due
to mutations and chromosome aberrations induced
 by radiation is referred to as genetic detriment.
Serious genetic disease includes inherited ill
health, handicaps, or  disabilities. Genetic disease
may be manifest at birth or may not become
evident   until   some    time  in   adulthood.
Radiation-induced genetic detriment includes
impairment  of life, shortened life  span,  and
increased hospitalization.    The  frequency of
radiation-induced genetic impairment is relatively
small in comparison  with the magnitude of
detriment associated  with spontaneously arising
genetic diseases (UNSCEAR  1982, 1988).

     Teratogenesis.    Radiation is a well-known
teratogenic agent. The developing fetus is much
"more sensitive to radiation than the mother. The
age of the  fetus at the time of exposure is the
most important factor in determining the extent
and type  of  damage  from radiation.  The
malformations produced in the embryo depend on
which cells,  tissues, or organs in the fetus are
most actively differentiating  at  the time of
radiation exposure.    Embryos are relatively
resistant to radiation-induced teratogenic effects
during the later stages of their development and
are most sensitive from just after implantation
until the end  of organogenesis (about two weeks
to eight weeks after conception) (UNSCEAR
 1986, Brent  1980). Effects on nervous system,
skeletal system, eyes,  genitalia, and skin have been
noted (Brent 1980).   The brain appears to be
most sensitive during development  of the
neuroblast  (these  cells  eventually become the
nerve cells).  The greatest risk of brain damage
for the human fetus occurs at 8  to  15 weeks,
which  is  the time the nervous  system is
undergoing the most rapid differentiation and
proliferation of cells  (Otake 1984).

 10.6.2    DOSE-RESPONSE RELATIONSHIPS

     This section describes the relationship of the
risk of fatal cancer, serious genetic effects, and
other detrimental health effects to exposure to low
levels of ionizing  radiation. Most important from
the standpoint of the total societal risk from
exposures to  low-level ionizing radiation are the
risks of cancer and genetic mutations. Consistent
with our current understanding of their origins in
terms of DNA damage, these effects are believed
to be stochastic that is, the probability (risk) of
these effects increases with the dose of radiation,
but the severity of the effects is independent of
dose. For neither induction of cancer nor genetic
effects, moreover, is there any convincing evidence
for a "threshold" (i.e., some dose level below
which the risk is zero). Hence, so far as is
known, any dose of ionizing radiation, no matter
how small, might give rise to a cancer or to a
genetic effect in future generations. Conversely,
there is no way to be certain that a given dose of
radiation, no matter how large,  has caused an
observed cancer in an individual or will cause one
in the future.

     Exhibit 10-5 summarizes EPA's  current
estimates of the risk of adverse effects associated
with human exposure to ionizing radiation (EPA
1989a). Important  points from this summary table
are provided below.

     •   Very large doses (> 1 Sv) of radiation
        are required to  induce  acute and
        irreversible adverse  effects. It is unlikely
        that such exposures would occur in the
        environmental setting associated with a
        potential Superfund site.

     •   The risks  of serious noncarcinogenic
        effects associated with chronic exposure
        to radiation  include genetic   and
        teratogenic  effects.  Radiation-induced
        genetic effects have not been observed
        in human populations, and extrapolation
        from animal data reveals risks per unit
        exposure  that are smaller than,  or
        comparable to, the risk of cancer. In
        addition, the genetic risks are spread
        over several generations. The risks per
        unit exposure  of serious teratogenic
        effects are greater than the risks of
        cancer. However, there  is a possibility
        of a threshold, and the exposures must
        occur over a specific period of time
        during gestation to cause the effect.
        Teratogenic effects can be induced only
        during the nine months of pregnancy.
        Genetic effects are induced during the
        30-year reproductive generation and
        cancer can be induced at any point

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                                                                                       Page 10-31
                                       EXHIBIT 10-5
                SUMMARY OF EPA'S RADIATION RISK FACTORS3
       Risk
 Significant Exposure  Period
Risk Factor Range
Low LET (Gv"'I

Teratogenic:b
     Severe mental retardation

Genetic
     Severe hereditary defects,
     all generations

Somatic
     Fatal cancers

     All  cancers

High LET (Gy51)

Genetic
     Severe hereditary defects,
     all generations

Somatic:
     Fatal cancers
     All  cancers
Weeks 8 to 15 of gestation


30-year  reproductive generation
Lifetime
In utero
Lifetime
30-year reproductive generation
Lifetime
Lifetime
Radon Decay Products nO'6WLM"'Y
     Fatal lung cancer               Lifetime
 0.25-0.55
 0.006-0.11
 0.012-0.12
 0.029-0.10
 0.019-0.19
 0.016-0.29
 0.096-0.96
 0.15-1.5
                                       140-720
   "In addition to the stochastic risks indicated, acute toxicity may occur at a mean lethal dose of 3-5 Sv
     with a threshold in excess of 1 Sv.

   bThe range assumes a linear, non-threshold dose-response.  However, it is plausible that a threshold
     may exist for this effect.

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Page 10-32
          during the lifetime. If a radiation source
          is  not  controlled, therefore,  the
          cumulative risk of cancer may be many
          times greater than the risk of genetic or
          teratogenic effects due to the potentially
          longer period of exposure.

      Based on these observations, it appears that
 the risk of cancer is limiting and may be used as
 the sole basis  for assessing the radiation-related
 human health risks of a site contaminated with
 radionuclides.

      For situations where the  risk  of  cancer
 induction in a  specific target organ is of primary
 interest, the committed dose  equivalent  to  that
 organ may be multiplied by an organ-specific risk
 factor. The  relative radiosensitivity of various
 organs (i.e., the cancer induction rate per unit
 dose) differs markedly for different organs  and
 varies as a function of the age and sex of the
 exposed individual.   Tabulations  of such risk
 factors as a function of age and sex  are provided
 in the Background Information Document for the
 Draft Environmental Impact Statement for Proposed
 NESHAPSfor Radionuclides (EPA 1989a) for
 cancer mortality and cancer incidence.
 10.7 RISK CHARACTERIZATION

     The final step in the risk assessment process
 is risk characterization. This is an integration step
 in which the risks from individual radionuclides
 and pathways are quantified and combined where
 appropriate. Uncertainties also are examined and
 discussed in this step.

 10.7.1   REVIEWING OUTPUTS FROM THE
         TOXICITY AND EXPOSURE
         ASSESSMENTS

     The exposure assessment results should be
 expressed as  estimates of radionuclide intakes by
 inhalation and ingestion, exposure rates and
 duration for external exposure pathways, and
 committed effective dose equivalents to individuals
from all relevant radionuclides and pathways. The
 risk assessor should  compile the supporting
 documentation to ensure that it is sufficient to
 support the analysis and to allow an independent
 duplication of the results. The review  should also
 confirm that the analysis is reasonably complete
 in terms of the radionuclides and pathways
 addressed.

     In addition, the review should evaluate the
 degree to which the assumptions inherent in the
 analysis apply to the site and conditions being
 addressed.   The mathematical models used to
 calculate  dose use  a  large   number of
 environmental transfer factors and dose conversion
 factors that may not always be entirely applicable
 to the conditions being analyzed. For example,
 the standard dose conversion factors are based on
 certain generic  assumptions  regarding the
 characteristics of the exposed individual and the
 chemical and  physical  properties   of  the
 radionuclides. Also, as is the case for chemical
 contaminants, the environmental transfer factors
 used in the models may not apply to all settings.

    Though the risk assessment models may
 include a large number of radionuclides  and
 pathways, the  important radionuclides  and
 pathways are usually few in number. As a result,
 it is often feasible to check the computer output
 using hand calculations.  This type of review can
 be performed by health physicists familiar with
 the models and their limitations. Guidance on
 conducting such calculations is provided in
 numerous references, including Till and Meyer
 (1983) andNCRP Report No. 76 (NCRP 1984a).

 10.7.2 QUANTIFYING RISKS

    Given that the  results  of the  exposure
 assessment are virtually complete, correct,  and
 applicable to the conditions being considered, the
 next step in the process is to calculate and
 combine risks. As discussed previously, the  risk
 assessment for radionuclides  is  somewhat
 simplified because only radiation carcinogenesis
 needs to be considered.

    Section  10.5 presents a methodology for
 estimating committed effective dose equivalents
 that may be compared with radiation protection
 standards and criteria. Although the product of
 these  dose equivalents (Sv) and an appropriate
 risk factor (risk per Sv) yields an estimate of risk
 the health risk estimate derived in such a manner
 is not completely applicable for members of the
general public. A better estimate of risk may be
computed using age- and sex-specific coefficients
for  individual organs  receiving significant radiation

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                                                                                        Page 10-33
 doses. This information may be used along with
 organ-specific dose conversion factors to derive
 slope factors that represent the age-averaged
lifetime excess cancer incidence per unit intake for
 the radionuclides of concern. The Integrated Risk
 Information System (IRIS) and the Health Effects
 Assessment Summary Tables  (HEAST) contain
 slope factor values for radionuclides of concern at
 remedial sites for each of the four major exposure
 pathways (inhalation, ingestion,  air immersion, and
 ground-surface irradiation), along  with  supporting
 documentation for the derivation of these values
 (see Chapter 7 for more detail on IRIS).

     The slope factors for the inhalation pathway
 should be  multiplied by the estimated inhaled
 activity (derived using the methods presented in
 Section 6.6.3 and Exhibit 6-16, without division
 of the body weight and averaging time) for each
 radionuclide of concern to estimate risks from the
 inhalation pathway.    Similarly, risks from the'
 ingestion  pathway  should  be  estimated by
 multiplying the ingestion slope  factors by the
activity ingested for each radionuclide of concern
 (derived using the methods presented in Exhibits
 6-11, 6-12, 6-14,  6-17, 6-18, and 6-19, without
division by the body weight and averaging time).
Estimates  of the risk from the air immersion
pathway should be computed by multiplying the
appropriate  slope  factors  by  the  airborne
radionuclide  concentration  (Bq/m3) and the
duration of exposure.   Risk  from the ground
surface pathway should be computed as the
product of the slope factor, the soil concentration
(Bq/m2), and the duration of exposure for each
radionuclide of concern.

     The sum of the risks from all radionuclides
and  pathways yields the lifetime risk from the
overall exposure.   As discussed in Chapter 8,
professional judgment must be used in combining
the risks from various pathways, as it may not be
physically possible for one person to be exposed
to the maximum radionuclide concentrations for
all pathways.

10.7.3    COMBINING RADIONUCLIDE AND
         CHEMICAL  CANCER RISKS

     Estimates of the  lifetime  risk of  cancer to
exposed individuals resulting from radiological and
chemical risk assessments may be summed in
order to determine the overall potential human
 health hazard associated with a site.  Certain
 precautions should be taken, however, before
 summing these risks.   First, the risk assessor
 should evaluate whether it is reasonable to assume
 that the same individual can receive the maximum
 radiological and chemical dose. It is possible for
 this to occur in some eases because many of the
 environmental  transport processes and routes of
 exposure are the same for radionuclides and
 chemicals.

     In cases where different environmental fate
 and transport models have been used to predict
 chemical  and radionuclide exposure, the
 mathematical models may incorporate somewhat
 different assumptions. These differences can result
 in incompatibilities in the two estimates of risk.
 One important difference of this nature is  how the
 cancer toxicity values (i.e., slope factors) were
 developed. For  both radionuclides and chemicals,
 cancer toxicity values are obtained by extrapolation
 from experimental and epidemiological data. For
 radionuclides, however, human  epidemiologies
 data form the basis of the extrapolation, while for
 many    chemical    carcinogens,    laboratory
 experiments are  the primary  basis  for the
 extrapolation.   Another even more fundamental
 difference between the two is that slope factors
 for chemical carcinogens generally represent an
 upper bound or 95th percent confidence limit
 value, while radionuclide  slope factors are best
 estimate values.

     In light of these limitations, the  two sets of
 risk estimates should be tabulated separately in
 the final baseline risk assessment.

 10.7.4    ASSESSING AND PRESENTING
         UNCERTAINTIES

     Uncertainties in the risk assessment must be
evaluated and discussed, including uncertainties in
the physical setting definition for the site, in the
models used, in the exposure parameters, and in
the toxicity assessment. Monte Carlo uncertainty
analyses are frequently performed as  part of the
uncertainty and sensitivity analysis for radiological
risk assessments.   A summary of the use of
uncertainty analyses in support of radiological risk
assessments  is provided in NCRP Report No. 76
(NCRP 1984a), Radiological Assessment (Till and
Meyer 1983), and in the Background Information

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 Page 10-34
Document for the Draft ElSfor Reposed NESHAPs
for Radionuclides (EPA 1989a).

 10.7.5    SUMMARIZING AND PRESENTING
         THE BASELINE RISK
         CHARACTERIZATION RESULTS

     The  results    of  the  baseline  risk
 characterization should be summarized and
 presented in art effective manner to assist in
 decision-making. The estimates of risk should be
 summarized in the context of the specific site
 conditions.    Information should include  the
 identity and concentrations of radionuclides, types
 and magnitudes  of health  risks predicted,
 uncertainties in the exposure estimates and toxiciry
 information, and characteristics of the  site and
 potentially exposed populations. A summary table
 should be provided in a format similar to that
 shown in Exhibit 6-22, as well as graphical
 presentations  of the predicted health risks (see
 Exhibit 8-7).
10.8 DOCUMENTATION,
        REVIEW, AND
        MANAGEMENT TOOLS
        FOR THE RISK ASSESSOR,
        REVIEWER, AND
        MANAGER

    The discussion provided in Chapter 9 also
applies to radioactively contaminated sites. The
suggested outline provided in Exhibit 9-1 may also
be used for radioactively contaminated sites with
only minor modifications.   For  example, the
portions that uniquely pertain  to the  CLP
program and noncarcinogenic risks are not needed.
In addition, because radionuclide hazard and
toxicity have been addressed adequately on a
generic basis, there is no need for an extensive
discussion of toxicity in the report.

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                                                                                                        Page 10-35

                                REFERENCES FOR CHAPTER 10
American Public Health Association. 1987.  QA Procedures for Health Labs Radiochemistry.

Beebe, G.W., Kate, H., and Land, GE. 1977. Mortality Experience of Atomic Bomb Survivors. 1950-1974. Life Span Study Repott
     8.. RERF TR 1-77. Radiation Effects Research Foundation. Japan.

Brent, R.L 1980. Radiation  Teratogenesis. Teratology 21:281-298.

Cember, H. 1983. Introduction to Health Physics (2nd Ed.) Pergamon Press. New York NY.

Department of Energy (DOE).  1987. The Environmental  Survey  Manual. DOE/EH-0053.

Department of Energy (DOE). 1988. External Dose-Rate Conversion Factors for Calculation of Dose to the Public. DOE/EH-0070.

Depatment of Energy (DOE). 1989. Environmental Monitoring for Low-level Waste Disposal Sites. DOE/LLW-13Tg.

Eisenbud, M. 1987. Environmental Radioactivity (3rd Ed.) Academic Press. Orlando, EL

Environmental Protection Agency (EPA).  1972. Environmental Monitoring  Surveillance Guide

Environmental Protection Agency (EPA). 1977a. Handbook of Analytical Quality Control in Radioanalvtical Laboratories. Office of
     Research and Development. EPA/600/7-77/008.

Environmental Protection Agency (EPA). 1977b. Quality Control for Environmental Measurements Using Gamma-Ray Spectrometrv.
     EPA/500/7-77/14.

Environmental Protection Agency (EPA). 1979a. Radiochemical Analytical  Procedures for Analysis of Environmental Samples.
     EMSL-LV-0539-17.

Environmental Protection Agency (EPA). 1980. Upgrading  Environmental Radiation Data. Office of Radiation Programs. EPA/520/1-
     80/012

Environmental Protection Agency (EPA). 1984a. Eastern Environmental Radiation Facility Radiochemistrv Procedures Manual. Office
     of Radiation Programs. EPA/520/5-84/006.

Environmental Protection Agency (EPA). 1984b. Federal Guidance Report No. 10: The Radioactivity Concentration Guides. Office
     of Radiation Programs.  EPA/520/1-84/010.

Environmental Protection Agency (EPA).  1987a. Population Exposure to External National Radiation Background in the United
     States. Office of Radiation Programs. EPA ORP/SEPD-80-12.

Environmental Protection Agency (EPA). 1987b. Handbook of Analytical Quality Control  in Radioanalvtical Laboratories. Office of
     Research and Development. EPA/600/7-87/008,

Environmental Protection Agency (EPA).  1988. Federal Guidance Report No. 11: Limiting Values of Radionuclide Intake  and Air
     Concentration and Dose Conversion Factors for Inhalation. Submersion, and Ingestion. Office of Radiation Programs. EPA/520/1-
     88/020.

Environmental Proctection Agency (EPA). 1989a. Background Information  Document. Draft EIS for Proposed NESE1APS  for
     Radionuclides. Volume  1. Risk Assessment Methodology.  Offic of Radiation Programs. EPA/520/1-89/005.

Environmental Protection Agency (EPA).   1989b. Annual Report Fiscal Year 1988 Laboratory Intercomparison  Studies  for
     Radionuclides.

Environmental Protection Agency (EPA).  1989c. CERCLA Conpliance with Other Laws Manual. Part II. Office of Emergency
     and Remedial  Response. (OSWER Directive 9234.1-02).

International commission on  Radiological Protection (ICRP). 1977. Recommendations of the TCRP ICRP Publication 26.

International Commision on Radiological Protection (ICRP). 1979.  Limits fnr Intake nf RaHinnnotiHRs by Workers ICRP Publication
     30.

-------
 Page  10-36


 International Commission on Radiological Protection (ICRP). 1983. Principles for Limiting Exposure of the Public to Natural Sources
      of Radiation. ICRP Publication 39.

 International Commission on Radiological Protection (ICRP). 1984. A Complilation of the Major Concepts and Quantities in Use
      by the ICRP. ICRP Publication 42.

 International Commission on Radiological Protection (ICRP).  1985. Principles of Monitoring for the Radiation Protection of the
      Population. ICRP Publication 43.

 International Commission on Radiological Protection (ICRP). 1987. Lung Cancer Risk from Indoor Exposures to Radon Daughters.
      ICRP Publication 50.

 Kato, H. and Schull, W.J. 1982. Studies of the Mortality of A-Bomb Survivors. Report 7 Part 1, Cancer Mortality Among Atomic
      Bomb Survivors, 1950-78. Radiation Research 90:395-432.

 Kocher, D.  1981.  Radioactive Decay Data Tables A Handbook of Decay Data for Application  to Radiation Dosimetrv and
      Radiological Assessments. DOE/TIC-11O26.

 Miller. 1984. Models and Parameters for Environmental Radiological Assessments. DOE/TIC-11468.

 National Academy of Sciences - National Research Council. 1972. The Effects on Populations of Exposuures to Low Levels of Ionizing
      Radiation.  (BEIR  Report).

 National Academy of Sciences - National Research Council. 1980. The Effects on Population of Exposures to Low Levels of Ionizing
      Radiation.  (BEIR  Report).

 National Academy of Sciences - National Research Council.  1988. Health Risks of Radon and Other Internally  Deposited Alpha-
      Emitters. (BEIR Report).

 National Council on Radiation Protection and Measurements (NCRP). 1989. screening Techniques for Determining Compliance
      with Environmental Standards. NCRP  Commentary No. 3.

 National Council on Radiation  Protection and Measurements (NCRP). 1976. F.nvironmental Radiation Measurements. NCRP Report
      No. 50.

 National Council on Radiation  Protection and Measurements (NCRP). 1978. Instrumentation and Monitoring Methods for Radiation
      Protection. NCRP  Report No. 57.

 National Council on Radiation Protection and Measurements (NCRP).  1979. Tritium in the Environment. NCRP Report No. 62.

 National Council on Radiation Protection and Measurements (NCRP). 1980. Influence of Dose and Its Distribution in Time on
      Dose-response Relationships for Low-LET Radiations. NCRP Report No. 64.

 National Council on Radiation Protection  and  Measurements  (NCRP).  1984a.  Radiological Assessment:  Predicting the
     Transport. Bioaccumulation.  and Uptake by Man of Radionuclides Released to the Environment. NCRP Report No. 76.

 National Council on Radiation Protection and Measurements (NCRP).  1984b.   Exposure from the Uranium Series with Emphasis
      on Radon and its Daughters. NCRP Report No. 77.

 National Council  on Radiation Protection and Measurements (NCRP). 1985a. A Handbook of Radioactivity Measurement Procedures.
      NCRP Report No.  58.

National Council on Radiation Protection and Measurements (NCRP). 1985b. Induction of Thyroid Cancer by Ionizing Radiation.
      NCRP Report No.  80.

National Council on Radiation Protection and Measurements (NCRP).  1985c. Ca.rhnn-14 in the Environment. NCRP Report No.
      81.

 National Council on Radiation Protection and Measurements (NCRP). 1987a. Ionizing Radiation Exposure of the Population of the
      United States. NCRP Report No. 93.

National Council  on Radiation  Protection and Measurements (NCRP). 1987b.  Exposure of the Population of the United  States and
      Canada from Natural  Background Radiation. NCRP Report No. 94.

-------
                                                                                                            Page 10-37


 National Council on Radiation Protection and Measurements (NCRP). 1989. Screening Technicques for Determining Compliance
      with Environmental Standards. NCRP Commentary No. 3.

Nuclear Regulatory Commission (NRC). 1977. Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for
      the Purpose of Evaluating Compliance with 10 CFR 50. Appemdix I. Regulatory Guide 1.109.

 Nuclear Regulatory Commission (NRC). 1979. Quality  Assurance Monitoring Programs (Normal Operation) — Effluent Streams and
      the Environment. NRC Regulatory Guide 4.15.

 Nuclear Regulatory Commission (NRC). 1989. Health Effects Modelsor Nuclear Power Plant Accident Consequence Analysis: T,ow-
      LET Radiation. Part II:  Scientific Bases for Health Effects Models. NUREG/CR-4214, Rev.  1. Part II.

 Otake, M. and Schull W. 1984. Mental Retardation in Children Exposed in Utero to the Atomic Bombs: A Reassessment. Technical
      Report RERF TR 1-83. Radiation Effects Research  Foundation. Japan.

 Schleien,  B.  and Terpilak, M., (Eds). 1984. The Health Physics and Radiolog ical Health Handbook. (7th Ed.) Nucleon Lectern
      Assoc., Inc. Maryland.

 Till, J.E. and Meyer, H.R. 1983. Radiological  Assessment  A Textbook on Environmental Dose Analysis. Prepared for Office of
      Nuclear Reactor Regulation. U.S. Nuclear Regulatory Commision.  Washington, DC NUREG/CR-3332

 Turner, J.E. 1986. Atoms  Radiation  and Radiation Protection Pergamon Press. New York, NY.

 United Nations Scientific Committee Report on the Effects of Atomic Radiation (UNSCEAR). 1958. Official ReenrHs- Thirteenth
      Session. Supplement No. 17(A/3838~). United Nations. New York NY.

 United  Nations  Scientific  Committee on the Effects of Atomic Radiation (UNSCEAR). 1977. Snnrres anH  F.fFm-.ts nf Tnniyina
      Radiation. United Nations. New York NY.

 United  Nations  Scientific  Committee on the Effects of Atomic Radiation (UNSCEAR). 1982  Tnni7ina T?aHiatinn  Sources and
      Effects.  United Nations. New York NY.

 United Nations scientific Committee on the Effects of Atomic Radiation (UNSCEAR). 1986. Genetic anH Snmatir. F.ffer.ts  nf Tnnizina
      Radiation. United Nations. New York, NY.

 United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR). 1988. Snnrr.es  F.ffer.ts anH Risks  nf Tnnizina
      Radiation. United Nations. New York, NY.

 Wakabayashi, T., et al. 1983. Studies of the Mortality of A-Bomb Survivors, Report 7, Part III, Incidence of Cancer in 1959-1978,
      Based on the Tumor Registry, Nagasaki. Radiat. Res.  93: 112-146.

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                                APPENDIX  A

                         ADJUSTMENTS  FOR
                   ABSORPTION  EFFICIENCY
    This appendix contains example calculations
for absorption efficiency adjustments that might be
needed  for Superfund site risk  assessments.
Absorption adjustments might be necessary in the
risk characterization step to ensure that the site
exposure estimate and the toxicitv  value for
comparison are both expressed as absorbed doses
or both expressed as intakes.

    Information concerning  absorption effi-
ciencies might be found in the sections describing
absorption toxicokinetics in  HEAs, HEEDs,
HEEPs, HADs, EPA drinking water quality
criteria or ambient water  quality criteria
documents, or in ATSDR toxicological profiles.
If there is no information on absorption efficiency
by the oral/inhalation routes, one can attempt to
find absorption efficiencies for chemically related
substances.    If no information  is available,
conservative default assumptions might be used.
Contact ECAO for further guidance.

    Adjustments may be necessary to match the
exposure estimate with the toxicity value if one is
based on an absorbed dose and the  other is based
on  an    intake   (i.e.,   administered   dose).
Adjustments may  also be necessary for different
vehicles of exposure (e,g., water, food, or soil).

    For the  dermal  route of exposure, the
procedures outlined in Chapter 6 result in an
estimate of the absorbed dose. Toxicity values
that are expressed as administered doses will need
to be adjusted to absorbed doses for comparison.
This adjustment is discussed in Section A.I.

    For the other routes of exposure (i.e., oral
and  inhalation),  the procedures outlined in
Chapter 6 result in an estimate of daily intake.
If the toxicity value for comparison is expressed
as an administered dose, no adjustment may be
necessary (except, perhaps, for vehicle of
exposure). If the toxicity value is expressed as an
absorbed dose, however, adjustment of the
exposure estimate (i.e., intake) to an absorbed
dose is needed for comparison with the toxicity
value. This  adjustment is discussed in Section
A.2.

    Adjustments  also may be necessary for
different absorption efficiencies  depending  on the
medium of exposure (e.g., contaminants ingested
with food or soil might be  less  completely
absorbed than contaminants ingested with water).
This adjustment is discussed in  Section A.3.
A.1 ADJUSTMENTS OF TOXICITY
    VALUE FROM  ADMINISTERED
    TO ABSORBED DOSE

    Because there are  few,  if any,  toxicity
reference values for dermal exposure, oral values
are frequently used to assess risks from dermal
      ACRONYMS FOR APPENDIX A

  AtSDR * Agency for Tone Substances and
          Disease Registry
   ECAO » Environmental Criteria and Assessment
          Office
    HAD = Health Assessment Document
    HEA = Health Effects Assessment
   HEED » Health and Environmental Effects
          Document
   HEEP w Health and Environmental Effects
          Profile
    RfD «* Reference Dose
      SF » Slope Factor

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 Page A-2
                                   DEFINITIONS FOR APPENDIX A
     Absorbed Dose. The amount of a substance penetrating the exchange boundaries of an organism after contact.  Absorbed
          dose is calculated from the intake and the absorption efficiency. It usually is expressed as mass of a substance absorbed
          into tbe body per unit body weight per unit time (e.g., mg/kg-day),

     Administered Dose.  The mass of substance administered to an organism and in contact with an exchange boundary (e.g.,
          gastrointestinal tract) per unit body weight per unit *ime (e.g., mg/kg-day).

     Exposure Route. The way a chemical or physical agent comes in contact with an organism (i.e., by ingestion, inhalation, or
          dermal contact).

     Intake. A measure of exposure expressed as the mass of substance in contact with the exchange boundary per unit body weight
          per unit time (e.g., mg/kg-day).  Also termed the normalized exposure rate, equivalent to administered dose.

     Reference iDose ffifD),. The Agency's preferred tenacity value for evaluating noncaronogenic effects resulting from exposures
          at Superfund sites. See specific entries tor chronic RfD, subchronic RfD, and developmental R£D. The acronym RfD,
          when used without other raodiOers, either refers genetically to all types of RfDs or specif ally to chronic RfDs; it never
          refers specifically to subchronic or developmental RfDs.

     Slope factor. A plausible upper-bound estimate of the probability of a response per unit intake of a chemical over a lifetime.
          The slope factor is used to estimate an upper-bound probability of an individual developing cancer as a result or a
          lifetime of exposure to a particular level of a potential Carcinogen.
exposure. Most RfDs and some slope factors are
expressed as the amount of substance administered
per unit time and unit body weight, whereas
exposure estimates for the dermal route of
exposure are eventually expressed as absorbed
doses. Thus, for dermal exposure to contaminants
in water or in soil, it may be  necessary to adjust
an oral toxicity value from an administered to an
absorbed dose. In the  boxes  to the right and on
the next page are  samples of adjustments for an
oral RfD and an oral slope factor, respectively.
If the oral toxicitv value is already empressed as an
absorbed dose (e.g. trichloroethvleneX it is not
necessary to adjust the toxicitv value.

     In  the absence  of any  information on
absorption for the substance or chemically related
substances, one must assume an oral absorption
efficiency. Assuming 100 percent absorption in an
oral administration study that serves as the basis
for an RfD or slope  factor would  be a non-
conservative approach for estimating the dermal
RfD or slope factor (i.e., depending on the type
of chemical, the true absorbed dose might have
been much lower than  100 percent, and hence an
absorbed-dose RfD  should similarly be much lower
or the slope factor should be much higher). For
example, some metals tend to  be poorly absorbed
   EXAMPLES ADJUSTMENT OF AN
  ADMINISTERED TO AN ABSORBED
                DOSE RfD

An oral  RfD, unadjusted  for  absorption,
equals 10 mg/kg-day.

Other  information   (or  an  assumption)
indicates a 20% oral absorption efficiency in
the species on which the  RfD is based.

The adjusted RfD that would correspond to
the absorbed dose would  be:

   10 mg/kg-day x 0.20  » 2 mg/kg-day.

The adjusted RfD of 2 mg/kg-day would be
compared with the amount estimated to be
absorbed  dermally each day.

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                                                                                     Page A-3
(less than 5 percent) by the gastrointestinal tract.
A relatively conservative assumption for oral
absorption  in  the  absence  of appropriate
information would be 5 percent.
     EXAMPLE:  ADJUSTMENT OF AN
          ADMINISTERED TO AN
     ABSORBED  DOSE SLOPE FACTOR

   Aa  oral slope  factor,  unadjusted  for
   absorption equals 1.6 (mg/kg-day)"1.

   Other  information  (Or an assumption)
   indicates a 20% absorption efficiency in the
   species on which the slope factor is based.

   The  adjusted  slope  factor that  would
   correspond to the absorbed dose would be:
   The  adjusted slope factor  of 8 (mg/kg*
  * day)"1 would be used to estimate the cancer
   risk, associated with the estimated absorbed
   dose for the dermal route of exposure.
A.2 ADJUSTMENT OF EXPOSURE
    ESTIMATE TO AN ABSORBED
    DOSE

    If the toxicity value  is expressed as an
absorbed rather than an administered dose, it may
be necessary  to convert the exposure estimate
from  an  intake into an  absorbed dose  for
comparison.    An example of estimating an
absorbed dose  from an intake using an absorption
efficiency factor is provided in the box in the top
right corner.  Do not adjust exposure estimates
for absorption  efficiency if the tnxicity values are
based on administered doses
A.3 ADJUSTMENT FOR MEDIUM
     OF EXPOSURE

     If the medium  of exposure in the site
exposure assessment differs from the medium of
       EXAMPLE: ADJUSTMENT OF
         EXPOSURE ESTIMATE TO
           AN ABSORBED DOSE

   The exposure assessment indicates that an
   individual  ingests  40  mg/kg-day of the
   chemical from locally grown vegetables.

   The oral RfD  (or  slope factor) for the
   chemical is based on  an  absorbed, not
   administered, dose.

   The human oral absorption efficiency for the
   contaminant from food is known or assumed
   to be 10 percent.

   The adjusted  exposure, expressed  as  an
   absorbed dose for comparison with the RfD
   {or slope factor), would be:

      40 mg/kg-day x 0.10 « 4 mg/kg-day.
exposure assumed by the toxicity value (e.g., RfD
values usually are based on or have been adjusted
to reflect exposure via drinking water, while the
site  medium of concern may  be soil),  an
absorption adjustment may,  on  occasion,  be
appropriate. For example, a substance might be
more completely absorbed following exposure to
contaminated drinking water than following
exposure to contaminated food or soil (e.g., if the
substance does  not desorb from soil  in the
gastrointestinal tract).    Similarly, a substance
might be more completely absorbed following
inhalation of vapors than following inhalation of
particulate. The selection of adjustment method
will  depend  upon the absorption efficiency
inherent in the RfD or slope factor used for
comparison.  To adjust a food  or soil ingestion
exposure estimate to match an RfD or slope
factor based on the assumption  of drinking water
ingestion, an estimate of the relative absorption
of the substance from food or soil and from water
is needed. A sample maculation is provided in
the box on the next page.

     In the absence of a strong argument for
making this  adjustment or reliable information
on relative absorption efficiencies, assume that the

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               Page A-4
                     EXAMPLE: ADJUSTMENT FOR
                         MEDIUM OF EXPOStfKE

                 The expected human daily  intake of the
                 substance in food or soil is estimated to be
                 10 mg/kg-day.

                 Absorption of the substance from drinking
                 water is known or assumed to be 90%, and
                 absorption  of the substance from food or
                 soil is known or assumed to be 30%.

                 The relative absorption of the substance in
                 food  or soil/drinking water is 033 (Le^
                 30/90),

                 The oral intake of the substance, adjusted
                 to be comparable with the oral RfD (based
                 on an administered dose in drinking water),
                 would be:

                    10 mg/kg-day x 0.33 * 3.3 mg/kg-day.
relative absorption efficiency between food or soil
and water is 1.0.

    If the RfD or slope factor is expressed as an
absorbed dose rather than an administered dose,
it is only necessary to identify an absorption
efficiency associated with the medium of concern
in the site  exposure estimate. In the example
above, this situation would translate into a relative
absorption of 0.3 (i.e., 30/100).
I

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                                   APPENDIX B
                                         INDEX
Absorbed dose
     calculation 6-34, 6-39, 7-8, 7-10, 7-12
     definition 6-2, 6-4, 6-32, 6-34, 7-10, 10-2
     following dermal contact with soil,
       sediment or dust 6-39, 6-41 to 6-43, 7-
       16
     following dermal contact with water 6-34,
       6-39, 7-16
     radiation 10-1, 10-2, 10-6
     toxicity value 7-10,  7-16, 8-5, A-l, A-2

Absorption adjustment
     dermal exposures 8-5, A-l, A-2
     medium of exposure 8-5, A-3, A-4

Absorption  efficiency
     default assumptions 6-34, 6-39, A-2 to A-4
     dermal 6-34, 6-39
     general 62,7-10,7-20, 8-5, 8-10

Acceptable daily intakes  7-1, 7-2, 7-6

Activity at time t 10-1

Activity patterns 6-2,  6-6, 6-7, 6-24, 7-3

Acute exposures See Exposure ~ short-term

Acute toxicants  6-23, 6-28

ADIs. See Acceptable daily intakes

Administered dose 6-2, 6-4, 7-1, 7-2, 7-10, 8-2,
  8-5, A-l to A-4

Agency  for Toxic Substances and Disease
   Registry  1-8,2-1,2-3, 2-4, 2-8 to 2-11,61, 6-
  17, 7-14, 8-1, 8-15, 8-24

Air data collection
     and soil 4-10
     background sampling 4-9
     concentration variability 4-9
     emission sources 4-15
     flow 4-8
     meteorological conditions 4-15,  4-20
     monitoring 4-8, 4-9, 4-14
     radionuclides 10-11
     sample type 4-19
     sampling locations 4-19
     short-term 4-15
     spatial considerations  4-15
     temporal considerations 4-15, 4-20
     time and cost 4-21

Air exposure
     dispersion models  6-29
     indoor modeling 6-29
     outdoor modeling 6-29
     volatilization 6-29

Analytes 4-2, 5-2, 5-5, 5-7, 5-10, 5-27

Analytical methods
     evaluation 5-5 to 5-7
     radionuclides 10-12, 10-13
     routine analytical services 4-22
     special analytical services 4-3, 4-22

Animal studies 7-1210-28, 10-29, 10-33

Applicable or relevant  and appropriate
  requirement 2-2, 2-7, 2-8, 8-1, 10-8 to 10-10

Applied dose 6-2, 6-4

ARAR. See Applicable or relevant and
  appropriate requirement

A(t). See Activity at time t

ATSDR, See Agency for Toxic  Substances and
  Disease Registry

Averaging time 6-23

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Page B-2
                      B
Background
     anthropogenic 4-2, 4-5
     comparison to site related contamination 4-
       9, 4.10, 4-18
     defining needs 4-5 to 4-10,6-29, 6-30
     information useful for data collection 4-1
     localized  4-5
     naturally  occurring 4-2, 4-5, 8-25, 10-14
     sampling 4-5 to 4-10, 10-14
     ubiquitous 4-5

BCF. See Bioconcentration factor

Bench scale tests 4-3

Benthic oxygen conditions 4-7

Bioconcentration 4-11, 6-31, 6-32

Bioconcentration factor 6-1, 6-12, 6-31,6-32

Biota sampling 4-7, 4-10, 4-16

Blanks
     evaluation 5-17
     field 4-22, 4-23, 5-17, 10-20
     laboratory 4-22, 5-13, 5-17
     laboratory calibration 5-17
     laboratory reagent or method 5-17
     trip 4-22, 5-17

Body weight as an intake variable 6-22,6-23, 6-
  39, 7-8, 7-12, 10-26, 10-33

Bulk density 4-7, 4-12
Cancer risks
     extrapolating to lower doses 7-11, 7-12
     linear low-dose equation 8-6
     multiple  pathways 8-16
     multiple  substances 8-12
     one-hit equation 8-11
     radiation 10-28 to 10-32
     summation of 8-12, 8-16

Carcinogenesis 7-10, 10-28 to 10-32

Carcinogen Risk Assessment Verification
    Endeavor 7-1, 7-13
Carcinogens 5-8, 5-21, 6-23, 7-10, 8-6, 10-30, 10-
  33

GDI. See Chronic daily intake

CEAM. See Center for Exposure Assessment
  Modeling

Center for Exposure Assessment Modeling 6-1,
  6-25,6-31

CERCLA See Comprehensive  Environmental
  Response, Compensation, and Liability Act of
  1980

CERCLA Information System 2-4

CERCLIS.  See CERCLA Information System

Checklist for manager involvement 9-14 to 9-17

Chemicals of potential concern
    definition 5-2
    listing 5-20
    preliminary assessment 5-8
    radionuclides 10-21
    reducing 5-20  to 5-24
    summary 5-24 to  5-27

Chronic daily intake 6-1, 6-2,  6-23,  7-1, 8-1, 8-6
  to 8-11

CLP. See Contract Laboratory  Program

Combustible gas indicator 5-6

Common laboratory contaminants 5-2, 5-3, 5-13,
  5-16, 5-17

Comprehensive  Environmental  Response,
  Compensation, and Liability  Act of 19801-1,
  1-3, 2-1 to 2-4

Concentration-toxicity  screen 5-20, 5-23

Conceptual model 4-5, 4-10

Contact rate 6-2, 6-22

Contract Laboratory Program
    applicability to radionuclides 10-16, 10-17,
       10-20, 10-21

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                                                                                              Page B-3
     definition 4-2
     routine analytical services 4-22, 5-5, 5-7, 5-
        15, 5-18,5-20
     special analytical services 4-3, 4-22, 5-5, 5-7
       to 5-10, 5-18 to 5-20
     statements of work 5-5

Contract-required detection limit. See
   Detection limit

Contract-required quantitation limit.  See
   Quantitation limit

CRAVE.  See  Carcinogen Risk Assessment
   Verification  Endeavor

CRDL. See Contract-required detection limit

Critical study. See Reference  dose

Critical toxicity effect.  See Reference dose

CRQL. See Contract-required quantitation
   limit
Curie 10-2,  10-4, 10-6
                      D
D. See Absorbed dose ~ radiation

Data
     codes 5-11 to 5-16
     positive 5-2
     qualifiers 5-11 to 5-16

Data quality objectives 3-4, 4-1 to 4-5, 4-19, 4-
  24, 10-14

DCF. See Dose conversion factor

Decay products  10-2,  10-7, 10-21, 10-24

Decision Summary 9-3

Declaration 9-3

Dermal
     absorption efficiency 6-34, 6-39
     contact with soil, sediment, or dust 6-39, 6-
       41to6-43,A-2
     contact with water 6-34, 6-37 to 6-39, A-2
     exposure 4-10, 4-11, 4-14, 6-34, 6-37 to 6-
       39, 6-43, 8-5, A-2
     external radiation exposure 10-22,  10-23,
       10-25, 10-26
     toxicity values 7-16

Detection frequency 5-20, 5-22

Detection limits
     contract-required 5-1, 5-2, 5-8
     definition 5-1,5-2, 5-8
     evaluation 4-3 to 4-5, 5-7 to 5-11,  5-20, 6-
       31
     instrument 4-1, 5-1, 5-7
     limitations to 4-15, 4-22, 5-8
     method 4-22, 5-1, 5-7
     radionuclides 10-17 to  10-20

Diffusivity 6-12

Dissolved oxygen 4-7

DL. See  Detection limit

Documentation. See Preparing and reviewing
  the baseline risk assessment

Dose
     absorbed vs administered 6-4, 7-10, 8-2, A-
       1 to A-3
     absorption efficiency A-l to A-3
     response curve 7-12
     response evaluation 7-1, 7-2, 7-11,  7-12

Dose conversion factor 10-1, 10-2, 10-24, 10-25,
  10-26

Dose equivalent
     committed 10-1,  10-2,  10-7, 10-24,  10-25,
       10-26
     effective 10-1, 10-2, 10-7, 10-24, 10-25, 10-
       26

DQO. See Data quality objectives

Dry weight 4-7

Dust
     exposure 6-39, 6-43
     fugitive dust generation 4-3, 4-5,4-15, 6-29
     transport indoors 6-29

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 PageB-4
                       E
 E. See Exposure level

 ECAO. See Environmental Criteria and
   Assessment Office

 Emission sampling
     rate 4-5, 4-7, 4-14
     strength 4-7

Endangernent Assessment Handbook 1-1,2-9

Endangerment assessments 2-1, 2-8

Environmental Criteria and Assessment Office
   7-1, 7-15, 7-16, 7-19, 8-1, 8-5, A-l

Enironmental Evaluation Manual 1-1, 1-11,2-9,
   4-16

Environmental Photographic Interpretation
   Center 4-4

EPIC. See Environmental  Photographic
   Interpretation  Center

Epidemiology
     site-specific  studies 2-10, 8-22, 8-24
     toxicity  assessment 7-3, 7-5

Essential nutrients 5-23

Estuary sampling 4-7,  4-13,4-14

Exposure
     averaging time 6-23
     characterization of setting 6-2, 6-5, to 6-8
     definition 6-2, 8-2
     event 6-2
     expressed as absorbed doses  6-34, 6-39, A-l
     for dermal route 6-34, 6-39,  6-41 to 6-43
     frequency/duration 6-22
     general considerations 6-19 to 6-24
     level 8-1
     long-term 6-23
     parameter estimation 6-19 to 6-23
     pathway-specific exposures 6-32 to 6-47
     point 6-2, 6-11
     potentially exposed populations 6-6 to 6-8
     radionuclides vs chemicals 10-22
     route 6-2, 6-11, 6-17, 6-18, 8-2, A-l
     short-term 6-23, 8-11,  10-25,  10-28, 10-30
 Exposure assessment
     definition 1-6, 1-7, 6-1, 6-2, 8-2
     intake calculations 6-32 to 6-47
     objective 6-1
     output for dermal contact with
       contaminated soil 6-39
     output for dermal exposure to
       contaminated water 6-34
     preliminary 4-3,4-10 to 4-16
     radiation 10-22 to 10-27
     spatial considerations 6-24 to 6-26

 Exposure concentrations
     and the reasonable maximum exposure 6-19
     in air 6-28, 6-29
     in food 6-31,6-32
     in ground water 6-26, 6-27
     in sediment 6-30
     in soil 6-27, 6-28
     in surface water 6-29, 6-30
     summarizing 6-32, 6-33, 6-50, 6-52

 Exposure pathways
     components  6-8, 6-9
     definition 6-2, 8-2
     external radiation  exposure 10-22, 10-23,
       10-25,  10-26
     identification 6-8  to 6-19
     multiple 6-47
     summarizing 6-17, 6-20
Fate and transport assessment 6-11, 6-14 to 6-
   16. See also Exposure assessment

Field blanks. See Blanks

Field investigation team 4-1, 4-16,4-20, 4-24,5-
   1,5-2

Field sampling plan 4-1, 4-24-23, 4-24, 10-15

Field screen 4-11, 4-20,4-21, 5-5,5-6, 5-24

First-order analysis 8-20

FIT. See Field investigation team

Five-year review 2-3, 2-5

Food chain 2-3,4-7,4-10,  4-16,6-31, 6-32

Fraction organic content of soil 4-7

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                                                                                         Page B-5
Frequency of detection. See Detection
  frequency

FS. See Remedial investigation/feasibility study

FSP. See Field sampling plan

                      G
Ground-water  data collection
    and air 4-13
    and soil 4-12
    filtered vsunfiltered samples 4-12, 6-27
    hydrogeologic properties 4-12
    sample type 4-19
    transport  route 4-11
    well location and depth 4-12

Grouping chemicals by  class 5-21, 10-21

                      H
HADs. See Health Assessment Documents

HAs. See Health Advisories

Half-life 6-12,  10-2

Hazard identification 1-6, 7-1, 7-2, 10-28 to 10-
  30

Hazard index
    chronic 8-13
    definition  8-1, 8-2
    multiple pathways  8-16, 8-17
    multiple substances 8-12, 8-13
    noncancer 8-12, 8-13
    segregation 8-14, 8-15
    short-term 8-13, 8-14
    subchronic 8-13, 8-14

Hazard quotient 8-2, 8-11

Hazard Ranking System 2-5, 2-6, 4-1, 4-4

HESee Dose  equivalent

HEi50_See Dose equivalent

Head measurements 4-7

Health  Advisories  2-10, 7-9, 7-10, 8-13
Health and Environmental Effects Documents
   7-1, 7-14, A-l

Health and Environmental Effects Profiles 7-1,
   7-14, A-l

Health Assessment Documents 7-1, 7-14, A-l

Health Effects Assessments 7-1, 7-14, A-l

Health Effects Assessment Summary Tables 7-1,
   7-14

Health physicist 10-3, 10-21

HEAs. See Health Effects Assessments

HEAST.  See Health Effects Assessment
   Summary Tables

HEEDs. See Health and Environmental Effects
   Documents

HEEPs. See Health and Environmental Effects
   Profiles

Henry's law constant 6-12

HI. See Hazard index

HNu organic vapor detector 5-6

Hot Spots 4-10 to  4-12, 4-17, 4-19, 5-27, 6-24, 6-
   28

HQ. See  Hazard  quotient

HRS.  See Hazard  Ranking System

HT. See Dose  equivalent

H^See Dose equivalent

Hydraulic gradient 4-7
I ARC. See International Agency for Research
  on Cancer

IDL. See Instrument detection limit

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 Page B-6
 Ingestion
     of dairy products 4-16, 6-47, 6-48
     offish and shellfish 4-3, 4-11, 4-14, 4-15, 4-
        16,6-43,6-45
     of ground water 6-34, 6-35
     of meat 4-15, 4-16, 6-47, 6-48
     of produce 4-16, 6-43, 6-46, 6-47
     of soil, sediment, or dust 6-39, 6-40
     of surface water 4-14, 6-34, 6-35
     while swimming 4-14, 6-34, 6-36

 Instrument detection limit. See Detection limit

 Inhalation 6-43, 6-44

 Intake 6-2, 6-4,6-19, 6-21, 8-2,  10-26

Integrated Risk Information System 7-1, 7-27-
   6, 7-12 to 7-15, 8-1, 8-2, 8-7, 8-8, 10-33

 International Agency for Research on Cancer 7-
   11

 International System of Units 10-1

 Ionizing radiation. See Radionuclides, radiation

 IRIS. See Integrated Risk Information System

                      K
Kd6-12
K 6-12
KOW6-12, 6-31
Kriging 6-19

                      L
Land use
     and risk characterization 8-10, 8-20, 8-26
     current 6-6
     future 6-7

Lentic  waters 4-14

LET. See  Linear energy transfer

Level of effort 1-6 to 1-8,3-3

Life  history stage 4-7
Lifetime average daily intake 6-2, 6-23, 8-4

Linear energy transfer  10-1, 10-2, 10-28,  10-29,
   10-31

Linearized multistage model 7-12, 8-6

Lipid content 4-7, 10-14

LLD. See Lower limit of detection

LOAEL See Lowest-observed-adverse-effect-
   level

Lotic waters 4-13, 4-14

Lower limit of detection 10-1

Lowest-observed-adverse-effect-level 7-1, 7-2, 7-
   7,8-1

                      M
Management tools 9-1, 9-14, 10-1,  10-34

Maximum contaminant levels 1-8, 5-8

MCLS. See Maximum contaminant levels

MDL. See Method detection limit

Media of concern
     air 4-14
     biota 4-15
     ground water 4-12
     sampling 4-2, 4-3, 4-10 to 4-16
     soil 4-11
     surface water/sediments 4-13

Metals
     absorption by gastrointestinal tract A-2, A-
       3
     default assumptions for A-2

Method detection limit. See Detection limit

MeV. See Million electron volts

MF. See Modifying factor

Million electron volts  10-1, 10-5

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                                                                                         Page B-7
Modeling 4-3 to 4-8, 5-8, 5-22, 5-27,6-25, 6-26,
  8-18 to 8-20

Modifying factor 7-7, 7-21, 8-4, 8-8, 10-1, 10-2,
   10-6

Monte Carlo simulation 8-19, 8-20

Multistage model. See Linearized multistage
   model

                     N
N. See Dose  equivalent

National Oceanographic and Atmospheric
   Administration 6-1, 6-6

National Oil and Hazardous Substances
   Pollution Contingency Plan 1-1, 2-2, 2-4, 2-5

National Priorities List 2-3, 2-5, 2-6, 10-1

National Response Center 2-4

National Technical Guidance Studies 6-1

NCP. See National  Oil and Hazardous
   Substances Pollution Contingent Plan

ND. See Non-detect

NOAA. See National Oceanographic  and
   Atmospheric Administration

NOAEL. See No-observed-adverse-effect-level

Noncancer hazard indices. See Hazard index

Noncancer hazard quotient. See Hazard
   quotient

NonCarcinogenic threshold toxicants 7-6

Non-detects 5-1, 5-2, 5-7, 5-10, 5-11,5-15, 5-16

No-observed-adverse-effect-level  7-1, 7-2, 7-7, 8-
 1

Normalized exposure rate 6-4, 8-2, A-2

NPL. See National  Priorities List
NRC. See Nuclear Regulatory Commission

NTGS. See National  Technical Guidance
  Studies

Nuclear Regulatory Commission  8-1, 10-8

Nuclear transformation 10-2

                     0
OAQPS. See Office of Air Quality Planning
  and Standards

OERR. See Office of Emergency and Remedial
  Response

Office of Air Quality Planning and Standards 6-
  1

Office of Emergency and Remedial Response 1-
  1

Office of Radiation Programs 10-3,  10-10, 10-14,
  10-24 to  10-26

Operable units 1-8, 1-9, 3-1, 3-2, 5-24

Oral absorption A-2, A-3

Oral cancer potency factor adjustment A-3

Oral reference dose adjustment A-2

Organic carbon content 4-7, 4-12, 5-5

Organic vapor analyzer 5-6

OVA. See Oxygen vapor analyzer

Oxygen-deficient atmosphere  5-6

                      P
PA. See Preliminary assessment/site inspection

Partition coefficient 4-7, 6-31, 6-32

PA/SI. See  Preliminary assessment/site
  inspection

PC See Permeability  constant

PE. See Performance  evaluation

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Page B-8
Performance evaluation 5-1, 5-5

Permeability  constant 6-34, 10-26

Persistence 4-2, 5-21, 6-4, 6-23, 6-24

pH4-7

PHE. See Public health evaluation

Porosity 4-7, 4-12

PQL. See Practical quantitation limit

Practical quantitation limit 5-1

Preliminary  assessment/site inspection 2-4,  2-5,
   2-6, 4-2, 4-4, 6-5

Preliminary remediation goals 1-3 to  1-5, 1-8, 8-
   1

Preparing and reviewing the baseline risk
   assessment
     addressing the objectives  9-1, 9-2
     communicating the results 9-1, 9-2
     documentation tools 9-1 to 9-8
     other key reports 9-3
     review tools 9-3, 9-9 to 9-14
     scope 9-2, 9-3

PRGs. See Preliminary remediation  goals

Primary balancing criteria 1-9

Proxy concentration 5-10

Public health evaluation 1-11

                      Q
Q. See Dose equivalent

QAPjP. See Quality assurance project plan

QA/QC. See Quality Assurance/Quality  Control

QL. See Quantitation  limit

Qualifiers. See Data

Quality assurance project plan 4-1, 4-2,4-23
Quality assurance/quality control 3-4, 4-1, 4-3, 5-
   1, 5-29

Quality factor 10-2, 10-6

Quantitation limit
     compared to health-based concentrations 5-
       2,5-5,5-7,5-8,5-11
     contract-required 5-1,  5-2, 5-8
     definitions 5-2, 5-5, 5-8
     evaluation 5-1 to 5-9, 10-20
     high 5-10
     radionuclides  10-17 to 10-20
     sample 5-8
     strategy 4-21
     unavailability  4-3, 5-10

                      R
RA. See Remedial action

Radiation.  See  Radionuclides,  radiation

Radiation advisory groups
     International  Commission on Radiation
       Protection 10-3,  10-9, 10-28
     National Academy  of  Sciences 10-28, 10-29
     National Council on Radiation Protection
       and Measurements  10-9, 10-28
     United Nations Scientific  Committee on
       the  Effects of Atomic Radiation 10-28,
       10-29, 10-30

Radiation detection instruments
     gas  proportional counters 10-12,  10-13
     Geiger-Mueller (G-M) counters 10-11,  10-
       12
     ionization  chambers 10-11 to  10-13
     scintillation detectors  10-11 to 10-13
     solid-state  detectors 10-12, 10-13

Radiation units
     becquerel 10-1, 10-2, 10-4, 10-6
     curie 10-1, 10-2,  10-4, 10-6
     picocurie 10-1
     rad  10-2, 10-6
     rem 10-2
     roentgen 10-2, 10-6
     sievert 10-1, 10-2, 10-6
     working level 10-7
     working level month 10-7

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                                                                                             Page B-9
Radionuclides,  radiation
     alpha particles 10-4,  10-5, 10-28
     beta particles 10-4, 10-5, 10-28
     decay products 10-2,  10-7, 10-21,  10-24
     definition  10-2
     external 10-2
     half-life 10-2
     internal 10-2
     ionizing 10-2
     linear energy transfer 10-2, 10-28, 10-29,
       10-31
     lower limit of detection 10-17, 10-20
     neutrons 10-4
     photons 10-4, 10-5, 10-28
     positrons 10-4
     quality factors 10-2, 10-6, 10-29
     radioactive decay  10-2,  10-2
     radon decay products 10-7
     regulatory  agencies 10-8, 10-9
     relative biological effectiveness 10-1, 10-6,
       10-29
     risk characterization  10-32 to 10-34
     toxicity assessment 10-27 to 10-32

RAS. See Routine analytical services

RBE. See Relative biological effectiveness

RCRA. See Resource  Conservation and
  Recovery Act

RD. See Remedial design

Reasonable  maximum  exposure
     and body weight 6-22, 6-23
     and contact rate 6-22
     and exposure concentration 6-19
     and exposure frequency and duration 6-22
     and risk characterization 8-1, 8-15, 8-16, 8-
       26
     definition 6-1, 6-4, 6-5
     estimation of 6-19 to 6-23, 8-15, 8-16

Record of Decision 2-5, 9-3

Redox potential 4-7

Reference dose
     chronic 7-1, 7-2, 7-5,  8-1, 8-2, 8-8, 8-10, 8-
       13, A-l, A-2
     critical toxic effect 7-7,  8-4, 8-10,  8-15
     critical study 7-7
     definition 7-1,7-2, 8-2, A-2
     developmental 7-1, 7-6, 7-9, 8-2
     inhalation 7-8
     oral 7-6, 7-7
     subchromc  7-1, 7-2, 7-6, 7-8, 7-9, 8-2, 8-9,
       8-14
     verified 7-10

Regional Radiation Program Managers 10-3, 10-
   10

Relative biological effectiveness 10-1, 10-6,  10-
   29

Release sources 6-10

Remedial action 1-3, 1-8 to 1-10, 2-5, 2-7, 2-9,
   3-1, 3-2, 6-8,  10-8

Remedial action objectives 1-3, 1-8, 2-7

Remedial design 2-5, 2-6, 2-9

Remedial  investigation/feasibility study 1-1 to 1-
   5, 1-8 to  1-10, 2-5 to 2-7, 3-1 to 3-3, 4-1 to
   4-5, 4-23, 8-1

Remedial project manager
     and background sampling 4-8
     and elimination of data 5-2, 5-17, 5-20, 5-
       21
     and ground-water sampling 4-13
     and radiation 10-3
     and reasonable maximum exposure 6-5
     and scoping meeting 4-3
     definition 1-2
     management tools for 9-14 to 9-17

Remedy selection 1-9, 2-5

Resource Conservation and Recovery Act 2-7,
   10-8

Responsiveness Summary  9-3

Reviewing the risk assessment.  See  Preparing
   and reviewing the baseline risk assessment

RfD. See Reference dose

R£DASee Reference dose

RfD See Reference dose

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Page B-10
RI. See Remedial investigation/feasibility study

RI/FS. See Remedial investigation/feasibility
   study

Risk assessment reviewer 1-2, 9-1, 9-3, 9-9 to 9-
   14

Risk assessor
     definition  1-2
     tools for documentation 9-1 to 9-8

Risk characterization 1-6, 1-7, 8-1

Risk information in the RI/FS process 1-3  to 1-
   10

Risk manager 1-2

RIME See Reasonable maximum exposure

ROD. See Record of Decision

Route-to-route  extrapolation 7-16

Routine analytical services. See Contract
   Laboratory Program

RPM. See Remedial project manager

                       S
salinity 4-7, 4-14, 6-5

Saltwater incursion extent 4-7

Sample Management Office 4-1, 4-2,5-1,5-5

Sample quantitation limit 5-1. See also
   Quantitation limit

Samples. See Sampling

Sampling
    annual/seasonal cycle 4-20
     composite 4-11, 4-14, 4-19
     cost 4-10,  4-17, 4-18, 4-20, 4-21
     depth 4-7, 4-11, 4-12, 4-19
     devices 4-21
     grab 4-19
     purposive 4-9,4-10, 4-12,4-18,4-19
     radionuclides 10-10 to 10-16
     random 4-9, 4-12, 4-18 to 4-20
    routes of contaminant transport 4-10 to 4-
       16
    strategy 4-16
    systematic 4-18, 4-19

sampling and analysis plan 1-4, 4-1, 4-2, 4-3, 4-
  22 to 4-24

SAP. See Sampling and analysis plan

SARA. See Superfund Amendments and
  Reauthorization Act of 1986

SAS. See Special analytical services

Scoping
    meeting 4-3, 4-18, 4-22,  4-23, 9-15, 10-15
    of project 1-3 to 1-5,  1-8, 2-7, 3-2, 3-3

SDL See  SubChronic daily intake

SEAM. See Superfund Exposure Assessment
  Manual

Segregation of hazard  indices 8-14, 8-15

Selection of remedy.  See Remedy selection

Semi-volatile organic  chemical 5-1

SI. See International System of Units,
  Preliminary assessment/site inspection

Site discovery or notification 2-4

Site inspection.  See Preliminary assessment/site
  inspection

Skin 5-29, 7-16, 10-4,  10-6, 10-22, 10-29. See
  also Dermal

Slope factor 5-9, 5-21, 7-3, 7-11 to 7-13, 7-16, 8-
  1, 8-2 to 8-7, 8-10 to 8-12, 10-2, 10-33, A-l
  to A-4

SMO. See Sample management office

Soil data collection 4-11
    and  ground water 4-12
    depth of samples 4-12
    heterogeneity 4-11
    hot spots 4-11

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                                                                                           Page B-ll
 Solubility 6-12

 Sorption  6-27

 SOW. See Statements of work

 Special analytical services. See Contract
   Laboratory Program

 Specific organ 4-7, 10-7,  10-22

 SPHEM. See Superfund Public Health
   Evaluation Manual

 SQL. See Sample  quantitation limit

 Stability class 4-7

 Statements of work.  See Contract  Laboratory
   Program

 Statistics
     and background 4-8 to 4-10, 5-18
     certainty 4-8, 4-17, 4-18
     methods 4-8, 4-18
     power 4-9, 4-18
     sampling strategy 4-16 to 4-20
     variability 4-9, 4-18

 Structure-activity studies  7-5

 SubChronic daily intake 6-1, 6-2,  6-23, 7-1, 8-1

 Superfund. See Comprehensive  Environmental
   Response, Compensation, and Liability Act of
   1980

 Superfund Amendments  and Re authorization
   Act of 19861-11, 2-1 to 2-4

Superfund Exposure Assessment Manual 2-1, 2-8,
   6-1

Superfund Public Health Evaluation Manual 1-1,
   2-8

 SVOC. See Semi-volatile organic chemical
T. See Tissue

TAL. See Target analyte list
 Target analyte list 4-1, 4-2, 5-5, 5-8,5-17

 Target compound list 4-1, 4-2, 4-22, 5-1,5-5, 5-
   8, 5-17, 5-21,  10-20

 TCL. See Target compound list

 Tentatively identified compound 4-1, 5-1, 5-13,
   5-17,5-18

 Thermocline  4-7

 TIC See Tentatively identified  compound

 Tidal cycle 4-7, 4-14

 Tissue 10-1

 TOC. See Total organic carbon

 Tools
     documentation 9-1 to 9-8
     management 9-13 to 9-17
     review 9-3, 9-9 to 9-14

 Topography 4-7

 Total organic carbon 5-1

 Total organic halogens 5-1

 TOX. See Total  organic  halogens

Toxicity assessment 1-6, 1-7, 7-1, 7-4, 10-27 to
   10-32

Toxicity values
     absorbed vs administered dose 7-10, A-l
     definition 7-3
     generation of 7-16
     hierarchy of information 7-15
     oral 7-16, 10-33, A-2
     radiation  10-22,  10-32
     reducing number of chemicals 5-21, 5-23

Transfer coefficients 6-32

Transformation 5-20, 6-27,  7-5, 10-210-3, 10-5

Treatability 5-21

Trip blanks. See Blanks

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Page B-12
                      u
UFs. See Uncertainty factors

Uncertainty  analysis
     exposure 6-17,6-34,6-47,6-49 to 6-51,8-
       18, 8-22
     factors 7-7 to 7-10, 8-4, 8-8, 8-9, 8-17,8-18,
       8-20,8-22
     first-order analysis 8-20
     model applicability and assumptions 6-50,
       8-18 to 8-22
     Monte Carlo simulation 8-20
     multiple substance exposure 8-22
     parameter value 8-19
     qualitative 8-20, 8-21
     quantitative 8-19,  8-20
     radiation 10-27, 10-33
     risk 8-17
     semiquantitative 8-20
     toxicity 7-19, 7-20, 8-22

Uncertainty factors. See Uncertainty  analysis ~
  factors

Unit risk 7-13
U.S. Geological survey 6-1, 6-6

USGS. See U.S. Geological Survey

                      V
Vapor pressure 6-12

VOC. See Volatile organic chemical

Volatile  organic chemical  4-2, 5-1,5-17,6-31

                      w
Water hardness 4-7

Weighting factor  10-1, 10-2, 10-7

Weight-of-evidence classification 5-20, 7-3, 7-9,
   7-11, 8-2,8-4,8-7,8-10

Whole body 4-7, 4-16, 6-31, 10-6,  10-7

Workplan 4-1, 4-4, 4-22 to 4-24, 9-15

WTSee Weighting factor
  *U.S.G.P.O.:1 992-311-893:62673

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I
CHAPTER 1:    INTRODUCTION
I
CHAPTER 2:
 STATUTES, REGULATIONS, GUIDANCE, AND STUDIES RELEVANT
 TO THE HUMAN HEALTH EVALUATION
I
CHAPTERS:   GETTING STARTED: PLANNING FOR THE HUMAN HEALTH
             EVALUATION IN THE RI/FS
   CHAPTER 4:   DATA COLLECTION
   CHAPTER 5:   DATA EVALUATION
   CHAPTER 6:   EXPOSURE  ASSESSMENT
   CHAPTER 7:   TOXICITY ASSESSMENT
   CHAPTERS:   RISK CHARACTERIZATION
I
CHAPTER 9:
DOCUMENTATION,REVIEW, AND
MANAGEMENT TOOLS FOR-THE RISK
ASSESSOR, REVIEWER, AND MANAGER
   CHAPTER 10:   RADIATION RISK ASSESSMENT GUIDANCE
                                                               PART A BASELINE
                                                               RISK ASSESSMENT
   APPENDIX A:  ADJUSTMENTS  FOR ABSORPTION EFFICIENCY
   APPENDIX B:  INDEX

-------