United States       Solid Waste And       9285.701A
            Environmental Protection   Emergency Response     July 1989
                        (OS-230)          Pre-Publication Copy
vxEPA      Risk Assessment
            Guidance For
            Superfund

            Human Health
            Evaluation  Manual
            Part A
            Interim Final

-------
                             OSWER Directive 9285.7-Ola
            INTERIM FINAL

RISK ASSESSMENT GUIDANCE
        FOR SUPERFUND

 Volume I:  Human Health Evaluation Manual
          Office of Emergency and Remedial Response
            U.S. Environmental Protection Agency
              Washington, D.C. 20460
               September 29, 1989

-------
                                                                                             Pagei
ABOUT THE REVISION . .  .
WHAT FT      EPA's Human Health  Evaluation  Manual  is  a  revision  of  the  Superfund Public
IS             Health Evaluation Manual (SPHEM; October  1986); it is Volume I of the two-volume set
               called Risk Assessment Guidance for Superfund.   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.)

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

WHAT'S       This revision builds upon the process established  in  SPHEM and provides more detailed
NEW          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
               investigation/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 toxicity 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.

DISTRIBU-    This manual  is being distributed  as an interim final document while the proposed NCP is
TION PLAN   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.

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

-------
                                                                                             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.

-------
Page iii
                                 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 the following page) 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.

-------
                                                                                       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

-------
                                                                             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 THE HUMAN HEALTH EVALUATION ..........................    2-1

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

          2.1.1 CERCLA and 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 Assessments  ..................................    2-8
          2.2.2 ATSDR Health Assessments ..................................    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   Goal 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

-------
Page vi
          4.1.2  Data Needs and the RI/FS	   4-2
          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

-------
                                                                                  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 Test Positive 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 a Medium	  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

     5.6  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-Toxicity  Screen	  5-23

     5.10 SUMMARY AND PRESENTATION OF DATA	  5-24

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

-------
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 EXPOSURE:  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

-------
                                                                                    Page ix


CHAPTER 7   TOXICITY ASSESSMENT	   7-1

      7.1  TYPES OF TOXICOLOGICAL INFORMATION CONSIDERED IN
          TOXICITY ASSESSMENT	   7-3

          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 FOR NONCARCINOGENIC 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 (RfD^)	   7-8
          7.2.5  Derivation of a  Developmental Toxicant RfD (RfDA)  	   7-9
          7.2.6  One-day and Ten-day Health Advisories	   7-9
          7.2.7  Verification  of RfDs	  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

-------
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/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

-------
                                                                                          Page xi


CHAPTER 10  RADIATION RISK ASSESSMENT GUIDANCE	    10-1

      10.1  RADIATION PROTECTION PRINCIPLES AND  CONCEPTS	    10-3

      10.2  REGULATION OF RADIOACTIVELY 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 by 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 Quantifying 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

-------
Page xii


     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

-------
                                                                                          Page xiii
                                    LIST OF  EXHIBITS

Exhibit                                                                                      Page

  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 Governing 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 Qualifiers 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	  5-25
  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 Environmental 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	  6-40
  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

-------
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       Types of 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

-------
                                                                                           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 Superfiind.   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 Risk 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 Hazardous 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
organisms;  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 health 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

-------
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
Environmental  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.

-------
INTRODUCTION

-------
                                    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/ 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).5   It
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
Environmental 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
        evaluating 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

-------
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/and, 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 RISK ASSESSMENT/
             RISK MANAGEMENT

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

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

   Remedial Project Manager (RPMX  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.

   Risk Manager.  The individual 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 headquarters 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

-------
                                                                                            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

-------
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
   Chapters for information on planning the human health
   evaluation.)
     The   preliminary   characterization  during
project scoping 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;

-------
                                                              Page 1-5
                          EXHIBIT 1-1

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






	 *



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 evaluation 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  toxicity  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

-------
                                                                                        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
    Toxicity Assessment
•  Collect qualitative and
   quantitative loxicity 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  conducted  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

-------
                                                                                              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

-------
Page 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.

-------
                                                                                                             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.

-------
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,
     1986).

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

Environmental Protection Agency (EPA).  1986d.  Guidelines  tor 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 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). 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 -89/001 A.  (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).

-------
                             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 assessments;

    •   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 clean up the

-------
Page 2-2
                                   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
                           Rcauthorization 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)

-------
                                                                                           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 2-4
    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 lexicological 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 quantities 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

-------
                                                                                             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 evaluation 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

-------
Page 2-6
                                      EXHIBIT 2-2

                ROLE OF THE HUMAN HEALTH EVALUATION IN
                      THE SUPERFUND REMEDIAL PROCESS
               Preliminary Assessment/
               Site Inspection/Listing
               Site Inspection
               (PA/SI/LSI)
HRS Scoring/
NPL Listing
Remedial
Investigation/
Feasibility
Study
(RI/FS)
                                            PART A
                                          Baseline Risk
                                           Assessment
                                             (RD
                              PARTC
                           Risk Evaluation
                            of Remedial
                           Alternatives (FS)
                                                       PART B
                                                     Development/
                                                      Refinement
                                                     of Preliminary
                                                     Remediation
                                                      Goals (FS)
                  * The RI/FS can be undertaken prior to NPL listing.

-------
                                                                                           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 I988d; 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  (CAA), 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  "applicable"  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
         requirements;

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

     •    Chapter   3   provides   guidance  for
         compliance with  CW^. substantive (for
         onsite   and  offsite   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;

-------
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

-------
                                                                                           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

     CERCLAsection 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 listed 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

-------
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 Superfitnd
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 full-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

-------
                                                                                               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.

-------
Page 2-12


                                 REFERENCES  FOR CHAPTER 2
Environmental Protection Agency (EPA).  1985. National Oil and Hazardous 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/540A-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 9285.4-02).

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 (HRS) 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).  1988e.  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.

-------
                                 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

-------
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
analysts  should foresee  that exposure  pathways
outside  the scope of  the  focused  RI/FS may
ultimately 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, implementability, 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

-------
                                                                                           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
necessary  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.7
     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.

-------
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).

-------
         PART A
BASELINE RISK ASSESSMENT

-------
                             CHAPTER 4
                      DATA COLLECTION
                                        Toxicity
                                      Assessment
FROM:
• Site discovery
• Preliminary
 assessment
•Site inspection
    listing
    Risk
Characterization
• 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

-------
                                    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

-------
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 (DOOst. 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 (QAPjPV  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;

-------
                                                                                              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 of fish, 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

-------
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 information
   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).

-------
                                                                                           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)  anthropogenic    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.,

-------
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

-------
                                                                                         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 Parameters0
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
    a 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.

-------
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  applicable  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 SamplingQualityAssurance 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

-------
                                                                                            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 ft 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 fixed 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  at RCRA Facilities (EPA  1989c)  is useful
for   designing  sampling  plans  for  comparing
information  from  many  fixed  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.

-------
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 lexicological -- 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

-------
                                                                                            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+5
versus Cr+<5), 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 Spill
                                               Sites to Verify Cleanups (EPA 1986b)

                                               A Compendium ofSuperfiind 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.

-------
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 of SuperfundField Operations
                                               Methods (EPA 1987c)

                                               Handbook: Ground Water (EPA 1987d)

                                               Statistical  Methods for Evaluating Ground
                                               Water from Hazardous Waste Facilities (EPA
                                               1988b)

                                               Guidance   on  Remedial   Actions  for
                                               Contaminated  Ground Water at Superfund
                                               Sites (EPA 1988e)

                                               Ground-water Sampling for Metals Analyses
                                               (EPA 1989d)
     Hydrogeologic  properties.    The  extent  to
which the hydrogeologic properties (e.g., hydraulic
conductivity,   porosity,   bulk  density,  fraction
organic carbon, productivity) of the aquifer(s) are
characterized may have a significant effect on the
risk  assessment.  The ability to  estimate future
exposure concentrations depends on the extent to
which hydrogeologic properties needed to evaluate
contaminant migration are quantified.  Repetitive
sampling of wells is necessary to obtain  samples
that   are  unaffected  by   drilling   and  well
development   and   that   accurately   reflect
hydrogeologic properties of the aquifer(s).

     Well location and depth.   The location of
wells should be such that both the horizontal and
vertical  extent   of  contamination   can   be
characterized. Separate water-bearing  zones may
have different aquifer classifications and uses and
therefore may need to be evaluated separately in
the  risk assessment.   In addition,  sinking or
floating layers of contamination  may be  present
at different depths of the wells.

     Filtered vs. unfiltered samples.  Data  from
filtered and unfiltered ground-water samples are
useful for evaluating chemical migration in ground
water,   because   comparison   of   chemical

-------
                                                                                           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 paniculate matter and
not  dissolved  in  the  ground  water.    This
information   on  the  form  of chemical  (i.e.,
dissolved or suspended on paniculate 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  um filter may screen
         out some potentially mobile particulates
         to which contaminants are absorbed and
         thus    under-represent   contaminant
         concentrations.      (Recent   research
         suggests that a  1.0 um may be a  more
         appropriate filter size.)

     •    Pumping velocity.  Pumping at too high
         a rate will entrain particulates (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)

-------
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
composited. 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

-------
                                                                                            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 proce'dures, and
QA/QC procedures.  Step four details the day-to-
day  activities  related  to conducting  the  air
maintenance  and calibration,  and documentation
of laboratory 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 in
   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 19881)
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

-------
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)

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

   A Compendium ofSuperfund 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

-------
                                                                                            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:
RIfFS Activities at a Site with Contaminated
Soils  and  Ground Water (EPA 1987b)

Expanded Site Inspection (ESI) Transitional
Guidance for FY 1988 (EPA 1987f)

Quality Assurance Field Operations Manual
(EPA 1987g)

Statistical  Methods  for   Evaluating  the
Attainment of Super/and Cleanup Standards:
Volume 1,  Soils  and Solid Media  (EPA
                                               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

-------
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 necessary.
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

-------
                                                                                           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

-------
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 water/low 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  chromatographs).
(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

-------
                                                                                           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
cost 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 Services 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.

-------
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.
                                          Analytical Services (RAS) may not be appropriate
                                          (e.g., lower detection limits may be needed),4 and
                                          (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
                                          1988J).

                                              In reviewing the historical data at a site, the
                                          risk  assessor should  determine  if  non-TCL
                                          chemicals are expected. As 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.
4.8 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
                                          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

-------
                                                                                           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    concentrations   by
            medium,
         --  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.

-------
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 concentrations;

    •   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 sampling
and analysis  plan 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.

-------
                                                                                                              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
Operations Branch for further information.

-------
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 Vegas,  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 PCB 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.

-------
                                                                                                                 Page 4-27


Environmental  Protection Agency (EPA). 1986c.  Resource Conservation and Recovery Act CRCRA1 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 9335.0-7B).

      •    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 analysis 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 Superfund 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 Regulations
      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 sites 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
           coordinators, and contractors assisting in RVFS -related activities) with an overall understanding of the RI/FS
           process.  Includes general information concerning scoping meetings, the development of conceptual models at
           the beginning of a site investigation, sampling, and analysis.

-------
Page 4-28
Environmental Protection Agency (EPA). 19885.  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 sampling
           procedures 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 sites, 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.

      •     Provide 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 DQO's, 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.

-------
                                                                                                                 Page 4-29


Environmental Protection Agency (EPA). 1989e.  Air Superfund National Technical Guidance Series.  Volume IV:  Procedures for
      Dispersion Modeling and Air Monitoring for Superfund Air Pathway Analysis. Interim Final.  Office of Air Quality Planning and
      Standards. Research Triangle Park, NC.  EPA/450/1 -89/004.

      •     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 Superfund 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  Superfund 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). 19891.  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 of fish 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.

-------
             CHAPTER 5
     DATA EVALUATION
/FROM:     N
 •Site discovery
 • Preliminary
  assessment
 • Site inspection
\»NPL listing ^
                       Toxicity
                     Assessment
  Data       Data
Collection  Evaluation
    Risk
Characterization
                      Exposure
                     Assessment
 TO:
 •Selection of
  remedy
 • Remedial
  design
 • Remedial
.. 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

-------
                                     CHAPTERS
                            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 steps, the
EPA remedial project manager (RPM) should be
consulted to determine if certain steps should be
modified, added,  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

-------
Page 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 chemicals (considered by EPA to be 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 the site.

     Contract-required Quantitation Limit (CRQL).  Chemical-specific levels 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 quantitation limit
         of a given chemical in a given sample.

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

     Non-dctects (NDs). 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 "U" 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 non-detect).

     Quantitation Limit (QL). The lowest level at which a chemical can be accurately and reproducibly quantitated. Usually equal
         to the instrument detection limit multiplied by a factor 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.

-------
                                                                                                                                         Page 5-3
                                                       EXHIBIT 5-1
                                               DATA EVALUATION
f  Sampling data from
I  each medium of concern
V       (Sec. 5.1).
                                       Analytical
                                   method appropriate
                                     for quantitative
                                     risk assessment
                                       Sec. 5.2)7
                 Eliminate data associated with
               inappropriate methods. Possibly use
                    qualitatively in other risk
                     assessment sections.
                                             Is a
                                     chemical not detected
                                          in a sample
                                          (Sec. 5.3)?
                                                                    quanititation limit (QL)
                                                                     health-based reference
                                                                       concentration?
                                                                      Reanalyze or address
                                                                   qualitatively,as appropriate.
                                                                                                                                If QL cannot be reduced
                                                                                                                                 useOL or 1/2 QL as
                                                                                                                                 proxy concentration, or
                                                                                                                                 eliminate chemical in
                                                                                                                                sample, as appropriate
                                                                                                     Do other
                                                                                                  samples in same
                                                                                                medium test positive1'
Use QL or 1/2 QL as
proxy concentration.
                                                      Gene rally eliminate
                                                           chemical.
                                          Qualifiers
                                      and codes attached
                                       to data (Sec. 5.4)'
                                                                    Evaluate qualified data, and
                                                                   eliminate, modify, or leave data
                                                                    as they are, as appropriate.
                                                                                                               Sample
                                                                                                          concent rational Ox
                                                                                                           ank concentration7
                                         Blank
                                      contamination
                                       (Sec. 5.5)'
                     Common lab
                    contaminants?
                                                                             Sample
                                                                         concentration^ 5x
                                                                         a* concentration'
                                            Many
                                      tentatively identified
                                       compounds (TICs;
                                          Sec. 5.6)?
                                                                        Expected to be
                                                                    present and are primary
                                                                     contaminants at site'
                                 Eliminate TICs (as appropriate).
                                                         Use SAS, if possible, to confirm identity and concentration
                                                             otherwise use TICs as they are (as appropriate).
                                             Site
                                           chemicals
                                      equal to background
                                           (Sec 5.7)?
/"chemicals of potential
I  concern for quantitative
V    risk assessment.
            Calculate risk of background chemicals
            separately from site-related chemicals.
NOTE:   See text for details
          concerning specific
          steps in this flowchart.

-------
   Page 5-4
)-H



1
a













X
1




























' O =0







Q «
3 ^ B
O CM *T C^l 06 5
 6 3 3 Q












' ^00
— CQ „ '— ' t«
O Q£ T ^f W
CO CO O I-H 3





a.
J£ (*!
Q U
1 1 * 1
•g c/5 3 Q

ff 1-2.2 1
B E fi S c _«
a> 


Ulllll


„ ^^
„.,._
D D 3 ^ ^ -,



Q 0 Q CM >0 0 0
-«aa




S ""


O ID ^




SSi§S§2


ggiSgSS




1-1 oJ f) ^ ^  C 00
"" o O
« 8 i
i ? *
                                                                                                 I

                                                                                                 B
                                                                                                 .2

-------
                                                                                                           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 Laboratory 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 fill 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 quality control (QC), and also  must successfully  analyze performance
   evaluation (PE) 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 quantitation limits, QC requirements, and report format. Protocols are provided in the CLP Statement
   of Work (SOW) for Inorganics (EPA 1988b) and the CLP Statement of Work for Organics (1988c). The SOWs also contain
   EPA's target analyte or compound lists (TAL for inorganics, TCL for orgamcs), which are the  lists of analytes and required
   quantitation limits (QLs) for 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 1988d]  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 EPA 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,
   and 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.

-------
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 Chromatography0           Field Screen/Analytical          Specific Volatile and
                                  Method                       Semi-volatile Organic
                                                               Chemicals
" 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.

-------
                                                                                           Page 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

-------
Page 5-8
certain reference concentrations (e.g., maximum
contaminant   levels    [MCLs],   concentrations
corresponding to a 10~6 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.7   Estimation of
cancer risks  for several  other  chemicals  (e.g.,
arsenic, styrene) at  their  CRQLs  yields  cancer
risks exceeding  W'4, based on  the  same  water
ingestion factors. Most potential carcinogens with
EPA-derived slope factors have CRQLs that yield
cancer risk levels exceeding  10~6  in water,  and
none of the carcinogens with EPA-derived slope
factors have CRQL values  yielding  less than  10"7
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 1DL 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 non-detected chemicals.

-------
                                                                                                 Page 5-9
          EXAMPLE OF HEALTH RISKS FROM INGESTION OF WATER CONTAMINATED
                WITH SELECTED CHEMICALS AT THEIR QUANTITATION LIMITS"
   Chemical
                  CRQL or
  CAS #         CRDL (ug/L)b  CRDL/RfCc
                         Cancer Risk
                      at CRQL or CRDLd
   Antimony
   Arsenic
   Benz(a)pyrene
   Bis(2-CMoroethyl)ether
   2,4-Dinitrotoluene
   Hexachlorobenzene
   N-NitrOso-di-n-dipropylamine
   PCB-1254
   PCB-1260
   Sfyrene
   Vinyl chloride
 7440-36-0
 7440-38-2
  50-32-8
 1H -44-4
 121-14-2
 118-744
 621-64-7
11096-69-1
11096-82-5
 100-42-5
  75-01-4
60
10
10
10
10
10
10
 1
 1
 5
10
4.3
              SxlQ'4
              3x10-3
              3xlO-4
              2xlO-4
              5xlO'4
              2X10'3
              2xlO-4e
              2xlO-4
              4xlO'4
              7xlO'4
   a All values in this example are for illustration purposes only.

   k 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 on the August 1989 reference dose for oral exposure, assuming a 70-kilogram
             adult drinks 2 liters of contaminated water per day),

   d Cancer Risk at CRQL or CRDL =  Excess upper-bound lifetime cancer risk (based on the August 1989 slope 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

-------
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 (ug/kg>	
   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.

-------
                                                                                           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 SQLs. 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
characteristics 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

-------
Page 5-12
                                     EXHIBIT 5-4
    CLP LABORATORY DATA QUALIFIERS AND THEIR POTENTIAL USE
                     IN QUANTITATIVE RISK ASSESSMENT
Qualifier     Definition
                                             Indicates:
Uncertain
 Identity?
  Uncertain
Concentration?
Include Data in Quantitative
     Risk Assessment?
Inorganic Chemical Data:"
      B     Reported value is                 No
            IDL.

      U     Compound was analyzed for,       Yes
            but not detected.
                 No
                 Yes
                          Yes
            Value is estimated due to
            matrix interferences.
    No
      Yes
           Yes
      M     Duplicate injection precision
            criteria not met.
    No
      Yes
           Yes
      N     Spiked sample recovery not
            within control limits.
    No
      Yes
           Yes
      S     Reported value was determined     No
            by the Method of Standard
            Additions (MSA).

      W    Post-digestion spike for furnace     No
            AA analysis is out of control
            limits, while sample absorbance
            is  <50% of spike absorbance.

      *     Duplicate analysis was not         No
            within control limits.
                 No
                 Yes
                          Yes
                          Yes
                 Yes
                          Yes
            Correlation coefficient for
            MSA was <0.995.
     No
      Yes
           Yes
Organic Chemical Data:*
      U    Compound was analyzed for,
            but not detected.
     Yes
      Yes
                                        (continued)

-------
                                                                                  Page 5-13

                              EXHIBIT 5-4 (continued)

    CLP LABORATORY DATA QUALIFIERS AND THEIR POTENTIAL USE
                     IN QUANTITATIVE RISK ASSESSMENT
                                             Indicates:
                                      Uncertain      Uncertain     Include Data in Quantitative
Qualifier     Definition                   Identity?    Concentration?       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:0
    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).*
                 Yes
                 Yes
                 Yes
Yes
No
                 Yes
—  = Not applicable

a Source:  EPA 1988d,e.

b Organic chemical data only.

-------
                                                                                                  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

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

            	Concentration (ug/L'j	
   Chemical  Sample 1  Sample 2  Sample 3 Sample 4
   Tetrachioro-
   ethene   14,000 Ja    40     30 Ub
20J
   8 J = The numerical value is an estimated quantity.

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

    Tetrachlorethene  was  detected  in  three of four
   samples at concentrations of 14,000 pg/L, 40 jig/1, and
   20 ug/1; therefore, these concentrations — as well as the
   non-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 (us/L}	
                    Chemical  Sample 1 Sample 2 Sample 3  Sample 4

                    Manganese   310     500 Ra  30 URb   500
                    a R  = Quality control indicates that the data are
                    unusable (compound may or may not be present).

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

                      These data have been validated, and therefore the R
                    qualifiers 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 inorganics.   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-
qualified 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 Inorganics and the SOW for Organics
(EPA 1988b,c)  for laboratory qualifiers, and the
Functional  Guidelines for  Inorganics  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 Inorganics (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 any 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

-------
                                                                                                       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 lie 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 "blind" 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 laboratory 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 all 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 all 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 5-18
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's TCL may be a limited 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
   on the TCL,  the analysis of VOCs and SVQCs may
   indicate the presence of additional organic compounds
   not on the TCL.  These additional compounds are
   shown  by "peaks"  on  the  chromatograms.    (A
   chromatogram 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 analysis 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]

-------
                                                                                          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 eliminate 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.

-------
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

-------
                                                                                             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 all 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.

-------
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
all 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

-------
                                                                                             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

           Rij  = (CV)(T»

   where:

     RIJ  = risk factor for chemical i in
           medium j;

     Ctj  =• concentration of chemical i in
           medium j; and

     T#  = toxicity value for chemical i in
           medium j (i.e., either the slope
           factor or  1/RfD),

-------
Page 5-24
    The units for the risk factor R,y 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.  To
be conservative,  the  concentration used  in  the
above equation should be the maximum detected
concentration determined according to procedures
discussed in Chapter 6, 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
toxicity 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 toxicity 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., Rfy/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,y/Ry 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
         TOTAL CHEMICAL SCORES
     R
       y *   ;/                ...

   where

     Rj -total risk fector for medium j; and

     R^ -f . . . -f Rfj =risk factors for
   chemicals 1 through i in medium j.
significantly to risks, as calculated in subsequent
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.

-------
                                                                              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
Detection0
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.

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

-------
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
(rag/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 Air
(ug/kg) (ug/m5)
100 - 45,000
0.1 - 940
— = Not available.

-------
                                                                                            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 evaluation 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

-------
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.

-------
                                                                                           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.

-------
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 Test 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 calculations.

Environmental Protection Agency (EPA). 1986. Test  Methods for Evaluating Solid Waste (SW-8461:  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 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 Federal 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 Program Statement of Work for Organics Analysis:  Multi-
     media, Multi-concentration.   Office of Emergency and Remedial Response.  SOW No. 288.

     •     Provides procedures 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. Laboratory  Data  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 arsenic ingestion and  arsenic as an essential nutrient.

-------
            CHAPTER 6
 EXPOSURE ASSESSMENT
 FROM:     ^
 • Site discovery
 • Preliminary
  assessment
 • Site inspection
\«NPUisting>
                      Toxicity
                    Assessment
  Data   i   Data
Collection  I Evaluation
    Risk
Characterization
                     Exposure
 TO:
 •Selection of
  remedy
 • Remedial
  design
 • Remedial
.  action
             EXPOSURE ASSESSMENT

           • Characterize physical setting

           • Identify potentially exposed
             populations

           • Identify potential exposure
             pathways

           • Estimate exposure
             concentrations

           • Estimate chemical intakes

-------
                                   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
          Regisuy
    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 ss Subchronic Daily Intake
   SEAM « Superfund Exposure Assessment Manual
   USGS = U.S. Geological Survey

-------
Page 6-2
                                       DEFINITIONS FOR CHAPTER 6

     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 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 an exchange boundary (e.g.,
          gastrointestinal tract) per unit body weight per unit time (e.g., mg/kg-day).

     Applied Dose. The amount Of a substance given to an organism, especially through dermal contact.

     Chronic Daily Intake (CD II. Exposure expressed  as mass of a substance contacted per unit body weight per unit time,
          averaged over a long period of time  (as a Superfund program guideline, seven years to a lifetime).

     Contact Rate. Amount of medium (e.g., ground water, soil) contacted per unit time or event (e.g. liters of water ingested
          per day).

     Exposure. Contact of an organism with a chemical or physical agent. Exposure is quantified as the amount of the agent
          available at the exchange boundaries of the organism (e.g., skin, lungs, gut) and available for absorption.

     Exposure Assessment.  The determination  or estimation (qualitative or quantitative) of the magnitude, frequency, duration,
          and route of exposure.

     Exposure Event.  An incident of contact with a chemical or physical agent. An exposure event can be defined by time (e.g.,
          day, hour) or by the incident (e.g., eating  a single meal of contaminated fish).

     Exposure Pathway,  The course a chemical or physical agent takes from a source to an exposed organism.  An exposure
          pathway describes a unique mechanism by which an individual or population is exposed to chemicals or physical agents
          at or originating from a site.  Each exposure  pathway includes a source or release from a source, an exposure  point,
          and an exposure route. If the exposure point differs from the source, a transport/exposure medium (e.g., air) or media
          (in cases of intermedia transfer) also is included.

     Exposure Point.  A location of potential contact between an organism and a chemical or physical agent.

     Exposure Route. The way a chemical or  physical  agent comes in contact with an organism  (e.g., by ingestion, inhalation,
          dermal contact).

     Intake.  A measure of exposure expressed  as the mass of a substance in contact with the exchange boundary per unit body
          weight per unit time (e.g., mg chemical/kg body weight-day). Also termed the normalized exposure rate; equivalent to
          administered dose.

     Lifetime Average Daily Intake.  Exposure expressed as mass of a substance contacted per unit body weight per unit time,
          averaged over a lifetime.

     Subchronic Daily Intake fSDII. Exposure expressed as mass of a substance contacted per unit body weight per unit time,
          averaged over a portion of a lifetime (as a Superfund program guideline, two weeks to seven years).
validated and the chemicals  of potential concern
have been selected (see Chapter 5,  Section 5.3.3).
The   exposure  assessment  proceeds  with  the
following steps.

      Step 1 -- Characterization of exposure setting
      (Section 6.2).    In  this  step, the  assessor
      characterizes the exposure setting with respect
      to the general physical characteristics of the
      site and the characteristics of the populations
      on   and   near  the   site.      Basic   site
characteristics  such as  climate,  vegetation,
ground-water hydrology, and the presence and
location of surface water are identified in this
step.  Populations also are identified and are
described with respect to those characteristics
that  influence  exposure,  such  as  location
relative to the site,  activity patterns, and the
presence  of sensitive subpopulations.   This
step   considers   the  characteristics  of the
current population, as well as those of any

-------
                                                                  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

-------
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 mechanism 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  6.5).   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 6.6).  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

-------
                                                                                            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 a.lso 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

-------
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
         Rl;

     •   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,

-------
                                                                                               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  exampje,   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 less 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  based  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

-------
Page 6-8
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
         RECEIVING 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.

-------
                                                                                     Page 6-9
                                       EXHIBIT 6-2

                           ILLUSTRATION OF EXPOSURE
                                        PATHWAYS
                                        Prevailing Wind Direction
Exposure
   Point
                                                             Transport
                                                             Medium (Air)
                                                                   Release Mechanism
                                                                   (Volatilization)
Inhalation
Exposure
Route
 'V
                                                 Release
                                              Mechanism
                                                  (Spill)

                                               Exposure
                                                 Medium
                                                  (Soil)
                                                                               Release Mechanism
                                                                               (Site Leaching)
                                                                     Transport Medium
                                                                     (Ground Water)

-------
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
Volatilization
                                   Fugitive dust
                                   generation
Surface wastes — lagoons,
 ponds, pits, spills
Contaminated surface water
Contaminated surface soil
Contaminated wetlands
Leaking drums

Contaminated surface soil
Waste piles
                Surface water
Surface runoff

Episodic overland
flow

Ground-water
seepage
Contaminated surface soil

Lagoon overflow
Spills, leaking containers

Contaminated ground water
                Ground water
Leaching
Surface or buried wastes
Contaminated soil
                Soil
Leaching

Surface runoff

Episodic overland
flow

Fugitive dust
generation/
deposition

Tracking
Surface or buried wastes

Contaminated surface soil

Lagoon overflow
Spills, leaking containers

Contaminated surface soil
Waste piles


Contaminated surface soil
                Sediment
                Biota
Surface runoff,
Episodic overland
flow

Ground-water
seepage

Leaching
Uptake
(direct contact,
ingestion, inhalation)
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

-------
                                                                                            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., convected 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.

-------
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 Koc, 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 (f^), use Kd = K^xfoc. The higher the Kd,
             the more likely a chemical is to bind to soil or sediment than to remain in water.


     K^     provides a measure of the extent of chemical  partitioning between water  and  octanol at
             equilibrium. The greater the K ow the 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 solubility 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 DCF. 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.

-------
                                                                         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?

-------
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,
                            Dispersion
           Potential Release of
             Fugitive Dust/
             Contaminated
           Particles from Site
          Consider Direction and
          Distance of Particulate
          Movement with Wind
            Currents;  Major
         Mechanisms: Wind Speed,
        Particle Size, Gravitational
          Settling, Precipitation
                                           Could
                                        Contaminants
                                       Potentially Reach
                                        Agricultural,
                                         Hunting or
                                        Fishing Areas?
                                      No
                                                 Yes
                                      Consider Transfer
                                      of Contaminants to
                                      Plants or Animals
                                      Consumed by Hu-
                                      mans; Assess Fate
                                       in these Media
  Determine
   Probable
 Boundaries of
   Elevated
 Concentrations
    Identify
  Populations
Directly Exposed
 to Atmospheric
 Contaminants
     Could
  Contaminants
   Potentially
  Reach Surface
    Water?
Consider Transfer
 of Contaminants
to Surface Water;
 Assess Fate in
  this Medium
            Source: Adapted from EPA 1988b.
                                                (continued)

-------
                                                                      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

                                 I






Release to Surface Water 1

! 1
Consider Direction and Rate of Conta
Migration Within Waterbody
Assess Distance Downstream, or Areas of Lake
Major Mechanisms: Currents in Affected Rive
Dispersion in Impoundments: Tidal Currents s
Estuaries; Partitioning to Sedime





minant
s and Estuaries
nd Flushing in
lit
_t
Estimate Surface Water Contaminant Concentrations
Major Factors: Source Release Strength, Dilution Volume

r~




Could Exchange
of Water
Between Surface
Water and
Ground Water
be Significant?
f
No 1

<
r
Yes
i

Consider
Transfer of
Contaminants
to Ground
Water; Assess
Fate in this
Medium


*




Could Water be
Used for Irriga-
tion or Watering
Livestock, or
Does Waterbody
Support
Commercial or
Sport Fish
Population?



t
No 1

'
r
Yes
i


\
Consider
Transfer of
Contaminants to
Plants or
Animals
Consumed by
Humans; Assess
Fate in these
Media


*
Is Contaminant
Volatile?

• <">
ir

Consider
Sediment as a
, Source of
Surface Water
Contaminants

t t
No Yes
i 1
Identify Human
Populations
Directly
Exposed to
Surface
Water
Consider
Transfer of
Contaminants
to Air;
Assess Fate
in this Medium


Estimate
ncentrations
i Sediment


1

Identify Human
Populations
Directly
Exposed to
Sediment
 Source: Adapted from EPA I988b.
                            (continued)

-------
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 Unsaturated
                                            Soils Rased on Soil Permeabilities, Water or Liquid Recharge Rates
                 Release to Ground
                Water Beneath Site
                             Could
                          Contaminants
                            Potentially
                          Reach Ground
                             Water?
Does
Contaminated
Soil Support
Edible Species?

Are Contaminants Vola-
tile? Are Contaminants
in Fine Particle Form or
Sorbed to Particulates?
I I
            Consider Direction and Rate of
              Ground Water Flow Using
            Available Hydrogeologic Data,
            or by Assuming These Will Ap-
            proximate Surface Topography
                                    Ves
 No
        Yes
                   No
                             Yes
     Consider
    Transfer of
   Contaminants
     to Surface
   Water; Assess
    Fate in this
     Medium
                                                      Yes
                              Is Well Water Used for
                             Irrigation or for Watering
                             Livestock, or Could it be?
  Identify
  Human
Populations
  Directly
Exposed to
Well Water
                               JL
                                No
Consider Transfer of Contami-
  nants to Plants or Animals
   Consumed by Humans;
  Assess Fate in these Media
                                            No
                                                       Yes
Could Contaminants
Reach A Surface
Waterbody?
* t
Could Contaminants
Reach Any Wells
Located
Downgradient?
t +
Is Plume Sufficiently Near
Ground Surface to Allow
Direct Uptake of Contami-
nated Ground Water by
Plants or Animals?
                                                                No
                                                                         Yes
Consider Transfer of
  Contaminants to
 Atmosphere: Assess
Fate in this Medium
 Identify Human
  Populations
Directly Exposed
    to Soils
   Source: Adapted from EPA 1988b.

-------
                                                                                           Page 6-17
    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;
     •    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)

-------
Page 6-18
                                       EXHIBIT 6-7
                 MATRIX OF POTENTIAL EXPOSURE ROUTES
Exposure Medium/ Residential Commercial/Industrial Recreational
Exposure Route Population Population Population
Ground Water
Ingestion
Dermal Contact
Surface Water
Ingestion
Dermal Contact
Sediment
Incidental Ingestion
Dermal Contact
Air
Inhalation of Vapor
Phase Chemicals
Indoors
Outdoors
Inhalation of
Particulates
Indoors
Outdoors
Soil/Dust
Incidental Ingestion
Dermal Contact
Food
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

A
A

A
A

A
A



A
A


A
A

A
A


—
—
—
—
"

—
—

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.

-------
                                                                                          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
any estimate of exposure concentration, the upper
confidence limit ("i.e..  the  95 percent upper
confidence limit) on the arithmetic average will be
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

-------
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 I,and Use
        Residents
        Residents
        Industrial
        Workers
        Future Land Use
        Residents
        Residents
Ingestion of ground water
from local wells down-
gradient of the site

Inhalation of chemicals
volatilized from ground
water during home use
Direct contact with
chemicals of potential
concern in soil on the
site
Direct contact with chemi-
cals of potential concern
in soil on the site

Ingestion of chemicals
that have accumulated in
fish located in onsite
ponds
     Yes
     Yes
     Yes
     Yes
                                                         No
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.

-------
                                                                           Page 6-21
                         EXHIBIT 6-9

    GENERIC EQUATION FOR CALCULATING
                  CHEMICAL INTAKES
                 I =  C x CR x EFD  „  1
                           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)

   Variables that describe the exposed population

        CR  =  contact rate; the amount of contaminated medium contacted
               per unit time or event (e.g., 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

-------
                                                                                             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 best
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
evaluating    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

-------
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 characteristics
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)

-------
                                                                                           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 1988b)
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
(ERL) 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

-------
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-steady-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 cases
         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

-------
                                                                                            Page 6-27
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, desorption, 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

-------
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.

-------
                                                                                           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   air
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

-------
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,   stormwater,
         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.

-------
                                                                                            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 (K^).  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 K^ 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
KOH,   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

-------
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 KOH, 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 K^ 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

-------
                                                                                    Page 6-33
                              EXHIBIT 6-10

    EXAMPLE OF TABLE FORMAT FOR SUMMARIZING
                  EXPOSURE CONCENTRATIONS
Populations/Pathways
    Exposure
    Concentration
     Comments
Current Residents
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
 1200 mg/kg

   48 mg/kg

   2 mg/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  case, the
calculated exposure is actually the absorbed dose.
not the amount of chemical that comes in contact
with  the  skin (i.e.,  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., 8.4xlO~4cm/hr].) Note

-------
                                                                                   Page 6-3S
                             EXHIBIT 6-11

        RESIDENTIAL EXPOSURE: INGESTION OF
              CHEMICALS IN DRINKING WATER a
       (AND BEVERAGES MADE USING DRINKING WATER)
     Equation:
                      Intake (mg/kg-day) =  CW \ 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).
a
 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.

-------
Page 6-36
                                      EXHIBIT 6-12

                             RESIDENTIAL EXPOSURE:
            INGESTION OF CHEMICALS  IN SURFACE WATER
                                  WHILE SWIMMING0
             Equation:
                              Intake (mg/kg-day)  = CW x CR x ET x EF x ED
                                                         BW x AT
              Where:
              CW =
              CR  =
              ET  =
              EF  =
              ED  =
              BW =
              AT  =
Chemical Concentration in Water (mg/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 i988b, 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.

-------
                                                                        Page 6-37
                         EXHIBIT 6-13

                 RESIDENTIAL EXPOSURE:
  DERMAL CONTACT WITH CHEMICALS IN WATER"
Equation

Where:
CW =
SA =
PC =
ET =
EF =
ED =
CF =
BW =
AT =
Absorbed Dose tmg/kg-dav) = CW x SA x PC x ET x EF x ED x CF
BWxAT

Chemical Concentration in Water (rag/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)

1










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)

-------
Page 6-38
                                  EXHIBIT 6-13 (continued)

                                RESIDENTIAL EXPOSURE:
               DERMAL CONTACT WITH CHEMICALS IN WATER"
            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 198Sa.  Values for adults presented in EPA I989d 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 198Sa,  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.]
                       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 rale and exposure frequency and duration variables.

-------
                                                                                             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 desorption 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.

-------
Page 6-40
                                      EXHIBIT 6-14

                             RESIDENTIAL EXPOSURE:

                     INGESTION OF CHEMICALS IN SOIL°
            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 (10-6 kg/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 "6 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.

-------
                                                                                          Page 6-41
                                  EXHIBIT 6-15

                        RESIDENTIAL EXPOSURE:
         DERMAL CONTACT WITH CHEMICALS IN SOIL'
     Equation:
                 Absorbed Dose (mg/kg-day) = CS x CF x SA x AF x ABS x EF x ED
                                                        BW x AT
      Where:
      CS  =
      CF  =
      SA  =
      AF  =
      ABS =
      EF  =
      ED  =
      BW  =
      AT  =
   Chemical Concentration in Soil (mg/kg)
   Conversion Factor (10 ~6 kg/ing)
   Skin Surface Area Available for Contact (cm2/event)
   Soil to Skin Adherence Factor (ing/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:

             CF:

             SA:
          Based on site-specific measured value

          10"* kg/mg
             50th Percentile Total Body Surface Area (ma) (EPA 1989d. 1985a)
                          AGE (YRS)

                          3 < 6
                          6 < 9
                          9 < 12
                          12 < 15
                          15 < 18
                          Adult
                               0.728
                               0.931
                               1.16
                               1.49
                               1.75
                               1.94
    FEMALE

    0.711
    0.919
    1.16
    1.48
    1.60
    1.69
             50th Percentile Body Part-specific Surface Areas for Males (m2) (EPA 1989d. 1985a)
             AGE (YRS)
             3 < 4
             6 < 7
             9 < 10
             Adult
                         ARMS
                         0.096
                         0.11
                         0.13
                         0.23
HANDS
 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 198Sa.
Values for adults presented in EPA 1989d or calculated from information presented in EPA 1985a.
a 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 50th percentile values for SA; see text for rationale.
                                   (continued)

-------
Page 6-42
                                EXHIBIT 6-15 (continued)

                              RESIDENTIAL EXPOSURE:
               DERMAL CONTACT WITH CHEMICALS IN SOIL"
            NOTE (continued): Information on surface area of other body parts (e.g., head, feet) and for female
                  children andadults 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 desorption 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 frost-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 rale
            and exposure frequency and duration variables.

-------
                                                                                             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 particulates.
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/nv3)
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 um 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 on 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

-------
Page 6-44
                                        EXHIBIT 6-16
                              RESIDENTIAL EXPOSURE:
       INHALATION OF AIRBORNE (VAPOR PHASE) CHEMICALS
                                                                        ab
             Equation:
                             Intake (mg/kg-day) = CA x IR x ET x EF x ED
                                                        BWxAT
             Where:
             CA  =
             IR  =
             ET  =
             EF  =
             ED  =
             BW =
             AT  =
Contaminant Concentration in Air (mg/m3)
Inhalation Kate (m3/hour)
Exposure Time (hours/day)
Exposure Frequency (days/year)
Exposure Duration (years)
Body Weight (kg)
Averaging Time (period over which exposure is averaged — days)
          Variable Values:


                     CA:

                     IR:
                     ET:
                     EF:
                     ED:
                     BW:
                     AT:
      Site-specific measured or modeled value

      30 nvVday (adult, suggested upper bound value; EPA 1989d)
      20 m3/day (adult, average; EPA 1989d)
      Hourly rates (EPA 1989d)
      Age-specific values (EPA 1985a)
      Age, sex, and activity based values (EPA 1985a)
      0.6 m3/hr — showering (all age groups; EPA 1989d)

      Pathway-specific values  (dependent on duration of exposure-related
        activities)
      12 minutes — showering (90th percentile; EPA 1989d)
      7 minutes — showering (50th percentile; EPA 1989d)

      Pathway-specific value (dependent on frequency of showering or other
       exposure-related activities)

      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 6.6.3 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.

-------
                                                                                      Page 6-45
                                 EXHIBIT 6-17
        RESIDENTIAL EXPOSURE: FOOD PATHWAY —
  INGESTION OF CONTAMINATED FISH AND SHELLFISH*
     Equation:
                       Intake (mg/kg-day) = CF x IR x FI x EF x ED
                                                BWxAT
     Where:
       CF
       IR
       FI
       EF
       ED
       BW
       AT
Contaminant Concentration in Fish (rag/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:




             BW:


             AT:
      Site-specific measured or modeled value

      0.284 kg/meal (95th percentile for fin fish; Pao et al.  1982)
      0.113 kg/meal (50th percentile for fin fish; Pao et al.  1982)

      132 g/day (95th percentile daily intakes averaged over three days
       for consumers of fin fish; Pao et al. 1982)
      38 g/day (50th percentile daily intake, averaged over three days
       for consumers of fin fish; Pao et al. 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)

      Pathway-specific value (should consider local usage patterns)

      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)

      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 6.6.4 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.

-------
Page 6-46
                                      EXHIBIT 6-18

              RESIDENTIAL EXPOSURE:  FOOD PATHWAY —
    INGESTION OF CONTAMINATED FRUITS AND VEGETABLES
           Equation:
                             Intake (mg/kg-day) = CF x IR x FI x EF x ED
                                                       BVVxAT
           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:
                   BW:


                   AT:
  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 (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 6.6.4 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.

-------
                                                                                           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 et al. (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

-------
Page 6-48
                                          EXHIBIT  6-19

                 RESIDENTIAL EXPOSURE: FOOD PATHWAY —
                 INGESTION OF CONTAMINATED  MEAT, EGGS,
                                  AND  DAIRY PRODUCTS"
              Equation:
                                Intake (mg/kg-day) = CF x IR x FI x EF x KD
                                                          BWxAT
              Where:
                 CF  =  Contaminant Concentration in Food (mg/kg)
                 IR   =  Ingestion Rate (kg/meal)
                 FI   =  Fraction Ingested from Contaminated Source (unitless)
                 EF  =  Exposure Frequency (meals/year)
                 ED  =  Exposure Duration (years)
                 BVV  =  Body Weight (kg)
                 AT  =  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 (90th 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).
          a 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.

-------
                                                                                 Page 6-49
                                  EXHIBIT 6-20

         EXAMPLE OF TABLE FORMAT FOR SUMMARIZING
                VALUES USED TO ESTIMATE EXPOSURE
Variable
Range
Midpoint
Value Used
 Brief Rationale
 PCB concentration    ND - 3,500      250
   in soil (nig/kg)               (arithmetic mean)
 Chronic exposure
   (rag/kg)
                            1,400       95th percentile upperbound
                                       estimate of mean concentration
Acute exposure
   (rag/kg)
                            3,500
                            Maximum detected concentration
Adult soil ingestion     0 - 170        17
   rate (mg/d)                (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.

-------
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.

-------
                                                                                         Page 6-51
                                  EXHIBIT 6-21

           EXAMPLE OF AN UNCERTAINTY TABLE FOR
                         EXPOSURE ASSESSMENT

                                                 EFFECT ON EXPOSURE "
          ASSUMPTION
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.
               Moderate
                               Low
   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 "low", 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 affect estimates of exposure by more than
two orders of magnitude.

-------
Page 6-52
                                   EXHIBIT 6-22

           EXAMPLE OF TABLE FORMAT FOR SUMMARIZING
            THE RESULTS OF THE EXPOSURE ASSESSMENT-
                              CURRENT LAND USE*
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
c

0.000013


0.00008
c
c

(CDI) (mc/kg-day)
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 CDI
         and SDI estimates under future land use conditions.

         CDI for noncarcinogenic effects not calculated for benzene because it does not have an EPA-verified
         chronic reference dose (as of the publication dale of this manual).
       c CDI for carcinogenic effects not calculated for chemicals not considered by EPA to be potential human
         carcinogens (as of the publication date of this manual).

-------
                                                                                                              Page 6-53

                                  REFERENCES FOR CHAPTER 6
Baes, C.F., III, Sharp, R.D., Sjoreen, A.L., 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.  82:188-194.

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 Ranges 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  Hazard 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 Register 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.  Selection Criteria for Mathematical Models Used in Exposure Assessments: Surface
     Water  Models.  Office of Health and Environmental Assessment.  EPA/600/8-87/042.

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

Environmental Protection  Agency (EPA).  1988b.  Superfund 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 for Mathematical Models Used in Exposure Assessments: Ground-
     water Models.  Office of Health and Environmental Assessment.  EPA/600/8-88/075.

Environmental Protection  Agency (EPA).  1989a.  Air Superfund 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.

Environmental Protection  Agency (EPA).  1989b.  Air Superfund 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 Superfund National Technical Guidance Series. Volume IV: Procedures for
     Dispersion Modeling and Air Monitoring for Superfund Air Pathway Analysis.  Interim Final. 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.  Proposed Amendments  to the Guidelines for the  Health Assessment of Suspect
     Developmental Toxicants.  54 Federal Register 9386 (March 6, 1989).

-------
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,  C.H.   1973.   Long-term Studies of Residue Retention and Excretion by Cows Fed a
     Polychlorinated Biphenyl (Aroclor 1254).  J. Agric. Food Chem.  21:117-121.

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

Jensen, D.J., Hummel, R.A., Mahle, N.H., Kocher, C.W., and Higgins, H.S.  1981. A Residue Study on Beef Cattle Consuming 2,3,7,8-
     Tetrachlorodibenzo-p-dioxin.  J. Agric. Food Chem. 29:265-268.

Jensen, D.J.  and Hummel, R.A.  1982. Secretion of TCDD in Milk and Cream Following the Feeding of TCDD to  Lactating Dairy
     Cows.  Bull. Env. Contam.  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-Milk 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.S., and Thompson,  S.E.  1979. Transfer  Factors for Assessing the Dose from Radionuclides in  Agricultural
     Products.  Biological Implications of Radionuclides Released From Nuclear Industries.  In:  Proceedings of an International
     Symposium on Biological Implications of Radionuclides Released from Nuclear Industries.  Vienna.  March 26-30,1979.  IAEA-
     SM-237/54.  Vol.  II.

Ng, Y.C., Colsher, C.S.,  and Thompson, S.E. 1982. Transfer Coefficients for Assessing the Dose from Radionuclides in Meat and Eggs.
     Lawrence Livermore National Laboratory.  NUREG/CR-2976.

Pao, E.M., Fleming, K.H., Gueuther, P.M., and Mickle, SJ. 1982.  Food Commonly Eaten by Individuals: Amount Per Day and Per
     Eating Occasion.  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, C.C.  and Arms,  A.D.  1988. Bioconcentration of Organics in Beef, Milk, and Vegetation. Environ. Sci. Technol.   22:271-274.

Van Bruwaene, R., Gerber, G.B., Kerchmann, R., Colard, J. and Van Kerkom, J. 1984. Metabolism of 51Cr, 54Mn, 59Fe and 60Co
     in Lactating Dairy Cows.  Health Physics 46:1069-1082.

-------
                              CHAPTER 7

                    TOXICITY ASSESSMENT
/FROM:     "
 •Site discovery
 • Preliminary
  assessment
 •Site inspection
\»NPL listing ^
  Data
Collection
                                        ToxicHy
                                      Assessment
i   Data
! Evaluation
    Risk
Characterization
                                        Exposure
                                       Assessment
 •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

-------
                                     CHAPTER?
                       TOXICITY ASSESSMENT
    The purpose of the toxicily 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 lexicological
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 lexicologist.  This
chapter provides step-by-slep guidance for localing
EPA  loxicily  assessments   and  accompanying
values, and advises how lo deiermine which values
are mosl appropriale when multiple values exist
Prior lo Ihis procedural  discussion,  background
        ACRONYMS FOR CHAPTER 7
   ADI *=
   AIC =
   A1S =

CRAVE =

 ECAO =

  HAD =
  HEA =
HEAST =

 HEED =

 HEEP =

   IRIS =
LOAEL =
NOAEL =
 NOEL =
   RfD =
            Acceptable Daily Intake
            Acceptable Intake for Chronic Exposure
            Acceptable Intake for Subchronic
            Exposure
            Carcinogen Risk Assessment
            Verification Endeavor
            Environmental Criteria and Assessment
            Office
            Health Assessment Document
            Health Effects Assessment
            Health Effects Assessment Summary
            Tables
            Health and Environmental Effects
            Document
            Health and Environmental Effects
            Profile
            Integrated Risk Information System
            Lowest-Observed-Adverse-Effect-Level
            No-Observed-Adverse-Effect-Level
            No-Observed-Effect-Level
            Reference Dose (when used without
            other modifiers, RfD generally refers to
            chronic reference dose)
            Developmental Reference Dose
            Subchronic Reference Dose

-------
Page 7-2
                                            DEFINITIONS FOR CHAPTER 7

   Acceptable Daily Intake (ADIV 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 fAIC). An estimate similar in concept to the RfD, but derived using a !ess strictly
        defined methodology.  Chronic RfDs have replaced AICs 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 CAISt.  An estimate similar in concept to the subchronic RfD, but derived using a
        less strictly defined  methodology.  Subehrome  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  fRtDV 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. Chronic 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 (RfDj;).  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 Evaluation.  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
        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 (IRISV  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-Observed-Adverse-Effect-Level (LOAELV 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 (NOABU).  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 CNOBL).   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 (RfD>.  The Agency's preferred toxicity 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 generically to  all types of RfDs or specifically to chronic RfDs; it  never
        refers specifically  to subchronic or  developmental RfDs.
                                                           (continued)

-------
                                                                                                 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.

   Subchronic Reference Dose (RfD,). 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 portion of a lifetime (as a Superfund program guideline, two weeks to seven years).

   Toxicitv Value.  A numerical expression of a substance's dose-response relationship that is used in risk assessments.  The most
       common toxicity values used in Superfund program risk assessments are reference doses (for noncarcinogenic effects) and
       slope factors (for carcinogenic effects).

   Weight of Evidence 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 lexicological 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 contaminant  to  cause  adverse
health effects (carcinogenic and noncarcinogenic)
in humans.  These sources may  include controlled
epidemiologic investigations, 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.

-------
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

-------
                                                                                           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

-------
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, noncarcinogenic
   effects of chronic exposures were evaluated using values
   called acceptable daily intakes (APIs') or acceptable
   intakes for chronic exposure (AICsV 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
   (AISs) 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 (RfD^s'), 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 the 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 the 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 RfD
(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 (RfD0)

     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

-------
                                                                                               Page 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-lever
(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 lexicological significance. In
some studies, only LOAEL rather than a NOAEL
is available.  The  use  of  a LOAEL,  however,
   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 prevented,
   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.
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

-------
Page 7-8
applicable uncertainty  factors and the modifying
factor.  That is:

     RfD = NOAEL or LOAEL/(UF7 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   physicochemical
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
physicochemical 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 physicochemical 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 respiratory tract or,  if the
contaminant  can  be  absorbed  and  distributed
through  the body,  some  extrarespiratory 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
physicochemical 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.,
ventilatory  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/m5 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 m3/day are used to convert between an
inhaled intake expressed in units of mg/kg-day and
a concentration in air expressed in mg/m5.

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

-------
                                                                                             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 RfDs is 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 (RfDA)

     In developing an RfD^r, 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 RfD^t is 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,  RfD^,  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 RfD^ 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

-------
Page 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 based 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 doses to toxicity values expressed
   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.

-------
                                                                                             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 weight-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
     B2
            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
            humans
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.

-------
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  consistency
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/kg-day,
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 particulates 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)"^.  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.)

-------
                                                                                          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   m3/day)   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
                    20m3/day x 10'3

    water unit risk = risk per ug/L
                   = slope factor x 1/70 kg x
                     2L/day x 10'3

The multiplication by  10~3 is necessary to convert
from  mg  (the slope factor, or q/, is given in
(mg/kg-day)";) to ug  (the  unit risk is given in
       -1 or (ug/L)-r).
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

-------
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) RiDs 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 requestors 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

-------
                                                                                                Page 7-15
                             HIERARCHY OF TOXICITY INFORMATION

     Because toxicity informatioa 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 it values are 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 information 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 information could not be found in IRIS or HBAST.  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
physicochemical  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 lexicological 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
      NONCARCINOGENIC 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

-------
Page 7-17






r- —
E-
U
U
U
^•N
Z
11
H£
^ ^
s tf
si
rv. *C
O
s§
33 i-!
< 3
H P
fa Z
O U
si
OH ^
^^; • •
5 CA
S w
S3
g
£
h-«
U
R
o
H






« T3
S-dS
•i °°
ft
jjj "2
O 3




»g
ffl 1
ii



II


i%
1




It
U oo
If
u "-•



's
1
w
u
1 ^ ^-

o ^f o %*
S- E - 2" x «
u u ii ii
U, U. [L, U.
D 2 D S




£ n from LOAEL to
S «
1.8.
2 E
BB
u u
CO J








-------
Page 7-18
                                   EXHIBIT 7-3

                      EXAMPLE OF TABLE FORMAT FOR
        TOXICITY VALUES:  POTENTIAL CARCINOGENIC EFFECTS
    Chemical
Slope Factor (SF)      Weight-of-Evidence      Type of
   (mg/kg-day)';         Classification         Cancer"
                            SF Basis/
                            SF Source
    Oral Route

     Benzene


     Chlordane


    Inhalation Route
       0.029*
       1.3*
B2*
              Leukemia
Water6/
IRIS

Water6/
IRIS
    * Values for illustration only.

    a Identify type(s) of cancer in this table for Class A carcinogens only.

    * Slope factor based on administered dose in drinking water and assumed absorption fraction of 1.0.

-------
                                                                                            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  consistency 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.

-------
                                                                                                         Page 7-21


                                   ENDNOTES FOR CHAPTER 7



1. The MF is set less than one for a small number of substances 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 represent a 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 most
valuable aspects of IRIS.

-------
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).  19865.  Guidelines for the Health Assessment of Suspect Developmental Toxicants.  51
     Federal Register 34028 (September 24, 1986).

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 Priority 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. Guidelines 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).

Environmental Protection Agency (EPA). 1989f. Reference Dose (RfDI: 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. IARC 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 Review 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
   . 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

           • Quantify risks from multiple
            chemicals

           • Combine risks across exposure
            pathways

           • Assess and present uncertainty

           • Consider site-specific human
            studies
TO:
•Selection of
 remedy
• Remedial
 design
• Remedial
 action

-------
                                    CHAPTERS
                    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 following
development  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 - Applicable or Relevant and Appropriate
           Requirement
   ATSDR« Agency for Toxic Substances and Disease
           Registry
     COI - Chronic Daily Intake
   ECA0 = Environmental Criteria and Assessment
           Office
       E = Exposure Level
      HI " Hazard Index
     IRIS = Integrated Risk Information System
  LOAEL = Lowest-Observed-Adverse-Effect-Level
  NOAEL = No-Observed-Adverse-Effect-Level
     NRC = Nuclear Regulatory Commission
     RfD = Reference Dose (when used without
           other modifiers, RfD generally refers to
           chronic reference dose)
    RfD
-------
Page 8-2
                                          DEFINITIONS FOR CHAPTER 8

    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
        the body per unit body weight per unit time (e.g., mg/kg-day).

    Administered Dose.  The mass of substance given to  an organism and in contact with aiv exchange boundary (e.g,,
        gastrointestinal tract) per unit body weight per unit time (e.g., mg/kg-day).

    Chronic Reference Dose (RED).  An estimate (with uncertainty spanning perhaps an order Of magnitude or greater) of a daily
        exposure level for the Iranian population, including sensitive subpopulations, that is likely to be without an appreciable risk
        of deleterious effects during a lifetime. Chronic RfDs are specifically developed to be protective for tong-iertn exposure
        to a compound (as  a Superfund program guideline, seven years to lifetime).

    Developmental Reference Dose (RfD,^). An estimate (with uncertainly 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 development effects.  Developmental RfDs are used to evaluate the effects of a single exposure event.

    Exposure.  Contact of an organism with a chemical or physical agent.  Exposure is  quantified as the amount of the agent
        available at the exchange boundaries of the organism (e.g., skin, lungs, gut) and available for absorption.

    Exposure Assessment. The determination or estimation (qualitative or quantitative) of the magnitude, frequency, duration, and
        route of exposure.

    Exposure Pathway,  The course a chemical or physical agent takes from a source to an exposed organism.  An exposure pathway
        describes a  unique  mechanism by which an individual or population is exposed to chemicals or physical agents at of
        originating from a site.  Each exposure pathway includes a source or release from a source, an exposure point, and an
        exposure route.  If the exposure point differs from the Source, a transport/exposure medium (e.g., air) or media (in cases
        of intermedia transfer) also  is included,

    Exposure Route.  The way a chemical or physical agent comes in contact with an organism (e,g,, by ingestion, inhalation, dermal
        contact).

    Hazard Index (HI}. The sum  of more than one hazard quotient for  multiple substances and/or multiple exposure pathways.
        The HI is calculated separately for chronic, subchronic, and shorter-duration exposures.

    Hazard Quotient. The ratio of a single substance exposure level over  a specified time period (e.g., subchronic) to a reference
        dose for that substance  derived from a similar exposure period.

    Intake.  A measure of exposure  expressed as the mass of a  substance in  contact with the exchange boundary per unit body
        weight per unit time (e.g., mg chemical/kg body weight-day).  Also termed the normalized exposure rate; equivalent to
        administered dose,

    Integrated Risk Information System flRIS).  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.

    Reference Dose CRiDV   The Agency's preferred toxicity value for evaluating noncarcinogenic effects result 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.

    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.
    Subchronic Reference Dose fRfD^. 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 portion of a lifetime (as a Superfund program guideline, two weeks to seven years).

    Weight -of-Evidencfe Classification.  An  EPA classification  system  for characterizing the extent to which  the available data
         indicate thai an agent is a human carcinogen.  Recently, EPA has developed weight-of-evidence classification systems tor
         some other kinds of toxic effects, such as developmental effects.

-------
                                                                              Page 8-3
                             EXHIBIT 8-1

               STEPS IN RISK CHARACTERIZATION
   Step 1: Organize Outputs of
Exposure and Toxicity Assessments
     •   Exposure Duration
     •   Absorption Adjustments
     •   Consistency Check
  Step 2: Quantify Pathway Risks
  For Each Substance, Estimate:
     •  Cancer Risk
     •  Noncancer Hazard Quotient
  For Each Pathway, Calculate:
     •  Total Cancer Risk
     •  Noncancer Hazard Index
 I                         1
 .   Exposure Assessment   .
~"      Intake Estimates
 |	|
J    Toxicity Assessment    '
 |      Toxicity Values      I
 i	j
                    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
 Step 6: Summarize Results of the
 Baseiine Risk Assessment
 I       Identify ARARs
 i	.	

 I
      Develop Preliminary
      Remediation Goals

-------
Page 8-4
routes and relevant  substances).  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 same time period.
    For  each chemical or substance  evaluated  in
the toxicity assessment, use the checklist provided
in the box below  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
     TOXICITY INFORMATION NEEDED
       FOR RISK CHARACTERIZATION

   «   Slope factors for all carcinogenic chemicals.

   •   Discussion of weight of evidence and classifications
       for all 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).

   •   Critical effect associated with each RfD.

   •   Discussion of uncertainties, uncertainty  factors,
       and modifying factor used in deriving each RfD
       and "degree of confidence" in  RfD (i.e., high,
       medium, low),

   •   Whether the toxicity values are expressed  as
       absorbed or administered doses.

   •   Pharmacokinetic  data  that may  affect  the
       extrapolation from animals to humans for both
       the RfD and slope factor.

   •   Uncertainties in any route-to-route extrapolations.
estimates correspond as closely as possible with
the assumptions used  in  developing the toxicity
values.

   Averaging period for exposure.  If the toxicity
value is  based on average lifetime exposure (e.g.,
slope factors), then  the exposure duration  must
also be expressed in  those terms.  For estimating
cancer risks, always use average lifetime exposure;
i.e.,   convert   less-than-lifetime  exposures  to
equivalent  lifetime  values   (see  EPA  1986a,
Guidelines for Carcinogen Risk Assessment).  On
the   other   hand,   for   evaluating   potential
noncarcinogenic   effects   of.  less-than-lifetime
exposures, do not compare chronic RfDs to short-
term exposure  estimates, and do   not convert
short-term exposures to equivalent lifetime values
to compare with the chronic  RfDs.   Instead, use
subchronic or  shorter-term  toxicity  values  to
evaluate short-term  exposures.   Check that the
estimated exposure duration is sufficiently similar
to the duration of the  exposure in the study used
to identify  the toxicity value  to be  protective of
human  health (particularly  for subchronic and

-------
                                                                                             Page 8-5
shorter-term effects). A lexicologist 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 RfD 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
     AND ASSESSMENT OFFICE (ECAO)
          TECHNICAL ASSISTANCE

                FTS 684-7300

                 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 risks associated with
dermal  exposure to the substance. At this time,
EPA considers it appropriate only to  extrapolate
dermal toxicity 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.   See Section 7.5.1 for  additional
information.

   Inhalation RfD,- values obtained  from IRIS
will   usually  be  expressed  as  ambient  air
concentrations  (i.e.,   mg/m5),   instead   of  as
administered doses (i.e., mg/kg-day).   It may be
necessary, therefore, to calculate the RfDi in 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
RfD,-  in  mg/m5 multiplied by 20 m3 air 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
      administered-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   absorption
      efficiencies   based  on  the  medium  of
      exposure (e.g., food, soil, or water for oral
      exposure,   water  or   particulates  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

-------
Page 8-6
       reasonable or conservative estimate of risk.
       See Appendix A.


8.2    QUANTIFYING RISKS

   This section describes 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 procedures  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 Carcinogen 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 test 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 box below.
        LINEAR LOW-DOSE CANCER
              RISK EQUATION
            Risk = CDI x SF
   where:
     Risk —  a unitless probability (e.g.,  2 x
             1Q~5) of an individual developing
             cancer;

     CDI =  chronic daily intake averaged over
             70 years (mg/kg-day); and

     SF  =  slope factor, expressed in (mg/kg-
   The CDI is identified in Exhibits 6-11 through 6-19 and
   6-22 and the SF is identified in Exhibit 7-3.
   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  upper-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

-------
Page 8-7






!/j
H
>n
s
tt
c/2

U
52
•fl
r^i ^j
OQ ^
H 0
pj *
£ H

td §
3
0



j
-,
CO
u.1
1/3 1
o &1
5*|



Chemica



























u
a
Z
I
;estion of Contaminated Private

b
3

"b "to
^ A
t. X
S w
^ >
1 1

«
E
1
3


ft
* (S]
< CO





*
C~l *
o —
* ft
m 10
6 ci


u
1 'H
1 £
O iC
B3 U































;estion of Contaminated Fish
c

t
£
s
&




^
b
K

Is
3

u
Cfl
^
i







»
oa





.
2
o
tt
C3



e
1
_o
6


"b
i—i
m









v
m
B
e
I
f
a.
c
V
'§
'o
£

i

.!S
t-i
u
u
B
(3
S
C
e
.2
"3
o.
o
OL,
is
1
•o
1
S



2
i
1"
S Q
i .a
||
55 n
n _
338




2 s
ol
B M
5 •*
5 -S
ll
B-8
Is
i 2
"S _g
• S 2
>,-^


Sk( "
3 ^ &0
|« II
in only.
er in this table for Class A carci
ild be expressed as one significar
A dose administered in drinking
' evidence for carcinogens contril
.2 g g o o

S 3 "> 15 ,c
| -s 

-------
Page 8-8


CM
1
^J
iCn
C
p^
t^o
Ed

X
£
*"*
^j
j^
53
^
N
N^
ffi
^^
^4
EXHIBIT 8-3
FOR CHRON
H
^f'
M
S
O
fe
s
tt
•«t!
^•^
^
fe
O
w
3
ON
1
W





U
f3 ill
£ £
H|
PW

 §8
o do




0 00
Z Z Z

» *
T-l f^)
d do
S
g u
"5 -o H
g § g
S z o"

































fS
fi

1

c
1

(M
o
I
1
1"
CQ
BL,
5





^
d




r-H T-.
d d

* *
1-* 1^

^
-J
CO CO
< -

*
i §
d d

1 tt
w UJ
£ 2



^
d






















s
•o
•H
a
I
u
"S
g
6
•g
o

J
>
£
c
B
_O
"3
CM
£
1
s
•a
8
o:
S1"

.
"8 e5
a a.2
'C .„ ra
g a ' >,
ilfii §
^ 2 ° g S o Q
O C T3 E -^
t 2 °-s| 11
o S g ^.E. — g
u **- ^ — "^ >> ^
^ •- 00,0 ^ '« *0
c^ C "a 'r; c *~
•r •— ^ v 'TO u °
~ M 73 S" = 's 'a
2 05 'S c 3 u U
II II II
1 se
21 u a



J JS
U ob
< S
§ •
o X
•g J
I . |Si I
g E « O -3
ig o Z S
if ^lij :

g S .S g 2 1 1 5
| o 1 |1 §• §• S
s§s >«BS |
III "1 II II II g
< X < to -I U

2 1
3 'S
5 • .> ^2
•S ^ 8 o
C W3 ^ O CU
S O * C 2 eo
a) U • •— " O . *O t?
.— £• ^ ,O O« U V o

f
§ 1 « .a 1 -o | S 3f
'= WSx&,S«El5
« wSw^N^ju
1 ^ gl £^ ^ ~-l
S Hil3.i|tf
"! o_ G ra x 2 oj
> ^^ScofiDE"
• « -O U "«

-------
Page 8-9


73
H
5
?^J
H


^^
X
Q
g

§
N

«

U
HH
z
Tf O
• &
t! K
fe u
« «
NN P
S w
B 05
W 0
b
H
5J
^
CS
o
fa

j
^H

fa
O
EXAMPLE

u
"3 5 <5 ^<
i§ jjLJ |
^
11 Is
*•* {g "O
0, ft «
a
c
"2 .1
N O
xa
QO
is
•a o

If
« « E
ill
C -a
a <
t/i
i "o1
CQ -3
it
||
«•?
es
O5 "S)
C
" — '
o G
o
-S&
HI

^_^
a"
5 £?
S
Chemical (mg/1






















ra
.2
§
O

•o
I
x:
u
VI
I
c
1
2
c
5
"3
c
o
I
jr
&
2
u





^.
o



O C-l o O
O O C5 O

« "1 » »


* * »
^ ^ ^

s x a: x


4 4 4
» 0 0 T3
1 I I 1
tn LU en uJ
I I I X
CO 2 0 «3 5" ^
Z R- S Z > •§
U a « CJ j 2

» ro
* Q S *
•O w 5j ^
o dec


8 S 8 o
>* >< >^ 2



» S
d d ci cJ
! i s
£P cs d
« jj u



-CJ
d



















"O
c

s
P3

Llbchronic
w
„„
S
£
earby Elementary Schoolyard -
Z

« o c
°i< o B 3
<||i J
w 2 "° if 2g
S S ^3 ^ c
t! « 8 S i- S
2 o. § •& '» t3
a 2 ^ 'S Q o:
(fl ta C W
^ u O -^ £ 0 <->
M O _ "3 C '£ 'c
flfll 11
u u u
, ) vi
1 °e






« tu
c - <
2 c O
E u g
if >. § 2
< f :1 1 J
111 i SB
2 u 1 e a-f
85" § c g
c •*« •S S « K
D •§ o _g E *
j; 3 'S .S •= .0
^ o g c 2 «
|=1 |H
'> o "& 2 i «
U •"• IJ ^ C9 QJ
^ CO "c II I] II
g d, a " u II
< X < -1


2
o
f ^
« 1 -
c « -5
.2 2 " S S. "

i-^s |g ^
Values for illustration only.
All hazard indices and hazard
be expressed as one significan
If hazard index is greater than
Section 8.2.2 for guidance on
segregation of hazard index b>
RfDs expressed as administere
* "a us u

-------
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 feast two summary tables generally would  be required: one for current land uses  and one for future land uses.  In the
   example provided in Exhibit 8-2, 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 chlordane and ingestion of
   fish contaminated with chlordane.  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 (GDI), averaged over a  lifetime, 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 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 an absorption fraction of 1.0 was used as a conservative assumption.  If, for example, available data had indicated
   that only 10 percent of chlordane ingested with fish is absorbed, the GDI could have been adjusted downward to 0.000008 mg/kg-
   day (i.e., 0.00008 mg/kg-day x 0.10 absorption fraction).

       Values for  the slope factors (SF), weight-of-evidenee 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 and SF using the linear low-dose cancer
   risk equation (risk = GDI 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 total 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 of 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 ethyl ketone (MBK).  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 (GDI), 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
   absorption efficiency because the RfDs for these substances are based on ingestion  in water and an absorption fraction of 1.0.
   The GDI for phenol and MEK  in fish was not adjusted for vehicle of exposure (i.e., food versus water) because absorption
   efficiency data were limited, and an absorption fraction of 1.0 was used as a conservative assumption.  If, for example, available
   data had indicated that only 20  percent of MEK ingested with fish is absorbed, the GDI for MEK could have been adjusted
   downward to 0.001 mg/kg-day (i.e., 0.005 mg/kg-day x 0,20 absorption efficiency).

      Values for the RfDs, confidence level in the RfD, critical effect, source of the value, and basis  of the RfD (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 GDI 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 the hazard indices for the two exposure pathways.

      Note that it is important to include the noncarcinogenjc 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;

      CDI  = chronic daily intake averaged
             over 70 years (mg/kg-day); and

      SF   = slope factor, in (mg/kg-day)"7.
potential for noncarcinogenic effects is evaluated
by comparing 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

     Noncancer 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 typically range in duration from
two weeks to seven years 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
sources by  more  than one exposure pathway.

-------
Page 8-12
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
                Riskr =  S Risk,-
   where:
     Riskj = the total cancer risk, expressed
              as a unitless probability;  and

     Risk/ = the risk estimate for the  ith
              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 carcinogenicity 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,
and should be considered in consultation with the
RPM (e.g., Arcos et al.  1988).  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

-------
                                                                                           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 = E1fRfD1 + E2/RfD2 + ...
                   + E;/RfD;

   where:

     E,     —  exposure level (or  intake)  for
               the ith toxicant;

     RfD/  =  reference diose for  the i*
               toxicant; and

     E and RfD are expressed in  the same
     units and represent the same exposure
     period (i.e., chronic, subchronic, or
     shorter-term).
   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.
                    CHRONIC NONCANCER HAZARD
                                 INDEX

                 Chronic
                 Hazard Index s= CDI;/RfD7 + CDI2/RfD2
                                 4- ... + CDtyRfD;

                 where;

                   CDI,- = chronic daily intake for the \th
                           toxicant in mg/kg-day, and

                   RfD,- = chronic reference dose for the
                           f* toxicant in mg/kg-day.
                 The CDI is identified in Exhibits 6-11 through 6-19
                 and 6-22 and the RfD is 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 subchronic
   daily  intake  (SDI)  to  the  subchronic
   reference  dose  (RfDJ   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

-------
Page 8-14
         SUBCHRONIC NONCANCER
              HAZARD INDEX
   Subchronic
   Hazard Index ~
                   + ... +
   where:
     SDI/  ss subchronic daily intake for the
              Ith toxicant in mg/kg-day; and
           = subchronic reference dose for
              the ith toxicant in mg/kg-day.
       effects following exposures of only a few
       days.    See  Guidelines  for  the Health
       Assessment  of  Suspect  Developmental
       Toxicants  (EPA 1986c;  EPA 1989)  for
       further guidance.

   There are several limitations to this approach
that must be acknowledged. As mentioned earlier,
the level of concern does not increase linearly as
the reference  dose is approached or  exceeded
because the RfDs do  not have equal accuracy  or
precision  and are not based on the same severity
of  effect.   Moreover,  hazard quotients  are
combined  for substances  with  RfDs based  on
critical effects of varying lexicological significance.
Also, it  will often be the case  that  RfDs  of
varying levels of confidence that include different
uncertainty adjustments and modifying factors will
be combined (e.g., extrapolation from animals  to
humans,  from LOAELs to  NOAELs, from one
exposure  duration to  another).

   Another  limitation with  the hazard index
approach is that the assumption of dose  additivity
is most   properly applied  to  compounds  that
induce the same effect by the same mechanism of
action.  Consequently, application of the hazard
index equation to a number of compounds  that
are not  expected to  induce the same type  of
effects or that do not act by the  same mechanism
could  overestimate   the  potential  for effects,
although  such an approach is appropriate at a
screening level.  This possibility is generally not
of concern  if only one or two  substances are
responsible for driving the HI above unity. If the
HI  is  greater than unity as a  consequence  of
summing several hazard quotients of similar value,
it  would  be   appropriate  to  segregate  the
compounds by effect and by mechanism of action
and  to derive separate  hazard indices for each
group.

   Segregation of hazard indices.  Segregation  of
hazard indices by effect  and mechanism of action
can be complex and time-consuming because it is
necessary to identify all of the major effects and
target  organs for  each chemical and  then  to
classify the chemicals according to target organ(s)
or mechanism  of  action.  This  analysis  is not
simple and should be performed by a toxicologist.
If  the  segregation is  not carefully done,  an
underestimate of true hazard could result.  Agency
review of particularly complex or  controversial
cases can be  requested  of ECAO through the
regional risk assessment support staff.

   The procedure  for  recalculating the  hazard
index by effect  and by  mechanism of action  is
briefly described in the box on the next page.  If
one  of the effect-specific hazard  indices  exceeds
unity,  consideration of the mechanism of action
might  be warranted.  A strong case is required,
however, to indicate that two compounds which
produce adverse effects on the same organ system
(e.g., liver), although by different mechanisms,
should not be treated  as dose additive.  Any such
determination should  be reviewed by ECAO.

   If  there are specific data  germane   to the
assumption   of dose-additivity  (e.g.,   if  two
compounds are present  at the same site and it is
known that the combination is five times more
toxic than  the  sum  of  toxicities  for  the  two
compounds), then modify the development of the
hazard index  accordingly.   Refer  to  the EPA
(1986b) mixtures guidelines for discussion of a
hazard  index   equation   that   incorporates
quantitative interaction data.  If data on chemical
interactions are available, but are not adequate to
support  a  quantitative  assessment,  note  the
information   in   the   "assumptions"   being
documented for the site risk assessment.

-------
                                                                                              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 neurotraricity,
   developmental   toxicity,   reproductive  toxicity,
   immunotoxicity, and adverse effects by target organ (i.e.,
   hepatic,   renal,   respiratory,   cardiovascular,
   gastrointestinal, hematological, musculoskeletal, 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 independent 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 be 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
from 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/)
.... -f
   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 (i.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

-------
                                                                                            Page 8-17
      HAZARD INDEX EQUATION FOR
           MULTIPLE PATHWAYS

   Total Exposure Hazard Index =

   Hazard Index(exposure pathway;) +
   Hazard Index(exposure pathway2) -f	
   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-uses,  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
               UNCERTAINTIES

   •   For chemicals not included in the quantitative 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 the selection of exposure
       pathways considered to contribute to exposure of
       the same individual or group of individuals over
       the 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 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

       List/summarize the key model assumptions.

       Indicate the potential impact  of each on risk:

       - 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 certainly 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

-------
                                                                                Page 8-21
                                    EXHIBIT 8-5

     EXAMPLE OF PRESENTATION OF IMPACT OF EXPOSURE ASSUMPTIONS

                           ON CANCER RISK ESTIMATE
                    digestion of Fish Contaminated with Chemical X

                             (30 mg X/Kg Fish Wet Weight)
XL
co
ir
k_
CD
O
c
CO
O
CD

'•^
CD
CO
en
CD
O
X
LLI
O
_Q
i_
CD
Q.
Q.
    164'5J
    165° J
    165'5-J
                  10
20        30        40


        Grams/Person/Day
50
60
                           	Fillet with Skin
                          Fillet Only
           The risk of developing cancer is plotted on a log scale. A risk of 10~4indicates a probability

           of 1 chance in 10,000 and a risk of 10'5indicates 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 all 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, 95th).

   •   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/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 additivity ignores possible
synergisms or  antagonisms among chemicals, and
assumes similarity in mechanisms  of action and
metabolism.  Unfortunately, the data available 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-additivity
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

-------
                                                                       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 -
X
0)
_c
•9
I
  0.5 -
              10        20        30        40

                              Grams/Person/Day
    50
60
                      	Fillet with Skin
Fillet Only

-------
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 the 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 final 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

-------
                                                                                           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  10~4 to
       10"7 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
based  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.

-------
                                                                           Page 8-27
                                 EXHIBIT 8-7
EXAMPLE OF PRESENTATION OF RELATIVE CONTRIBUTION OF INDIVIDUAL

CHEMICALS TO EXPOSURE PATHWAY AND TOTAL CANCER RISK ESTIMATES
_
co

tr
i_
CD
O

rt
O

CD

E
10-H
 a 10"°-
 CO
 CO
 CD
 O
 X
111

T3
10-H
   10-H
 .
 CD
 Q.
 a.
10-H
    10
      -7
                          Nearby Resident Population

                      Excess Lifetime Cancer Risk <  3 x 10~4
                 Public Water Supply
                 < 2x10'
           - !•

           - >  
-------
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
                         Nearby Resident Population
                          Chronic Hazard Index = 0.6
    1.1 -

     1 _

    0.9 _

    0.8 _
  x
  •D 0.7 _

  "S 0.6 _

  I 0.5 _

    0.4 _

    0.3

    0.2 _

    0.1 _
                                            Phenol
                                            Nitrobenzene
                                            MEK
 Well Water
*™5s%8fe *""
                 Contaminated Fish
                                                        Swimming
                                 Exposure Pathway

-------
                                                                                                           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 carcinogens.  For two carcinogens, the precise equation for estimating this probability is risk} + risk2 -
probability (risk}, risk2) 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 (riskj)(risk2). This equation
can be expanded to evaluate risks from more than two substances.

-------
Page 8-30

                                   REFERENCES  FOR  CHAPTER 8
Arcos, J., 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. J., Gardner, R. H., and Hoffman, F. O. 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).

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

Environmental Protection Agency (EPA).  1986c.  Guidelines  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 9386 (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 8:71-90.

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 Regulatory 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.

Vesely, W.  E. and D. M. Rasmuson. Uncertainties in Nuclear Probabilistic Risk Analysis. Risk Analysis 4:313-322.

-------
                                 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 results 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., IB a
         glossary); and

         use a standard quantitative system - preferably
         the metric system -- throughout and Units that
         are the same Mvnere possible (e.g., ugft, for all
         water concentrations).
   Avoid:
         the use of large blocks of text uiibrblcen by
         any headings, graphics, tables, lists, or other
         'Visual dividers";

         the  presentation  of  much  quantitative
         infonaation within the text (rather than in
         tables); 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  for   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 I988a)
     (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

-------
                                                                                              ee9-3
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?

-------
Page 9-4
                                       EXHIBIT  9-1
   SUGGESTED OUTLINE FOR A BASELINE  RISK ASSESSMENT REPORT
1.0  INTRODUCTION

    1.1 Overview
        •  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)

-------
                                                                                        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)

-------
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 TOXICITY 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)

-------
                                                                                         Page 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)

-------
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 objectivef'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 (DQO) statement provided?  (HHEM - 4.1.4)

           - a statement specifying both the qualitative and quantitative nature of the  sampling data,
              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 key 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)

-------
Page 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 appropriate 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 key 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"?  (HHEM - 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 QA/QC 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 fe.g.. human  carcinogens^) eliminated from analysis without
           appropriate justification?  (HHEM - 5.9)

                                            (continued)

-------
                                                                                       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 appropriate 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/animals, 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-specific characteristics 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? (HHEM
         - 6.4, 6.5)

         ~  was a valid rationale provided for using geometric or  arithmetic means?

         Were appropriate 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)

-------
                                                                                         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 toxicity  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^), 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 toxicity 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)

-------
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.

-------
                                                                                        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 personnel  (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 assessor with available guidances and site data.

    •    Determine (or review) data collection needs for risk assessment, considering:
         --  modeling parameter needs;
         --  type and location of background samples;
         --  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)

-------
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 land 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)

-------
                                                                              Page 9-17





                             EXHIBIT 9-3  (continued)





                 CHECKLIST FOR MANAGER INVOLVEMENT









8.   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.

-------
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).  19885.  Guidance  for Conducting Remedial Investigations and Feasibility 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.

-------
                                  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

 A(t) - Activity at Time t
  Bq = Becquerel
   Ci » Curie
 CLP = Contract Laboratory Program
   D « Absorbed Dose
 DCF = Dose Conversion Factor Per Unit Intake
  HE = Effective Dose Equivalent
  HX = Dose Equivalent Averaged Over Tissue or
     •  Organ T
     = Committed Effective Dose Equivalent Per
       Unit  Intake
HT,50 = Committed Dose Equivalent Averaged
       Over Tissue T
 LET = Linear Energy Transfer
 LLD = Lower Limit of Detection
 MeV - Million Electron Volts
   N « Modifying Factor in the Definition of
       Dose Equivalent
  pCi = PicoCurie (10'12 Ci)
   Q = Quality Factor in Definition of Dose
       Equivalent
 RBE = Relative Biological Effectiveness
   SI = International System of Units
   Sv = Sievert
   T = Tissue or Target Organs
  Wf = 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 Pose fD\  The mean energy imparted by ionizing radiation to matter per unit mass. The special SI unit of
           absorbed dose is the gray (Gy); the conventional unit is the rad (1  rad « 0.01 Gy).

     Beccmerel CBq.V  One nuclear disintegration per second; the name for the SI unit of activity. : 1 Bq ~ 2.7 x 10'H Q.
      Committed Dose Equivalent {Hf*n\  The total dose equivalent (averaged over tissue I) 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 (CD. 3.7 x 10-*^ nuclear disintegrations per second, the name for the conventional Unit of activity, 1 Ci =  3.7 X
     Decay Produces'). A radiouucHde or a series of radkmuclides formed by the nuclear transformation of another
           radionuclide which, in this context, is referred to as the parent.

     Dose Conversion Factor fDCFX  The dose equivalent per unit intake of radionuclide.

     Dose Equivalent CHI.  The product of the absorbed dose (D), the quality factor (Q), and any other modifying factors (N).
           The SI unit of dose equivalent is the sievett (Sv); the conventional unit is the rem (1  rem = 0.01 Sv).

     Effective Dose Equivalent fHgl.  The sum over specified tissues of the  products of the dose equivalent in a  tissue or
           organ (T) and the weighting factor for that tissue.

     External Radiation.  Radiations incident upon the body from an external source.

     Gray /Cy).  The SI unit of absorbed dose.  IGy =  I Joule kg'1 =  100  rad,

     Half-Life (physical, biological, or effective').  The time for a quantity of  radionuclide, i*., its, activity, to diminish by a,   .
           factor of a half (because of nuclear decay events, biological elimination o£ the material, or both.).           :

     Internal Radiation. Radiation emitted from radionuclides distributed within the body.

     Ionizing Radiation. Any radiation capable of displacing electrons  from atoms or molecules, thereby producing ions.

     Linear Energy Transfer (LET).  A measure of the rate of energy absorption, defined as the average energy imparted to
           the absorbing medium by a charged particle per unit  distance (KeV per um).

     Nuclear Transformation.  The spontaneous transformation Of one radionuclide into a different nucjide or into a different
           energy State of the same nuclide.

     Quality Factor (Q).  The principal modifying factor that is  employed in  deriving dose equivalent, H, from absorbed dose,
           D; chosen to account for the relative biological effectiveness (RBE) of the radiation fa question, but to be
           independent of the tissue or organ under consideration,  and of the biological endpoint. For radiation protection
           purposes, the quality factor is determined by the linear energy transfer (LET) of the radiation.

     Rad. The conventional unit for absorbed dose of ionizing radiation; the corresponding SI unit is  the gray (Gy); 1 rad —
           0.01 Gy  = 0.01 Joule/kg.

     Rem.  An acronym of radiation equivalent  man, the conventional  unit of dose equivalent; the corresponding  SI unit  is the
           Sievert; 1 Sv = 100 rem.

     Sievert  (Sv). The special name for the SI unit of dose equivalent. 1 Sv  = 100 rem.

     Slope Factor.  The age-averaged  lifetime excess cancer incidence rate per unit intake (or unit exposure for external
           exposure pathways) of a radionuclide.
      Weighting Factor fw-j-V  Factor indicating flie relative risk of cancer induction or hereditary defects from irradiation of a
           given tissue or organ; used in calculation of effective dose equivalent and committed effective close equivalent.

-------
                                                                                           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 external 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 radionuclides

-------
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  3.7x10™  atoms 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 W12 Ci.  Occasionally,
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 and two neutrons, which are ejected monoenergeticalty
   from the nucleus of an atom when the neutron to proton ratio is 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, cany 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 skin  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.  Internally, beta panicles have a much greater range than alpha particles in tissue.  However,
   because they cause fewer ionizations per unit path length, beta particles deposit much less energy to small volumes of tissue and,
   consequently, inflict 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 ittay be  overcome by electron capture, whereby one of the orbital electrons
   is 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 main ways in which x- and gamma rays
   interact with matter: the photoelectric effect, the Cbmpton effect, and pair production. All 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.

     Neutrons 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 SITES0
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-lifec
4.32X102 y
7.38X103 y
2.55x10° h
5.73x10* y
2.84X102 d
2.85x10* y
l.SlxlO7 y
5.27x10° y
2.77X107 d
2.06x10° y
2.30xl06 y
S.OOxlO7 y
4.45x10' d
1.23X107 y
1.57xl07 y
8.04x10° d
1.28X109 y
3.13X102 d
6.60X107 h
2.03xl04 y
2.14xl06 y
\A3xlQ1 d
2.23x10' y
1.38X102 d
8.77x10' y
2.41xl04 y
6.54X103 y
1.44x10' y
3.76X105 y
1.60X105 y
5.75x10° y
3.68xl02 d
8.74x10' d
5.05X107 d
2.91x10' y
2.13X105 y
6.02x10° h
7.70x10"* y
lAlKlO10 y
2.44X105 y
7.04X108 y
4.47X109 y
Average
Alpha
5.57x10°
5.36x10°
	
	
—
5.89x10°
5.89x10°
_.
	
	
_.
—
—
-.
_.
	
—
	
„
__
4.85x10°
-.
	
5.40x10°
5.59x10°
5.24x10°
5.24x10°
1.22X10-4
4.97x10°
4.86x10°
—
..
_^
	
	
—
—
4.75x10°
4.07x10°
4.84x10°
4.47x10°
4.26x10°
Radiation Energies (MeV/decav1fc
Beta, Electron
5.21xlO"2
2.17xlO2
6.37xlO'2
4.95xlO2
9.22xlO"2
1.38x10''
8.59xlO"5
9.65X10'2
3.86X10'5
1.64xlO7
6.73xlQ-2
1.87x10-'
1.17x10"'
5.68X10'3
6.38X10'2
1.92x10''
5.23x10''
4.22xlO"3
3.93x10-'
1.68x10-'
7-OlxlO"2
6.95x10''
3.80xlQ-2
8. 19x10-*
1.06xlO-2
6.74X10'5
1.06xlO"2
5.25xlO'5
8.73xlQ-J
3.59X10'5
1.69xlO'2
l.OOxlO'2
4.88X10"2
5.83x10"'
1.96x10''
1.01x10-'
1.62xlO-2
1.42xlO'2
1.25X10'2
1.32xlO-2
4.92xlO-2
l.OOxlO-2

x, Gamm;
3.25xlO-2
5.61xlO2
5.98x10"'
	
2.07xlQ-2
1.35xlO'
1.70xlO-5
2.50x10°
3.26xlQ-2
1.55x10°
„
—
1.19x10°
„
2.46xlQ-2
3.81x10"'
1.56x10-'
8.36x10-'
1.50x10-'
1.57x10°
3.46X10'2
..
4.81xlQ-3
8.51xlO-6
l.SlxlO"3
8.07xlO'4
1.73xlQ-5
2.55xlO-6
1.44xlO'3
6.75X10'5
4.14xlQ-9
	
	
8.45xlO-5
__
_-
1.26xlO'
1.55xlO"5
1.33xlO"3
1.73xlO5
1.56x10''
1.36X10'5
 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.
c Half-life expressed in years (y), days (d), and hours (h).

-------
Page 10-6
     The  activity  per  unit  mass  of  a given
radionuclide is called the specific activity, and is
usually expressed in units of becquerels 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 4x10^  Bq/g, whereas Np-237 has a
half-life of 2 million years and a specific activity
of 3xl07 Bq/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  =
2.58xlQ-4 C/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=l  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
modifying  factor is currently assigned a value of
unity  (N=l) 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 (Cember
   1983)

   Atoms, Radiation, and Radiation Protection
   (Turner 1986)

   Environmental Radioactivity  (Eisenbud
   1987)

   The Health Physics and Radiological Health
   Handbook (Shleien and Terpilak 1984)

-------
                                                                                                  Page 10-7
                                   EFFECTIVE DOSE EQUIVALENT

     The effective dose equivalent, Hg , is a weighted sum of dose equivalents to all organs and tissues (ICRP 1977, ICRP 1979),
   defined as:


                                                   T

   where w-j- is the weighting factor for organ or tissue T and Hj is the mean dose equivalent to organ or tissue T,  The factor
   w-p, 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, Hg^Q, is defined as the weighted sum of committed dose equivalents to all irradiated
   organs and  tissues, as follows:
                                            HE,50 =
  HT 50
   Kg and Hj5 50 thus reflect both the distribution of dose among the various organs and tissues of the body and their assumed
   relative sensitivities to stochastic effects. The organ and tissue weighting factor values wr- are as follows: Gonads, 0.25; Breast,
   0.15; Red Marrow, 0.12; Lungs, 0.12; 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 (Hj^o), 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  (H£) and
committed effective dose equivalent (H^ 50), which
are defined as weighted sums of the organ-specific
dose equivalents (i.e., S wyHj-) and organ-specific
committed   dose   equivalents  (i.e.,   ^wTHT50~),
respectively.  Weighting factors, wr, 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
l.SxlO5 MeV 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.

-------
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  [NARMJ).   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 83-703 - 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 radionuclides 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-Level Radioactive Waste Policy Act of 1980,  Public Law 96-573 - made states responsible for disposal of LLRW
  generated within their borders and encouraged formation of inter-state compacts.

• Nuclear Waste Policy Act of 1982, Public Law 97-425 - mandated the development of repositories for the disposal of
  high-level radioactive waste and spent nuclear fuel.

• Low-Level Radioactive Waste Policy Act Amendments of 1985, Public Law 99-240 - amended LLRWPA requirements 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

-------
Page 10-11





C/3
H
§
^
p
05
Z
z
o
^H
H
U
i 2
H §

M Z
K O
W ^
Q

m

S
fa
O
^0
Cd
E^
t-1











Remarks




8

1
H.


S .S

DO ^
1 «
55
o|
il




Inslruments






•o
E
o.
I
3
.3
E
"5-
co

OO
.e
o
ti
1

co



8
2
o"
6 .E
O C
S" s
o
3
I6
Is S6
i-Gamma Surface Monito
Portable Count Rate Met
Walled or Thin Window
•->
CQ
£
1
Cu
o
1
>i
•3
I
£
JS
.2?
Not accurate in f
fragile window

00
B
•S
"o
n
?f
1
3
W


Ji
O
c
c
I


u-
u
c
5
ha Surface Monitors
Portable Air Proportional
with Probe
Cu
 S
JP
h»
'•5

B
I

Q.
requires sc
y;
Used continuous!
60
.3 •£
CO Jj
Is
£ 1
8 »
o g
•3 00
B B
85





||
2?
2 8
Ss-



i
1
£


8
1

.c
I
•o
c
1
o
Sample deposited
separate counter
00
o
'B
0
e
«5
3)
O
3
tc
c
s
1



•JT
j|
~E
s
c
'f




o
'E.
1
5




^
C
3
3
n
a.
3
b"
(A
3
S
1
co


B
_0
B
B
'g
2

CQ
O.





B O
1?




1
'a.


e
.2
1
.g
I*M
O
i
1
i
0
0
1
1

an
|
•~
O
o
3
B
B
3





.a
1
o
o




tium Monitors
Flow ionization chambers
•«
H




















B
1
•a
e
3
•H
h«
1 1
*3 ^"
wi Di
E 5-
o ?,
'2 ""
i i
! 1
(A OS
S u
'o
2 1
» W

-------
Page 10-12
      RADIONUCLIDE 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
   I979a)

   Eastern Environmental Radiation Facility
   Radiochemistry Procedures Manual (EPA
   1984a)

   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

-------
Page 10-13






a
OS
H
STRUMEN
Z
SECTION
NN
Q
Z
O
HH
H
2
Q

05
s^
0
H
O
S
^j
.
O
C^
CsJ
e
^
















5
B
Data Acquisition


E
1
u
'5.
n
to

1
'S.

If
3&0
.— c
j?&







1
I

























^
00
f-l
0-
e
z,
S
%
1
v
o:
(X,
C*
u

"Source



-------
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
and 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  abundance 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 from the Uranium Series with
   Emphasis on Radon and its Daughters
   (NCRP I984b)

   Carbon-14 in the Environment (NCRP
   1985c)

   Environmental Radioactivity (Eisenbud
   1987)

   Population Exposure to External Natural
   Radiation Background in the United States
   (EPA 1987a)

   Ionizing Radiation Exposure of the
   Population of the United States  (NCRP
   1987a)

   Exposure of the Population of the United
   States and Canada from Natural
   Background 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-ments
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.

-------
                                                                                          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 Services (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 METHODS0
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
-Air^
-Water
-Water

-Soil (dry wt.)

-Biota (wet wt.)

-Air
-Water
-Soil (dry wt.)
-Biota (wet wt.)
-Air
-Water


-Soil (dry wt.)
-Biota (wet wt.)
-Air
-Water
-Soil (dry wt.)
-Biota (wet wt.)
-Air
-Water
-Soil (dry wt.)
-Biota (wet wt.)
-Air
LLD
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)

-------
                                                                                         Page 10-19
                                   EXHIBIT  10-4 (continued)
                EXAMPLES OF LOWER LIMITS OF DETECTION (LLD)
FOR  SELECTED RADIONUCLIDES USING STANDARD ANALYTICAL METHODS*
                                            LLD
Isotope
Pu-238
Pu-239
Pu-240

Sample Media*
-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 radionuclide-, media-,
      sample size-, and laboratory-specific:  higher and lower LLDs than those reported above are possible.  The risk assessor should
      request and report the LLDs supplied by the laboratory performing the analyses.

   b  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 radionuclide 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.

-------
                                                                                         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.

     •    As   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
10.5.3
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.)

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 10-25
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
terms  (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/m2 for ground  contamination or  Sv/hr  per
Bq/m5 for 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

-------
Page 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/m5), the  breathing rate (mj per  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/m5),  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

-------
                                                                                          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/m5),
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  EIS for
Proposed  NESHAPS for  Radionuclides  (EPA
1989a), Radiological Assessment (Till and  Meyer
1983), and NCRP Report No. 76 (NCRP 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

-------
Page 10-28
radiation dose.  In theory, any dose of radiation
has the potential to produce an adverse effect.
Accordingly,   exposure   to  any  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
  1977)

  Limits 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
  Low Levels of Ionizing Radiation (NAS
  1980)

  Induction of Thyroid Cancer by Ionizing
  Radiation (NCRP  1985b)

  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
carcinogenesis.

    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

-------
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

-------
                                                                                        Page 10-31
                                       EXHIBIT 10-5
                SUMMARY OF EPA'S RADIATION RISK FACTORS0
       Risk
Significant Exposure Period
Risk Factor Range
Low LET (G\*)

Teratogenic:b
     Severe mental retardation

Genetic:
     Severe hereditary defects,
     all generations

Somatic:
     Fatal cancers

     All  cancers

High LET
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
 0.25-0.55
 0.006-0.11
 0.012-0.12
 0.029-0.10
 0.019-0.19
Radon Decay Products  (W6 WLM';)
     Fatal lung cancer               Lifetime
 0.016-0.29
 0.096-0.96
 0.15-1.5
                                       140-720
   a  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.

   b  The range assumes a linear, non-threshold dose-response.  However, it is plausible that a threshold
     may exist for this effect.

-------
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
NESHAPS for  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) and NCRP 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

-------
                                                                                          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) contains 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 from the IRIS data base 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/m5) 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 cases 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  epidemiological
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
Document for the Draft ElSfor Proposed NESHAPs
for Radionuclides (EPA 1989a).

-------
Page 10-34
10.7.5   SUMMARIZING AND PRESENTING
        THE BASELINE RISK
        CHARACTERIZATION RESULTS

    The    results   of   the   baseline   risk
characterization   should  be  summarized  and
presented  in an  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 toxicity
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.

-------
                                                                                                          Page 10-35

                                 REFERENCES FOR CHAPTER  10
American Public Health Association. 1987. QA Procedures for Health Labs Radiochemistry.

Beebe, G.W., Kato, H., and Land, C.E.  1977.  Mortality Experience of Atomic Bomb Survivors. 1950-1974, Life Span Study Report
     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.

Department 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, FL.

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 Spectrometry.
     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 Natural 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  Protection Agency (EPA).  1989a.   Background Information Document. Draft  BIS for  Proposed NESHAPS for
     Radionuclides. Volume I, Risk Assessment Methodology. Office 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  Compliance 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 ICRP.  ICRP Publication 26.

International Commission on Radiological Protection (ICRP). 1979. Limits for Intake of Radionuclides 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 Compilation 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 Dosimetry and
     Radiological Assessments.  DOE/TIC-11026.

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 Exposures to Low Levels of Ionizing
     Radiation.  (BEIR Report)

National Academy of Sciences - National Research Council.  1980. The Effects on Populations 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. Environmental 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. Carbon-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 Techniques 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, Appendix 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 Models for Nuclear Power Plant Accident Consequence Analysis: Low-
     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 Radiological 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 Commission.  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 Records:  Thirteenth
     Session, Supplement No. 17(A/38381.  United Nations. New York, NY.

United Nations  Scientific Committee on the Effects of  Atomic Radiation (UNSCEAR).   1977.  Sources and  Effects  of Ionizing
     Radiation.  United Nations. New York, NY.

United Nations  Scientific Committee on the Effects of Atomic Radiation (UNSCEAR).  1982.  Ionizing Radiation:  Sources and
     Effects. United Nations.  New York,  NY.

United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR).  1986. Genetic and Somatic Effects of Ionizing
     Radiation.  United Nations. New York, NY.

United Nations Scientific Committee on the  Effects of Atomic Radiation (UNSCEAR). 1988. Sources. Effects, and Risks of Ionizing
     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.

-------
APPENDICES

-------
APPENDIX A

-------
                                 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.l.

    For the other routes of exposure  (i.e., oral
and inhalation),  the procedures  outlined  in
Chapter  6 result in an estimate of daily intakes.
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
A2.

    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  A3.
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 Toxic Substances and
          Disease Registry
   BCAO = Environmental Criteria and Assessment
          Office
    HAD = Health Assessment Document
    HEA = Health Effects Assessment
   HEED = Health and Environmental Effects
          Document
   HEEP « Health and Environmental Effects
          Profile
    RfD ~ Reference Dose
      SF = Slope Factor

-------
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, and it usually is expressed as mass of a substance
         absorbed into the body per unit body weight per unit time 
-------
                                                                                       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

   An  oral   slope  factor,  unadjusted  for
   absorption equals 1.6 (mg/kg-day)^.

   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:

     1.6(mg/kg-day)-r/0.20 = 8 (mg/kg-day)^.

   The  adjusted slope factor  of 8 (mg/kg-
   day)~; 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 toxicity values are
based on administered  doses.
A3 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
particulates. 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 calculation is provided in
the box on the next page.

     In the  absence  of a  strong  argument for
making this adjustment or  reliable information
on absorption efficiencies, assume that the relative

-------
Page A-4
       EXAMPLE:  ADJUSTMENT FOR
          MEDIUM OF EXPOSURE

   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 0.33 (i.e.,
   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.
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).

-------
APPENDIX B

-------
                                   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 6-2, 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, 6-1, 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 7-12, 10-28, 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

-------
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

CDI.  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 1980 1-1,'
  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

-------
                                                                                               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-
       41  to 6-43, 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

-------
Page B-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

Endangerment 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

Environmental 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, 4-2, 4-23, 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

-------
                                                                                           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 vs unfiltered 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

H£.  See 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

HJ-.  See Dose  equivalent

HT>50.  See Dose equivalent

Hydraulic gradient 4-7

                      I
LARC.  See International Agency for Research
  on Cancer

IDL. See Instrument detection limit

-------
Page B-6
Ingestion
     of dairy products 4-16, 6-47, 6-48
     of fish 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, 7-2, 7-
   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

IQ6-12

K0C 6-12

KOH, 6-12,  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

MR  See Modifying factor

Million electron volts 10-1,  10-5

-------
                                                                                           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 Contingency 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

                     O
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

-------
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

pH 4-7

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

-------
                                                                                               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
     subchronic 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

        See  Reference  dose
RfDj.  See Reference dose

-------
Page B-10
RI.  See Remedial investigation/feasibility
  studies

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

RME.  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, 3r2, 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

-------
                                                                                            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 Reauthorization
  Act of 1986 1-11,  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
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,  10-2, 10-3, 10-5

Treatability 5-21

Trip blanks.  See Blanks

-------
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
     semi-quantitative 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

Wr.  See Weighting factor

-------