United States
Environmental Protection
Agency
Region III
Office of Superfund
Hazardous Waste Management
Philadelphia, PA 19103
EPA/903/8-91/002
November 1991
Region III
Technical Guidance Manual
Risk Assessment
    Exposure  Point Concentrations
         In Groundwater
                                                           EPA Contact: Dr. Debra L. Forman
                 EPA
                 Region
                                                           Hazardous Waste Management Division
                                                                         November 1991
The EPA method of risk assessment uses long term or chronic exposure as a basis for determining the excess cancer risk
at a Superfund site. Oftentimes, the risk from exposure to contaminated groundwater is inappropriately calculated from the
single highest confirmed concentration found in a groundwater well. This approach is mathematically and conceptually
indefensible since a single measurement cannot represent the contamination in an entire plume at a Superfund site. Instead,
a sufficient database is required to effectively represent site risk during a lifetime of exposure. The larger database serves
to reduce the uncertainty inherent in risk analysis, and the Remedial Project Manager is provided with a more scientifically
sound risk  evaluation on which to trigger a remedial decision. While this approach applies to most Superfund sites,  factors
such as calculation method, well placement and use of the historical database  attain particular importance at sites where
groundwater contamination is not clearly established. This guidance is intended to improve the quality and consistency of
deriving exposure point concentrations in groundwater in risk assessments performed in  Region III. (EPA/903/8-91/002)
COMMUNICATION

In accordance with our longstanding policy of involving
scientists at the early stages of the RI/FS process, this
Guidance document stresses communication. Clear lines
of contact both between the technical support staff and
the  risk  manager as  well  as among the  technical
personnel are essential to the  process. The Guidance
outlines a sampling strategy, including both spatial and
temporal collection and handling of groundwater data. This
strategy promotes a coherent technical  approach to the
RI/FS process, initiating the proper experimental design
and correct data usage. Hence, the risk manager  is
provided with a justifiable risk conclusion based on sound
                    scientific methodology.

                    The risk associated with groundwater usage at a site is
                    generally  calculated  by  combining  the  pollutants'
                    concentrations in the aquifer of concern along with site-
                    specific  exposure  parameters.  This  result  is  then
                    combined with  chemical specific exposure factors to
                    obtain the final risk value. The approach assumes that the
                    pollutants' concentration is  linearly related to risk, thus,
                    changes in concentration may have a significant influence
                    on the risk analysis for the site. A clear understanding of
                    this relationship and its potential impact on the final risk
                    value underscores the  requirement for a conceptually
                    correct derivation of the exposure point concentration.

-------
WELL PLACEMENT

During the scoping meeting, the toxicologist may present
the guidelines for risk analysis from  contamination in
groundwater. These may include selecting the location of
groundwater wells and proposing analytical methods of
sampling for  suspected contaminants. The choice of
groundwater wells is of prime importance in determining
the appropriate concentrations of pollutants in the aquifer
of concern. Placement of wells in both the horizontal and
vertical  planes should be  considered. In general, both
horizontal  and  vertical  placement  of   groundwater
monitoring wells should  be designed so that monitoring
well data can be  extrapolated to future residential  well
usage. Consultation with  the hydrogeologist  is required to
outline any hydrological and/or geological concerns which
may impact the subsequent well selection.

S))))))))))))))))))))))))))))))))))))))))))
Both horizontal and vertical placement of groundwater
monitoring wells should  be designed so that monitoring
well data can be  extrapolated to future residential  well
usage.
A. Horizontal Well Placement

Hydrogeologists  may  locate wells  for  a variety  of
purposes, yet toxicologists primarily utilize water quality
data to assess the potential risks to human health. Since
toxicologists usually  do not direct well placement, the
body of data obtained for hydrogeological objectives may
be used by the toxicologist for a  different purpose.

For example, groundwater wells may be located by the
hydrogeologist  purposely  to   identify the  fringe  of
contamination.  On  the  other  hand, the  toxicologist
requires information concerning the reasonable maximum
concentration of pollutants in the aquifer of concern. In
this case, the ideal placement of wells for risk purposes
is near the apparent center of the plume.  The choice of
wells may be different for on site  and off site scenarios or
if multiple sources are present.
B. Vertical Well Placement
The aquifer of interest should provide sufficient water for
residential use. In some cases, monitoring well data from
two independent aquifers may be combined if each aquifer
cannot supply enough water individually. If the aquifer is
not currently  used as a drinking water source, consider
the likelihood of its future use as a drinking water source.
For example, monitoring well  data from a perched aquifer
is not appropriate for risk assessment because it  usually
does not provide sufficient water for residential  use. In
any case, the appropriateness of spatial placement may
depend on  hydrogeological factors. Thus,  consultation
with  a  hydrogeologist  is required  to outline  potential
problems.

Identification of wells should be such that the toxicologist
may  combine water quality data from several wells in
order  to achieve a  reasonable maximum estimate of
groundwater contamination. Those wells which  meet the
criteria  discussed above may be grouped for  spatial
analysis. Temporal analysis may be achieved by multiple
sampling of the chosen wells.
It is important to  recognize that the combined data from
multiple  well  sampling should  belong  to the  same
statistical data population data, i.e. the apparent center of
the plume.

C. Well Construction

Once  the well locations have been  determined, the
hydrogeologist should  be  consulted  to  determine the
adequacy of well construction. The problems identified
with well construction may also influence the choice of
data to be used by the risk assessor.

Although both filtered  and  unfiltered data should be
collected (USEPA, 1990b), the data is evaluated on a well
by well basis by the  risk assessor for its potential use in
extrapolating  monitoring well data to  a residential well
scenario. Generally,  unfiltered data is preferred,  however,
if there  is an obvious discrepancy  in the levels of
inorganics, or if secondary MCLs are  exceeded,  filtered
data may be selected for use  in the risk assessment.
This issue is  addressed more fully in a separate  Region
III  guidance document which is currently in draft form
(USEPA, 1991b).

S))))))))))))))))))))))))))))))))))))))))))
The  appropriateness  of spatial  placement in  both
horizontal  and  vertical  planes  may  depend  on
hydrogeological factors.

-------
                                                          RISK ASSESSMENT
HISTORICAL DATABASE

During the  scoping phase,  the  complete historical
database should be thoroughly examined. If the historical
data demonstrate clear trends,  the toxicologist should
incorporate relevant site-specific information into the risk
calculation.  Site-specific  information  should  also be
considered in determining the confidence assigned to the
trend direction. In addition, the historical database should
be evaluated for landmark actions, such as  emergency
removal or remedial action prior to the RI/FS. Use of the
historical  database  should  include  consideration  of
potential  inconsistencies  in  analytical  methods,  data
validation  protocols and  QA/QC  practices which  may
have changed with time (USEPA, 1990c).

If the  available information is inadequate to substantiate
the risk assessment, additional sampling events should
be performed for each well identified for risk assessment
purposes.  The sampling events should be spaced such
that an independent sample population is obtained. The
selected  time  interval should  be acceptable  to all
members of the investigation team.

As  data is collected, the results should  be reviewed for
trends,  the  number of  sampling rounds  should be
sufficient to yield a database with clear trends.  The
sampling effort may be a continual  process, such that the
RI/FS process is not delayed. In this respect,  information
obtained from ongoing sampling efforts may be submitted
as addendums to the Remedial Investigation  report.

DATA QUALITY OBJECTIVE

A high data quality objective is recommended. Depending
on  site conditions,  analysis of  samples  using  SAS
procedures may be warranted. For example, EPA method
500 series for drinking water,  which have lower detection
limits  for some  contaminants,  can  provide  greater
sensitivity for assessing  contaminant  concentrations.
Thus,  a  clearer   evaluation   of the  relevance  of
contaminants  detected  at concentrations  below the
detection limit may be attained.  In some cases, this
approach may eliminate the need to apply the "0.5 times
the detection  limit" rule  (USEPA, 1989). In addition, and
if  logistics  permit,   provisions  should  be  made for
reanalysis of rejected or estimated samples  within  their
holding times.
A. Current Scenarios

The current, on site risk should be based on the most
reliable  database  obtained  during   the  entire  site
investigation which may include studies other than the
RI/FS. The data to be included in the calculation consists
of useable, water quality data obtained from repeated
sampling  of the wells identified for risk assessment
purposes  as well  as  useable historical information.
Treatment of non-detects is considered  in a separate
Region III guidance  document  (USEPA,  1991 a).  The
reasonable maximum concentration of pollutants in the
aquifer can  be calculated as the upper 95th percent
confidence limit of the arithmetic  mean, UCL95 (See
Highlights). If the database is sufficient, a preliminary
conservative risk assessment may be performed following
the Phase I  investigation. Current off site risk may be
assessed  using  water quality data from  a set of wells
independent  of those  identified for on site risk (possibly
residential wells).

B. Future Scenarios

Future risk may be  estimated using the results of a fate
and transport groundwater modelling effort. Consultation
with the hydrogeologist is recommended to determine the
appropriate modelling approach. If the hydrogeologist
determines that groundwater modelling is not appropriate
due to site specific conditions, current monitoring well
data may be used to assess future risk.

-------
HIGHLIGHT #1:
LOGNORMAL DISTRIBUTION

The following calculations are used to
determine the UCL-95 for the useable
groundwater dataset.

1. Identify the frequency distribution of the
sample population.  A lognormal distribution
can be characterized as having no zero values
and the relative percentage of data points
greater than or less than the mean is not equal.
The W test by Shapiro and Wilk may be used
to test the distribution type (Gilbert, 1987).

According to Dean,  1981, most environmental
datasets are skewed lognormally and the data
can be assumed to be lognormally distributed.
Note that this assumption is supported only by
a large dataset and may not necessarily apply
to small datasets available at Superfund sites.

2. If the sample frequency distribution is
lognormal, transform the detected data to
logarithmic equivalents using the expression

t = ln(x)

where:
                                                where:

                                                • g = arithmetic mean of log transformed data
                                                •2 = variance of log transformed data
                                                H = Tabular H statistic, depends on geometric
                                                •, n, and selected degree of probability
                                                (Gilbert, 1987).
                                                n = sample size

                                                5. If the UCL-95 is greater than the maximum
                                                value, use the W test to examine the sample
                                                population for normality.

                                                HIGHLIGHT #2:
                                                NORMAL DISTRIBUTION

                                                The following calculations are used to
                                                determine the UCL-95 for the useable
                                                groundwater dataset.

                                                1. Identify the frequency distribution of the
                                                sample population as outlined in highlight #1.

                                                2. Calculate the UCL-95 using the following
                                                expression

                                                UCL-95 = x, +1(' /n0-5)

                                                where
x = raw groundwater data
t = transformed data

3.  Obtain an estimate of the arithmetic mean of
the transformed data, if desired, using the
expression
= exp(»
             • 2
               /2)
4. Obtain the UCL-95 using the expression

UCL-95 = exp(' g + • 2/2 + • H / (n-lf5)
(Land, 1971, 1975)
x,, = arithmetic mean of the raw data
• = arithmetic standard deviation of the raw
data
t = Tabular t statistic, depends on degree of
freedom (df = n-1) and selected degree of
probability (one tailed @ p<0.05).
n = sample size

3. If it is determined that the sample population
is neither lognormally distributed nor normally
distributed, omit the non-detect data and obtain
a maximum likelihood estimate of the detect
data (Gilbert, 1987).

-------
References

Dean,  R.B.  (1981). Use of Log-Normal  Statistics  in
Environmental Monitoring, in Chemistry in Water Reuse.
Vol. 1. (ed.)  Cooper, W.J., Ann Arbor Science, pp. 245-
258.

Gilbert,   R.O.   (1987).   Statistical  Methods   for
Environmental   Pollution  Monitoring.  Van  Nostrand
Rheinhold Co.,  New York, pp. 152-185.

Land,   C.E.  (1971).  Confidence  intervals  for  linear
functions of  the normal mean  and variance. Annals of
Mathematical Statistics 42: 1187-1205.

Land,  C.E. (1975). Tables of confidence limits for linear
functions of the normal mean and variance, in Selected
Tables in Mathematical Statistics. Vol.  3. American
Mathematical Society, Providence, R.I., pp. 385-419.

USEPA  (1989).  Risk  Assessment  Guidance  for
Superfund. Volume I, Human Health Evaluation Manual
(Part A). EPA/501/1-89/002.

USEPA (1990a). Guidance  for Data  Useability in Risk
Assessment. EPA/540/G-90/008.

USEPA (1990b). Field Filtration Policy for Monitoring Well
Groundwater Samples Requiring Metals Analysis, Region
III QA Directive, Bulletin #QAD009, USEPA, Region III,
Philadelphia, PA.

USEPA (1990c). Guidance  for Data  Useability in Risk
Assessment, EPA/540/G-90/008.

USEPA  (1991 a).  Chemical Concentration  Near  the
Detection Limit, Region  III Technical Guidance Manual,
EPA-3/HWMD/11-91/001.

USEPA (1991b).  Useability of Filtered vs.  Unfiltered
Metals data for Risk Assessment, Region  III Technical
Guidance Manual, (Draft document).
For additional information, (215) 597-6626.
Approved by:	
                Thomas C. Voltaggio, Division Director

-------