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5.0 REFERENCES
1. Federal Register. Draft Schedule for the Promulgation of
Emission Standards. Volume 57, No. 186. September 24,
1993. pp. 44147-44159.
2. Draft methodology for the Source Category Ranking System.
U. S. Environmental Protection Agency. Research Triangle
Park, NC. September 1992.
3. Memorandum and appendix from Fields, S. and R. Dobson,
Radian Corporation, to Source Category Schedule for
Standards Project files. Post- Federal Register Publication
Relative Risk Ranking for Categories of Sources on the
Initial List. August 31, 1992.
4. Focus Chemicals for the Clean Air Act Amendments Great
Waters Study. U. S. Environmental Protection Agency.
Research Triangle Park, NC. Draft August 15, 1991.
5. Memorandum and attachments from Leininger, A., Radian
Corporation, to Source Category List Docket (A-90-49).
Emission and Exposure Data for the Source Category Ranking
System. June 29, 1992.
6. Memorandum from French, Charles, to Source Category Schedule
Docket (A-91-14). Supplementary Data for Environmental
Effects Screening Analysis. U. S. Environmental Protection
Agency. Research Triangle Park, NC. May 28, 1993.
RB52-2*/«l».078 5-1
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ATTACHMENT A
FOCUS CHEMICALS
FOR THE CLEAN AIR ACT AMENDMENTS
GREAT WATERS STUDY
DRAFT REPORT
Prepared For:
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
Prepared By:
ICF Incorporated
9300 Lee Highway
Fairfax, Virginia 22031
August 15, 1991
-------
PREFACE
The analysis documented by -this report was conducted for the U.S. Environmental
Protection Agency (EPA), Office of Air Quality Planning and Standards (OAQPS), Emission
Standards Division (ESD), in Research Triangle Park, North Carolina, by ICF Incorporated
(ICF), with extensive environmental data collection and methods development assistance
provided by EPA's Environmental Research Laboratory in Duluth, Minnesota (ERL-Duluth).
This report was prepared by ICF.
The work by ICF was conducted under two EPA contracts: #68-09-0158 and #68-00-
0102. The work by ERL-Duluth was conducted through a cooperative agreement between
ESD and ERL-Duluth.
The EPA Project Manager for this analysis was Melissa McCullough of ESD's Pollutant
Assessment Branch. To provide comments on the analysis or to obtain a copy of the report,
contact:
Melfssa McCullough
EPA/OAQPS/ESD/PAB (MD-13)
411 West Chapel Hill Street
Durham, NC 27701
Phone: 919-541-5646
Draft-August 15, 1991
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- Ill
TABLE OF CONTENTS
PREFACE ii
LIST OF EXHIBITS vi
LIST OF ACRONYMS vii
EXECUTIVE SUMMARY ES-1
1. INTRODUCTION 1
1.1 PURPOSE 1
1.2 GENERAL APPROACH AND LIMITATIONS 1
1.3 ORGANIZATION. OF REPORT 2
2. BACKGROUND 3
2.1 ENVIRONMENTAL PROCESSES AND FACTORS 3
2.1.1 Release to Air, Fate in Air, and Deposition to Water 3
2.1.2 Fate in Surface Water 5
2.1.3 Impacts : 5
2.2 "IDEAL" ASSESSMENT 5
2.3 REVIEW OF PREVIOUSLY DEVELOPED SCREENING-LEVEL
SYSTEMS 6
2.3.1 Criteria 6
2.3.2 Screening Systems 6
3. RANKING METHODOLOGY 9
3.1 SUBSTANCES TO BE RANKED 9.
3.2 GENERAL APPROACH TO RANKING 9
3.3 DESCRIPTION OF RANKING CRITERIA 10
3.3.1 Human Toxicity Criterion 10
3.3.2 Environmental Criteria 13
3.4 OVERALL SCORES • .' 16
3.5 GROUPS OF SUBSTANCES 16
3.6 "SPECIAL" FOCUS CHEMICALS ' 17
3.6.1 Water Quality Board of the International Joint Commission .... 17
3.6.2 Air Resources Branch of the Ontario Ministry of the
Environment 20
3.6.3 Great Lakes Atmospheric Deposition Network 21
3.6.4 Lake Michigan Lakewide Management Plan 21
3.6.5 Lake Ontario Toxics Committee 21
4. RESULTS 23
4.1 SUBSTANCES LACKING CRITERIA SCORES 23
4.2 . DATA QUALITY AND COVERAGE 23
4.2.1 Human Toxicity 25
Draft-August 15, 1991
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- IV -
TABLE OF CONTENTS (continued)
4.2.2 Aquatic Toxicity . . 27
4.2.3 Bioconcentration Potential 27
4.2.4 Environmental Persistence 27
4.3 CRITERIA-SPECIFIC SCORES AND OVERALL RANK 28
4.3.1 Criteria-specific Scores 28
4.3.2 Overall Scores and Ranks 28
4.4 "SPECIAL" FOCUS CHEMICALS 38
4.5 SENSITIVITY ANALYSIS 38
4.5.1 Comparison With "Special" Focus Chemicals 38
4.5.2 Ranking With an Additional Criterion 42
4.5.3 Ranking With the Modified IRP Method 43
4.6 IDENTIFYING FOCUS CHEMICALS 43
APPENDICES
A. OTHER CHEM'CAL PRIORIT1ZATION SYSTEMS A-1
A.1 CER-LA SECTION 102(A) REPORTABLE QUANTITY (RQ) ADJUSTMENT
METHODOLOGY A-1
A.1.1 Introduction A-1
A.1.2 Criteria Description A-3
A.1.3 Relevanc'e : . . A-5
A.2 SUPERFUND REVISED HAZARD RANKING SYSTEM (HRS) A-5
A.2.1 Introduction A-5
A.2.2 Criteria Description A-5
A.2.3 Relevance A-7
A.3 DRAFT REVISED HAZARD ASSESSMENT GUIDELINES FOR LISTING
^ -EMICALS ON THE TOXICS RELEASE INVENTORY (TRI) A-7
r j.1 . Introduction A-7
A.3.2 Criteria Description A-7
A.3.3 Relevance A-9
A.4 PERSISTENT BIOACCUMULATORS SCREENING CLUSTER A-9
A.4.1 Introduction A-9
A.4.2 Criteria Description -. A-10
A.4.3 Relevance A-10
A.5 'ODIFIED HAZARDOUS AIR POLLUTANT PRIORITIZATION SYSTEM
SHARPS) A-11
A.5.1 Introduction A-11
A.5.2 Criteria Description A-11
A.5.3 Relevance A-12
A.6 RCRA HAZARDOUS WASTE SCHEDULING METHODOLOGY A-12
A.6.1 Introduction A-12
A.6.2 Criteria Description A-12
A.6.3 Relevance A-13
A.7 "^PTS REVIEW OF 224 CHEMICALS A-13
7.1 Introduction A-13
.7.2 Criteria Description A-13
Draft-August 15, 1991
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- V -
TABLE OF CONTENTS (continued)
A.7.3 Relevance A-13
A.8 - ERLINERTS RANKING PROGRAM -A-13
A.8.1 Introduction A-13
A.8.2 Criteria Description A-14
A.8.3 Relevance A-14
APPENDIX A REFERENCES A-14
B. READILY AVAILABLE TERTIARY DATA SOURCES EXAMINED B-1
C. DATA USED FOR SCORING INDIVIDUAL CRITERIA C-1
C.1 DATA QUALITY AND DATA COVERAGE
C.2 DATA FOR HUMAN TOXICITY CRITERION
C.3 DATA FOR ENVIRONMENTAL CRITERIA
D. SCORES/RANKS UNDER ALTERNATIVE RANKING ALGORITHMS D-1
D.1 FINAL RANKS FOR OVERALL SCORES WITH ENVIRONMENTAL
PARTITIONING AS FIFTH CRITERION
D.2 FINAL RANKS USING IRP METHOD
Draft-August 15, 1991
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- VI -
LIST OF EXHIBITS
EXHIBIT 1 SELECTED PROCESSES AND FACTORS ASSOCIATED WITH
POTENTIAL IMPACTS 4
EXHIBIT 2 SUMMARY OF CRITERIA INCLUDED IN CHEMICAL PRIORITIZATION
SYSTEMS 7
EXHIBIT 3 SCALES FOR SCORING HUMAN TOXICITY 12
EXHIBIT 4 SCALES FOR SCORING ENVIRONMENTAL CRITERIA 15
EXHIBIT 5 INDIVIDUAL CHEMICALS USED TO SCORE FOR GROUPS 18
EXHIBIT 6 SUBSTANCES NOT RANKED 24
EXHIBIT 7 FINAL RANKS AND OVERALL SCORES 29
EXHIBIT 8 PERCENTAGES OF CHEMICALS ACROSS CRITERIA-SPECIFIC
SCORES 37
EXHIBIT 9 FREQUENCY DISTRIBUTION OF FINAL RANKS 39
EXHIBIT 10 "SPECIAL" FOCUS CHEMICALS 40
EXHIBIT A-1 SUMMARY OF RELEVANT CRITERIA ADDRESSED BY PREVIOUS
CHEMICAL PRIORITIZATION SYSTEMS A-2
Draft—August 15, 1991
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- VII -
LIST OF ACRONYMS
Acronym
Definition
AQUIRE
BAF
BCF
CAAA
CAS
CERCLA
CURE
EC50
EHS
EPA
ERL
GLAD
HEAST
HIRIS
MRS
IJC
IRIS
!RP •
LaMP
LC50
LD50
MATC
MED
OAQPS
OPP
OPTS
QSAR
RTECS
RCRA
RfD
RQ
SARA
SF
SCDM
TSCA
WOE
Aquatic Toxicity Information Retrieval (data base)
Bioaccumulation Factor
Bioconcentration Factor
Clean Air Act Amendments of 1990
Chemical Abstracts Service
Comprehensive Environmental Response, Compensation, and Liability Act
Chemical Unit Risk Estimate (data base)
Effective Concentration (for 50% of population)
Effective Dose (for 10% of population)
Effective Dose (for 50% of population)
Extremely Hazardous Substance
U.S. Environmental Protection Agency
Environmental Research Laboratory
Great Lakes Atmospheric Deposition (network)
Health Effects Assessment Summary Tables
HEAST and IRIS (ICF data base)
Hazard Ranking System
International Joint Commission
Integrated Risk Information System (data base)
Inerts Ranking Program
Lakewide Management Plan
Lethal Concentration (for 50% of population)
Lethal Dose (for 50% of population)
Maximum Acceptable Toxicant Concentration
Minimum Effective Dose
Office of Air Quality Planning and Standards
Office of Pesticide Programs
Office of Pesticides and Toxic Substances
Quantitative Structure Activity Relationship •
Registry of Toxic Effects of Chemical Substances (data base)
Resource .Conservation and Recovery Act
Reference Dose
Reportable Quantity
Superfund Amendments and Reauthorization Act of 1986
Slope Factor
Superfund Chemical Data Matrix (data base)
Toxic Substances Control Act
Weight of Evidence (rating for human carcinogenicity)
Draft-August 15, 1991
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EXECUTIVE SUMMARY
Section 112(m) of the Clean Air Act Amendments of 1990 (CAAA) requires the U.S.
Environmental Protection Agency (EPA) to conduct a program to assess the atmospheric
deposition of hazardous air pollutants to the Great Lakes, Chesapeake Bay, Lake Champlain,
and certain coastal waters (collectively referred to as Great Waters). This report summarizes
an initial step in this program, a screening-level analysis to identify substances of priority
concern for air deposition. The objective "of identifying such "focus chemicals" is to facilitate
futir analyses under the CAM section 112(m) program, including, for example, monitoring
stuc ., detailed risk and impact assessments, and source studies.
The analysis had two main components:
• development and application of a numerical, hazard-based chemical scoring
system; and
• identification of substances previously designated by other groups as
substances of concern for air deposition to the Great Waters..
The scoring system was largely adapted from existing systems, especially EPA's Inerts
Ranking Program (IRP) scoring method and the revised Superfund Hazard Ranking System
(MRS). At the beginning of the project, it was decided to (1) base the scoring system on
hazard/risk assessment principles; (2) incorporate intrinsic chemical properties only, and not
source information; (3) address both human health and aquatic ecosystem effects; and (4)
emphasize potential impacts of long-term deposition and buildup.
After an initial review of a number of existing scoring systems, potential ranking criteria
were identified and then narrowed down to a" manageable set. The following four criteria
were ultimately selected as the primary basis for ranking:
human toxicity;
• aquatic toxicity;
• bioconcentration potential; and
• environmental persistence.
Each of these criteria was considered to be an important determinant of a substance's
potential impact on the Great Waters. In addition, the necessary scoring data were expected
to be available for each of these criteria for most of the 190 CAAA hazardous air pollutants. A
simple algorithm, adopted directly from the IRP method, was used to combine scores for
individual criteria into a single overall substance score, which then was used for ranking.
The scoring system was applied to the CAAA section 112(b) list of hazardous air
pollutants, and adequ 3 data were collected to score 179 of the 190 substances on that list..
Section 4 of this repc ^resents a ranked list of these 179 substances and discusses
possible ways to selec: focus chemicals for specific applications. Scores and score
distributions for the four individual criteria also are presented in Section 4, with detailed
scoring data provided in Appendix C. The final ranking was compared with the findings of
the research into previously designated substances of concern and found to be generally
consistent. In addition, several alternate scoring methods that used either additional or
different criteria were tested, and the resulting rankings were compared with the final ranking
presented in Section 4.
Draft-August 15, 1991
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1. INTRODUCTION
This report describes the methods and results of an analysis to select focus
chemicals—that is, chemicals of priority concern—for future monitoring and other studies of
atmospheric deposition to the Great Waters.1 This introduction addresses this purpose in
more detail, as well as the general approach used in the analysis (and its limitations) and the
organization of the remainder of this report.
1.1 PURPOSE
Section 112(m) of the Clean Air Act Amendments of 1990 (CAAA) requires the U.S.
Environmental Protection Agency (EPA) to conduct a program to identify and assess the
extent and impact of atmospheric deposition of the 190 hazardous air pollutants listed in
section 112(b) (and, as appropriate, other air pollutants) to the Great Waters. A logical first
Step of this program is to ascertain which hazardous air pollutants are, or likely will be,
chemicals of priority concern—i.e., focus chemicals—due to atmospheric deposition to the
Great Waters.2 This step could facilitate a later step of selecting individual chemicals to be
monitored at specific water bodies, as well as provide input to other parts of the program
(e.g., prioritization of emissions sources for standards development). This report documents
how that first step was taken by describing both the methodology used to develop a list of
focus chemicals for the Great Waters and the results of applying that methodology.
1.2 GENERAL APPROACH AND LIMITATIONS
The general approach for this analysis can be described as a screening-level, hazard-
based ranking (or grouping) of chemicals. The specific area of concern was the chemicals'
potential for causing adverse human health and environmental impacts to the Great Waters.
This potential was captured by "scoring" the relevant environmental processes and factors for
each chemical, and then using these scores to rank or group the chemicals and thus identify
the focus chemicals. An additional step of identifying "special" focus chemical—substances
previously reported as known or suspected to significantly impact Great Waters—was
conducted.
Because this was intended to be (and was designed as) a screening-level analysis, it
did not address several factors that might have provided a more precise analysis and a more
certain ranking. In particular, the analysis did not consider either the relative or absolute
mass flux of individual chemicals into the Great Waters via air deposition (or any surrogate of
this, such as air emissions quantity), an important factor in assessing both human health and
environmental risks. Therefore, chemicals with similar scores should not be considered
1
Section 112(m) of the Clean Air Act Amendments of 1990 (CAAA) describes .the
atmospheric deposition assessment and monitoring program required for the Great Lakes,
Chesapeake Bay, Lake Champlain, and certain coastal waters. For the purposes of this
report, these waters are termed the Great Waters.
rt
For the purposes of this report, a focus chemical is defined as a substance with
relatively high potential to be a significant contributor to adverse human health and/or
environmental impacts due to its presence in surface water.
Draft-August 15, 1991
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-2-
different in terms of potential for air deposition and adverse effects. Similarly, only chemicals
with very different scores should be considered to differ in this potential.
1.3 ORGANIZATION OF REPORT
The remainder of this report is organized as follows:
Section 2—Background. This section provides a description of: (1) the
various environmental processes and factors that result in a chemical
depositing from air into water and causing adverse effects; (2) the "ideal"
assessment that would incorporate these processes and factors; and (3) a
review of other screening-level systems and criteria evaluated for
applicability to this project.
Section 3—Ranking Methodology. This section addresses: (1) the
chemicals to be ranked; (2) the general approach used to rank the
chemicals; (3) the criteria (e.g., aquatic toxicity, bioconcentration potential)
ultimately selected for ranking; (4) the methodology used to produce an
overall score; (5) the approach used for scoring groups of chemicals (e.g.,
"cadmium and compounds"); and (6) the identification of "special" focus
chemicals.
• Section 4—Results. This section addresses: (1) substances lacking criteria
scores; (2) the data quality and coverage for the chemicals and criteria; (3)
the criteria-specific scores and overall rank; (4) the results of the "special"
focus chemical review; (5) the results of the sensitivity analysis; and (6) how
to.identify the focus chemicals.
• Appendices. The appendices contain: (1) a description of other chemical
priorftization systems with potentially relevant components; (2) a matrix
showing data sources examined for potential use in this analysis; (3) the
chemical-specific data used for each of the individual ranking criteria; and
(4) scores/ranks under alternate ranking algorithms.
Draft—August 15, 1991
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2. BACKGROUND
In this section we provide a brief discussion of the processes (e.g., atmospheric
deposition) and factors (e.g., solubility) that can lead to adverse impacts of hazardous air
pollutants on the Great Waters. We also describe how these processes and factors could be
used in an "ideal" method to develop a list of focus chemicals (i.e., if there were no financial
or data availability constraints). Finally, we present a summary of several screening-level
systems that have been used for similar purposes and that we reviewed as an early step in
this project.
The main purpose of this section is to describe the underlying paradigm that guided
the assumptions and decision-making during the selection of screening criteria and
development of a method for identifying focus chemicals.
2.1 ENVIRONMENTAL PROCESSES AND FACTORS
The release of toxic substances into air, their subsequent transport through air, their
deposition to the Great Waters, and their fate in and impact on the Great Waters are highly
complex processes.3 Exhibit 1 summarizes selected processes and factors in a flowchart.
2.1.1 Release to Air, Fate in Air, and Deposition to Water
Release sources for hazardous air pollutants that can deposit into Great Waters can be
local (e.g., nearby industrial areas) or remote (e.g., distant pesticide applications), point (e.g.,
stack emissions from a chemical plant) or nonpoint (e.g., automobiles), and routine (e.g., from
stacks) or accidental (e.g., particulates from slag piles). For a given chemical, factors such as
the amount released, the release location, and the nature/type of the release can have
significant effects on the chemical's ultimate impact on the Great Waters. As an example, for
a given chemical, large local upwind releases will have a greater impact on a water body than
a small remote downwind release. For a given amount of a local upwind release, a chemical
in a form that is amenable to rapid deposition (e.g., large particulates) generally will have a
greater impact than a chemical is in a form less amenable to rapid desorption (e.g., small
particulates).
After a chemical is released into the air, several factors affect the degree to which it will
be transported to a point in space that permits its deposition to one of the Great Waters.
These factors include climate/weather (e.g., precipitation tends to "wash" chemicals from the
air into the water), form (e.g., gas, particulate), inherent chemical-specific mobility factors (e.g.,
vapor pressure, diffusivity), and persistence/degradation. While a chemical is airborne, it may
be transformed (e.g., by sunlight) into other more or less toxic forms. A chemical released
into the air also, may enter surface waters through deposition to watersheds followed by
runoff or leaching to the water body.
3 Three examples of review articles describing these processes and factors include:
Arimoto, R., "Atmospheric Deposition of Chemical Contaminants to the Great Lakes", J. Great
Lakes Res., 15(2):339-356, 1989; East, K., "Atmospheric Deposition of Toxic Pollutants in the
Great Lakes: An Introduction", North Am. Envir., 1:6-12, 1988; and Eisenreich, S.J.(ed.),
Atmospheric Pollutants in Natural Waters, Ann Arbor, Ml: Ann Arbor Science Publishers, Inc.,
1981.
Draft—August 15, 1991
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EXHIBIT 1
SELECTED PROCESSES AND FACTORS ASSOCIATED WITH POTENTIAL IMPACTS
FACTORS
PROCESSES
Release to Air,
Fate in Air, and
Deposition to Surface Water
Fate in Surface Water
Impacts
• Amount released/release
rate
• Release location
• Nature/type of release
(release mechanism)
• Climate/weather
• Chemical form/state
• Inherent chemical-specific
mobility factors
• Persistence/degradation
• Gas exchange properties
• Dry/wet deposition factors
• Persistence/degradation
• Bioaccumulation
• Sediment adsorption
characteristics
• Water characteristics
• Background/relative
condition of water (with
respect to chemical)
• Receptor characteristics
• Human toxicity
• Aquatic toxicity
• Nutrient loading
• Receptor characteristics
• Type of effect/severity
• Duration/reversibility
• Aggregate effects
Draft-August 15, 1991
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-5-
After a chemical arrives near or at the air/water interface, several factors affect the
tendency of the chemical to leave the atmosphere and enter the water. For example, the
physical state of a chemical can be gaseous or particulate, or it can result in the chemical
being sorbed to particles. Chemicals can enter the water either directly (i.e., via gas
exchange and/or dry deposition) or through scavenging by water droplets and ice particles
(i.e., wet deposition). Important factors affecting deposition to water include Henry's Law
constant, vapor pressure, solubility, and wind speed.
2.1.2 Fate in Surface Water
A chemical entering a surface water body through air deposition can subsequently
return to the air (e.g., through volatilization and "ejection"), remain in the surface microlayer,
be transformed, and/or partition into lower water layers, sediments, and biota. Eventually, the
chemical can bioaccumulate in.aquatic organisms, especially those near the top of the food
chain, and/or be taken in by humans (e.g., through water ingestion, food consumption, and
use of the water for recreational activities). Several -factors determine the fate of hazardous
air pollutants deposited to water, including persistence/degradation, bioconcentration
potential, various water and sediment characteristics (e.g., currents, volume, salinity, organic
content), the background/relative condition of the surface water with respect to a particular
chemical, and receptor characteristics (e.g., lipid content of biota, human behaviors).
2.1.3 Impacts
Adverse impacts of a chemical after it has deposited to a water body and undergone
various transport and fate processes can be immediate and direct (e.g., toxicity to biota in the
surface microlayer) or more long-term and indirect (e.g., nutrient loading and subsequent
eutrophication, closing of fisheries due to elevated tissue residues). Most, if not all, of the
important impacts from air deposition are expected to result from long-term buildup and
exposure rather than more short-term, high-level loadings (e.g., accidental releases, certain
nearby point sources). Important factors commonly used to characterize adverse impacts of
chemicals in surface waters include .toxicity to humans, toxicity to aquatic organisms and
ecosystems, impacts from nutrient loading (e.g., phosphorus concentration), aggregate
effects (e.g., across exposure pathways and toxicity endpoints), and the type, severity, and
duration of the effects.
2.2 "IDEAL" ASSESSMENT
The "ideal" approach to identifying focus chemicals from the CAAA section 112(b) list
would involve a detailed quantitative exposure and risk assessment of the 190 (or more)
chemicals represented by that list. The steps in such an assessment would parallel the
release, fate, and impact processes outlined above. That is, the "ideal" assessment would
include quantitative analysis of:
(1) releases to air, fate in air, and deposition to water;
(2) fate in water; and
(3) impacts to human health and the environment.'
Using such an approach, it would be possible to estimate—albeit with considerable
uncertainty—the human health and environmental risks posed by individual chemicals and
Draft-August 15, 1991
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-6-
thus to identify the subset of chemicals that contribute the majority (e.g., 95 percent) of the
total risk. This subset would comprise the list of focus chemicals.
This type of "ideal" assessment of hundreds of chemicals from thousands of sources
being deposited into dozens of water bodies was not possible for this analysis due to data
limitations, the unquantifiable nature of some of the important processes, and resource
constraints—nor was it necessary. The screening-level assessment needed for this analysis
only had to be conservative to the extent that it would include "borderline" substances on the
focus chemical list. That is, the approach had to incorporate the most important processes
and factors using available data and resources and, where necessary, incorporate
assumptions that would result in a focus chemical list that favored (i.e., erred on the side of)
protecting human health and the environment.
2.3 REVIEW OF PREVIOUSLY DEVELOPED SCREENING-LEVEL SYSTEMS
As an initial step toward choosing the most appropriate approach to developing a
focus chemical list, we reviewed several previously developed screening-level systems,
focusing especially on the criteria they used and their methods for combining criteria.
2.3.1 Criteria
As discussed in Section 2.1 and 2.2, there are many criteria (e.g., aquatic toxicity,
persistence) that can be used to evaluate the air deposition of chemicals to water and
subsequent effects on human health and the environment and thus that can be used to
develop a focus chemical list. Some of the most frequently used criteria in other screening-
level systems with similar purposes are:
• human toxicity;
• aquatic toxicity;
• bioconcentration potential;
• persistence; and
• waste/release volume.
For air deposition to the Great Waters, other possibly relevant criteria might include volatility,
adsorptivity, source proximity, background levels, and emissions quantity rate. Of course,
some criteria are more important and/or more useful than others. For example, a criterion
can override (i.e., weigh more heavily than) another criterion with respect to impacts in water
bodies (e.g., high persistence can be more important than a moderate to low release
quantity). Also, data may not be available for many substances for some potentially important
criteria.
* *
2.3.2 - Screening Systems
The most relevant of the screening-level systems that we reviewed—and the criteria
addressed by them—are presented in Exhibit 2. Appendix A describes these eight systems in
more detail. These systems use a variety of different technical approaches, ranging from the
very simple (e.g., using one criterion with one cut-off level) to the very complex (e.g., the
"ideal" risk assessment discussed in Section 2.2). We determined early in the project that
none of these systems could simply be adopted in its entirety for selecting Great Waters
Draft-August 15, 1991
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7-
EXHIBIT 2
SUMMARY OF CRITERIA INCLUDED IN CHEMICAL PRIORITIZATION SYSTEMS
System
CERCLA Section
102(a) RQ
Adjustment
Methodology
Superfund Hazard
Ranking System
(Revised)
Draft Guidelines
for Listing
'Chemicals on the
Toxic Release
Inventory
TSCA Persistent
Bioaccumulators
Screening Cluster
Modified
Hazardous Air
Pollutant System
RCRA Hazardous
Waste Scheduling
Methodology
OPTS Review of
224 Chemicals for
OAQPS
Inerts Ranking
Program (IRP)
Human Toxicrty
Chronic
yes
yes
yes
»
yes
yes
Acute
yes
yes
yes
yes
yes
Aquatic
Toxicrty
yes
yes
yes
?
yes
yes
Biocon-
centration
yes
yes
yes
yes
yes .
yes
yes
Persis-
tence
yes
yes
yes
yes
?
yes
yes
Waste/
Release
Volume
yes
yes
yes
Draft-August 15, 1991
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-8-
focus chemicals. Our approach, explained in Section 3, is derived from these systems—
especially the Inerts Ranking Program (IRP) and Hazard Ranking System (MRS)—and
cor aration of basic hazard and risk assessment principles.
Draft-August 15, 1991
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3. RANKING METHODOLOGY
In this section we describe the chemicals to be ranked, the general approach used to
rank the substances based on intrinsic chemical properties, the ranking criteria, the
methodology used to combine individual scores for each criterion into an overall score, the
methodology used for scoring groups of chemicals (e.g., "cadmium and compounds"), and
the identification of "special" focus chemicals.
3.1 SUBSTANCES TO BE RANKED
The CAAA section 112(b) list of hazardous air pollutants contains a total of 190
substances, which includes individual chemicals as well as groups of chemicals. There are
173 individual chemicals and groups with specific Chemical Abstracts Service (CAS) numbers
on the list. All of these 173 chemicals or groups were addressed "as is" in this ranking. The
remaining 17 substances do not have CAS numbers because they represent groups and/or
mixtures of chemicals. Of these, 15 groups were ranked. The remaining two groups—listed
as radionuclides (including radon) and fine mineral fibers—were not addressed because of
difficulties in collecting data for and applying the chemical-based scoring method. Therefore,
the universe to be ranked consists of 188 substances (individual chemicals and groups) on
the CAAA section 112(b) list. The substances included in this ranking analysis are listed both
in Section 4 (ordered by final rank) and Appendix C (ordered as listed in CAAA).
3.2 GENERAL APPROACH TO RANKING
Our general approach was to first select potential ranking criteria, then to
develop/adapt methods for evaluating and scoring each criterion, then to develop/adapt a
method for combining individual scores into an overall score, and finally to test the methods
and rank the chemicals. Our guiding principle throughout was to develop simple methods
that adequately represent relative hazard.
As discussed in'Section 2, there are many hazard- and risk-related criteria that can be
used to rank a list of chemicals. To select the most appropriate criteria to use for this
analysis, we compiled an initial list of criteria, ordered them by relative importance to air
deposition and adverse effects in the Great Waters, and selected a manageable number of
criteria from the top of the list. It is important to keep the number small because the amount
of methods development and data gathering activity is proportional to the number of criteria;
therefore, a large number of criteria would defeat the purpose of a screening-level analysis.
After considering the importance of and data availability for the criteria initially identified, the
following four were chosen as the ranking criteria for this analysis:
• „ human toxicity;
• aquatic toxicity;
bioconcentration potential; and
environmental persistence (surface water).
These criteria are related to inherent chemical-specific properties, and they
characterize the potential fate and impacts of a chemical substance in surface water. Within
the context of the underlying paradigm presented in Section 2, the properties of
bioconcentration potential and persistence are proxies for fate in surface water, and human
and aquatic toxicity are proxies for impact potential. Viewed another way, bioconcentration
Draft—August 15, 1991
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and persistence are related to exposure, while human and aquatic toxicity are measures of
different types of toxicitv. In characterizing the potential risk to human health and the
environment, measures of both exposure and .toxicity are necessary.4 Appendix B describes
in detail some readily available data sources that we examined initially for these criteria and
the specific parameters that each source includes.
The Inerts Ranking Program (IRP) methodology developed by EPA's Environmental
Research Laboratory in Duluth (ERL-Duluth) for evaluating pesticide ingredients was selected
as a general framework for ranking the CAAA section 112(b) chemicals.5 This system
appeared to be the most relevant existing system for the purpose of ranking and selecting
Great Waters focus chemicals. We then modified this system to include human toxicity as a
criterion and to focus it more on chronic (rather than acute) exposure and toxicity.
3.3 DESCRIPTION OF RANKING CRITERIA
The following subsections address each criterion: what it is, how it was evaluated,
what data sources were used, and what type of data these sources contain. For situations in
which data were available from several sources, the source hierarchy is described. Also
discussed are any other considerations or assumptions made. For organizational purposes,
we have divided the criteria into two groups: the human toxicity criterion developed by ICF,
and the environmental criteria (i.e., aquatic toxicity, bioconcentration potential,'and
environmental persistence) developed by ERL-Duluth.
3.3.1 Human Toxicity Criterion
The following subsections briefly describe the human toxicity criterion, how it was
scored, and the data sources used.
X
Description of the Human Toxicity Criterion
The human toxicity criterion attempts to measure the harm a chemical can pose to
human health. Human toxicity is generally thought of as a function of the concentration of
and the duration of exposure to the chemical. In general, as toxicity increases, fewer
molecules of the chemical are necessary to cause adverse effects (i.e., adverse effects will
occur at lower environmental concentrations). Human toxicity is commonly measured using a
number of parameters, depending in part on the type of effect being considered, including
reference doses (RfDs), slope factors (SFs) plus weight-of-evidence ratings, ten percent
effective doses (ED10s) plus weight-of-evidence ratings, minimum effective doses (MEDs), and
median lethal concentrations or doses (LC^s or LD^s).
4 We also use one other criterion related to exposure—equilibrium partitioning behavior
based on fugacity—for certain chemicals to provide qualifying information.
5 For a general description of this methodology, see Appendix A. For details, see
Anderson et a]., Ranking of Pesticide Inert Ingredients Using the AQUIRE Data Base and
Structure Activity Relationships, Draft Internal Report, U.S. EPA, Environmental Research
Laboratory, Duluth (no date).
Draft-August 15, 1991
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Scoring the Human Toxicrty Criterion
Our methodology for scoring human toxicity is based primarily on the Superfund
Hazard Ranking System (HRS) toxicity scoring component. This approach was selected m
part because it relies on existing EPA data bases and EPA-published scoring algorithms.
Furthermore, the HRS approach met the needs of this analysis as it (1) provides adequate
discrimination by "sorting" chemicals into five relative toxicity categories; (2) emphasizes
chronic toxicity (including carcinogenicity) over acute toxicity; and (3) to the extent possible
uses high quality, peer reviewed data. Finally, the HRS toxicity scoring component had
already been developed, and more than half of the 188 hazardous air pollutants had recently
been evaluated with it.
Using this methodology, with some minor modifications, we distributed the 188
substances into five toxicity categories—corresponding to scores of 1, 1.5, 2, 2.5, and
36_based on three types of toxicity: carcinogenicity, chronic non-cancer toxicity, and acute
toxicity. The unmodified HRS toxicity scoring, method uses SFs combined with weight-of-
evidence ratings to score for carcinogenicity/ If an SF is not available for a substance, its
ED10 value is used to estimate an SF. RfDs and LD50s or LC50s are used as measures of
non-cancer toxicological responses of chronic exposure and acute exposure, respectively.
Subscores are developed for the two chronic toxicity types based on prder-of-magnitude
scoring scales, and the higher subscore is taken to represent the overall toxicity of a
substance. If appropriate chronic toxicity data are unavailable, the score is based on acute
toxicity. Details of the methodology are given in the HRS final rule (55 Federal Register
51532).
The scale used in this analysis for scoring the human toxicity criterion is presented in
Exhibit 3, and the general hierarchy of data sources and toxicity types and exposure routes
are presented below.
(1) Hierarchy of Data Sources. To the extent possible, we used peer-reviewed,
EPA-accepted cancer and chronic toxicity data such as SFs and RfDs from
EPA.'s Integrated Risk Information System (IRIS) and Health Effects
Assessment Summary Tables (HEAST). We extracted these data from the
April 1991 HRS data base—the Superfund Chemical Data Matrix (SCDM)—and
from HIRIS—an ICF in-house data base that stores data from both IRIS and
HEAST. If data were not available in these, the next tier of data sources
included EPA's Chemical Unit Risk Estimate (CURE) data base, followed by
the Registry of Toxic Effects of Chemical Substances (RTECS), and, finally,
EPA's 1990 reportable quantity (RQ) data base.
6 We modified the HRS scale, which assigns values of 1, 10, 100, 1,000, and 10,000 to the
five categories to make it consistent with the environmental criteria, which are scored as 1, 2,
or 3.
7 One modification we made, to be consistent with other OAQPS toxicity evaluations, was
to adjust the HRS scoring method for carcinogens such that Group C substances were
treated the same as Group B substances. We also incorporated a preference for oral toxicity
data over inhalation toxicity data.
Draft-August 15, 1991
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EXHIBIT 3
SCALES FOR SCORING HUMAN TOXICITY
Chronic Toxicrty:
RfD (mg/kg-day)
RfD < 0.0005 = 3
0.0005 _< RfD < 0.005 = 2.5
0.005 <. RfD < 0.05 3 2
0.05 <. RfD <: 0.5 = 1.5
0.5 <. RfD =1
No Data = 0
Carcinogenicity (substances are not assigned a score of 1):
SF (mg/kg-day)'1
WOE" = A WOE" = B,C
0.5 < SF 5 < SF =3
0.05 <. SF < 0.5 0.5 <. SF < 5 = 2.5
SF < 0.05 0.05 < SF < 0.5 =2
SF < 0.05 =» 1.5
No Data No Data = 0
v
Acute Toxicrty (substances are not assigned a score of 3):
Oral LOjQ (mg/kg)
LDgQ < 5 =2.5
5 <. LDgo < 50 =2
50 < LDgQ < 500 a 1.5
500 <. LDgQ = 1
No Data = 0
LC50 Ga* (PPm>
LCgg < 20 =2.5
20 <_ LCgQ < 200 =2
200 <. LCgQ < 2,000 = 1.5
. 2,000 <. LC50 = 1
No Data = 0
a WOE = EPA's weight-of-evidence rating for human carcinogenicity.
Dratt—August 15, 1991
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-13-
(2) Hierarchy of Toxicitv Types. We used chronic toxicity data over acute
toxicity data, when possible, to reflect the emphasis of this study on
potential long-term air deposition and buildup.
(3) Hierarchy, of Exposure Routes. We used oral toxicity data over inhalation
data when possible, because we are concerned with exposures and toxic
effects occurring after air deposition into the Great Waters, expected to be
mostly via oral routes such as drinking water and fish ingestion.
The results of our data search are presented in Section 4, which describes the integration of
these separate hierarchies and the number of substances that were scored using each tier.
3.3.2 Environmental Criteria
The environmental criteria used for ranking are aquatic toxicity, bioconcentration
potential, and environmental persistence. The following subsections briefly describe these
criteria, how they were scored, and the data sources used.
Descriptions of the Environmental Criteria
Aquatic toxicitv generally refers to a chemical's potential to harm living aquatic
organisms. As with human toxicity, it is a function of the concentration of and the duration of
exposure to the chemical. Aquatic toxicity is measured in parameters similar to those for
human toxicity. The parameters used in this ranking include the LC50, median effective
concentration (EC50), and the maximum acceptable toxicant concentration (MATC).
Bioconcentration potential refers to the tendency for chemicals to be taken in and
concentrated by biota. Bioconcentration factors (BCFs), which are specific to aquatic
.systems, are commonly used as a measure of bioconcentration potential. A BCF.is the
equilibrium ratio of the concentration of a chemical in the organism (or in a specific tissue)
and its concentration in the water column. Strictly speaking, the BCF is a measure only of
the direct uptake of the chemical by the organism from the water column (i.e., exposure via
the food chain is not included), although this distinction may not be significant for a particular
chemical.8
Environmental persistence is a measure of the amount of time that a chemical retains
its physical and chemical characteristics while being transported and distributed in the
environment. Persistence in a specific medium, such as surface water, also takes into
account a chemical's tendency for media transfers. Chemicals that are not significantly
degraded can accumulate to toxic levels in the environment. As persistence increases, the
a
A second main measure related to bioconcentration potential are bioaccumulation
factors (BAFs). A BAF is the equilibrium- ratio of the concentration of a chemical in the
organism (or specific tissue) and its concentration in an environmental medium (or another
organism). The BAF is a measure of uptake via all routes, including directly from
environmental media and via the food chain; thus, the BAF is always greater than or equal to
the BCF. BCFs and BAFs may be measured either for the whole body of the organism or
only for specific (e.g., edible) tissues. A related term, biomaQnification. refers to successively
higher concentrations at successively higher trophic levels.
Draft—August 15, 1991
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- 14-
time course over which adverse effects may occur is lengthened. Persistence in surface
water may be estimated from the octanol-water partition coefficient (Kow), solubility, Henry's
Law constant, and/or measured half-life data. A chemical's half-life is defined as the time
required to reduce its initial concentration by one-half.
Scoring the Environmental Criteria
The CAAA section 112(b) substances were scored for each of the environmental
criteria using a modification of the IRP methodology developed by ERL-Duiuth.9
Original IRP Scoring Method. The IRP scoring method was originally developed by
ERL-Duluth to assist EPA's Office of Pesticide Programs (OPP) by determining the potential
for high or low ecological concern of specified inert pesticide ingredients to aquatic
organisms. The original IRP ranks chemicals based on a summation of scores assigned to
each of five environmental criteria: (1) acute aquatic toxicity, (2) chronic aquatic toxicity, (3)
bioconcentration potential, (4) environmental persistence, and (5) environmental partitioning.
In the calculation of the overall IRP score, each of the five environmental criteria scores is
given equal weight. Each criterion has a possible score of 0, 1, 2, or 3. A score of 0
indicates that no data are available, and a score of 3 indicates highest concern. The overall
IRP score for a chemical is derived by adding the scores for each criterion, dividing by the
number of criteria for which there are data, and then multiplying by ten to produce an overall
IRP score on a scale of 10 (low aquatic concern) to 30 (high aquatic concern). This overall
scoring algorithm is equivalent to an arithmetic averaging of the individual criteria scores for
which data are available.
Modified Scoring Method. We modified the IRP method for scoring the environmental
criteria and for determining the overall scores for the CAAA section 112(b) chemicals. First,
we combined acute aquatic toxicity and chronic aquatic toxicity into a single criterion (i.e.,
aquatic toxicity). This criterion is scored based strictly on chronic toxicity data when possible;
scores are based on acute toxicity only if the chronic toxicity data are not available. This
change reflects our emphasis on chronic exposures and risks in this analysis, and it also
makes the aquatic toxicity criterion more consistent with the human toxicity criterion. Second,
we modified the environmental persistence scale such that substances will score a 1 or a 3
only. We did not find the scores of 1 and 2 to be very discriminating among the CAAA
substances with respect to persistence, nor did we consider the difference in a half-life of < 4
days (original IRP scale cutoff for a score of 1) versus 4 to 15 days (original IRP scale range
for a score of 2) very significant in light of this project'? focus on chronic exposures and risks.
Third, we did not consider environmental partitioning as a ranking criterion because of
concern about double-counting with other criteria (especially bioconcentration potential) and
uncertainties about how to properly scale and weight this criterion in the modified scoring
method. We did, however, use environmental partitioning as a "qualifying" criterion and in
sensitivity analyses. Scales used to derive scores for each of the environmental criteria are
presented in Exhibit 4.
9 For details on the IRP, see Anderson et a}., Ranking of Pesticide Inert Ingredients Using
the AQUIRE Data Base and Structure Activity Relationships, Draft Internal Report, U.S. EPA,
Environmental Research Laboratory, Duluth (no date).
Draft-August 15, 1991
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- 15-
EXHIBIT 4
SCALES FOR SCORING ENVIRONMENTAL CRITERIA
Chronic aquatic toxicity:
EffecVNo Effect or MATC < 0.1 mg/l = 3
EffecVNo Effect or MATC 0.1 - 10 mg/l = 2
Effect/No Effect or MATC > 10 mg/l = 1
No data or prediction available = 0
Acute aquatic toxicity;3
ECgoor LCgo <1 mg/l = 3
ECjoorLCgoMOOmg/l =2
EC50 or LC50 > 100 mg/l = 1
No data or prediction available = 0
Bioaccumulation potential:
BCF > 999 = 3
BCF 93-999 = 2
BCF < 93 =1
No data or prediction available = 0
Environmental persistence:
half-life > 15 days = 3
half-life < 15 days = 1
No data or prediction available = 0
Used only if chronic aquatic toxicity data are unavailable.
Draft—August 15, 1991
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-16-
Chronic aquatic toxicrty data (e.g., 28-day ECgg, effect/ho effect or MATC data) and
acute toxicity data (e.g., 4-day LC^ or ECgQ data) were obtained either from the Aquatic
Toxicity Information Retrieval (AQUIRE) data base or by application of Quantitative Structure
Activity Relationship (QSAR) data base and models (except for a few values based on
professional judgment). The data needed for scoring bioconcentration potential (e.g., the
BCFs and individual octanol-water partitioning coefficient [Kow] values) were also obtained
from AQUIRE or QSAR. Environmental persistence data (biodegradation half-life values) were
calculated based on QSAR and methods given in Neimi et al. (1987).10 The AQUIRE values
represent experimental data while QSAR values are based on correlation equations or
structure activity relationships. All of the data for environmental criteria were developed by
ERL-Duluth.
3.4 OVERALL SCORES
After a chemical was assigned scores for as many of the four criteria as possible, an
overall score based on all criteria-specific scores was derived. The methodology for this
derivation is similar to that for deriving the original IRP score. That is, for each substance, the
overall score was derived by adding the scores for the four criteria, dividing by the number of
criteria for which there were data, and then multiplying by 1 0 to produce an overall score on a
scale of 1 0 to 30. The overall score was then used to rank the CAAA section 1 1 2(b)
substances.
Another difference between the approach used for the CAAA chemicals and the
original IRP approach is that, for the CAAA chemicals, a chemical was not ranked if it did not
have data for at least one toxicity criterion and one exposure-related criterion. That is, a
substance must have either a human toxicity or aquatic toxicity score and either a
bioconcentration or persistence score to be ranked.
3.5 GROUPS OF SUBSTANCES
After two groups— radionuclides and fine mineral fibers— were removed from
consideration for this ranking, 1 9 remaining entries on the CAAA section 1 1 2(b) list of
hazardous air pollutants represent "groups" of chemicals (e.g., lead compounds, polycyclic
organic matter, glycol ethers) rather than individual substances. A slightly different method
was used to score these groups of chemicals.
The groups of chemicals could not be directly assigned to the human toxicity or
environmental criteria score categories. In order to score these groups, we first identified
representative members of each group. We then obtained data for each of the four criteria
for each representative member, scored each representative member as an individual
substance, and ranked the group based on its highest scoring member for each criterion.
That is, the score of the highest scoring member was assigned for each criterion, and thus
the four criteria-specific scores for a group could be based on up to four different members of
the group. For example, in the "arsenic compounds" group, arsenic had the highest acute
aquatic toxicity score (3) and chronic aquatic toxicity score (3), but arsenic pentoxide had the
highest bioconcentration potential score (2). The reason this approach was used, rather than
10 Niemi et al. 1987. Structural Features Associated With Degradable and Persistent
Chemicals. Environ. Toxicol. Chem. 6:515-527.
Draft-August 15, 1991
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- 17-
simply assigning the group the overall score of its highest scoring member, was primarily
because of the large amount of missing data for many group members. This approach,
though possibly overly conservative, was used so that all available data could be
incorporated. Furthermore, not all (or even most members of the various groups were
included in this analysis, so some conservatism in evaluating those members that were
included was considered to be a reasonable approach.
For some of the criteria, the entire group was given a score based on professional
judgment rather than a score for a member of the group. For example, an environmental
persistence score of 3 was given to all metal groups and PCBs based on professional
judgment.
Exhibit 5 indicates which individual substances provided the highest scores for the
groups. Scores for two groups cresols/cresylic acid and xylenes are based on the highest
scoring of their meta-, ortho-, and para-isomers, all of which are listed as individual
substances in CAAA section 112(b).
3.6 "SPECIAL" FOCUS CHEMICALS
"Special" focus chemicals refers to substances previously identified by various groups
as known or suspected to significantly impact Great Waters. We identified a set of special
focus chemicals as described below, and used them in our initial testing of various ranking
procedures and in our sensitivity analysis to evaluate the final ranking results.
In order to identify special focus substances, we targeted organizations that have
identified or that currently monitor critical pollutants present in or deposited into Great Waters.
We obtained information on the activities of five organizations:11 (1) the Water Quality
Board of the International Joint Commission; (2) the Air Resources Branch of the Ontario
Ministry of Environment; (3) the Great Lakes Atmospheric Deposition network; (4) Lake
Michigan Lakewide Management Plan (LaMP); and (5) the Lake Ontario Toxics Committee.
Each organization and their substances of concern are briefly described below. The level of
detail of these descriptions varies with the amount and level of detail of the documentation we
received. The specific substances of concern selected by each organization, and the reasons
for each selection, are presented in Section 4 (except where noted below). Based on the
documentation we received for each of these lists of substances of concern, it does not
appear that any were selected based on quantitative models or systems such as the one
developed and used in this analysis.
3.6.1 Water Quality Board of the International Joint Commission
The Water Quality Board of the International Joint Commission (IJC) selected 11
substances by-consensus as "critical pollutants".12 The Board noted that "these substances
11 We have identified a sixth organization which is concerned with Chesapeake Bay
chemicals; however, we were not abJe to obtain the relevant information before this analysis
was completed.
12 Great Lakes Water Quality Board, 7985 Report on Great Lakes Water Quality, Report to
the International Joint Commission, 1985.
Draft—August 15, 1991
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EXHIBIT 5
INDIVIDUAL CHEMICALS USED TO SCORE FOR GROUPS
Group/Representative Chemicals a
Criterion Scored
Antimony Compounds
Antimony trichloride
Elemental antimony
Arsenic Compounds
Arsenic oxide
Arsenic pentoxide
Non-soluble arsenic
Beryllium Compounds
Beryllium sulfate
Elemental beryllium
Cadmium Compounds
Cadmium
Cadmium chloride
Cadmium oxide
Chromium Compounds
Chromium
Chromium oxide
Chromic chloride
Cobalt Compounds
Cobalt chloride
Elemental cobalt
Cyanide Compounds
Hydrocyanic acid
Lead thiocyanate
Glycol Ethers
Heptaetnylene glycol
dodecylether .
Diethylene glycol monobutyl
ether
Ethylene glycol monomethyl
ether
Lead Compounds
Lead nitrate
Elemental lead
Manganese Compounds
Manganese
Manganese chloride
Elemental manganese
Acute Aquatic Toxicrty, Chronic Aquatic Toxicrty
Human toxicity
Acute Aquatic Toxicity, Chronic Aquatic Toxicity
Bioconcentration Potential
Human Toxicity
Acute Aquatic Toxicity
Human Toxicity
Acute Aquatic Toxicity
Chronic Aquatic Toxicity, Bioconcentration Potential
Human Toxicity
Acute Aquatic Toxicity
Chronic Aquatic Toxicity
Human Toxicity
Acute Aquatic Toxicity, Chronic Aquatic Toxicrty
Human Toxicity
Acute Aquatic Toxicity, Chronic Aquatic Toxicity
Human Toxicrty
Acute Aquatic Toxicity, Chronic Aquatic Toxicity,
Bioconcentration Potential
Environmental Persistence
Human Toxicity
Acute Aquatic Toxicrty, Bioconcentration Potential
Human Toxicity
Chronic Aquatic Toxicity
Acute Aquatic Toxicity
Human Toxicrty
Draft-August 15, 1991
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- 19-
EXHIBIT 5 (continued)
Group/Representative Chemicals a
Criterion Scored
Mercury Compounds
Mercuric acetate
Mercuric chloride
Aceto-o-phenyl mercury
Nickel Compounds
Nickelous chloride
Elemental nickel
Polycyclic Organic Matter/Coke Oven Emissions
Anthracene
1 -Methyl-phenanthrene
Benzo(b)fluoranthene
Selenium Compounds
Selenium
Soluble selenium
Oibenzofurans
3-Nitrodibenzofuran
2,3,4,7,8-Pentachloro
dibenzofuran
PCBs
Aroclor 1016
2,4'-Oichlorobiphenyl
Polychlonnated biphenyls11
Acute Aquatic Toxictty
Chronic Aquatic Toxicrty, Bioconcentration Potential
Human Toxicity
Acute Aquatic Toxicity, Chronic Aquatic Toxicity
Human Toxicrty
Acute Aquatic Toxicity
Chronic Aquatic Toxicity, Bioconcentration Potential
Human Toxicity
Acute Aquatic Toxicity, Chronic Aquatic Toxicrty
Human Toxicrty
Acute Aquatic Toxicity, Chronic Aquatic Toxicrty,
Bioconcentration Potential
Human Toxicrty
Acute Aquatic Toxicity
Chronic Aquatic Toxicity, Bioconcentration Potential
Human Toxicity
a At times, more than one chemical in a group had the same criterion score. In this exhibit, we present only one of
these chemicals to represent the chemical group for tfiat criterion.
IRIS provides a human toxicrty value for PCBs as a group.
Draft-August 15, 1991
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-20-
are all present in the Great Lakes ecosystem, are highly toxic and persistent, and can
bioaccumulate to levels which can threaten human health and the aquatic system." A later
IJC'report, in 1987,13 notes that 10 of the 11 consensus critical pollutants are present in air
(mirex excepted14) and that deposition into the Great Lakes basin, either directly onto the
water surface or indirectly onto the drainage basin with subsequent transport, has been
clearly demonstrated.15 The 1987 report also notes that the 11 consensus substances are
"Primary Track" critical pollutants in terms of abatement and control. The Primary Track
requires identification and quantification of sources, pathways, and fate of contaminants so
that control and abatement programs can be properly focused and directed.
In the 1988 IJC report,16 13 substances, including eight of the Board's 11 critical
pollutants, are evaluated with regard to atmospheric deposition. The report concludes that
organic anc organic contaminants on the 1985 critical pollutant list are present in rain,
snow, atmc sric aerosols, and in the vapor state in the Great Lakes basin. (For PCBs,
Aroclor 125*+ ^vas evaluated.)
Finally, the Great Lakes Water Quality Agreement of 1978 called for the compilation
and maintenance of three lists of substances (the Annex 1 Lists of Substances).17 These
three lists are "present and toxic", "present and potentially toxic", and "potentially present and
toxic". Substances for the three lists'have been selected using specified standard methods.
Note, however, that these three are not lists of substances of significant or highest concern in
the Great Lakes System. (For example, the "present and toxic" list contains substances that,
although toxic, are not present at levels of concern.) Rather, the lists identify the universe of
substances present or potentially present in the system, allowing systematic review to identify
substances of greatest concern. Annex 1 list substances are not included in Section 4.
3.6.2 Air Resources Branch of the Ontario Ministry of the Environment
-*
Under the auspices of the Acidic Precipitation in Ontario Study (APIOS), the Deposition
Monitoring Group of the Air Resources Branch of the Ontario Ministry of the Environment
13 Great Lakes Water Quality Board, 7987 Report on Great Lakes Water Quality, Report to
the International Joint Commission, 1987.
14 The Strachan and Eisenreich Report—discussed later in this section—suggests that
mirex, most commonly found in fish and sediment of Lake Ontario, probably comes from
industrial discharge and that atmospheric deposition is not likely to be a significant source of
mass loading to the Great Lakes.
15 The 1987 report, does not provide quantitative estimates of atmospheric loading for all
the '"itical contaminants; only semi-quantitative discussions for a few substances are
pro' 3d.
16 Strachan, W.M.J., and Eisenreich, S.J., "Mass Balancing of Toxic Chemicals in the
Great Lakes: The Role of Atmospheric Deposition", 1988 Report on Great Lakes Water
Quality, Report to the International Joint Commission, 1988.
17 International Joint Commission, Revised Great Lakes Water Quality Agreement of 1978,
September, 1989.
Draft-August 15, 1991
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(OME) carries out air deposition monitoring (three separate networks) for specific substances.
This monitoring will assist in assessinq the importance of atmospheric deposition of certain
chemical species to the Great Lakes.
3.6.3 Great Lakes Atmospheric Deposition Network
The Great Lakes Atmospheric Deposition (GLAD) network was established in 1981
under the Great Lakes Water Quality Agreement between Canada and the United States. The
GLAD network includes 36 monitoring stations along the U.S. shores of the Great Lakes to
characterize atmospheric deposition. These monitoring stations sample nutrients and
metals.19
3.6.4 Lake Michigan Lakewide Management Plan
A Great Lakes Water Quality Agreement of 1978 calls for the development of a
Lakewide Management Plan (LaMP) for Critical Pollutants for each of the Great Lakes.20
The purpose of a LaMP is to reduce loadings of "Critical Pollutants" in order to restore
beneficial uses of the open lake waters. Critical Pollutants are defined as substances that
persist at levels that singly, or in synergistic or additive combination, are causing, or are likely
to cause, impairment of beneficial uses despite past application of regulatory controls due to
their: (1) presence in open lake waters; (2) ability to cause or contribute to a failure to meet
Agreement objectives through their recognized threat to human health and aquatic life; or (3)
ability to bioaccumulate. The Lake Michigan LaMP has identified 23 candidate Critical
Pollutants. EPA has indicated that they may only focus on 13 of these 23 pollutants, although
all 23 pollutants (with the exception of oil and other petroleum products) are included in
Section 4 (primarily because it was not clear from our brief review why the 13 were selected).
3.6.5 Lake Ontario Toxics Committee
The Lake Ontario Toxics Committee identified substances of concern in Lake Ontario
based on their impacts on human health and biota.21 After reviewing available ambient
water column and fish tissue data, the Committee selected substances based on human
health impact if (1) measured concentrations of these substances in edible portions of fish
tissue exceeded Canadian or U.S. standards (or more stringent, but unenforceable EPA
guidelines), or (2) the substances are measured in ambient water column samples at levels
above standards and criteria designed to protect human health. Substances were also
included on the list if they bioaccumulate in fish tissue to levels that are unsafe for
18 Tang, et a]., Summary: Some Results From the API OS Atmospheric Deposition
Monitoring Program, Report ARN-110-86, 1986.
19 Gatz et a]., Great Lakes Atmospheric Deposition Network Data Analysis and
Interpretation, 1986.
20
U.S. EPA, Baseline Report: Lake Michigan Lakewide Management Plan, (no date).
21 Environment Canada, U.S. EPA, Ontario Ministry of the Environment, New York State
Department of Environmental Conservation, Lake Ontario Toxics Management Plan, A Report
by the Lake Ontario Toxics Committee, February 1989.
Draft-August 15, 1991
-------
-22-
consumption by wildlife or are measured in ambient water column samples at levels oove
standards and c';i9ria designed to protect aquatic life.
evidence of significant air deposition or potential for air deposition was not directly
considered in developing this list. In discussing the sources of toxic substances input into
Lake Ontario, however, the Committee implicated air deposition as one of the important
pathways for eight substances of concern. The Committee provided rough estimates of the
loadings (kg/day) of these substances into the lake (based on either monitoring data or
mass-balance estimation).
Draft—August 15, 1991
-------
4. RESULTS
In this section we present and discnas the ranting results. First, we address which
chemicals lack criteria scores and therefore cannot be ranked. We also discuss the quality
and coverage of the data that support the rankings. Then, for each substance, we present
the four criteria-specific scores, the overall score, and finally the overall ranking. Also in this
section, we discuss the results of the "special" focus chemical analysis and the sensitivity
analysis that we conducted to test the "accuracy"22 of the rankings.
4.1 SUBSTANCES LACKING CRITERIA SCORES
As discussed in Section 3.4, a substance was ranked only if it had both a toxicity-
related score and an exposure-related score. Thus, a substance must have either a human
toxicity or aquatic toxicity score and either a bioconcentration potential or environmental
persistence score to be ranked.
All of the 188 substances on the CAAA section 112(b) list that were to be ranked had a
toxicity score (human health and/or aquatic). Nine substances did not have data for both the
bioconcentration and persistence criteria (i.e., exposure-related data) and therefore were not
ranked. These nine substances, along with their individual criteria scores, are listed in Exhibit
6. The remaining 179 substances were ranked and are the focus of the remainder of the
results discussion.
4.2 DATA QUALITY AND COVERAGE
Because the quality and availability of data can significantly influence the accuracy of a
ranking, we evaluated these factors as part of-this analysis. For most criteria, this analysis
relied on experimental data where available. If a substance did not have experimental data,
then data based on QSAR were used. Finally, for some substances that still lacked data,
ERL-Duluth scored some of the criteria based on professional judgment.
Appendix C-1 shows the data quality and data coverage for the 179 scored
substances. For each of the four criteria used in the ranking (i.e., human toxicity, aquatic
toxicity,23 bioconcentration potential, and environmental persistence), the appendix lists: (1)
the individual score for the criterion which also (indicates data availability, i.e., 0 = no data);
and (2) whether the score was based on experimental data, QSAR predictions, or
professional judgment. In this appendix, "E" denotes that the score was based on
experimental data. For human toxicity, experimental data were from the sources discussed in
Section 3.3. Experimental data supporting scores for the environmental criteria were from
AQUIRE. Scores based on QSAR and on professional judgment are denoted by "Q" and "PJ",
respectively.
22
"Accuracy" is used here to loosely define the degree to which the ranking successfully
places chemicals that are known or suspected to be of relatively high concern (toxic and
persistent in aquatic systems) at the top of the scale and vice-versa.
23
Although aquatic toxicity was a single criterion in the ranking, data quality and
coverage are shown for both acute and chronic aquatic toxicity in Appendix C-1.
Draft-August 15, 1991
-------
-24-
EXHIBIT 6
SUBSTANCES NOT RANKED
CAS #
1332214
15667
75150
463581
334883
96457
7664393
7803512
7550450
Chemical Name
Asbestos
Calcium Cyanamide
Carbon Disulfide
Caroonyl Sulfide
Diazomethane
Ethylene Thiourea
Hvdrogen Fluoride (Hydrofluoric Acid)
osphine
Titanium Tetrachloride
Human
Toxicity
Score
3
1
1.5
1
2
1.5
1.5
3
1.5
Aquatic
Toxicity
Score
0
2
2
0
0
1
0
0
0
Biocon.
Poten.
Score
0
0
0
6
0
0
0
0
0
Envir.
Poten.
Score
0
0
0
0
0
0
0
0
0
Draft-August 15, 1991
-------
-25-
4.2.1 Human Toxicity
We were able to score 178 of the 179 substances for human toxicity based on data
from the sources listed in Section 3. Human toxicity data were not available for only one
substance—2,2,4-trimethylpentane. As indicated in Appendix C-1, all of the toxicity values
used for scoring were based either directly or indirectly on experimental data. Examples of
direct experimental data include RfD, MED, and LC^ values. The only indirect experimental
data used in evaluating human toxicity were the RQ-based data for acute toxicity, used for
only two substances (see Step 11 below).
Human toxicity scores for most of the 178 substances (87 percent) were based on
chronic toxicity data. Acute toxicity data were used to score only 24 substances (13 percent).
As indicated in Section 3, oral toxicity values were used in preference to inhalation or dermal
values. Thus, we assigned human toxicity scores by evaluating, in the following order,
chronic oral data, chronic inhalation data, acute oral data, acute inhalation data, RQ-
carcinogen data, and, finally, RQ-acute data. All scores were assigned based on the scales
given in Exhibit 3. A more specific description of the hierarchy used in our data search, along
with the number of chemicals addressed by each step (in parentheses), is presented
below:24
(1) Using oral R*fDs and oral SFs from SCDM, scores were assigned to as many
substances as possible. If a chemical had both an oral RfD and SF that
resulted in identical human toxicity scores (TOX scores), the oral RfD was
referenced as the source of the score. (101 substances)
(2) For as many of the remaining substances as possible, oral RfDs and oral
SFs from the HIRIS data base (an ICF in-house data base containing IRIS
and HEAST data) and from EPA Health Effects Assessment and Health
Assessment documents were used to assign scores. If a chemical had both
an oral RfD and SF that resulted in identical TOX scores, the oral RfD was
referenced as the source of the score. (17 substances)
(3) Next, we used oral ED10s from the SCDM. "Equivalent" SFs were estimated
by using the equation SF = l/(6 x ED10).25 These approximated SFs were
then used to assign the TOX scores. (1 substance)
(4) For the remaining substances, we searched for human MEDs in EPA's
CURE data base. "Equivalent" RfDs were estimated by using the equation
24 See Chapter 3 for references.
25 Correlation studies conducted by EPA's Carcinogen Assessment Group in 1986
indicate that potency factors based on ED10 (i.e., 1/ED10) are approximately six times greater
than upper bound slope factors based on the multistage model (i.e., qf). (Cogliano, EPA's
Methodology for Adjusting Reportable Quantities of Potential Carcinogens, 1987.)
Draft—August 15, 1991
-------
-26-
RfD = MED/60.26 These approximated RfDs were then used to assign
TOX scores. (23 substances)
(5) Next, we assigned scores based on inhalation RfDs and inhalation SFs from
SCDM. If a chemical had both an inhalation RfD and SF that resulted in
identical TOX scores, the inhalation RfD was referenced as the source of the
score. (2 substances)
(6) Next,-we assigned scores based on inhalation RfDs and inhalation SFs from
the HIRIS data base. Again, if a chemical had both an inhalation RfD and
SF that resulted in identical TOX scores, the inhalation RfD was referenced
as the source of the score. (2 substances)
(7) Next, we used acute LD50s (oral) from the SCDM to assign TOX scores.. (5
substances)
(8) Next, we used acute LC50s (inhalation) from the SCDM to assign TOX
scores. If both dust/mist and gas/vapor data were available for a chemical,
the route that resulted in the higher TOX score was used. (1 substance)
(9) Next, we searched for acute oral and inhalation data in RTECS. TOX scores
were assigned based on mammal studies conducted after 1970 that resulted
in the lowest LD50s or LC50s. (15 substances)
(10) Next, we searched EPA's RQ data base to determine if any of the remaining
substances have primary RQs based on carcinogenicity. If so, we extracted
the potency factors (i.e., 1/ED10 for these substances. "Equivalent" SFs
were estimated by using the equation SF = Potency Factor/6, as done in
Step 3. These approximated SFs were then used to assign TOX scores. (7
substances)
(11) Finally, we searched EPA's RQ data base to determine if any of the
remaining substances have primary RQs based on acute toxicity. If so, TOX
scores were assigned using the following scale, which was developed by
"mapping" the RQ acute toxicity scale onto the acute toxicity scale used in
this analysis (and shown in Exhibit 3) (2 substances):
RQ of 1 or 10 pounds = TOX score of 2.5
RQ of 100 pounds = TOX score of 2
RQ of 1000 pounds = TOX score of 1.5
RQ of 5000 pounds = TOX score of 1
26 Because the MEDs used in the RQ methodology are not directly comparable to RfDs,
we designed a simple procedure to convert MEDs into "equivalent" RfD values. Based on the
ratios of RfDs to MEDs from a large chemical data set and a review of the two derivation
methodologies, we determined that dividing MEDs by a factor of 60 would, for the purposes
of this screening analysis, account for the differences in these methodologies.
Draft—August 15, 1991
-------
-87-
For a few chemicals, exceptions to the methodology described above were needed.
These exceptions were:
• Lead compounds were assigned a "default1 human toxicity score of 3 based
on information in the MRS guidelines.
• For 1 ,2-propylenimine (2-methvl aziridine). the LD^ (dermal) from the
Extremely Hazardous Substances (EHS) data base (IGF in-house data base)
was used to assign a human toxicity score.
For all substances that were scored for human toxicity, Appendix C-2 lists the score along
with the "TOX type" (the toxicity parameter), "TOX value" (the actual toxicity value), and the
"TOX source" (source of the toxicity value).
4.2.2 Aquatic Toxicity
T*nf thig criUiiiuii, we ir?Ba the ERL-Duluth data to score 172 of the 179 substances,
with 1 47 (82 percent) based on chronic aquatic toxicity. Of these 1 47 substances, scores for
56 (31 percent of the 179) were based on experimental chronic toxicity data that was judged
by ERL-Duluth to be of high quality; scores for 58 (32 percent of the 1%79) were based on
chronic toxicity as predicted by QSAR; and scores for 33 (18 percent "of the 179) were based
on a professional judgment assessment of their chronic toxicity. Of this last set (i.e., 33
based on professional judgment), the chronic aquatic toxicity score was set at the maximum
value of 3 for 31 substances because they were identified as being "reactive electrophiles".
Such substances are likely to have toxic effects as a consequence of their electrophiiic
reactivity; that is, they cause alkylation or arylation of nucleophiiic moieties in critical
biological macromolecules (e.g., proteins, membranes).
Approximately 1 4 percent of the 1 79 substances were scored based on acute toxicity.
A little less than half of these substances had experimental data to support their aquatic
toxicity scores. The remaining substances were scored for aquatic toxicity based either on
acute toxicity as predicted by QSAR or on ERL-Duluth's professional judgment. Appendix C-3
lists the scores and the supporting parameter values for all the environmental criteria.
4.2.3 Bioconcentration Potential
Roughly 97 percent of the 1 79 substances were scored based on their potential to
bioconcentrate in aquatic organisms. Most of these scores were based on QSAR predictions
(79 percent). A relatively small number of substances (10 percent) have experimental data on
their bioconcentration potential, with the remainder based on professional judgement. In
general, substances with experimental data tended to score high for this criterion.
4.2.4 Environmental Persistence
were scored based on their tendency to
persist in the aquatic environment. None of these scores are based on experimental values;
environmental persistence was assessed based either on QSAR predictions (40 percent of the
substances) or on professional judgment (58 percent of the substances).
Draft-August 15, 1991
-------
-28-
4.3 CRITERIA-SPECIFIC SCORES AND OVERALL RANK
Using the methodology described in Section 3, the 179 substances with adequate data
for ranking were scored for each of the four criteria, and then these individual scores were
used to compute an overall score. Exhibit 7 shows these 179 substances ranked by their
overall scores; it also shows the criteria-specific scores. Twenty-three discrete scores were
obtained, and therefore 23 ranks were created using this approach. An asterisk (*) indicates
that the chemical is predicted to partition into less than one percent of the media of concern
(see Section 4.5.2).
4.3.1 Criteria-specific Scores
Exhibit 8 shows the distribution of scores for the two toxicity criteria and the two
exposure-related criteria. Percentages shown reflect the number of substances out of 179
that received scores of 0,' 1, 2, or 3 (or, in the case of human toxicity, scores of 0, 1, 1.5, 2,
2.5, or 3; and in the case of environmental persistence, scores of 0, 1, or 3).
Human Toxicitv. As discussed previously, and as shown in Exhibit 8, almost all the
substances were scored for human toxicity. Data were not available for only one substance,
2,2,4-trimethylpentane. As also shown in Exhibits, the scoring distributed the 178
substances into the five non-zero categories in a relatively even manner (approximately 20
percent of the substances in every category).
Aquatic Toxicitv. Approximately 96 percent of the substances were scored for their
toxicity to aquatic organisms. These scores tended toward the mid- and high-end of the
scale (scores of 2 and 3).
Bioconcentration Potential. Approximately 97 percent of the substances were scored
for their potential to bioconcentrate in aquatic organisms. Data for most substances (70
percent) indicated a relatively low tendency to bioconcentrate (as indicated by a score of 1). »
Environmental Persistence. Almost 97 percent of the substances were scored for their
tendency to persist in the aquatic environment. Most (72 percent) scored low on the scale
(score of 1), indicating a relatively short half-life in aquatic environments (i.e., less than 15
days). As indicated by a score of 3, approximately 25 percent of the substances are
expected to persist in the aquatic environment for longer periods (i.e., a half-life of greater
than 15 days).
4.3.2 Overall Scores and Ranks
As discussed above, Exhibit 7 shows the overall scores for all 179 substances that had
enough criterisFspecific scores to be ranked. The overall scores ranged from the maximum
score of 30 to the minimum of 10 (i.e., the substances were distributed over the entire range).
The maximum overall score of 30 was reached by five substances (three percent). Twenty
substances (11 percent) were in the top six ranking levels (i.e., had a ranking of 6 or lower).
The median—90 substance—occurs at ranking level 15, indicating that the scores are
distributed somewhat toward the lower end of the scale. Fourteen substances (eight percent)
received the lowest overall score of 10.
Draft—August 15, 1991
-------
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EXHIBIT 8
PERCENTAGES OF CHEMICALS ACROSS CRITERIA-SPECIFIC SCORES
CRITERIA
Human Toxicity
Aquatic Toxicity
Bioconcentration Potential
Environmental Persistence
SCORES
0
< 1%
4%
3%
3%
1
22%
20%
70%
72%
1.5
24%
2
16%
37%
15%
2.5
20%
3
17%
40%
13%
25%
Draft—August 15, 1991
-------
- 38 -
Many substances scored essentially the same and therefore were tied. The
distribution of these ties is shown in Exhibit 9. As shown in this exhibit, the distribution peaks
at the rank of 17, and otherwise tends to be clustered near the lower ranks (i.e., 12 to 23).
4.4 "SPECIAL" FOCUS CHEMICALS
This section presents the results of the "special" focus chemicals research described in
Section 3.6. Exhibit 10 presents the list of "special" focus chemicals—a total of 39 chemicals
and chemical groups—and the reasons for each chemical's selection as indicated by the
specific organizations (e.g., mercury is considered a chemical of concern by both the Lake
Ontario Toxics Committee [because its concentration exceeds human health criteria] and the
International Joint Commission [by consensus, and for air deposition concern]). Note,
however, that these reasons often are very general. Each chemical identified in Exhibit 10
was identified by one or more of the five organizations as a substance of concern for air
deposition in the Great Lakes region.27 'The 16 substances in Exhibit 10 that are listed in
CAAA section 112(b) are noted.
4.5 SENSITIVITY ANALYSIS
As part of a sensitivity analysis on the overall ranking, we examined how some of the
"special" focus chemicals would rank, and then examined how two alternative ranking
approaches would affect the results. This analysis helped to verify the selected ranking
scheme. This analysis also helped to answer questions concerning: (1) whether any high
ranked chemicals should actually be ranked low (i.e., because they are "false positives") or,
conversely, whether any low ranked chemicals should actually be ranked high (i.e., because
they are "false negatives"); and (2) whether the final ranking of substances was overly
sensitive to different ranking approaches.
4.5.1 Comparison With "Special" Focus Chemicals
Sixteen of the 39 "special" focus chemicals are also CAAA section 112(b) substances.
All 16 of these chemicals ranked within the top 32 percent (the top 12 ranking levels) in
Exhibit 7. Twelve of the chemicals ranked within the top 10 percent of the chemicals (ranking
levels 1 through 6). These chemicals and their ranking levels are as follows:
Level 1—chlordane. PCBs, 2,3,7,8-TCDD, cadmium compounds, and mercury
compounds;
Level 2—heptachlor, hexachlorobenzene, and toxaphene;
• Level 3—tindane (includes all isomers of hexachlorocyclohexane) and lead
~ compounds;
• Level 6—arsenic compounds and coke oven emissions/polycyclic organic
matter;
27 Note, however, that this does not mean that all organizations who consider a chemical
to be a chemical of concern do so because of air deposition.
Draft—August 15, 1991
-------
-39-
EXHIBIT 9
FREQUENCY DISTRIBUTION OF FINAL RANKS
Final
Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Overall
Score
30.000
28.750
27.500
26.667
26.250
25.000
23.750
23.333
22.500
21 .667
21 .250
20.000
18.750
1 8.333
17.500
16.250
1 5.000
13.750
1 3.333
12.500
1 1 .667
1 1 .250
10.000
Number of
Substances
5
4
4
1
1 .
5
5
3
8
3
6
12
16
3
14
18
22
15
1
13
•f
5
14
Cumulative
Number of
Substances
5
9
13
14
15
20
25
28
36
37
45
57
73
76
.90
108
130
145
146
159
160
165
179
Draft-August 15, 1991
-------
-40-
EXHIBIT10
•SPECIAL' FOCUS CHEMICALS
Chemicals
Alarm
Aluminum
ArMnie'
Banum
Benzo-a-pyrene c
Sen/Ilium
Boron
Cadmium »
Calcium
CMordaM*
Chromium
Cobalt
Copper
DOT + Metabolite!
(i «., 00£ ODD) •
Qieldnn
Dtoxin (2J.7.S-
TCOO) •
H«pUeMor/k
Heptachlor epoxide
HeiecMoro-
benzenek
HexacMoro-
cyclonwune*
iron
Lead*
Linden* (o-HCH) •
International Joint
Commission
• Concern for
Atmosphene Deposition
• 8y Consensus
• Concern for
Atmospheric Deposition
• Concern for
Atmospnenc Deposition
• By Consensus
• Concern for
Atmospheric Deposition
• Sy Consensus
• Concern for
Atmospheric Deposition
• Sy Consensus
• By Consensus
• Concern for
Atmosphene Deposition
• Concern for
Atmospnenc Deposition
• By Consensus
• Concern for
Atmosphenc Deposition
• Concern for
Atmospnenc Deposition
Air Resource*
Branch, OME
* Air Deposition
Monitoring
• Air Deposition
Monitoring
• Air Deposition
Monitoring
• Air Deposition
Monitonno,
\
• Air Deposition
Monitonng
• Air Deposition
Monitoring
• Air Deposition
Monitoring
* Air OepoMion
Monitoring
• Air Deposition
Monitoring
• Air Deposition
Monitoring
GLAD
Monitoring
Stations
• Air Deposition
Monitoring
• Air Deposition
Monitoring
• Air Deposition
Monitoring
• Air Deposition
Monitoring
• Air Deposition
Monitoring
• Air Deposition
Monitoring
• Au Deposition
Momtonng
• Air Deposition
Monrtonfloj
• Air Deposition
MonitortflQ
* Air Deposition
Monitoring
-
• Air Deposition
Monitoring
• Air Deposition
Momtonng
Lake Michigan
LaMP*
• Candidate for Air
Deposition Monitoring
• Candidate for Air
Deposition Monitoring .
• Candidate for AH
Deposition Momtonng
• Candidate for Air
Deposition Monitoring
• Candidate for Air
Deposition Monitoring
• Candida!* for Air
Deposition Momtonng
• Candidate for Air
Deposition Monitoring
• Candidate for Air
Deposition Monitonng
• Candidate for Air
Deposition Monitonng
• Candidate for Air
Deposition Monitonng
• Candidate for Air
Deposition Monitoring
• Candidate for Air
Deposition Monitonng
• Candidate for Air
Deposition Monitonng
• Candidate for Air
Deposition Monitonng
• Candidate for Air
Deposition Monitonng
Lake Ontario Toxics
Committee
• Exceeded Biota Criteria
• Atmospnenc Loading
• Exceeded HH " Critena
• Exceeded Biota Cntena
• Exceeded HH Critena
• Exceeded Biota Critena
• Atmosphenc Loading
• Exceeded HH Criteria
• Exceeded Biota Cntena
• Atmospnenc Loaomg
• Exceeded MM Criteria
• Exceeded Biota Critena
• Exceeded HH Criteria
• Atmospheric Loading
• Exceeded Biota Cntena
• Atmospheric Loading
•
Draft—August 15, 1991
-------
-41 -
EXHIBIT 10 (continued)
Chemicals
Lithium
Manganes**
Magnesium
Mercury "
Mirex
Nickel'
Octachiorostyrene
Oxycniordane
PC8a"
Potassium *
Sodium
Strontium
2.3,7,8-
Tetrachloro-
dibenzofaran •
Titanium
To>aph«iM "
Vanadium
Zinc
International Joint
Commission
• By Consensus
• Concern for
Atmospheric Deposition
• Sy Consensus
• Concern tor
Atmospnenc Deposition
• By Consensus
• Concern for
Atmosphere Deposition
• By Consensus
• Sy Consensus
• Concern tor
Atmospnenc Deposition
Air Resources
Branch, OME
• Air Deposition
Monitoring
• Air Deposition
Monitoring
• Air Deposition
Monitor no.
• Air Deposition
Monitoring
• Air Deposition
Monitoring
• Air Deposition
Monitoring
• Air Deposition
Monitonng
GLAD
Monitoring
Stations
• Air Deposition
Monitonng
• Air Deposition
Monitonng
• Air Deposition
Monitonng
• Air Deposition
Monitoring
• Air Deposition
Monitonng
• Air Deposition
Monitonng
• Air Deposition
Monitonng
• Air Deposition
Monitonng
• Air Deposition
Monitonng
• Air Deposition
Monitonng
Lake Michigan
LaMP*
• Candidate for Air
Deposition Monitonng
• Candidate for Air
Deposition Monitonng
• Candidate for Air
Deposition Monitonng
• Candidate for Air
Deposition Monitonng
• Candidate for Air
Deposition Monitoring
• Candidate for Air
Deposition Monitoring
• Candidate for Air
Deposition Monitonng
Lake Ontario Toxics
Committee
• Exceeded HH Criteria
• Atmospnenc Loading
• Exceeded HH Criteria
• Exceeded Biota Criteria
• Atmospnenc Loading
• Exceeded Siota Criteria
• Exceeded HH Cntena
• Exceeded Siota Criteria
'Oil and other petroleum products' has also been identified as a candidate critical pollutant.
Substance is listed.in CAAA section 112(b). (These substances also are in bold typeface.)
Substance is considered a member of the 'polycyclic organic matter* listed in CAAA section 112(b).
HH = human health
Only DDE is listed in CAAA section 112(b).
Draft—August 15, 1991
-------
-42-
Level 7—manganese compounds;
Level 9—DDE and nickel compounds; and
•. Level 12—dibenzofurans.
We believe that these data indicates that the results from the ranking method
described in this report corresponds well with the selection systems and professional
judgment used by the various organizations that identified the "special" focus chemicals.
4.5.2 Ranking With an Additional Criterion
To determine whether the rankings were sensitive to another exposure-related criterion,
we examined how the substances would rank if another intrinsic chemical property-
environmental partitioning—were considered. Environmental partitioning refers to the
equilibrium distribution for a chemical among the environmental compartments of air, water,
soil/sediments, and biota. These relationships were expressed as percentages in each
compartment. (Environmental partitioning data were calculated by ERL-Duluth using QSAR
and a method developed by Neely and Mackay28). For this ranking exercise, the 179
substances were scored for environmental partitioning based on the scale below:
> 90 percent in water, sediments, biota = 3
10-90 percent in water, sediments, biota = 2
< 10 percent in water, sediments, biota = 1
No data or prediction available ' =0
(This scale differs from the one used originally by ERL-Duluth, which had scoring cutoffs of:
> 75 percent, 25-75 percent, and < 25 percent. This change was made to allow for more
distinction between chemicals that partitioned into the media of concern and to increase the
consistency with the other scales being used.) The scores for environmental partitioning
assigned to the 179 substances are shown in Appendix D-1.
After assigning scores for environmental partitioning, we computed the overall scores
for 179 substances based on five criteria (i.e., human toxicity, aquatic toxicity,
bioconcentration potential, environmental persistence, and environmental partitioning), using
the same calculation algorithm as before. The substances were then ranked based on these
overall scores. The overall scores and ranks under this approach are also presented in
Appendix D-1.
After analyzing the distribution of substances based on this new ranking, we found that
of the top 10 percent (i.e., 18 substances) from the original ranking scheme (Exhibit 7), 15
remained in the top 10 percent. Three chemicals—pentachloronitrobenzene, parathion, and
28 Neely, W.B. and D. MacKay, "Evaluating Methods for Estimating Environmental Rate",
Modeling the Rate of Chemicals in the Aquatic Environment, Dickson, K.L et al. (Eds.), Ann
Arbor Science Publications, Ann Arbor, Ml, 1982.
Draft-August 15, 1991
-------
-43-
pentachlorophenol—dropped to within the top 15 percent. Similar minor changes in ranking
order occurred throughout the distribution.
Also significant is that environmental partitioning predictions for the top 10 percent of
the chemicals in Exhibit 7 estimated that they all would partition to more than 10 percent in
the media of concern (i.e., all scored 2 or 3 for environmental partitioning).
This criterion appears to have more of an effect on the lowest ranked substances (i.e.,
the 14 substances with an overall score of 10 in Exhibit 7). Nine of these substances appear
to have a high tendency to partition into the media of concern. For example, these nine have
data indicating a partitioning of 95 percent or greater into the media of concern. Due to the
low human toxicity, aquatic toxicity, bioconcentration potential, and environmental persistence
of these chemicals, however, they are still ranked relatively low—within the bottom 30
percent—even under the new scheme.
4.5.3 Ranking With the Modified IRP Method
We also ranked the 179 substances using essentially the original IRP method. That is,
acute aquatic toxicity, chronic aquatic toxicity, bioconcentration potential, environmental
persistence, and environmental partitioning were the five criteria scored (but using the
modified environmental persistence scaJe discussed in Section 3, and the modified
partitioning scale described above in Section 4.5.2). This ranking is provided in Appendix D-
2. After analyzing the distribution of substances based on this ranking, we found that of the
top 10 percent (i.e., 18 substances) from the original ranking scheme (Exhibit 7), 14 remained
in the top 10 percent. Four chemicals—cobalt compounds, lindane, pentachloronitrobenzene,
and arsenic compounds—dropped to within the top 21 percent.
\
4.6 IDENTIFYING FOCUS CHEMICALS
This section provides a brief discussion of how to use the information in this report to
identify focus chemicals for the Great Waters air deposition monitoring program. Identifying
the focus chemicals essentially involves "drawing the line" on the ranked list of chemicals in
Exhibit 7. It is quite possible that somewhat different sets of focus chemicals may be most
appropriate for different applications (e.g., deposition monitoring programs in different water
bodies; monitoring studies versus source studies). Several options exist for this step,
including the ones discussed below.
(1) Using "Special" Focus Chemicals. Use the "special" focus chemicals in one
of three methods. The first method would involve "drawing the line" in
Exhibit 7 at the lowest ranked "special" focus chemical that is also on the
CAAA section 112(b) list (i.e., at dibenzofurans, which is ranked 12th). This
method would result in 57 focus chemicals. A second method would
involve scoring the "special" focus chemicals that are not on the CAAA
section 112(b) list, and then "drawing the line" at the lowest ranked chemical
of all the "special" focus chemicals. This method would likely result in far
greater than 57 focus chemicals. A third method involving "special" focus
chemicals would involve using one of the other methods described in this
section to identify an initial list of focus chemicals, and then simply adding
the "special" focus chemicals to this list. All of these methods assume that
Draft-August 15, 1991
-------
-44-
the "special" focus chemicals were appropriately selected and are actually
high priority substances for Great Waters air deposition analyses.
(2) Using the "Ideal" Assessment. Another approach to selecting the focus
chemicals involves starting at the top of the list in Exhibit 7, and then
assessing the risk of each chemical in detail (as in the "ideal" assessment
described in Section 2) until all chemicals that are expected to result in most
of the adverse effects have been identified (i.e., additional chemicals do not
add significantly to the risk). This option is liable to be highly resource
intensive, although it should also result in the most likely "bad actor"
chemicals.
(3) Using Practical Considerations. As in Option 2, this option would involve
starting at the top of Exhibit 7 and evaluating each chemical in turn. This
evaluation would focus on practical considerations, such as monitoring
feasibility and resources available for monitoring. The "line" would be at the
point where adding another chemical to the focus chemical list is not
practical;
(4) Using Distribution Clusters. This option would involve "drawing the line" at a
point (or points) between clusters of chemicals, based on the assumption
that these clusters represent chemicals with similar potential for causing
adverse effects through air deposition. Two simple approaches could be
used for identifying clusters. The first approach involves examining the
distribution of chemjcals in the ranking, and then "drawing the line(s)"
between natural breaks. For example, one cluster in Exhibit 7 (though
easier to see in Exhibit 9) is seen above ranking level 4. This cluster
contains 14 chemicals. Another cluster may exist between ranking levels 5
and 8 (or 10). This cluster also contains 14 chemicals (or 25, if ranking level
10 is chosen as the lower bound). The second approach to identifying
clusters involves using statistical benchmarks such as percentiles. For
example, the 10th percentile (i.e., the top 10 percent) would encompass the
first 18 chemicals. These chemicals are ranked 1 through 6. The 10th to
20th percentiles would include the next 18 chemicals, spanning ranking
levels 6 through 9.
Determining the most appropriate approach -to use for actually selecting focus
chemicals for a specific application will involve additional analysis. For example, information
about air emission quatities, deposition rates, background levels, and/or monitoring methods
may need to be considered. The chemicals listed in the top portion of Exhibit 7, however,
provide a rational starting point for any such additional analysis.
Draft-August 15,1991
-------
APPENDICES
OF THE FOCUS REPORT
Draft-August 15, 1991
-------
-------
APPENDIX A OF THE FOCUS REPORT
Other Chemical Prioritization Systems
Draft-August 15, 1991
-------
APPENDIX A
OTHER CHEMICAL PRIORITIZATION SYSTEMS
This appendix presents a review of eight chemical prioritization systems that were
identified as potentially relevant to the selection of a method for identifying Clean Air Act
Amendment (CAAA) section 112(m) Great Waters air deposition focus chemicals. It includes
a summary matrix (Exhibit A-1) that lists the relevant selection criteria addressed by the
various prioritization systems. The prioritization systems reviewed in this appendix are:
(1) CERCLA RQ Adjustment Methodology;
(2) Superfund Revised Hazard Ranking System;
(3) Draft Revised Hazard Assessment Guidelines for Listing Chemicals on the Toxics
Release Inventory;
(4) Persistent Bioaccumulators Screening Cluster;
(5) Modified Hazardous Air Pollutant Prioritization System (MHAPPS);
(6) RCRA Hazardous Waste Scheduling Methodology;
(7) OPTS Review of 224 Chemicals; and
(8) ERL-Duluth Inerts Ranking Program.
These systems were examined in terms of their possible applications to the development of
screening criteria and a screening methodology for the Great Waters focus chemicals. The
five criteria tentatively considered for use in our analysis (i.e., chronic human toxicity, chronic
aquatic toxicity, persistence, bioconcentration, and environmental partitioning) were examined
where appropriate. For some systems, we also examined how these criteria were combined
to achieve a total score or rank. The summaries of each of the eight ranking systems are
organized into three sections: (1) an introduction explaining the purpose or use of the
system; (2) a description of how the relevant criteria are ranked or quantified and, in some
cases, how these rankings are combined for a total score; and (3) an indication of why the
system is relevant to this study. Exhibit A-1 summarizes the criteria as addressed by the eight
prioritization systems. Note that none of the eight systems was developed specifically for
ranking/selecting toxic air contaminants for deposition monitoring. We were unable to identify
any such systems, even as part of our review of known air deposition "special" focus
chemicals.
A.1 CERCLA SECTION 102(A) REPORTABLE QUANTITY (RQ) ADJUSTMENT
METHODOLOGY 1 2
A.1.1 Introduction
The purpose of this system is to determine the minimum quantity of a hazardous
substance spill or release that must be reported to EPA. The methodology was developed
and is used by EPA to adjust RQs for hazardous substances as specified by CERCLA section
Draft-August 15, 1991
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102(a). If a substance is released into the environment at volumes equal to or greater than its
RQ, then the release must be reported to the National Response Center. The RQ is basically
a measure of a compound's potential hazard. The methodology first evaluates the intrinsic
"primary criteria" properties of each hazardous substance (i.e., aquatic acute toxicity,
mammalian acute toxicity, ignitability, reactivity, chronic toxicity, and potential carcinogenicity)
and assigns several tentative RQ values based on the particular properties as data allow. The
lowest of the tentative RQ values (i.e., value representing greatest hazard) is taken as the
primary criteria RQ value for that substance. Subsequently, the substance is evaluated for its
susceptibility to biodegradation, hydrolysis, and photolysis (BMP). The primary criteria RQ
can be adjusted, if necessary, based on these "secondary adjustment criteria" to provide the
final RQ for the substance. This methodology has been used to develop other prioritizing; v'
schemes such as for the SARA section 110 list and the underground storage tanks risk-based
chemical ranking system. Components of the RQ methodology currently are being
considered as a basis for ranking CAAA section 112(b) hazardous air pollutants for purposes
of granting offsets under section 112(g).
A.1.2 Criteria Description
Chronic Human Toxicity
The basis for the RQ chronic human toxicity rating is the composite score, which is
derived by multiplying a rating score based on the human-equivalent minimum effective dose
(MED) by a severity rating score. The MED-based rating is termed the RVd, and the severity-
based rating is termed the RVe. Both the RVd and RVe vary over a scoring range of 1 to 10,
resulting in a range of 1 to 100 for composite scores. Using this system, those chemicals
with higher composite scores would be ranked as more toxic.
In the RQ system, the MED is expressed as mg/day and is derived from the lowest
observed adverse effect level (LOAEL), with factors included where appropriate-to adjust for
short and/or non-continuous exposure durations and to convert from animal to human
exposure levels. When more than one set of data is available, the LOAEL associated with the
highest composite score—which is not necessarily the lowest LOAEL—is used to develop the
RQ. If the log MED is < -3, an RVd of 10 is assigned. If the log MED is between -3 and 3, an
RVd between 1 and 10 is calculated as follows:
RVd = [(-1.5) x (log MED)] + 5.5.
If the log MED is > 3, an RVd of 1 is assigned. Thus, chemicals with effects at the lowest
dose levels are assigned the highest RVd values, as shown below:
RVd MED (mq/dav) MED (mq/kq-dav)
1 >. 1000 >. 14
2 220 3.1
3 46 0.66
4 10 0.14
5 2.2 0.031
Draft-August 15, 1991
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A-4
RVd MED (mq/dav) MED (mq/kq-dav)
6 0.46 0.0066
7 0.1 0.0014
8 0.022 0.00031
9 0.0046 0,000066
10 <. 0.001 <. 0.000014
For the RVe, effects with low recognized severity (e.g., enzyme induction or other
biological change with no pathological changes and no change in organ weights, or
hyperplasia, hypertrophy, or atrophy with no changes in organ weights) are assigned low
rating values. As the severity of the effect increases, the rating value also increases. By
multiplying the RVe by the MED rating (RVd), a composite score of 1 to 100 is calculated.
Chemicals with low composite scores are considered to have low relative toxicity whereas
chemicals with high composite scores are considered to be relatively toxic. In the RQ rating
system, composite scores correspond to RQ values, as shown below:
Composite Score RQ (Ibs)
81-100. 1
41-80 10
21 -40 100
6-20 1000
1-5 5000
Potential Carcinogenicity
The potential carcinogenicity evaluation for assigning RQs is based on a combination of
ED10 with weight-of-evidence of human carcinogenicity.
Aquatic Toxicity
Aquatic toxicity is another criterion used in adjusting primary RQs of hazardous
substances. For this purpose, EPA used the categories of aquatic toxicity that were
established pursuant to section 311 of the Clean Water Act. Five-level RQ rating scales have
been developed to assign the aquatic toxicity RQ to a substance based on its acute aquatic
toxicity data (i.e., LC^). These scales are shown below:
Aquatic Toxicity . RQ (Ibs)
LCso < 0.1 mg/L 1
0.1~mg/L <. LC50 < 1 mg/L 10
1 mg/L <. LC50 < 10 mg/L 100
10 mg/L <. LC^ < 100 mg/L 1000
100 mg/L <. LC50 < 500 mg/L 5000
Persistence
As mentioned above, after the primary criteria RQs are assigned, chemicals are further
evaluated for their susceptibility to certain extrinsic degradation processes, i.e.,
Draft-August 15, 1991
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A-5
biodegradation, hydrolysis, and photolysis (BMP). Persistence, as used here, refers to the
combination of these three processes. The BMP are "secondary criteria" that are used to
adjust the primary criteria RQ. If analysis indicates that a substance degrades rapidly to a
less harmful compound through one or more of these processes when it is released into the
environment, the primary criteria RQ is raised one level (i.e., to a greater number of pounds).
The respective criteria that are applied in evaluating whether a particular substance should
have its primary criteria RQ raised one level on the basis of the BHP processes are as
follows:
Biodegradation. If the reported biological oxygen demand value (BOD5, 5-day test at 20
degrees C) is equal to or greater than 50% of the theoretical oxygen demand, a
hazardous substance is considered to be sufficiently biodegradable to warrant an - - -
upward RQ adjustment.
Hydrolysis and Photolysis. Upward adjustment is based on either specific half-life data
reported in the literature or on statements made in the literature relative to the ability of
the substance to hydrolyze or photolyze with a half-life of 5 days or less.
A.1.3 Relevance
This screening system was reviewed because it is directly relevant to the Great Waters
focus chemicals criteria of chronic toxicity and persistence. It was also examined for
guidance on how to quantitatively combine across criteria.
A.2 SUPERFUND REVISED HAZARD RANKING SYSTEM (MRS) 3
A.2.1 Introduction
The MRS was developed by EPA as a screening device to evaluate the relative potential
of uncontrolled waste sites to cause human health threats or ecological and environmental
damage. Because of the site-specific nature of the MRS, this system is not strictly a chemical
prioritization system in the same sense as the other systems discussed in this memorandum.
Nevertheless, the MRS is still a useful system to examine. Specifically, one component of the
MRS scores the relative toxicity—both human and aquatic—of the waste at a site based on the
inherent toxicity of the single most toxic substance. Persistence, bioconcentration potential,
and mobility of the substance also are considered as exposure factors.
A.2.2 Criteria Description
The HRS/surface water migration pathway is evaluated below in terms of four criteria:
human toxicity, aquatic toxicity, persistence, and bioconcentration potential. In the MRS,
values are determined for these criteria for each substance and are combined as a part of the
site evaluation.
Human Toxicity
For the MRS human toxicity factor, the inherent toxicity of a substance is rated based
on a consideration of carcinogenicity, chronic noncarcinogenic toxicity, and acute toxicity.
The HRS methodology for toxicity scoring attempts to rely on high quality, peer reviewed
sources of data. In developing the toxicity scoring methodology of the HRS, EPA considered
Draft—August 15, 1991
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A-6
numerous toxicity assessment options and narrowed them down to three: (1) the RQ
approach; (2) the RfD/CPF (reference dose/cancer potency factor) approach; and (3) the
modified ADI/WOE (acceptable daily intake/weight-of-evidence) approach. The final
methodology adopted was a hybrid of these three options.
Human toxicity factor values are based on quantitative dose-response parameters for
each of three types of toxicity: cancer, non-cancer responses of chronic exposure, and non-
cancer responses of acute exposure. Slope factors (or cancer potency factors) are combined
with weight-of-evidence ratings for carcinogenicity. If a slope factor is not available for a
substance, its ED10 value is used to estimate a slope factor. Reference doses (RfDs) are
used as measures of non-cancer toxicological responses of chronic exposure, and acute
toxicity parameters such as LD50s are used as measures of non-cancer toxicological
responses of acute exposure. !f both Rf D and .slope factor values are available, the hazardous
substance is assigned a toxicity factor value based on the value that estimates greater
hazard. If only one of these values is available, the toxicity factor value is assigned based on
the available value. If neither is available, the substance is assigned a toxicity factor value
based solely on acute toxicity. If none of this information is available, the substance is
assigned an overall toxicity factor value of zero, and other substances for which information is
available are evaluated for that pathway. If a toxicity factor value of zero is assigned to all
substances of a particular pathway, a mid-range default value of 100 is assigned as the
overall toxicity factor value for all substances in the pathway.
Aquatic Toxicrty
Toxicity is assigned differently for the environmental threat to surface water. For this
category, an ecosystem toxicity factor value is assigned based on the following data
hierarchy: EPA chronic ambient water quality criteria (AWQC) for the substance, EPA chronic
ambient aquatic life advisory concentrations (AAUVC), EPA acute AWQC, EPA acute AALAC,
and, finally, lowest LC50 value. If none of this information is available, the substance is
assigned an ecosystem toxicity factor value of zero. If an ecosystem toxicity factor value of
zero is assigned to all substances eligible to be evaluated for the watershed, a mid-range
default value of TOO is assigned as the ecosystem toxicity factor value for all the substances.
Persistence
For the surface water migration pathway, a value for persistence is assigned to each of
the hazardous substances based primarily on the half-life of the substance In surface water
and secondarily on the sorption of the hazardous substance to sediments. The half-life in
surface water is defined for MRS purposes as the time required to reduce the initial
concentration in surface water by one-half as the result of the combined decay processes of
biodegradation, hydrolysis, photolysis, and volatilization. If one of these four component half-
lives cannot be estimated for the substance from the available data, that component is
disregarded. If none of the four component half-lives can be estimated, a default procedure
is used. Sorption to sediments is evaluated for the MRS based on the logarithm of the n-
octanol-water partition coefficient (log Kow) of the substance.
Bioconcentration Potential
The following data hierarchy is used to assign a bioconcentration potential factor value
to each hazardous substance: bioconcentration factor (BCF); log KQW; and, lastly, water
Draft—August 15, 1991
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A-7
solubility. If none of this information is available, a bioconcentration potential factor value of
0.5 is assigned.
A.2.3 Relevance
The methods used in the MRS to quantify human and aquatic toxicity, persistence, and
bioconcentration for the surface water exposure pathway were reviewed because of their
relevance to the Great Waters focus chemicals selection criteria. (The method for obtaining
and scoring the human toxicity criterion was ultimately selected for use.) In addition, the
methods used for combining these criteria were reviewed.
A.3 DRAFT REVISED HAZARD ASSESSMENT GUIDELINES FOR LISTING CHEMICALS
ON THE TOXICS RELEASE INVENTORY (TRI) 4
A.3.1 Introduction
These draft guidelines present the general approach and criteria that the Office of Toxic
Substances (OTS) of EPA uses for evaluating chemicals for addition to or deletion from the
list of toxic chemicals subject to reporting under section 313 of SARA. They provide for a
method of screening either a single chemical or a large list of chemicals so that a quick initial
evaluation can be made. Before any regulatory decision is to be proposed, however, a
hazard evaluation is required. The hazard evaluation can range from a relatively
straightforward verification of the data used during screening to a more complicated, in-depth
review of a chemical's entire toxicity data base.
A.3.2 Criteria Description
A chemical may be added to the list if any one of the following statutory criteria are met:
(1) the chemical is known to cause or can be reasonably anticipated to cause
significant adverse acute human health effects at concentration levels that are
reasonably likely to exist beyond facility site boundaries as a result of continuous
or frequently recurring releases;
(2) the chemical is known to cause or can be anticipated to cause in humans:
cancer or teratogenic effects (see note below) or serious or irreversible
reproductive dysfunctions, neurological disorders, heritable genetic mutations, or
other chronic health effects; or
(3) the chemical is known to cause or can be anticipated to cause, because of its
toxicity, persistence, or bioconcentration, a significant adverse effect on the
environment.
(Note: Current EPA risk assessment guidelines consider all manifestations of developmental
toxicity, including fetal death, structural abnormalities, growth alterations, and functional
deficits, to be of concern. Teratogenicity is a subcategory of the broader category "structural
abnormalities." For the purposes of this document, all categories of developmental toxicity
are considered together.)
Draft—August 15, 1991
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A-8
Both screening and hazard evaluation are integral to the overall process of listing
chemicals under section 313. Screening, the first step in the process, provides an initial
categorization of a chem ai's toxicity data as "sufficient," "may.be sufficient," or "insufficient"
for listing, based on the toxicological effect and the level at which the effect is observed. A
chemical's production volume may also be considered as part of the screening step. Hazard
evaluation, the second step, provides, an overall assessment and validation of a chemical's
toxicity data base.
Human Toxicity
After analysis of various numerical indices of non-cancer toxicity for a large number of
chemicals, including those used in the RQ system (i.e., MED and composite score), OTS
selected the human-equivalent MED—as defined and used in the RQ system—as the basis of
numerical screening criteria for human toxicity to be used for TRI listing purposes. The main
reason for selecting the MED, rather than the composite score or the reference dose (RfD) (or
'ome other numerical index), is that the MED undergoes relatively limited manipulation in its
Jerivation from the actual study data (i.e., fewer calculation steps and assumptions are .
required to derive an MED). Furthermore, use of the MED in chemical screening and ranking
systems has been reviewed extensively by past Agency workgroups and accepted as a
reasonable approach.
EPA selected an MED of 10 mg/kg-day as the upper bound for the "sufficient for listing"
category and 500 mg/kg-day as the lower bound for the "insufficient for listing" category; all
intermediate MED values are considered to be in the "may be sufficient for listing" category.
EPA selected these numerical screening criteria values so that the majority of chemicals
already listed on various CERCLA/SARA lists, and thus known or suspected to be toxic
and/or hazardous, would fall into the "sufficient for listing" category. Of the 369
CERCLA/SARA chemicals for which MED values were available in 1990, the breakout into
categories is as shown below:
Category Numerical Criteria % of Chemicals (Number)
Sufficient for listing MED<.10 87.5% (323)
May be sufficient for 10 < MED <. 500 12% (44)
listing
Insufficient for listing 500 < MED 0.5% (2)
Environmental Toxicity, Persistence, and Bioconcerrtration
The numerical screening criteria for environmental effects are divided into three separate
categories: (1) consideration of toxicity only; (2) consideration of toxicity and persistence;
and (3) consideration of toxicity and bioconcentration. For 'toxicity only," the Agency has
identified acute and chronic numerical screening criteria that indicate such severe toxicity that
any chemical meeting these criteria would generally be listed based on its hazard alone. EPA
considers a chronic aquatic MATC (maximum acceptable toxicant concentration) of 10 ppb to
be generally indicative of high concern. To set a "sufficient for listing" criterion, this figure was
reduced by an order of magnitude to 1 ppb. Thus, the numerical screening criteria for
"toxicity only" reflect the reduction by one order of magnitude of what is generally accepted
Draft—August 15, 1991
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A-9
as indicative of "high" hazard concern. This approach ensures that only those chemicals that
present extremely high concerns for potential hazard will meet the "sufficient for listing"
criterion.
For numerical screening criteria based on both toxicity and persistence, a somewhat
different approach was taken. Because there was the additional consideration of persistence,
the toxicity values were adjusted up by one order of magnitude from the "toxicity alone"
values. This results in toxicity screening criteria that reflect generally accepted standards for
"high" hazard concern in OPTS. For chemicals that meet the chronic toxicity screening
criteria, a half-life of four days or greater would justify listing. The four-day figure was chosen
because acute toxicity tests are usually conducted over four days. Therefore, it was
assumed, if chronic effects criteria were met and if the chemical was persistent for the length
of time it takes to cause acute toxicity, this would justify listing the chemical. Note that both
criteria must be met for the chemical to be listed based on "toxicity and persistence."
For numerical screening criteria based on both toxicity and bioconcentration, the toxicity
values we.re again adjusted upward by one order of magnitude from the "toxicity and
persistence" values. This results in toxicity screening criteria that reflect generally accepted
standards for "moderate" hazard concern in OPTS. When a chronic toxicity screening
criterion is met, a measured bioconcentration factor (BCF) of 1,000 is considered sufficient to.
justify listing the chemical. The 1,000 BCF figure was chosen because it is generally
accepted as a BCF level of concern. In the absence of actual measured BCF data, the log P
(logarithm of the octanol-water partition coefficient, or log Kow) may be used to estimate a
BCF figure. When measured log P data are available, a log P criterion of 4.35 is used. When
log P must be estimated, a value of 5.5 is used. The measured log P value of 4.35 was
chosen because that is the value that calculates out to a BCF of 1000. The calculated log P
value of 5.5 was chosen because of the uncertainties involved in calculating log P from
chemical structure or other chemical properties; using a calculated log P of 4.35 might
overestimate BCF values.
The numerical screening criteria defining the "may be sufficient for listing" category were
derived by adjusting the "sufficient for listing" toxicity values upward by approximately one
order of magnitude (persistence and biocon'centration values remained the same). The
numerical screening criteria defining the "insufficient for listing" category were derived by
adjusting the "sufficient for listing" toxicity values upward by approximately two orders of
magnitude (persistence and bioconcentration values remained the same).
A.3.3 Relevance
This screening system's method for determining human and environmental toxicity was
examined for its usefulness in determining toxicity ranges and cut offs. Its method of
combining toxicity with persistence and with bioconcentration also was examined.
A.4 - PERSISTENT BIOACCUMULATORS SCREENING CLUSTER 5
A.4.1 Introduction
This methodology is used by OPTS to screen the TSCA Inventory of 60,000 chemicals
and provide a preliminary list of potentially persistent and bioaccumulative chemicals.
Draft-August 15, 1991
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A - 10
A.4.2 Criteria Description
Persistence
A total of 521 chemicals were screened for persistence. The chemicals were scored
based upon an estimated environmental half-life of less than or greater than 30 days. This
criterion is used by OTS's Exposure Evaluation Division for the assessment of the persistence
of industrial chemicals. A total of 80 compounds have been identified as having an
environmental half-life of equal to or greater than 30 days.
Bioconcentration
The initial screening of the TSCA Inventory conducted by the Environmental Research
Lab at Duluth resulted in a data base of 6668 discrete organic chemicals with estimated log
P's greater than 3.5. Criteria were developed by which to conduct a screen of these 6668
chemicals that would result in a list of chemicals of the most concern for bioconcentration.
The criteria developed to assist in the screening of the data base are not hard-and-fast
cut offs but rather approximate cut offs to aid in the reduction of a large data base.
The screening process focused on those chemicals currently in commerce as indicated
by information available through the CUS data base on production/volume. The threshold for
reporting on CUS is 10,000 Ib/yr. The intersection of the Duluth data base with the CUS data
base yielded a total of 1034 discrete organic chemicals. The remaining chemicals were set
aside for later screening.
The criterion set forth in the Environmental Effects Testing Scheme uses a
bioconcentration factor value of 1000 or higher as the concern for potential bioconcentration
effects. This corresponds to a log P of 4.3. (The relationship of BCF to log P is log BCF =
0.79 x log P - 0.40.) Therefore, the chemicals with log P values less than 4.3 are probably of
less concern for bioconcentration. Also, for log P's greater than 8.0, an exposure period
greater than 28 days may be needed for the residues to come to equilibrium. At log P's
greater than 8.0, an evaluation would have to be done on a case-by-case basis. Therefore,
chemicals with log P's less than 4.3 and greater than 8.0 were set aside (except for the
halogenated compounds with log P's greater than 8.0, which were evaluated for persistence).
The next group of chemicals to be set aside were those with a molecular weight greater
than 600 (except for the halogenated chemicals of this subset which were evaluated for
persistence). It is generally held that for compounds with a molecular weight greater than
600, uptake through biological membranes decreases exponentially with increasing molecular
weight. Chemicals with molecular weights of 1000 or greater are only insignificantly
absorbed.
A.4.3 Relevance
This screening system was examined for its direct relevance to establishing numerical
cut offs by which to evaluate persistence and bioconcentration for the Great Waters focus
chemicals. This system was also reviewed for its set of physical/chemical criteria to identify
chemicals that may present environmental problems from persistence and bioconcentration.
Draft—August 15, 1991
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A-11
A.5 MODIFIED HAZARDOUS AIR POLLUTANT PRIORITIZATION SYSTEM (MHAPPS) 6
A.5.1 Introduction
The Modified Hazardous Air Pollutant Prioritization System (MHAPPS) is a computerized
ranking method that EPA uses to screen potential air pollutants for further assessment prior
to making regulatory decisions. The procedure that the system is based on was intended to
consider multimedia exposures through various routes (e.g., air, water, consumer usage).
MHAPPS ranks substances by scoring them in eight areas (called factors), which are
weighted and combined into five groups: (1) carcinogenicity (combination of oncogenicity
and mutagenicity), (2) reproductive ^and developmental toxicity, (3) toxicity (acute toxicity and
effects other than acute toxicity), (4) exposure (combination of potential for airborne release
and bioconcentration), and (5) existing standards. The system can be used to prioritize a
group of chemicals without the use of a computer. Factors are combined into groups, and
then these five unrelated groups are weighted- and combined to arrive at the final prioritization
score. The system provides different alternative user-selected ranking schemes that
emphasize special conditions (e.g., acute versus chronic toxicity).
A.5.2 Criteria Description
We did not examine in detail how MHAPPS addresses toxicity because it focuses
primarily on human toxicity by the inhalation route, which is less directly relevant to the
selection of section 112 (m) focus chemicals than the oral route. Also, in the computation of
factors for oncogenicity, mutagenicity, reproductive and developmental toxicity, and acute
lethality, greater weight is given to criteria for exposure via inhalation than for exposure via
other routes (such as oral or dermal routes).
Potential for Airborne Release
For this factor, MHAPPS combines two subfactors. The first of these is the yearly
commercial production volume. Additionally, one of the weighting alternatives for this
subfactor allows the user to account for production of airborne hazardous chemicals by
combustion as opposed to relying on data for commercial production volumes alone. If this
prioritization option is chosen, each pollutant being ranked will be checked against a list of
combustion products. A higher weight is given to substances that enter the atmosphere as
products of combustion. Without this feature, a substance that is not commercially produced
but is created in the combustion process would receive no score in the production volume
subfactor.
The second subfactor is the physical state/vapor pressure at ambient conditions.
Gases are ranged as being the most difficult to contain, and, thus, the most likely to be
released in large quantities. Solids are weighted equal in importance to highly volatile liquids.
This is based in part upon consideration of the importance EPA places upon solid particulate
matter air pollution. Liquids are scored on the basis of vapor pressure, or boiling point if
vapor pressure data are not available.
Draft-August 15, 1991
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A- 12
Bioconcerrtration Potential
This factor is based on the octanoi/water partition coefficient. This coefficient is related
to the tendency of a substance to accumulate in fat rather than water, and, hence, to
accumulate in animals. The greater the tendency the substance has to accumulate, the
higher the weight assigned to this factor. The following weighting criteria are used to account
for bioconcentration, where P represents the octanol/water partition coefficient:
10
8
6
1
1
A.5.3 Relevance
The method for evaluating production levels/volumes (known as "potential for airborne
release") was examined, but was felt not to be applicable to further development of the
section 112(m) screening methodology because of the amount of resources that would have
been needed. The methods for evaluating bioconcentration also were examined.
A.6 RCRA HAZARDOUS WASTE SCHEDUUNG METHODOLOGY 7
A.6.1 Introduction
This methodology was used to schedule waste streams listed in 40 CFR 261 into three
tiers (which corresponded to statutorily specified time-frames) for land disposal prohibition
determinations. A numerical scheme was developed to rank the hazardous waste
constituents listed in Appendix VII of 40 CFR 261 based on their inherent toxic potential.
A.6.2 Criteria Description
In this methodology, the tc -;ity of the single most toxic constituent was assigned the
toxicity ranking of that waste str n. Acute toxicity was assessed on the bas,s of LD50s or
LC50s (or LD10s or LC10s if the former were not available), which are the lethal doses or
concentrations for fifty (or ten) percent of the test population. Chronic toxicity (both
carcinogenic and noncarcinogenic) was summarized as the equivalent dose estimate (EDE),
which is defined as that dose at which the estimated risk associated with a compound is
comparaole among all compounds being evaluated. The EDEs were derived from the
acceptable dally intakes (ADIs), no observed effect levels (NOELs), or lowest observed effect
levels (LOELs) for noncarcinogens, and from unit carcinogenic risk (UCR) values for
carcinogens. If a UCR value was not available for a substance designated as either a human
or an animal carcinogen, the UCR was calculated using either a multistage or a one-hit model
(dose-response models).
The toxic potential of each waste stream was combined with a volume score to
generate the final ranking, which could range from 1 to 100. Because toxicity scores were
statutorily required for 363 waste constituents, this methodology used a systematic means of
Draft—August 15, 1991
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A- 13
assigning the scores for all the compounds regardless of the extent of data available for each
compound (e.g., by the use of data for structural analogues or the use of less appropriate
data combined with uncertainty factors). The EDEs derived for the 363 constituents varied
over 10 orders of magnitude.
A.6.3 Relevance
This system's method of ranking toxicity was reviewed for its relevance to establishing a
toxicity ranking methodology for the Great Waters focus chemicals. The system's method of
combining toxicity scores with volume scores was also examined.
A.7 OPTS REVIEW OF 224 CHEMICALS 8
A.7.1 Introduction
The Health and Environmental Review Division (Office of Pesticides and Toxic
Substances, EPA) provided a list of the ecotoxicity of 224 chemicals identified by the Office of
Air and Radiation. The review considers the following criteria: acute aquatic toxicity,
persistence, bioconcentration, and chronic aquatic toxicity.
A.7.2 Criteria Description
In this analysis, acute aquatic toxicity concerns are ranked as: high (acute toxicity
value less than 0.1 mg/L); moderate (acute toxicity value between 0.1 and 1.0 mg/L); low
(acute toxicity value above 1.0 mg/L); none expected; or unknown. Persistence is classified
as: persistent in the environment; may be persistent; expected to readily degrade in the
environment; or unknown. Bioconcentration potential is labeled as: will bioconcentrate in
organisms; may bioconcentrate; is not expected to bioconcentrate; or unknown. Finally,
overall concern is ranked as high, moderate, or low. Also provided in the list are acute
toxicity values, as geometric means of acute LC50 values for all aquatic species. If one group
of species was more sensitive than any other group, then the acute toxicity value was
reported for that group. In addition, persistent chemicals were designated as either "chronic"
or "inert" according to whether they had a high or low probability of causing chronic toxicity.
A.7.3 Relevance
This screening system was examined for relevance to establishing criteria by which to
evaluate persistence, bioconcentration, and chronic aquatic toxicity for the Great Waters
focus chemicals. Given the limited documentation available and the apparent extensive use
of professional judgment in classifying the chemicals, the methods used were felt not to be
directly applicable.
A.8 ERL INERTS RANKING PROGRAM 9
A.8.1 Introduction
This quantitative scheme—used to rank pesticide inert ingredients based on the AQUIRE
data base and structure activity relationships—was developed by EPA's Environmental
Research Laboratory (ERL) in Duluth for the Office of Pesticide Programs (OPP). It was used
Draft—August 15, 1991
-------
A- 14
to determine the potential for high or low ecological concern of specified inert chemicals to .
aquatic organisms.
A.8.2 Criteria Description
The Inerts Ranking Program uses a ranking scheme based on a summation of scores
assigned to each of five categories: acute aquatic toxicity; chronic aquatic toxicity;
bioconcentration; environmental persistence; and environmental partitioning. Each of the five
categories has a possible score of 0, 1, 2; or 3. A score of 0 indicates that no data are
available, and a score of 3 indicates high toxicity, bioconcentration, persistence, or
partitioning. For each chemical, the overall rank is derived by adding the scores for each
category, dividing by the number of categories for which there was data, and multiplying by
10 to achieve a value in the 0 to 30 range. A score of 0 indicates that no data are available
and a score of 30 indicates a high level of ecological concern.
The scoring is based on chemical-specific data from the Aquatic Toxicity Information
Retrieval (AQUIRE) data base and the Quantitative Structure Activity Research (QSAR) data
base. The acute aquatic toxicity scoring is based on three categories of EC50 or LC50 data
(< 1 mg/L; 1-100 mg/L; or > 100 mg/L) while the chronic aquatic toxicity scoring is based on
three categories of Effect/No effect or MATC data (MATC < 0.1 mg/L; 0.1-10 mg/L; or > 10
mg/L). Bioconcentration scores are determined based on three categories of the BCF (BCF
> 999; BCF = 93-999; and BCF < 93), and environmental persistence is scored based on
the half-life of the substance (3 categories based on: 1/2 life > 15 days; 1/2 life 4-15 days;
and 1/2 life < 4 days). Environmental partitioning is based on three categories of the
percentage of the substance that is estimated to be distributed in water, sediments, and biota
at equilibrium, on the basis of fugacity concepts (more than 75% of the substance in water,
sediments, and biota; 25-75% of the substance in water, sediments, and biota; and less than
25% of the substance, in. water, sediments, and biota).
A.8.3 Relevance
This system's ranking scheme was determined to be the most relevant to all the criteria
(except for human toxicity) for the Great Waters focus chemicals selection methodology. The
system also provided one option for combining across multiple criteria.
APPENDIX A REFERENCES
1. Federal Register 13456, April 4, 1985, "Notification Requirements; Reportable Quantity
Adjustments; Final Rule and Proposed Rule".
2. Technical Background Document to Support Rulemaking Pursuant to CERCLA Section
102, Volome 1, March 1985.
3. Federal Register 51532, December 14, 1990, "Hazard Ranking System; Final Rule".
4. Draft Revised Hazard Assessment Guidelines for Listing Chemicals on the Toxics
Release Inventory (TRI), Office of Toxic Substances, October 25, 1990.
5. Final List of Potential Bioaccumulators Screened from the TSCA Inventory, Memorandum
from Office of Pesticides and Toxic Substances, February 19, 1991.
Draft-August 15, 1991 .
-------
A- 15
6. The Modified Hazardous Air Pollutant Prioritization System (MHAPPS), Final Report
submitted to the Office of Air Quality, Planning, and Standards, May 1987.
7 RCRA (Section 3004) Scheduling of Hazardous Wastes Methodology, Environ
Corporation, March 1985.
8. OAR Request for Ecotox Data/Review of 224 Chemicals, Memorandum from Office of
Pesticides and Toxic Substances to Office of Air and Radiation, September 13, 1988.
9. Ranking of Pesticide Inert Ingredients Using the AQUIRE Data Base and Structure Activity
Relationships, Report from EPA's Environmental Research Laboratory, Duluth.
Draft—August 15. 1991
-------
-------
APPENDIX B OF THE FOCUS REPORT
Readily Available Tertiary Data Sources Examined
Draft—August 15. 1991
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APPENDIX C OF THE FOCUS REPORT
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APPENDIX D OF THE FOCUS REPORT
Scores/Ranks Under Alternative Algorithms
Draft—August 15. 1991
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ATTACHMENT B
BASIS FOR AND ASSUMPTIONS USED
TO DERIVE ADDITIONAL. EMISSIONS ESTIMATES
FOR THE RANKING OF SOURCE CATEGORIES
-------
-------
Hazardous Waste Incineration
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Lead
Mercury
Chlorine
Total
Ib/hr
69
0.53
0.95
1.3
0. 19
21
69
79
240.97
kg/yra
185909.589
1428. 00119
2559. 62473
3502. 64444
511. 924957
59581.1795
185909.589
212853.008
649255.563
aBased on assumed operating schedule;
year.
18 hours/day at 330 days a
Boat Manufacturing
• Available data were for total HAP. Assumed all HAP was
styrene.
Total styrene emissions:" 25,082 kg/yr
Secondary Lead Smelting
Available data2 stated 37,466.7 kg/yr from one company.
Assumed national emissions equal to twic£ reported emissions from
one company.
Total lead emissions: 74,933.5 kg/yr lead
-------
References
1. Memorandum from Brown, H., Radian Corporation, to
Dave Svendsgaard, EPA/CPB. Documentation of Major Sources.
March 31, 1992.
2. Memorandum from Brown, H., Radian Corporation, to Source
Category Schedule docket (A-91-14). Documentation of
National Emission Rate Estimates Used in Manual Calculations
of Risk Scores for Several Categories of Sources on the
Initial Source Category List. January 30, 19'92.
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
REPORT NO.
EPA-453/R-93-053
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Scneuule for Standards: Methodology and Results for
Ranking Source Categories Based on Environmental
Effects Data
5. REPORT DATE
Septemoer 1993
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT SO
PERFORMING ORGANIZATION NAME AND AOORESS
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, Nortti Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO
bci-Dl-0117
12. SPONSORING AGENCY NAME AND AOORESS
Director, uffice of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, Nortti Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
6. ABSTRACT
In developing the source category schedule for emission standards, the EPA developed
the source category ranking system (SCRS) to help prioritize source categories. In
response to puulic comments that the SCRS did not specifically consider environmental
effects as required under section 112 of the Clean Air Act, the EPA conducted d
ranking of source categories oased on readily available environmental effects u^ta.
This document explains tne methodology for this ranking.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Croup
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (Tt\isReport!
20. SECURITY CLASS (TliiS pagtt
22. PRICE
EPA Form 2220-1 («•«. 4-77) PNKVIOU* COITION is OSSOLKTC
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