l.'nttcd Slates
        Agency
Office 01 Research and
Development
Washington, IX" 20460
&EPA  Characterizing Risk
        at Metal Finishing
        Facilities
        Meeting the Needs of
        All Stakeholders
        An EPA Reinvention Initiative

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CHARACTERIZING RISK AT METAL FINISHING FACILITIES
                         27 January 1998
                       Dennis J. Brown, Ph.D.
                   Parsons Engineering Science, Inc.
                    2101 Webster Street, Suite 700
                       Oakland, CA  94612

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     A draft of this report was prepared during the author's tenure as a Fellow under the
American Association for the Advancement of Science/U.S. Environmental Protection Agency
Fellowship Program during the summer of 1997.  Since that time significant changes have been
made to the report in response to comments received from technical reviewers both from -within
and from outside of EPA.  The views expressed herein are  entirely  the author's and do not
represent official policy of either the EPA or AAAS.  The report is subject to further review and
revision. Mention of trade  names of commercial products does not constitute endorsement or
recommendation.
                               ACKNOWLEDGMENTS

      The author wishes to thank the AAAS and the EPA for providing the opportunity to pursue
the work described herein and for supporting the 10-week  Summer Environmental Science and
Engineering Fellowship Program.  The author also wishes to thank his mentor, Paul Shapiro, for
his guidance, helpful discussions, and review of the  work both during and after the fellowship
period.  The author is grateful to the following persons who provided assistance during the
fellowship:  Babasaheb Sonawane and the staff of  EPA's National  Center for Environmental
Assessment for providing technical support and the resources to  conduct this work;  Michael
Callahan, John Schaum, and Herman Gibb for reviewing and commenting on various versions of
this document; Peter Gallerani, for discussing his work on metal finishing facility emissions and
for arranging a tour of the B.F.  Goodrich metal finishing operation in Vergennes, Vermont;
Ronald Vezzi, B.F. Goodrich Process Engineer; Karen Morehouse, EPA Fellowship Coordinator;
and Claudia Sturges, AAAS Fellowship Program Manager. The author is grateful to the National
Metal Finishing Resource Center for providing information on the metal finishing industry.

      Among those who provided useful comments on the earlier draft report the author wishes
to thank Caroline Freeman and William Perry, Occupational Safety and  Health Administration;
Amy Vasu and Ted Palma, EPA, Office of Air Quality Planning and Standards; Peter Preuss and
Richard Walentowicz, EPA, ORD, National Center for Environmental Research and Quality
Assurance; Dean Menke, 1997/1998  AAAS/EPA  Risk  Assessment Fellow;  Chris Branson,
National Institute of Standards and Technology/Industrial  Technology Institute Manufacturing
Extension Center; and Joel Barnhart, American Chrome and Chemicals Company and the Chrome
Coalition.

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                          TABLE OF CONTENTS

                                                                     Page

ABSTRACT                                                             v

1. INTRODUCTION	1

  1.1 NEW APPRO ACHES TO ENVIRONMENTAL PROTECTION	1

  1.2 THE METAL FINISHING INDUSTRY	2

  1.3 COMMON SENSE INITIATIVE	3

  1.4 PROJECT OBJECTIVES	8

2. RISK ASSESSMENT FOR METAL FINISHING FACILITIES	9

  2.1 THE RISK ASSESSMENT PROCESS	9
    2.1.1 Hazard Identification	11
    2.1.2 Dose-Response Assessment	13
    2.1.3 Exposure Assessment	18
    2.1.4 Risk Characterization	22
  2.2 ASSESSING RISK FOR CHROMIUM ELECTROPLATING FACILITIES	25
    2.2.1 Hazard Identification	25
    2.2.2 Dose-Response Values for Hexavalent Chromium	25
    2.2.3 Exposure Assessment	27
    2.2.4 Risk Characterization	32
  2.3 RISK COMMUNICATION	34

3. SUMMARY	36

4. REFERENCES	37

ACRONYMS	41

APPENDIX A Output from Risk Assistant™                                    A-l
                                    111

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                                       TABLES

No.                                                                              Page
1-1  Chemical Substances Potentially Used in, Generated by, or Emitted from
     Metal Finishing Facilities	4
2-1  Principle Steps of the Risk Assessment Process for Metal Finishing Facilities	12
2-2  Published EPA Human Health Toxicity Values for Chemical Substances
     Potentially Emitted by Metal Finishing Processes	15
2-3  Exposure Assessment Data Needs for Metal Finishing Facilities	19
2-4  Generalized Dose Equations	20
2-5  Environmental Concentrations of Hexavalent Chromium Used in the
     Example Risk Assessment	27
2-6  Summary of Exposure Factors Used in Example Risk Assessment	28
2-7  Relative Proportion of Hexavalent Chromium Concentrations Measured
     in the Workplace	29
2-8  Predicted Lifetime Excess Cancer Risks and Hazard Quotients
     for Exposure to Hexavalent Chromium	33
                                      FIGURES

No.                                                                             Page
 1-1  Metal Finishing Sector Organization Within the Common Sense Initiative	5
2-1  The Risk Assessment/Risk Management Paradigm	9
2-2  Conceptual Exposure Model for Electroplating Process	18
2-3  Exposure Scenarios for Workers	.-	30
2-4  Exposure Scenarios for Residents	31
2-5  Lifetime Excess Cancer Risk for Community Residents for
     Example Risk Assessment	34
                                          IV

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                                     ABSTRACT

     Facility-based risk characterization for workers and surrounding communities is a high
priority issue for stakeholders in the Environmental Protection Agency's Common Sense Initiative
Metal Finishing Sector.  Platers, environmental groups, community groups, labor, and regulators
all need and want to know what emissions are  coming out and in what amounts from metal
finishing  operations.  They also want to know what health risks those emissions create for
workers and the surrounding communities.

     A process is described herein that includes a problem formulation phase to identify the types
and forms of information that are  wanted by the different  stakeholders and a risk assessment
phase to quantify  the  health risks associated with  facility  emissions.  A screening level risk
assessment is performed in which toxicity information and exposure data are used to show how a
facility-based risk  assessment  could be  performed  for  a  typical  electroplating  operation.
Information needs for a more refined assessment are presented.

     A single  iteration of the problem formulation and risk assessment processes may lead
directly to a risk management  decision or the steps  may be modified and repeated, taking into
account input from stakeholders obtained during the risk communication process.  Uncertainties
associated with toxicity information and exposure scenarios will present challenges for providing
simple (but not simplistic) methods of risk assessment that can be applied by facility operators,
community groups, and other stakeholders.  This type of risk characterization is not only desired
but possible to carry out for a variety of exposure scenarios.

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                               1.  INTRODUCTION

     The mission of the United States Environmental Protection Agency (EPA) is to protect and
improve the quality of public health and the environment.  As applied to industrial sources of
pollution, this mission has been carried out primarily through the development and implementation
of policies and programs to reduce or prevent releases of chemicals to the environment.  Many of
these policies and programs focus on media-specific (i.e., air, water, soil) controls on emissions
through the authority granted the EPA by various regulatory statutes (e.g., the Clean Air Act, the
Clean Water Act, and the Resource  Conservation and Recovery Act).  The EPA and others have
recently suggested  that the  current  regulatory system,  which uses  a  chemical-by-chemical,
medium-by-medium, risk-by-risk approach to assess and reduce environmental health  risks, be
modified to consider health and environmental effects of pollutants in their broader context, which
often includes emissions to more than one medium and/or exposures of multiple populations (e.g.,
on-site workers, the public) (Browner, 1994; Presidential/Congressional Commission on Risk
Assessment and Risk Management, 1997a, 1997b).

1.1  NEW APPROACHES TO ENVIRONMENTAL PROTECTION

     To aid in the development and assessment of new approaches to environmental protection,
EPA has sought input from persons who may be affected by any change in EPA's regulatory
process through programs such as the Common Sense Initiative (CSI)  and Project XL.  These
persons (stakeholders) may include  representatives from industry, workers, trade organizations,
community groups, environmental justice groups, environmental groups, and  state and local
governments.  It is EPA's stated purpose to use the input from these groups to reinvent the way
that it accomplishes environmental protection (Browner, 1994).  One form that reinvention has
taken is  to move  away from "command-and-control"  policies  toward the  greater use of
performance-based approaches that reward environmental excellence as much as they punish non-
compliance (EPA,  1997b).  The EPA has developed several pollution prevention programs that
encourage industry to reduce the quantity of hazardous chemicals released to the environment by
substituting less toxic chemicals in their operations, by using smaller quantities of chemicals, or by
recycling or reusing chemicals within their manufacturing operations (EPA, 1995d).

     As measured  by reduced total emissions of toxic chemicals to the air, soil, and water,
pollution prevention programs have been successful (EPA, 1997c). However, a reduction in total
emissions reveals only part of the  story.  Reduced emissions do not necessarily equate to a
proportional  reduction  of health  risks.   The  relative  change in  health  risks  may  be
disproportionately larger or smaller than the reduction in total emissions because health risks are a
function of both the degree of exposure to toxic chemicals and the nature and intensity of the
chemicals' toxic effects.  With regards to exposure, reducing emissions where there is little or no
exposure would yield a smaller health benefit relative to reducing emissions where there is much
potential  exposure.  With regards to toxicity, a large decrease in the emission of a chemical of
relatively low toxicity may have a smaller health benefit than a small decrease in a more toxic
compound.  Only by describing emissions in terms of both exposure and toxicity can any health
benefits from reduced emissions be determined.

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      Risk assessment is the process of estimating the chance that adverse health effects will result
from  exposure to a chemical, biological, or physical agent.   Human health risk  assessment
attempts to  quantify the adverse health effects by identifying the nature of the potential injury
(hazard identification) and the populations that are at risk (exposure assessment), by measuring
the relationship between a given exposure and the potential injury (dose-response assessment),
and by combining these three pieces  of information to estimate the  probability that harm will
occur (risk  characterization)  (NRC, 1983; NRC 1994).   Risk assessment is used by EPA and
others as one input to making risk management decisions.

      Risk management  is the process  of identifying, evaluating,  selecting, and implementing
actions to reduce risk to human health and to ecosystems.  The goal of risk management is to
identify and implement actions that reduce or prevent risks  while taking into account social,
cultural,  ethical,  political,   and  legal   considerations.     A   recent   report  by   the
Presidential/Congressional Commission on Risk Assessment  and  Risk Management  (1997a,
 1997b) emphasizes the importance of engaging stakeholders throughout the risk assessment/risk
management process to assure that risk managers~e.g., government officials—take into  account
these considerations to achieve good risk management decisions.

      The development  of a better understanding  of the  risks to workers and  surrounding
communities associated  with emissions from  individual  facilities is  a high priority issue  for
stakeholders in EPA's CSI Metal Finishing Sector (EPA, 1997a).  Platers, environmental groups,.
community  groups, labor, and regulators all need and want to know what emissions are being
produced and in what amounts by metal finishing operations.  They also want to know what
health risks  those emissions create for workers and the surrounding communities. The process of
risk assessment can provide a tool for stakeholders associated with the metal finishing industry to
better understand and  evaluate the human health effects associated with chemicals emitted  by
metal finishing facilities.  The next two sections provide a brief overview of the metal finishing
industry and discuss the forum (i.e., the EPA's Common  Sense Initiative) that provided  the
impetus for  this project.

1.2 THE METAL FINISHING INDUSTRY

      The metal finishing industry encompasses a broad range of processes that are performed  on
manufactured  parts,  usually  after they have been shaped and machined (Murphy,  1996; EPA,
1995 a,  1995c). These processes generally alter the surface of the article to lend it properties not
possessed in its "unfinished state."  The processes most commonly impart a decorative finish  on
the article or provide it  with additional functional characteristics such as corrosion resistance.
Common  metal  finishing  operations  include  electroplating,  electroless  plating,  anodizing,
conversion coating, and painting (Murphy, 1996). Additional steps that may be performed before
or after finishing operations include cleaning (e.g., degreasing with organic solvents), etching, and
corrosion protection.   Many of these processes (e.g.,  electroplating, electroless plating, and
anodizing) involve the immersion of the metal parts through a series of liquid baths containing
solutions that impart the desired finish.

      The metal finishing industry is comprised of both "job shops," mostly small businesses with
limited capital and personnel, and "captive" metal finishing operations within larger manufacturing

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facilities.  Job shops perform finishing processes on parts that they receive from outside sources,
whereas captive shops perform finishing processes on parts that their firms manufacture. Captive
shops  are typically involved  in the manufacture  of such items as  machinery,  automobiles,
appliances, and musical instruments. Job shops involved in metal finishing are classified primarily
under the Department of Commerce's Standard Industrial Classification (SIC) Code 3471, metal
plating  and polishing.   Manufacturing facilities that  incorporate captive shops are generally
classified  within  SIC Codes 34 through  39,  which encompass facilities that fabricate metal
products.

      Estimates of the number of metal finishing facilities varies somewhat depending upon how
the industry is defined, but it is believed  to include  about 3,000 job  shops and about 10,000
captive shops (EPA, 1997d).  The typical job shop is about 30 years old, employs about 10 to 20
people  and has annual net sales of approximately  $1.1  million  (NCMS,  1994; CAMP, 1995).
Facilities can be found throughout the country,  but are concentrated in industrialized areas in the
Northeast, Midwest, Texas, and California.

      Metal finishing facilities release a variety of toxic compounds (EPA, 1995a). Chlorinated
hydrocarbons are emitted during cleaning (degreasing) of metal parts, caustic mists, cyanides, and
metals are released from electroplating operations;  and volatile organic compounds are emitted
during painting.  The emitted chemicals can cause a variety of adverse health effects  depending
upon the toxic nature of the chemical; the medium of exposure (i.e., air, water, soil, or food); the
chemical concentration to which an individual is exposed; and  the duration and frequency of the
exposure.  In addition, exposed individuals will have varying degrees of sensitivity to  chemicals
depending upon the person's health status, age, and  sex.  Adverse health effects may include
cancer  (hexavalent  chromium,  benzene), developmental  toxicity  (lead,  mercury,  glycols),
neurotoxicity (solvents, mercury), chemical bums (acids and alkalis), or dermal, respiratory, or
eye irritation (acid vapors, solvents, metals) (Klaasen, 1995).

      Table 1-1 lists some of the chemicals that  may be found in metal finishing process emissions
(EPA, 1995a).  The list  is not a description of the actual emissions from any specific facility.
Emissions  from each facility are dependent upon the processes performed and the  types and
effectiveness of any pollution control practices and control devices that are used at the facility. By
combining emissions data with chemical exposure and toxicity information in the risk assessment
process, an evaluation of the human health effects of emissions can be made.

1.3 COMMON  SENSE INITIATIVE

      CSI is an attempt by EPA to take a  new approach to creating policies and environmental
management solutions for American industries (Browner, 1994). Participants in the CSI program
have been asked to work together to achieve environmental protection on an industry-by-industry
basis.  Stakeholders associated with six industrial sectors—automobile manufacturing,  computers
and  electronics,  iron and  steel,  printing, metal  finishing, and petroleum refining—currently
participate in the CSI program.  These six sectors represent a cross-section of American industry
and taken together they comprise over 11% of the U.S. Gross National Product; employ over 4
million people;  and account for about 12%  of reported releases of toxic substances.  Because of

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                                           Table 1-1
        Chemical Substances Potentially Used in, Generated by, or Emitted
                              from Metal  Finishing Facilities
Metals and Metal Compounds
Aluminum
Arsenic, arsenic disulfide
Barium
Cadmium, cadmium acetate, cadmium chloride
Chromium, chromic acid
Copper
Iron
Lead
Manganese
Mercury
Nickel, nickel acetate, nickel sulfate
Nickel-cobalt acetate
Selenium
Silver
Tin-lead
Zinc
Alkalis
Sodium hydroxide
Cyanides
Potassium cyanide
Sodium cyanide
Zinc cyanide
Strong Acids
Hydrochloric acid
Hydrofluoric acid
Nitric acid
Phosphoric acid
Sulfuric acid
Weak Acids
Acetic acid
Citric acid
Oxalic acid
Tartaric acid
Other Inorganics
Chlorine
Fluoride
Potassium nitrate
Sulfur dioxide
Organics
Acetone
Acetone cyanohydrin
Benzene
Carbon disulfide
Carbon tetrachloride
Chlorinated fluorocarbons, l,l,2-trichloro-l,2,2-
   trifluoroethane (Freon-113), Trichlorofluoro-
   methane
Chlorobenzene
Chloroform
Cresols (cresylic acid)
Dichloromethane (methylene chloride)
Ethyl acetate
Ethyl benzene
Ethyl ether
2-ethoxyethanol
Formaldehyde
Glycols
Isobutanol
Kerosene
Ketones, cyclohexanone, methyl ethyl ketone, methyl
   isobutyl ketone
Methanol
Mineral oil
Naphtha
n-butyl alcohol
Nitrobenzene
2-nitropropane
1,2-dichlorobenzene
Phenol
Pyridme
Tetrachloroethylene
Toluene
1,2,4-trichlorobenzene
1,1,1 -trichloroethane
1,1,2-trichloroethane
Trichloroethylene
Xylene
                                                                      (Modified from USEPA, 1995c)

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the importance of these industries as measured by these characteristics and because of their
diversity in size, products, and operations, EPA believes that they offer an excellent opportunity
to create environmental solutions that can operate across industries and to expand CSI to other
sectors (EPA, 1994).

      The overall direction of CSI is  determined by stakeholders from each industry  sector.  A
CSI Council, comprised of high-level decision-makers from all stakeholder groups and across all
involved industrial sectors, provides a forum for the exchange of ideas among sectors (Figure 1-
1). The CSI Council is chaired by the EPA Administrator. For each industrial sector in CSI, EPA
also has convened a team of stakeholders (i.e.,  a  sector-specific subcommittee) that  looks for
opportunities to create new sector-specific alternatives to the current regulatory system to achieve
greater environmental gains at less cost to industries and taxpayers (a process sometimes labeled
"cleaner, cheaper, smarter") (EPA, 1994).
                                       Figure 1-1
                         Metal Finishing Sector Organization
                         Within the Common Sense Initiative
                                     Common Sense
                                    Initiative Council
        Printing
     Subcommittee
  Petroleum
  Refining
Subcommittee
    Metal
  Finishing
Subcommittee
                      Metal Finishing
                         Sector
                      Work Groups
                                                   ±
Iron and Steel
Subcommittee
Computers &
 Electronics
Subcommittee
                                                           JL
   Auto
Manufacturing
Subcommittee
                                                 Regulatory and Reporting
                                                Research and Technology
                               Risk Characterization
                                               Promoting Improved Performance

                                            Environmentally Responsible Transition
                                                Compliance and Enforcement
                                                    Access to Capital
                                                     Strategic Goals
      EPA hopes that  CSI, with its  involvement  of a diverse  and comprehensive group  of
stakeholders, will serve  as a model for changing the environmental protection process from one of
conflict to one of collaboration and consensus.  Historically, much of EPA's rule-making has
resulted in litigation.  This process  diverts valuable resources of all parties from the work  of
protecting the environment and public health.  The EPA hopes CSI will provide a forum within

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which former adversaries  will become partners in protecting the  environment.   To  assure
communication  among  stakeholders, sector subcommittees  have met regularly since CSFs
inception to identify and refine their objectives, to plan projects to meet those objectives, and to
discuss progress in the various projects underway, policy considerations, and other issues (EPA,
1997d).

      Each industry sector subcommittee has been asked to explore common issues, including
alternative regulatory  systems,  pollution  prevention, reporting,  compliance,  permitting,  and
environmental technology, that may have broad applicability to their sector as well as to other
industry sectors. EPA  hopes  that the new  systems  will  be  more flexible,  will encourage
innovation, and will be tailored to the needs of the industry and its environmental problems, while
at the same time the systems will encourage public participation, provide information about
facilities' environmental performance, and meet or exceed legal requirements (EPA, 1994).

      The Metal Finishing Subcommittee  has about 24 members representing  metal finishing
companies, trade associations, suppliers, environmental and community groups, organized labor
and  state  and  local governments.    Representative  organizations  include  the  American
Electroplaters and  Surface Finishers Society (AESF), the Natural Resources Defense  Council
(NRDC), the United Auto Workers (UAW),  the Barrio Planners of Los Angeles, the Water
Environment  Federation, and  the Association  of Municipal  Sewerage Agencies  (AMSA).
Members of the subcommittee have identified a set of National Performance Goals for the sector
that include three facility-based performance goals:

       • Reduction in hazardous emissions and exposures ("cleaner");

       • Increased economic payback and decreased costs ("cheaper");

       • Improved resource utilization ("smarter");

and two sector-wide performance goals:

       • Industry-wide achievement of the facility-based goals;

       • Industry-wide  compliance with environmental  performance requirements  (EPA,
           1997b).

To meet these goals, the subcommittee has endorsed 14 projects, and supports an additional CSI
small business sector project.  It has created eight work groups (Figure 1-1) to  carry out these
projects  and to identify important needs for the sector.

      The Metal Finishing Subcommittee's  Research and Technology Work Group examines  and
provides information about new technologies for the metal finishing industry and seeks to better
understand the technology needs of the  metal finishing industry, as a basis for tailoring Federal
and private sector research and development to meet those needs.  The work group's desired end
product is a "customer-oriented" research and development strategy for the industry.  The work
group's objectives are to assure that research efforts (including technology transfer and diffusion)
will address the most significant environmental needs of the metal finishing industry; that  the

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results will be accessible to the typical metal finishing job shop; and that the research program will
focus on pollution prevention and remediation technologies, so as to be of greatest benefit to
small job shops, some of which are located in brownfield areas.

      The work described herein  was undertaken in response to one of eight priority research
needs identified by the Research and Technology Work Group in its National Metal Finishing
Environmental R&D Plan (R&D Plan) (EPA,  1997a).  The eight priority research needs were
identified from among  74 projects that were rated by 27 experts from all metal finishing sector
stakeholder groups.  The experts  rated the research needs according to three criteria—the likely
impact of the project in achieving or exceeding Federal, state, and local compliance requirements;
achieving  widespread  adoption  within the  industry; and  reducing risks  to  workers,  the
surrounding community, and the environment.  The  rating system was used to prioritize research
and development needs and to make recommendations for the highest priority research areas.

      The eight specific recommendations for further research that were made in the R&D Plan
include:

       •  Develop and apply simple methods to describe the emissions from plating operations
          and use these values to characterize risks to workers, surrounding communities,  and
          the environment;

       •  Continue and expand research and development on various aspects of reducing  and
          eliminating multi-media emissions from hexavalent chromium plating operations;

       •  Focus research and development on  reducing cyanide emissions  and on developing
          improved analytic methods to determine the presence, concentration, and impacts of
          cyanide in waste streams;

       •  Demonstrate methods of off-site recovery of metals, acids, and cleaners;

       •  Focus research and development on low emission and  emissionless chlorinated  solvent
          vapor degreasing systems for metal plating operations and on evaluating alternatives to
          chlorinated  solvents for  cleaning—especially new,   alternative  cleaners  that have
          recently come on the market;

       •  Develop  a  rapid  verification protocol that provides  information  on technology
          performance, cost and maintenance  requirements on which companies could base
          decisions to purchase technologies;

       •  Conduct  research and development to reduce cadmium  emissions and to seek
          alternatives to its use; and

       •  Develop  and disseminate  short,  well-researched,  peer-reviewed articles   on  the
          selection and use of simple technologies for improved environmental performance.

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1.4 PROJECT OBJECTIVES

     Among the goals in the R&D  Plan the highest  priority was given to developing and
applying  simple methods to characterize the  emissions from plating  operations (and  more
specifically, chromium  electroplating operations) and to  use the output from these methods to
characterize the health  risks to workers, surrounding communities, and the environment (EPA,
1997a). To help attain this goal the objectives of this project  are:

      1)   to identify the types and sources of information that are needed to assess risks to
          workers and  surrounding communities from metal finishing facilities;

      2)   to  develop  a general  facility model  that describes  potential  human  exposure
          pathways;

      3)   to  present equations that characterize the exposure pathways from emission
          sources to workers and the public; and

      4)   to  quantify the lifetime excess cancer  risk and potential for other health hazards
          from hexavalent chromium in a screening risk assessment process.

By explaining the steps performed and the data needed to conduct a risk assessment we hope to
assist those associated with the industry to better understand the risk assessment process and the
questions that can be answered by the process.

      Although this report focuses on the potential effects  that emissions from metal finishing
operations may have on human health, emissions from some facilities may also affect ecological
receptors.  An ecological risk assessment can be performed  for those facilities where ecological
receptors may  be at  risk  beginning with a problem formulation  phase that  develops a site
conceptual model for the ecological receptors  at risk and identifies the  questions that the risk
assessment process would be designed to answer (EPA, 1996b).

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       2.  RISK ASSESSMENT FOR METAL FINISHING FACILITIES
2.1 THE RISK ASSESSMENT PROCESS

     Human health risk assessment is one part of the process that begins with the recognition
that a potential health problem exists (Problem Formulation) and continues to a decision by risk
managers to take actions (Risk Management) to reduce or eliminate any identified potential for
harm  (Figure 2-1).  Risk assessment  entails the evaluation of information on the hazardous
properties of chemicals and the extent of human exposure and the characterization of the resulting
risks.   The complete risk  assessment process is comprised of four steps—hazard identification,
dose-response assessment, exposure assessment, and risk characterization (NRC, 1983; 1994).
                                     Figure 2-1
                The Risk Assessment/Risk Management Paradigm
Research _
Epidemiology
Clinical Studies
Animal Studies
Cell/Tissue Experiments
Exposure Monitoring
Develop Fate and
Transport Models





rroDiem rormuiation -*-
Discussion Among Risk Assessor,
Risk Manager, and Stakeholders
-^P-
_. . .
Risk Assessment ~^~
^^,
" Hazard Identification
Dose Response Assessment
Exposure Assessment
Risk Characterization
-^P^
Risk Communication
Discussion Among Risk Assessor,
Risk Manager, and Stakeholders
~^0-
Risk Management
Evaluation of Public Health, Social,
Economic, Political, Engineering
Factors

Repeat St<
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V>
3
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1


Decision or Action
No Action
Information Programs
Economic Incentives
Ambient Standards
Pollution Prevention
Chemical Substitution
Chemical Ban
                                                                   (Based on NRC, 1983; 1994)

     Although complete risk assessments contain all four steps, they may nevertheless involve
varying levels of effort. Risk assessments are often performed using a phased approach hi which
upper estimates of exposure and chemical concentrations, which are believed to be conservative
(i.e., health protective) and likely to overestimate risk, are first used to assess risk.  A phased
approach to risk assessment  allows the risk assessor to identify those  health risks that are
potentially the most important and consequently to eliminate from further evaluation those
chemical exposures that clearly do not present a health risk.  This approach  simplifies and focuses

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subsequent phases of analysis and at the same time reduces the cost and time to perform the risk
assessment, especially at facilities with relatively low levels of emissions or emissions of relatively
non-toxic compounds.

      Problem formulation is a useful  process to perform prior to the risk assessment process
because it provides an opportunity to gather input from all stakeholders prior to commencing any
analysis.   The purpose of the problem formulation process is to sharpen the focus of the risk
assessment  on  those  problems  of greatest  concern to those persons, risk  managers and
stakeholders  alike, who will be using the information.   Problem  formulation  may involve  a
statement of the suspected problem based on available information; the identification of questions
to be answered by the  risk assessment; the identification of any research that may be needed
before beginning the risk assessment; and/or the presentation, review, and comment on an analysis
plan for  the risk assessment process.   Once the objectives of the risk assessment  process have
been identified the four steps of risk assessment can be conducted.

      The first step  of the risk  assessment process,  hazard  identification, seeks to identify the
potential health effects (e.g.,  dermal irritation, neurotoxicity, cancer, reproductive toxicant) that
may result from exposure to a chemical or physical agent.  This information is gathered from the
health effects literature, which may provide  evidence either for or against the agent as the cause of
a specific type of health effect.  Such studies often characterize the behavior of a chemical within
the body and its interactions with  organs, cells, or  even parts of cells.   Data regarding these
interactions may be of value in answering the ultimate question of whether the forms of toxicity
observed in an epidemiology study,  population group, or test animal are also likely  to occur as  a
result of an environmental exposure.

      For any harmful effect that is identified, the second step of the risk assessment process,
dose-response assessment, is conducted.  Dose-response  assessment attempts to determine the
relationship between the quantity of substance to which an individual is exposed and the severity
of the adverse  health effect.   Dose-response data are  derived from animal studies or, less
frequently, from studies in exposed human  populations (e.g., epidemiological studies of workers
have been performed for chemicals of concern to industry). There may be several dose-response
relationships for a substance because it may induce more than one type of harmful effect or it may
induce different  effects via different pathways of exposure.  The level of confidence in an estimate
of a dose-response relationship is partly dependent upon the source of data used  to derive the
estimate. Generally, estimates derived from human  studies, such as epidemiological studies of
workers, contain less uncertainty than those derived from  animal studies.  The first two steps of
the risk assessment process are chemical (substance) specific. Once completed, the information
can be used again in many assessments of various "real-life" situations.

      The third  step of the risk assessment process,  exposure assessment, seeks to characterize
"real-life" situations  by  determining the intensity, frequency, and duration of exposures  to the
chemical substance(s) in question that are known to occur or could occur in the future.  Exposure
assessments can evaluate past, present, or future exposures and may involve either direct or
indirect assessments  of exposure. Direct assessments measure the contact between the exposed
person(s) and the substance(s) being studied through the use of personal  monitors  (e.g., a small
air pump and filter that collects  air contaminants from within the breathing zone of the person
                                            10

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being studied).  Indirect assessment uses measurements of concentrations and other data in the
physical surroundings of the people being studied (e.g., air flow direction and rate), along with
information about where the people are and what they are doing to bring themselves into contact
with the substance(s).

      Risk  characterization,  the final  step  of the  risk  assessment process,  combines  the
assessments of hazard, dose-response, and exposure to estimate the probability of the occurrence
of a specific adverse effect in an exposed individual or population.    The results  of the risk
characterization are then communicated  to risk managers  and other  interested parties with an
overall analysis of the quality of the information in the assessment (NRC, 1994).  The uncertainty
associated with the risk  assessment and the sources of this uncertainty are presented.   The
uncertainty analysis should indicate whether the assumptions made in the preceding steps tend to
under- or over-estimate the level of risk.

      Risk assessment is closely linked but distinct from risk management, the process by which
the results of a  risk assessment are integrated with political, social, economic,  and engineering
considerations to arrive at decisions about the need and  methods for reducing risk.  A risk
assessment should be prepared, therefore, with both risk managers and stakeholders in mind, to
assure that appropriate information will be provided in a format that is understandable and useable
to all interested parties. Maintaining communication among risk managers, stakeholders, and the
risk assessor throughout the risk assessment process will increase the likelihood that all interested
parties will remain engaged in  the process and will contribute input on political,  social, and
economic issues that are part of the risk management process.

2.1.1 Hazard Identification

      The first step of the risk assessment process at a metal finishing facility is to identify the
chemicals present that may affect human health (Table 2-1).  Chemicals that may be used, stored,
or  generated at the  facility  from all  potential  sources including raw  materials, process
intermediates, and waste products  should be considered.  A preliminary list of the hazardous
substances that may be associated with metal finishing processes has been compiled (Table 1-1)
(EPA, 1995a).  The actual list of chemicals at  any given facility will consist of a subset of this list,
possibly supplemented with additional chemicals (e.g., as technology innovations occur and new
chemical processes  are developed, additional  chemicals may require evaluation).  Raw  materials
could be identified from company purchasing records or from the facility's Material Safety Data
Sheets; process  intermediates could be identified by evaluating the chemical  processes that are
conducted at  the facility; and waste products  could be identified from government-required
reporting forms such as EPA forms for the reporting of chemicals to the Toxic Release Inventory.

      Once a facility-specific list of chemicals is compiled,  the adverse health effects associated
with the chemicals can be identified by reviewing existing toxicological information.  One source
of this information is EPA's Integrated Risk Information System (IRIS), which is available on the
internet (www.epa.gov/ncea/iris.htm). It is possible at this step of the risk assessment that some
chemicals will be identified for which little or no toxicological information is available.  Lack of
such information is  a  source of uncertainty  in the risk assessment.  Additional laboratory or
epidemiological research on the chemicals may be needed to  reduce this uncertainty.


                                            11

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                                           Table 2-1
                   Principle Steps of the Risk Assessment Process
                               for Metal Finishing Facilities
    Risk Assessment Step
                       Associated Tasks
Hazard Identification
Identify chemicals emitted or released from known chemical usage and
emissions data from the facility or industrial sector.
Identify unwanted health effects of chemicals that are emitted or released.
Dose-Response Assessment
Identify cancer potency factors, unit risks, reference concentrations, and
reference doses for each chemical as derived by EPA or by others from
animal studies and human epidemiological studies.

Verify assumptions used in existing data with historical information about
the facility or industrial sector.
Exposure Assessment
Collect  plant emissions information from  permits,  emissions  reports,
interviews, and industry  records.    Characterize any  variations in
emissions over  time (e.g.,  daily or longer term fluctuations that result
from variations in facility schedules and production runs).

For workers, describe work environment, such as ventilation in rooms, air
exchange rates,  direction of air flow, and whether any special systems are
present  to prevent  or reduce worker exposure (including  any personal
protective equipment that workers may be required to wear). Describe
design, placement and effectiveness of building ventilation system.

For  more refined  assessments  of exposure  pathways in air,  obtain
meteorological data from weather service and air districts (commonly
available for use in EPA air models)  and predict concentrations of
pollutants in air at  varying distances from the emission source using air
dispersion model(s).

For more refined assessments of exposure pathways in  water, collect
hydrogeological data from United States Geological  Survey  (USGS),
water districts, or state  and county governments and use to  predict the
movement of chemicals in groundwater and surface water.

Collect demographic information from census information, county and
city records, and site surveillance.

Verify concentrations  of chemicals in  environmental media  through
workplace and/or community observation and/or monitoring.  Describe
how emissions controls and environmental fate and transport processes
affect exposure concentrations for off-site populations.
Risk Characterization
Describe the probability of unwanted health effects by  combining
information from hazard identification, dose-response assessment, and
exposure assessment steps.

Identify and discuss sources of uncertainty and variability associated with
variables in the risk assessment.
                                                                                 (Based on Schaum, 1997)
                                                12

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2.1.2 Dose-Response Assessment

      The dose-response assessment attempts to determine the relationship between the quantity
of substance ingested, inhaled, and/or absorbed (e.g., through the skin) and the probability of the
occurrence and severity of an adverse health effect.  The dose-response assessment considers
whether sensitive or special populations, such as  children, persons with compromised immune
systems, or the elderly may be more susceptible to  a chemical's harmful effects.  Generally, dose-
response  information is  gathered from two types  of sources—animal studies  and  human
epidemiologjcal studies.  Dose-response values derived from both types of studies contain some
degree of uncertainty.  Values  that  are based on animal  studies are extrapolated from the
responses of test animals that are exposed under  laboratory conditions, often at relatively high
concentrations. Adjustments must be made to the experimentally-derived dose-response values to
obtain a dose-response value appropriate for humans. The adjustments account for metabolic and
physiological differences between  humans  and animals, differences in  exposure duration  and
intensity, and differences in exposure pathways (e.g., ingestion in food versus ingestion in water).
Values that are based on  studies of human populations contain less uncertainty but still often
require extrapolation from a high dose,  short-term exposure, such as occurs from accidental
exposure  or  an intentional  overdose,  to a low  dose, chronic  exposure.   When the studied
population used to derive  the dose-response value is similar to the population of interest in the
risk assessment  (e.g.,  epidemiological studies of workers used to derive  safe workplace
concentrations) the estimates of dose-response are more certain.

      EPA's IRIS database contains dose-response information for over 500 specific chemical
substances.   The database was  initially developed  for EPA staff in response  to  demand for
consistent information on chemical substances for  use in risk assessments, decision-making,  and
regulatory activities.  Dose-response values in the database  represent EPA consensus scientific
positions on potential adverse human health effects that may result from chronic (e.g., lifetime)
exposure to environmental contaminants.  This information has been evaluated by scientists from
EPA's program offices and Office of Research and Development (ORD) who are experienced in
issues related to both the  qualitative and  quantitative risk assessment  of carcinogenic and toxic
agents.   The  review process leads  to an internal EPA scientific consensus  regarding  risk
assessment information on  a chemical.

      Dose-Response Values for  Noncarcinogenic Effects.   One widely held view among
toxicologists is that many of the harmful effects that result from exposure to toxic chemicals occur
only when an individual's exposure (via  inhalation, ingestion, and/or dermal contact)  exceeds
some threshold level of uptake.  The threshold level is generally  expressed as a chemical dose
(e.g., reference dose, or RfD) to which an individual may be exposed over a portion of a lifetime
(subchronic RfD) or during  a lifetime (chronic RfD) without an appreciable risk of adverse
effects.  The chemical dose is expressed as the weight of chemical per kilogram of body weight
per day (e.g., milligrams/kilogram»day or mg/kg*day). For chemicals in air the threshold level is
expressed as a concentration  (reference concentration, or RfC) such as micrograms of chemical
per cubic meter of air (ug/nr*).

      The dose-response values noncarcinogenic effects are  based on toxicological information
derived from either animal  or human studies. Chemical exposure in these studies may be acute (a
brief exposure of a few minutes to a few days), subchronic (a few weeks to months), or chronic

                                           13

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(usually includes at least a tenth of the life span of a species, generally six months or more).
Chronic  exposures generally have  the lowest thresholds  for  adverse  effects and  are  most
commonly  used to derive chemical RfDs and RfCs for EPA risk  assessments.   However, if
emissions are episodic or of short duration, the RfDs and RfCs that relate to acute exposures may
be appropriate to use in the risk assessment. The RfDs and RfCs cited in this report were derived
by EPA's program offices and ORD and have been reported in the  IRIS  database or in EPA's
Health Effects Assessment Summary Tables (EPA 1995b; 1997e) (Table 2-2).  These values are
estimates (with uncertainty spanning perhaps an order of magnitude) of continuous exposure to
the human population that are likely to be without appreciable risk of deleterious effects during a
lifetime.

      EPA's RfDs and RfCs have been calculated to be protective of sensitive members of human
populations.  A margin  of safety has been applied to derive RfDs and RfCs from experimental
data. This margin of safety is applied to account for intra- and inter-species variations, for limited
or  incomplete data,  for  evaluating  the significance of adverse effects,  and for adequately
protecting sensitive human populations.  In practice, the experimentally-derived values are divided
by an uncertainty factor (generally, a number between 3 and  1,000) and possibly by an  additional
modifying  factor to add this margin of safety to the RfDs  and RfCs.  EPA's rationale for the
application of these safety factors is given in the IRIS database for each chemical where a RfD or
RfC is given.

      Dose-Response Values for Carcinogenic Effects.  EPA considers the weight of evidence
that a chemical is  a carcinogen and for chemicals that are known or likely to cause cancer, the
agency calculates an oral slope factor and/or inhalation unit risk (EPA, 1986; 1996a).  Oral slope
factors and unit risks are estimates of the relationship between dose or concentration and the
probability that a chemical will induce cancer. Oral slope factors are upper bound estimates of the
cancer risk per unit intake of a chemical over a person's lifetime.  Inhalation unit risks  are upper
bound estimates of the cancer risk per unit of concentration of a chemical  in air over a person's
lifetime.  Because the slope factors and unit risks are upper bound estimates, the risk of cancer for
an exposed individual over a lifetime is unlikely to exceed  the calculated probability and  likely will
be less.  Oral slope factors and/or inhalation unit risks are given in Table 2-2 for  each chemical
where information is  available.    Slope factors  are expressed  as the inverse   of the  dose,
"(rng/kg*day)"V while  unit  risks  are expressed as the  inverse  of concentration, "(ng/m3)"1"
Slope  factors and  unit risks in this  report  were  derived by EPA's program offices and ORD.
Some states, notably California, have derived slope factors that differ from those derived by EPA
(DTSC,  1994b).

      The dose-response estimates have numerous uncertainties,  including those associated with
extrapolations from animal data to  humans and from  high   experimental doses  to lower
environmental exposures.  These uncertainties may span an order  of magnitude or more.  Actual
incidence of health effects is influenced by the physiology and health-status of the exposed
individual or populations such as general health, age, and sex and by the degree of exposure to the
chemical, which is estimated during the exposure assessment step of the risk assessment (EPA,
1993).
                                           14

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                                                    Table 2-2
                       Published EPA Human Health Toxicity Values for Chemical Substances
                                 Potentially Emitted by Metal Finishing Processes
Chemical
Metals (1)
Aluminum
Arsenic
Barium
Cadmium
Chromium (VI)
Copper
Iron
Lead
Manganese
Mercury (3)
Nickel
Selenium
RfC
mg/m3

|'ft|f"i
ill::. "'JV^-lv: .;;.
5.0 x 10'4
n.d.
n.d
n,d.
n,d.
Bas
5.0 x 10'5
3.0 x lO'4
n.d.
n.d
unit risk
(lig/mV

m.*m
4.3 x 10"3
'•••'•'•'.-n-iai^-.
1.8 x 10'3
1.2 x 1C'2
•::,.n.a,;,;'
' ':[''.'M'. :':/ '
^d on biokine
n.a.
n.a.
n.a.
n.a.
RfD0
mg/kg/day

1.0 xlO1
3.0x10-"
7.0 x 10'2
5.0 x 10'4
5.0 x 10-3
3.7xlO'2
n.d.
SF0
(mg/kg/day)-1

.::/'• n^a- '!
1.5 x 10°
:::v'::nift;:-' !;j;:
;;:::::.n;a.' /.:!!;
::: n.a. !.'
.:; :-.*><8:. :;.. •'
':•;•• •ihia.^;i::::
tic uptake models
4.7 x ID'2
3.0 x 10'4
2.0 x 10'2
5.0 x ID'3
';: ;;•' n;a.': ' :.:.
::::;:::,n.a.:. •:;;:;.
:;; /.:bia.;:;:;:;;;
:':;::n:a.: '-:'
Chemical
Silver
Tin
Zinc
Alkalis (4)
Sodium hydroxide
Cyanides
Potassium cyanide
Sodium cyanide
Zinc cyanide
Mineral Acids (4)
Hydrochloric acid
Hydrofluoric, nitric, and
sulfuric acids
Phosphoric acid
RfC
mg/m3
n.d.
ltd.
n.d.

'I.1 . ^.li: . .::

n.d.
n.d.
n.d.

2.0 x 1Q-2
n.cL
l.Ox 10'2
unit risk
(ng'm3)'1
n.a.
n.a.
n.a.

ii::;:: 'n.a. ... . .;

n
-------
                                              Table 2-2 (continued)
                       Published EPA Human Health Toxicity Values for Chemical Substances
                                 Potentially Emitted by Metal Finishing Processes
Chemical
Organic Acids (4)
Acetic, citric, oxalic, and
tartaric acids
Other Inorganics
Fluoride
Potassium nitrate (5)
Sulfur dioxide
Chlorine
Organics
Acetone
Acetone cyanohydrin
Benzene
Carbon disulfide
Carbon tetrachloride
RfC
mg/m3

n.d.

n.d.
n.d.
n.d,
n.d.

: .»•<>•
n,d.
6.0 x 10'3
7.0x10-'
2.0 x 10'3
unit risk
(jig/m3)-1

n.a.

n.a.
n.a.
n.a.
n.a.

n.a.
: n.a.
8.3 x 10'6
n.a.
l.SxlO'5
RfD0
mg/kg/day

n.d.

6.0 x 10'2
1.6x10°
n.a.
1.0 x 10°

1.0 xlO'1
8.0 x 10'4
n.d. ....,
1.0 x 10'1
7.0 x 10-"
SF0
(mg/kg/day)'1

n.a.

n,a.
n,a.
n,a.
n.a.

n,a.
n.a.
2.9 x 1Q-2
nia.
1.3 x 10-'
Chemical
Chlorobenzene
Chloroform
Cresol (Cresylic acid)
Cyclohexanone
1 ,2-dichlorobenzene
Dichloromethane
(methylene chloride)
2-ethoxyethanol
Ethyl acetate
Ethylbenzene
Ethyl ether
Formaldehyde
Glycols (6)
Isobutanol
RfC
mg/m3
2.0 x 10'2
n.d
n d
n.d.
2.0 x ID'1
3.0x10°
2.0 x 10''
n.d.
1.0x10°
n.d.
'••• "4
n.d.
n.d.
unit risk
(ng'm3)'1
n.a.
2.3 x 10'5
n.a.
n,a.
n,a.
4.7 x 1Q-7
n.a.
n.a.
; n,a.
n.a.
1.3 x ID'5
n,a.
: n.a.
RfD0
mg/kg/day
2.0 x lO'2
1.0 x 10'2
n.d.
5.0 x 10°
9.0 x 10'2
6.0 x 10'2
4.0 x 10'1
9.0 x 10'1
1.0 x 10'1
2.0 x 10'1
2.0 x 10"'
2.0x10°
3.0x10-'
SF0
(mg/kg/day)"1
n.a.
6.1 x 10'3
n.a.
n,a.
n,a.
7.5 x 1Q-3
n,a.
n.a.
n,a.
n,a.
n,d,
n.a.
n,a.
Footnotes are listed at end of Table 2-2.
                                                       16

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                                                           Table 2-2 (continued)
                             Published EPA Human Health Toxicity Values for Chemical Substances
                                           Potentially Emitted by Metal Finishing Processes
Chemical
Kerosene
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Mineral oil

Naphtha
n-butyl alcohol
Nitrobenzene
2-nitropropane
Phenol
RfC
mg/m3
n.d
n.d.
1.0x10°
8.0 x 10'2
n,d,

fl.d
n.d.
2.0 x 10'3
2.0 x 10'2
n.d.
unit risk
(ng/m3)-'
n.a.
n.a.
n.a;
n.a.
n.a.

n,a.
n.a.
n.a.
n.a.
n.a.
RfD0
mg/kg/day
n.d.
5.0 x ID'1
6.0 x 10'1
8.0 x ID'2
n.d.

ti.d.
l.OxlO'1
5.0 x lO'4
n.d.
6.0 x 10'1
SF0
(mg/kg/day)-1
n.a.
n.a.
n,a.
n,a.
n,a.

ita.
n.a.
n.a.
n.a.
n.a.
Chemical
Pyridine
Tetrachloroethylene
(perchloroethylene)
Toluene
1 ,2,4-trichlorobenzene
Trichlorofluoromethane
(Freon-11)
1,1,2-trichloro- 1,2,2-
trifluoroethane (Freon-113)
1,1,1 -trichloroethane
1 , 1 ,2-trichloroethane
Trichloroethylene
Xylene (1)
RfC
mg/m"
rV:M^':'.'f
:' ::;; ltd/":. ::
4.0 x 10'1
2.0 x ID'1
7.0 x 10-'

3.0x10'
ltd.
n.d
rtd.
ruL
unit risk
(ng/m3)'1
:..::::' n.a:..
^•:;'n.dr
• ;:: n,a. • .
n:y'.h;a.:::l:'
i::l n4

; n.a.
n.a.
1.6 x 10'5
n.d.
n.a.
RfD0
mg/kg/day
1.0 x 10-3
1.0 x 10'2
2.0 x 10'1
l.OxlO-2
3.0 x 10"'

3.0 x 101
3.5xlO'2
4.0 x 10'3
6.0 x 10'3
2.0 x 10°
SF0
(mg/kg/day)-1
n.a.
5.2 x 10-2
n,a.
n,a.
n,a.

n.a.
n.a.
5.7 x 10"2
l.lxlO'2
n.a.
Source: (EPA 1995b; 1997e)  Because the source references are updated periodically, values in table should be verified before using in a risk assessment.
(1) Includes metals and metal compounds
(2) n.d. - not determined. EPA has not determined a reference concentration, reference dose, or unit risk for this chemical.
    n.a. - not applicable. Cancer slope factor or unit risk value has not been derived for this chemical because there is a lack of evidence that indicates that this
    chemical is a carcinogen, because this chemical is not carcinogenic, or because the chemical is not carcinogenic by the oral or inhalation exposure route.
(3) RfD0 is for mercuric chloride; RfC is for elemental mercury.
(4) The primary hazard associated with most acids and alkalis is corrosivity. The more volatile acids produce irritating vapors.
(5) Values for potassium nitrate are based on the toxicity of the nitrate anion and are expressed as nitrate-nitrogen.
(6) Values in table are for ethylene glycol; values for other glycols will vary.
(7) Value is for mixed xylenes.

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2.1.3  Exposure Assessment

     Exposure assessment seeks to determine the intensity, frequency, and duration of actual or
potential exposures to  a chemical  in the environment  (Figure  2-2).   To  assess exposure,
information about the concentrations of chemicals in air, soil, water, and food is needed along
with information about how humans may  be  exposed to  these media (through breathing, skin
contact with water or soil, drinking of water or milk, or eating produce or other foods) to assess
the level of exposure (Table 2-3).  An individual's exposure will vary over time because chemical
concentrations in the environment vary (e.g., with distance from the emissions source or with time
as the chemical is dispersed  by physical processes or is degraded by  biological, chemical or
physical processes) and because an individual's location relative to the facility varies  over time.
To accurately describe exposure for different groups of people, chemical concentrations in water,
air, soil, and food must be measured or estimated in several directions and at various distances
from a source of chemical emissions.  Information about the variation in concentrations over time
also increases  the accuracy of the exposure assessment.   This information  may be obtained by
measuring and analyzing emissions or, for outdoor air concentrations, by using  environmental fate
and transport models  and/or air dispersion models  (e.g., ISC2, an  existing EPA model, or the
Total  Risk  Integrated  Methodology,  which  is currently  in  development)  to  establish  the
relationship between emissions and chemical concentrations in the environment.
                                       Figure 2-2
               Conceptual Exposure Model for Electroplating Process
t
/Venti
y'Treatmer
>
i
ation N.
t System\^
..'-.'• ' • -. • - Fugi
• - I; ; ' Mist ' ; !• Emis!
• '• • formation- • '.
±
Plating Bath

i
Worker
Exposure
Inhalation
tive ' Ingestion
>ions jf _
/* Dermal
Jpills Contact
Water Treatment
System
f
\ /
,
\
(
^
(
i
i
\
^ i

I
•3
D
3
a
y
= Public
Exposure i
Inhak
^- Soil r—^-
, W"9
Water ^ ^
r
ition
-^.
estion
*•*•
nal
tact
      Concentration data for each medium are combined with information regarding population
characteristics (e.g., volume of air breathed during different work activities, surface area of skin
exposed to soil during gardening, volume of water drunk, or amount of food consumed) and
                                           18

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                                          Table 2-3
          Exposure Assessment Data Needs for Metal Finishing Facilities
   Exposed
 Population
                                              Required Inputs
  Chemical Concentration
    Exposure Duration and
          Frequency
    Population
  Characteristics
 Nearby
 Residents
Site-specific and media-specific
chemical concentration data
(concentrations may be
measured or modeled)

Regional or local area chemical
concentrations monitoring data

Emissions rate information

Local meteorology (wind
direction, speed, turbulence,
solar radiation)

Surrounding terrain and
buildings
Duration of residence

Daily activity patterns by age group:

  Hours spent at home

  Hours spent outdoors
Age

Sex

Health Status
 Workers
Site-specific and media-specific
chemical concentration data
(concentrations may be
measured or modeled)

Materials balance for facility
processes

Ventilation patterns and
exchange rates

Controls on indoor emissions
Activity patterns by job description
or category

By job description or category:

  Hours worked per week

  Weeks worked per year

  Years worked per job

  Degree of exertion

Engineering and administrative
controls on exposure

Personnel protective equipment
Age

Sex

Health Status
                                                                             (Based on Sdiaum, 1997)

activity patterns (e.g., hours  spent  performing a specific  work process,  hours spent at home
outdoors, number of years spent at a residential location) to determine the amount of chemical to
which an individual is exposed (Table 2-4).

      In Table 2-4, all values (exclusive of conversion  factors) that are  used to calculate the
average  daily dose have some degree of variability associated with them.  Variability refers to
observed differences attributable to heterogeneity in a population or exposure parameter.  Sources
of  variability  are the  result of natural  random  processes  and  may  be  associated  with
                                              19

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         Table 2-4
Generalized Dose Equations
Route of Exposure
Equation 2-1
Inhalation of Volatiles or Particulates
*nn _ r ,. InhRa x ETa x EFa x EDa
BW x AT x 365 days/yr
Equation 2-2
Ingestion of Soil, Dust, or Surface Deposits
Ann r ._ IRsxEFsxEDsXlCT6
AJJJJsi Us X
BW x AT x 365 days/yr
Equation 2-3
Ingestion of Water
APPuoL., = rwx IRwxEFwxEDw
BWxATx365days/yr
Values
ADDai
MlRa
ETa
EFa
EDa
BW
AT
ADD*
{-*$
IRs
EFS
EDS
10"6
BW
AT
ADD™
Cw =
IRw
EFW
EDW
BW
AT
= Average Daily Dose
via air inhalation
= Chemical concentration in air
(milligrams/meters3)
= Inhalation rate
(meters3/hour)
= Exposure time
(hours/day)
— Exposure frequency
(days/year)
= Exposure duration
(years)
= Body weight
(kilograms)
= Averaging time
(years)
= Average Daily Dose
via soil ingestion
= Chemical concentration in soil
(milligrams/ldlogram)
= Intake rate
(milligrams/day)
= Exposure frequency
(days/year)
- Exposure duration
(years)
= Conversion factor
(kilograms/milligram)
= Body weight
(kilograms)
= Averaging time
(years)
= Average Daily Dose
via water ingestion
Chemical concentration in water
(milligrams/liter)
= Intake rate
(liters/day)
= Exposure frequency
(days/year)
(years)
= Body weight
(kilograms)
= Averaging time
(years)
            20

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                                    Table 2-4  (continued)
                                Generalized Dose Equations
  Equation 2-4

  Dermal Contact with Soil, Dust or Surface Deposits
           = c x  SSAs x AF x ABS x ETS x EFS x EDS x
                             BWxATx365days/yr
ADDsc= Average Daily Dose
       via soil contact
Cs   = Chemical concentration in soil
       (milligrams/kilogram)
SSAs = Skin surface area
       (centimeters2/hr)
AF   = Soil adherence factor
       (rnilligram/centimeter2)
ABS = Dermal absorption factor
       (unitless)
ETS  = Exposure time
       (hours/day)
EFS  = Exposure frequency
       (days/year)
EDS  = Exposure duration
       (years)
1CT6  = Conversion factor
       (kilograms/milligram)
BW  = Body weight
       (kilograms)
AT   = Averaging time
  	(yearsj   	
  Equation 2-5

  Dermal Contact with Water
     ADD™  =
Tw x IP'3 x EVW x EFW x EDW x SSAW

   BWxATx365days/yr
  (steady state equation - see text for discussion of non-steady state approach)
ADDwc = Average Daily Dose
       via water contact
    = Chemical concentration in water
     (milligrams/liter)
     = Dermal permeability constant
       (centimeters/hour)
SSAW = Skin surface area
       (centimeters2)
Tw  = duration of event (hr/event)
EVW = Event frequency
       (events/day)
EFW  = Exposure frequency
       (days/year)
EDw = Exposure duration
       (years)
10~3  = Conversion factor
       (liters/centimeters3)
BW  = Body weight
       (kilograms)
AT  = Averaging time
       (years)	
environmental, lifestyle, and genetic differences among humans and other organisms.  Examples of
variability include physiological variation such as differences in body weight, breathing rate, and
the amount of food and water consumed. Environmental variation may include fluctuations in air
temperature,  wind  speed  and  direction,  and  soil  conditions,  all  of  which  can  affect  the
concentration of a  chemical in a  specific medium  in the  environment and  thus the average
concentration term that is used in the dose equation. Variability is usually not reducible by further
measurement or study (although it can be better characterized).
                                               21

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     Finally, different methods are used for inorganic and organic chemicals to calculate the
amounts of these chemicals that are absorbed from water (EPA, 1992). The method for inorganic
chemicals assumes a "steady-state" approach whereas the method for organic chemicals assumes a
"nonsteady-state" approach.  Steady-state means that the system reaches equilibrium over time
and then does  not change or changes only negligibly over the measurement time period.  In
general, the  nonsteady-state approach  is  believed  to  most accurately reflect normal  human
exposure conditions since the short contact times associated with bathing and swimming generally
mean that steady-state (equilibrium) conditions will not occur.  The nonsteady-state method also
accounts for the dose that can  occur  after the actual exposure event  due to absorption of
contaminants stored in fats and oils in the skin.  Application of this method requires that the
chemical in question partition between an organic solvent (octanol)  and water. Inorganics do not
exhibit  this  characteristic and  thus  the nonsteady-state methodology  is  not applicable  to
inorganics. The steady-state approach is therefore currently recommended for inorganics.

2.1.4 Risk Characterization

     Risk characterization combines the assessments of hazard, dose-response, and exposure to
estimate the probability of specific harm to an exposed individual or population.   It assesses the
overall  quality of the information  in the  assessment,  identifying any sources  of uncertainty
associated  with the risk assessment, and it indicates  whether the assumptions made  in the
preceding steps tend to under- or over-estimate the level of risk.

     Cancer risks are expressed as probabilities.  As presented here the risk equations estimate
the upper bound incremental increase in cancer risk over a lifetime due to the described exposure
scenario. Because the calculated risks are upper bound estimates, the actual  risks are unlikely to
be greater.  The calculated risks are the incremental  increase over the "background" cancer rate
among persons living in the U.S. The current U.S. background rate for all cancers over a lifetime
is 30 about percent (i.e., 30 persons in 100 will be diagnosed with some form of cancer in their
lifetime).  The  calculated risk due to the chemical exposure is the  additional risk (e.g., one in a
thousand, ten in a million, one in a million) above this  lifetime background level.

     For noncancer health effects the RfD or RfC is compared to the calculated dose or exposure
concentration.  When the exposure dose  divided by the RfD  or the exposure concentration
divided  by the RfC is greater than one (the calculated values are called "hazard quotients"), some
potential for harmful health effects exists.

     The  general  equations for the  calculation   of  risk for  carcinogens and hazard  for
noncarcinogens are as follows:

Risk via air inhalation

             risk = unit risk*Ca*(InhRa/0.83)*(EFa/365)*(ETa/24)*(EDa/70)*(70/BW)2/3

                                         HQ=
                                            22

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Where:
       Ca = Concentration in air
       InhRa = Inhalation rate (meter3/hour)
       EFa = Exposure frequency (days/year)
       ETa = Exposure time (hours/day)
       EDa = Exposure duration (years)
       BW = Body weight (kilograms)
       HQ = Hazard quotient
       RfC = Reference concentration (may require adjusting from published value to account for
       populations that differ from default EPA exposure scenarios)
Risk via ingestion of soil

                    risk = oral slope factor*Cs*(IRs*EFs*EDs*CFs)/(BW*ATcarc)

                   HQ = [Cs*(IRs*EFs*EDs*CFs)/(BW*AT*365days/year)]/RfD

Where:
       Cs = Concentration in soil
       IRs = Intake rate for soil (milligrams/day)
       EFS = Exposure frequency (days/year)
       EDS = Exposure duration (years)
       CFS = Conversion factor (10"6 kilograms/milligrani)
       BW = Body weight (kilograms)
       ATcarc = Averaging time for carcinogens (25,550 days)
       HQ = Hazard quotient
       RfD = Reference dose
       AT  = Averaging time for noncarcinogens, equal to exposure duration (years)

Risk via ingestion of water

                     risk - oral slope factor*Cw*(IRw*EFw*EDw)/(BW*ATcare)

                           HQ = [Cw*(IRw*EFw*EDw)/(BW*AT)]/RfD

Where:
       Cw = Concentration in water
       IRW = Intake rate for water (liters/day)
       EFW = Exposure frequency (days/year)
       EDW = Exposure duration (years)
       BW = Body weight (kilograms)
       ATcarc = Averaging time for carcinogens (25,550 days)
       HQ  = Hazard quotient
       RfD = Reference dose
       AT = Averaging time for noncarcinogens, equal to exposure duration (years)
                                          23

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Risk via dermal contact with water (steady-state conditions)

           risk = oral slope factor*(Cw*Kp*Tw*CFw)*(EVw*EFw*EDw*SSAw)/(BW*ATcarc)

          HQ = [(Cw*Kp*Tw*CFw)*(EVw*EFw*EDw*SSAw)/(BW*AT*365days/year)]/RfD

Where:
       Cw = Concentration in water (milligrams/liter)
       Kp = Dermal permeability (centimeters/hour)
       Tw = Duration of event (hours/event)
       CFW = Conversion factor (10~3 liters/centimeter3)
       EVW = Event frequency (events/day)
       EFW = Exposure frequency (days/year)
       EDW = Exposure duration (years)
       SSAW = Exposed skin surface area (centimeter2)
       BW = Body weight (kilograms)
       ATcare = Averaging time for carcinogens (25,550 days)
       HQ = Hazard quotient
       RfD = Reference dose
       AT = Averaging time for noncarcinogens, equal to exposure duration (years)

Risk via dermal contact with soil/dirt

           risk = oral slope factor* Cs*(SSAs*AFs*0.01*ETs*EFs*EDs*CFs)/(BW*ATcarc)

           HQ = [Cs*(SSAs*AFs*0.01*ETs*EFs*EDs*CFs)/(BW*AT*365days/year)]/RfD

Where:
       Cs = Concentration in water (milligrams/liter)
       SSAs = Exposed skin surface area (meter2)
       AFS = Soil adherence factor (unitless)
       ETS = Exposure time (hours/day)
       EFS = Exposure frequency (days/year)
       EDS = Exposure duration (years)
       CFS = Conversion factor (10"6 kilograms/miUigram)
       BW = Body weight (kilograms)
       AT^ = Averaging time for carcinogens (25,550 days)
       HQ = Hazard quotient
       RfD = Reference dose
       AT = Averaging time for noncarcinogens, equal to exposure duration

     Transfer of Chemicals Between Environmental Media.  In addition to the sources of
uncertainty regarding  environmental concentrations,  exposure factors,  and  toxicity values
discussed above, the estimates of risk presented here do not account for the potential transfer of
contaminants between different environmental media.   For some chemicals and under some
exposure conditions, the transfer  of  contaminants between environmental media may represent
                                          24

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significant exposure pathways.  For example, volatile contaminants in water may be released to
the air during showering, dish washing, or other indoor household activities.  The volatilized
chemical could then be inhaled.  A conceptual model of a facility should be prepared prior to
performing a facility-specific risk assessment to  identify those pathways of exposure that are
important for that facility.

2.2 ASSESSING RISK FOR CHROMIUM ELECTROPLATING FACILITIES

2.2.1  Hazard Identification

      Chrome plating is a common process in metal finishing operations and as a result, chromium
(primarily as hexavalent chromium) is prevalent in metal finishing emissions.  Eight of the top 25
most  commonly used metal finishing processes use chromium and it is estimated that about 2
million pounds per year of chromium are  emitted to  the  air (23,000 pounds), discharged in
wastewater (4,600 pounds), or disposed as wastewater  sludge (900,000 pounds) or other solid
waste (1,100,000 pounds) by hard chrome operations  in the U.S. (EPA, 1995a).   Hexavalent
chromium is emitted during the chromium electroplating process in the form of a visible yellow
mist.  The mist is composed of entrained chromic acid droplets that form when hydrogen and
oxygen gases are released from the surface of the plating solution.

      Hexavalent chromium is a human carcinogen and can cause a variety of other adverse health
effects (ATSDR, 1993; IARC, 1990; EPA,  1984).  Breathing in chromium can cause irritation to
the nose, such as runny nose, sneezing, itching, nosebleeds, ulcers, and, over long periods of time,
holes  in the nasal septum. Respiratory system effects (e.g., asthma) and immune system effects
(e.g.,  allergic sensitivity from dermal exposure) have been documented (ATSDR, 1993).

2.2.2  Dose-Response Values for Hexavalent Chromium

      Inhalation Unit Risk.  EPA estimates that  the unit risk for hexavalent chromium is 0.012
(ug/m3)"1  The IRIS database provides the following  information about the derivation of the
inhalation unit risk.

            "Results of occupational epidemiologic studies of chromium-exposed
      workers are found to be consistent across investigators and study populations.
      Dose-response relationships have been established for chromium exposure and
      lung cancer.  Chromium-exposed workers are exposed to both chromium III and
      chromium VI compounds.  Because only chromium  VI has been found to be
      carcinogenic in animal studies, however, it was concluded that only chromium VI
      should be classified as a human carcinogen. "

      The IRIS database notes that the unit risk  should not be used if the air concentration of
hexavalent chromium exceeds 0.8 ng/m3 The assumption that the relationship between risk and
concentration is linear may not be appropriate above this  concentration (EPA, 1997e).  Both
higher and lower estimates of the inhalation unit risk for  hexavalent chromium have been derived
from human epidemiological studies (DTSC, 1994b;  OSHA, 1995).  A discussion of the merits
                                          25

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and weaknesses of these various estimates is outside the scope of this paper, but is noted as a
source of uncertainty in attempting to quantify human health risks.

      Oral Slope Factor.  The IRIS database does not contain an oral slope factor for hexavalent
chromium because EPA believes that hexavalent chromium is not carcinogenic by the oral route
of exposure. When ingested, hexavalent chromium is reduced to trivalent chromium  hi the saliva
and gastric juice of the upper alimentary tract (Anderson  et al., 1993 and  references therein).
Because the reduction of hexavalent  chromium  to  trivalent chromium is relatively rapid and
because trivalent chromium is not carcinogenic in animals EPA believes that  ingested hexavalent
chromium is not carcinogenic (EPA, 199la).   However, there is some disagreement with this
conclusion and at least one state, California, has provisionally derived an oral slope factor of 4.2 x
10"1 for hexavalent chromium.

      Reference Concentration. EPA does not currently list a RfC for hexavalent chromium. In
1991, EPA proposed a RfC of 0.002  ug/m3 for both hexavalent and trivalent  chromium (EPA,
1991b), but this value has been withdrawn and the RfC for hexavalent and trivalent chromium are
currently under review.  It has been argued by Finley, et al. (1992) that separate RfCs should be
established for the different valence states as well as for the different forms  (particulates versus
acidic mists) of chromium since they present different toxicological profiles.   They  proposed
alternative RfCs of 1.2 and 0.12 ug/m3 for hexavalent chromium particulates  and  acidic mists,
respectively.

      Reference Dose. EPA's RfD for soluble salts of hexavalent chromium, such as potassium
and sodium dichromates and potassium and sodium chromates, is 0.005 mg/kg»day. This value
was derived from a  chronic (1-year) drinking  water study in rats in which no adverse health
effects were observed hi the test animals over the treatment period.  Similar "no-effect" levels
have been observed in dogs and humans (EPA,  1997e).  An uncertainty factor (margin  of safety)
of 500 was applied to the experimental "no-effect" dose in the rat study. The IRIS database notes:

             "Confidence in  the chosen study is low because of the  small number  of
       animals tested, the small number of parameters measured and the lack of toxic
       effect at the highest dose tested.  Confidence in the data base is low  because the
       supporting studies are of equally low quality, and teratogenic  and reproductive
       endpoints are not -well studied.  Low confidence in the RfD follows. "

      Dermal Toxicity Values.  Because there are few toxicity data for chemicals administered
to the skin of laboratory animals or humans,  toxicity via dermal exposure is often evaluated using
oral RfDs or slope factors (EPA, 1992). This introduces a degree  of uncertainty hi risk estimates
because chemicals introduced via the oral route may behave differently than if introduced through
the skin.  Since pharmacokinetic data are not available for most chemicals  to help interpret or
correct for potential differences hi chemical behavior/toxicity, it is often uncertain how the use of
oral toxicity factors may affect the estimate of true risk from dermal exposure.  The oral RfD for
hexavalent chromium is used to assess the  potential noncarcinogenic risk that can result from
dermal exposure.
                                           26

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2.2.3  Exposure Assessment

     Two worker and two residential exposure scenarios that include possible exposures via
inhalation, ingestion of drinking water, incidental ingestion of soil or other dirt (e.g., through
contamination of hands and subsequent hand to mouth actions), and dermal contact are evaluated
(Figures 2-3 and 2-4). Two levels of hexavalent chromium concentrations were selected for each
medium in the example risk assessments from among values reported in the scientific literature
(Table 2-5).
                                       Table 2-5
        Environmental Concentrations of Hexavalent Chromium Used in the
                             Example Risk Assessment

Concentration Level 1
Concentration Level 2
Environmental Medium
Air
Workers
0.5 ng/m3
5|ig/m3
Residents
1 ng/m3
5 ng/m3
Water
Workers/Residents
0.02 ng/L
0.2ng/L
Soil/Dirt
Workers/Residents
0.4 mg/kg
4.0 mg/kg
      Although some professional judgment was used to estimate worker exposures and "typical"
residential exposures, data used in the example risk assessment for an electroplating facility are
based generally on population information compiled by EPA (EPA, 1989).  The values used in the
calculation of risk estimates (Section 2.2.4) are summarized in Table 2-6. These values represent
only a few of the possible exposure scenarios.  Actual exposures would vary among individual
facilities.  For the dermal exposure pathway a dermal permeability factor, Kp,  is needed to
determine exposure dose.  A Kp  of 2.0 x 10"3 cm/hr, the recommended value for  sodium
chromate, is used (EPA, 1992).  This value was selected by EPA because it was reported in
several studies using both human and animal subjects. Experimentally-derived Kp values ranging
from 3.1 x 10  to 1.2 x 10 cm/hr have been reported for other chromium compounds.

      Concentrations in Workplace Air. OSHA's Integrated Management Information System
(IMIS) database contains the results of 424 personal, full-shift air samples that were collected
between 1979 and 1993 and were analyzed for hexavalent chromium (Table 2-7). These samples
were collected in industry sectors  classified in SIC  Codes 33 through 39 and represent 8-hour
TWA exposure of employees with job titles such as "plater," "plating operator," "electroplater,"
and "anodizer."  Almost two-thirds of the IMIS samples were obtained in  industry sectors within
SIC  Code 3471.  Approximately 92% of the values were less than 10 ug/m3 and almost 75% were
less  than  1.0  ug/m3   OSHA  is currently considering a new  workplace exposure limit  for
hexavalent chromium in the range  of 0.5  to 5.0 ug/m3 (Freeman  and Condit, 1995).  Workplace
concentrations of 0.5 ng/m3 and 5.0 M-g/m3 are used in the example risk assessment calculations.
                                          27

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                        Table 2-6
Summary of Exposure Factors Used in Example Risk Assessment

Air
Scenario Name
adult resident-Scenario 2
adult resident-Scenario 1
child resident-Scenario 2
child resident-Scenario 1
worker-Scenario 2
worker-Scenario 1

Water
Scenario Name
adult resident-Scenario 2
adult resident-Scenario 1
child resident-Scenario 2
child resident-Scenario 1
worker-Scenario 2
worker-Scenario 1

Soil/Dirt
Scenario Name
adult resident-Scenario 2
adult resident-Scenario 1
child resident-Scenario 2
child resident-Scenario 1
worker-Scenario 2
worker-Scenario 1




Inhalation Rate
0.83
0.63
0.42
0.36
0.83
0.63


m3/hour
m3/hour
m'/hour
m3/hour
m3/hour
m3/hour


Intake Rate
2.4
1.4
1.3
0.7
2.4
1.4


L/day
L/day
L/day
L/day
L/day
L/day


Intake Rate
100
50
400
200
100
50
mg/day
mg/day
mg/day
mg/day
mg/day
mg/day

































Exposure Frequency
350
340
350
340
250
240


days/year
days/year
days/year
days/year
days/year
days/year










Exposure Frequency
350
340
350
340
250
240


days/year
days/year
days/year
days/year
days/year
days/year










Exposure Frequency
350
275
350
275
250
240
days/year
days /year
days/year
days/year
days/year
days /year










Exposure Time
24
16
24
16
8
8


hours/day
hours/day
hours/day
hours/day
hours/day
hours/day


Exposure Time
0.25
0.17
0.14
0.11
0.50
0.25


hours/day
hours/day
hours/day
hours/day
hours/day
hours/day


Exposure Time
23
16
23
16
8
8
hrs/day
hrs/day
hrs/day
hrs/day
hrs/day
hrs/day

































Exposure Duration
24
7
6
2
25
7


years
years
years
years
years
years










Exposure Duration
24
7
6
2
25
7


years
years
years
years
years
years










Exposure Duration
24
7
6
2
25
7
years
years
years
years
years
years




























Skin Surface Area
23,000
20,000
9,180
7,930
4,290
3,190


cm2
cm2
cm2
cm2
cm1
cm2


Skin Surface Area
5.800
6,000
2,300
1,980
4,290
3,190
cm2/hr
cm2/hr
cm2/hr
cm2/hr
cm!/hr
cm2/hr

































Averaging Time
24
7
6
2
25
7


years
years
years
years
years
years










Averaging Time
24
7
6
2
25
7


. years
years
years
years
years
years










Averaging Time
24
7
6
2
25
7
years
years
years
years
years
years







































Body Weight
70
70
15
15
70
70


kg
kg
kg
kg
kg
kg










Body Weight
70
70
15
15
70
70


kg
kg
kg
kg
kg
kg










Body Weight
70
70
15
15
70
70
kg
kg
kg
kg
kg
kg












Soil Adherence Factor

AFelRMe
AFelcr


1.0
0.2

Averaging Time
AT
" ' cauinogens al

Kp
















70

0.002

















mg/cm2
mg/cm2


years

cm/hr
















                           28

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Note that the higher concentration exceeds the recommended upper concentration limit for use
with EPA's unit risk as described in Section 2.2.2.
                                      Table 2-7
           Relative Proportion of Hexavalent Chromium Concentrations
                             Measured in the Workplace
Concentration in Air (jig/m3)
<0.1
70%
0.1 -1.0
3.5%
1.0-2.0
2.8%
2.0 - 5.0
8.5%
5.0 - 10.0
6.8%
10.0-50.0
6.4%
>50.0
2.6%
Total does not equal 100% due to rounding.

      Concentrations in Ambient Air.  Measurements of atmospheric hexavalent chromium hi a
non-industrial area of New Jersey ranged from 0.2 to 3.8 nanograms (ng)/m3, with a mean of 1.2
ng/m3 (Finley, et al., 1995). Measurements hi 20 California cities reportedly ranged from less than
0.2 to 9 ng/m3 with a majority of samples  at about 1 ng/m3 (Finley,  et al., 1996). A recent
Canadian study reported atmospheric concentrations of 0.1 to 1.6 ng/m3, with a geometric mean
of 0.55 ng/m3 (Bell and ffipfher, 1997).  The Canadian study also cites other works that indicate a
hexavalent chromium concentration hi the range of  1 to 5 ng/m3 hi urban areas.  Ambient air
concentrations of 1  and 5 ng/m3 are used in the example risk assessment calculations for the
residential exposure scenario.  These concentrations represent the estimated current background
concentration of hexavalent chromium from natural and anthropogenic (human-related) sources,
which may include  some contribution of chromium from plating facilities.   Concentrations of
hexavalent chromium may be higher than background in the vicinity of chromium plating facilities.
Any increase hi concentration that results from emissions would result hi an incremental increase
hi risk for exposed populations.  As noted above, air concentrations can  be determined by
dispersion modeling or by measurement.

      Concentrations in Drinking Water. A survey of tap water hi the United States conducted
during the 1970s found that the concentration of total chromium ranged from 0.4 to 8.0 ug/L,
with a mean of 1.8 ^g/L (ATSDR, 1993). ATSDR notes that these values may be higher than the
actual values,  due to  inadequate flushing of tap water before sample  collection.  In addition,
because the values are for total chromium, hexavalent chromium would be expected to be some
percentage of the total chromium concentration.  Hexavalent chromium concentrations of 0.02
and 0.2 ug/L, approximately 1% and 10% of the mean total chromium concentration hi the cited
study, are used hi the example risk assessment calculations for both the worker and residential
exposure scenarios.

      Concentrations in  Soils.  The natural chromium concentrations  hi soils vary greatly and
depend on the composition of the parent rock from which the soils were formed. The trivalent
form of chromium predominates hi most soils (ATSDR, 1993).  A study of soils hi the United
States by  the United States Geologic Survey (USGS,  1984) reported that the concentration of
total chromium ranged from 1 to 2,000 mg/kg, with a geometric mean of 37 mg/kg.   A Canadian
                                          29

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                                 Figure 2-3
                     Exposure Scenarios for Workers
        Air Emissions
   Ventilation
Treatment System

     •   Mist"  .
     formation'
 Fugitive
Emissions
  Plating Bath
                      Spills
Inhalation

Ingestion

  Dermal
  Contact
       Water Treatment
            System
7-Year Worker
Exposure Scenario

 8-hour work day
 40-hour work week
 4 weeks of leave per year
 7 years on the job
 Moderate breathing rate and
   water consumption at
   typical exertion level
        Air Emissions
   Ventilation
Treatment System
                      f
             Inhalation
     •  Mist   .
     formation'
 Fugitive ^   Ingestion
Emissions Jj
 Plating Bath
                      Spills
               Dermal
               Contact
       Water Treatment
           System
25-Year Worker
Exposure Scenario

 8-hour work day
 40-hour work week
 2 weeks of leave per year
 25 years on the job
 Elevated breathing rate and
   water consumption at
   above average exertion level
                                    30

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                                     Figure 2-4
                        Exposure Scenarios for Residents
    Air Emissions
   ventilation
Treatment System
9-Year Resident Exposure Scenario

 16 hours per day
 340 days/year (about 4 weeks away
  from home)
 2 years as a child plus 7 years
  as an adult for carcinogens OR
  2 years as a child for noncarcinogens
  (see text for explanation)
 Breathing rate and water consumption
  at average levels
                                                   Inhalation
                                                       Ingestion


                                                      Dermal
                                                      Contact
    Air Emissions
   Ventilation
Treatment System
30-Year Resident Exposure Scenario

 24 hours per day
 350 days/year (about 2 weeks away
  from home)
 6 years as a child plus 24 years
  as an adult for carcinogens OR
  6 years as a child for noncarcinogens
  (see text for explanation)
 Breathing rate and water consumption
  at above average levels
                                                   Inhalation
                                                       Ingestion


                                                       Dermal
                                                       Contact
                                          31

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study reported concentrations that ranged from 5 to 1,500 mg/kg, with a mean of 43 mg/kg
(ATSDR, 1993).  Hexavalent chromium concentrations of 0.4 and 4 mg/kg, approximately 1%
and  10% of the mean total chromium concentration in the two cited studies, are used in the
example risk assessment calculations for both the worker and residential exposure scenarios.

      The  estimate  of workplace exposure via dermal pathways contains a  great  deal  of
uncertainty because concentrations of hexavalent chromium in the work environment are highly
dependent upon the effectiveness of industrial hygiene practices applied in the workplace. While
concentrations of chromium on  surfaces near electroplating tanks may be high,  the use  of
personnel protective equipment such as gloves would greatly reduce exposure via dermal contact.
2.2.4 Risk Characterization

      Using the input variables for toxicity, exposure and environmental concentrations described
in the preceding sections, estimated excess cancer risks and hazard quotients have been calculated
for exposure  to hexavalent chromium in two  settings,  a workplace  exposure scenario and  a
residential exposure scenario.  For each of the two exposure settings the exposure factors (e.g.,
inhalation  rates,  exposure  time, exposure  duration)  and  environmental  concentrations  of
hexavalent chromium were varied to yield a total of four estimates of cancer risk and assessments
of the potential for adverse health effects due to noncarcinogenic effects.  Estimates of excess
cancer risks to residents were calculated using the assumption that exposure occurred over  a
period of time that includes both adult and  childhood exposure.  Hazard quotients for residents
were calculated using exposure factors for children only. Hazard quotients for children are higher
than for adults (at exposure to equivalent environmental  concentrations) because children have
lower body weights and higher intakes via certain pathways (e.g., ingestion of soil) than adults.
Calculations  were  performed by entering  example exposure  data  (Section 2.1.3), example
environmental concentrations (Section 2.1.4), and risk equations (Section 2.1.4) onto a computer-
based spreadsheet in Microsoft® Excel.

      Residential Exposure Scenario.  The four estimates of total lifetime  excess cancer risk
(Table 2-8 and Figure 2-5) for residential exposures are calculated for hypothetical 9-  and 30-
year exposures (Table 2-5) at the lower and upper environmental concentrations (Table 2-6).  The
9-year exposure assumes that the  exposed individual is present for 2 years as a child and 7 years
as an adult.  The 30-year exposure assumes that the exposed individual  is present for 6 years as a
child and 24 years as an adult. The scenarios yield estimates of total lifetime excess cancer risks
that  range from 8.3 x 10~7 to 2.7 x 10~5   All  of this risk is derived from the inhalation pathway
because hexavalent  chromium is not believed to be carcinogenic by ingestion or dermal uptake.
Because the risk calculation for the inhalation pathway uses a hexavalent chromium concentration
in air that has been reported for several urban areas, these values  reflect a minimum (background)
estimate of risk for the inhalation route of exposure that can be calculated using this methodology
and the exposure factors presented herein.

      The hazard quotients for the residential exposures are all well below unity,  indicating that
concentrations  of hexavalent chromium for these  exposure scenarios would not  present  a
noncancer health hazard.
                                           32

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                                       Table 2-8
           Predicted Lifetime Excess Cancer Risks and Hazard Quotients
                        for Exposure to Hexavalent Chromium
Excess Cancer Risks

Concentration Level 1
Concentration Level 2
Worker Exposure Scenario
7-Year Exposure
2.0 x W4
*
25-Year Exposure
4.3 x 1(T3
*
Resident Exposure Scenario
9-Year Exposure
8.3 x 1CT7
4.1x10^
30-Year Exposure
5.3 x 1CT6
2.7 x 1CT5
* Concentration of hexavalent chromium exceeds valid range for calculating risk using EPA's unit risk value.

Hazard Quotients for Noncarcinogens

Concentration Level 1
Concentration Level 2
Worker Exposure Scenario
7-Year Exposure
<.001
.001
25-Year Exposure
<.001
.004
Resident Child Exposure Scenario
2-Year Exposure
.001
.012
6-Year Exposure
.003
.029
      There is  uncertainty associated  with the environmental concentrations  of hexavalent
chromium in water and soil. While several estimates of hexavalent chromium concentrations in air
were available in the scientific literature, the values for water and soil are based on percentages of
measured values for total chromium.  As actual concentrations may be higher or lower, it is
uncertain how the use of these estimates may affect the estimate of risk from oral and dermal
exposures. Direct measurement of facility-specific concentrations would reduce the uncertainty
associated with exposure point concentrations.

      Worker Exposure Scenario.  Two estimates of total  lifetime excess cancer risk for
workplace  exposures  are calculated for hypothetical  7-  and  25-year worker exposures  at the
lower environmental concentration. No excess cancer risk is included for the highest workplace
air concentration because it exceeds 0.8 fig/nf, the maximum concentration for which EPA
considers its unit risk to be valid. The scenarios yield estimates of lifetime excess cancer risks that
range from 2.0 x 10"4 to 4.3 x 10"3. As is the case for the residential exposure,  all of this risk is
derived from the inhalation pathway.

      Although the workplace  estimates  of risk are  higher than that  usually associated  with
environmental exposures (EPA generally regulates carcinogens in the range of one in ten thousand
[1 x 10"*] to  one in a million [1 x 10"6] chances of excess cancer risk), the estimated risks are
similar to the one in a thousand (1 x 10~J) risk level that OSHA considers a "significant" risk when
                                           33

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making risk management decisions to  regulate workplace  carcinogens.  However,  OSHA's
estimates of risk are not directly comparable to these estimates because OSHA assumes an 8-hour
day and a 240-day work-year over a 45-year working lifetime and because OSHA develops its
own cancer potency factors, which may differ from EPA's (Rhomberg, 1996). Actual workplace
concentrations and exposure factors would vary among facilities and would depend upon many
factors including the operation and maintenance of ventilation systems, administrative controls to
limit worker exposures, and the use of personnel protective equipment.  Direct measurement of
chromium concentrations within workers'  breathing  zones would reduce uncertainty associated
with worker exposures.
                                       Figure  2-5
               Lifetime Excess Cancer Risk for Community Residents
                            for Example Risk Assessment
            3.0E-05
       
       cr
       o
       c
       CO
       O
       in
       in
       x
       HI
                     9-Yr Exposure
                    Low Cone. Levels
 9-Yr. Exposure
Upper Cone. Levels
30-Yr. Exposure
Low Cone. Levels
 30-Yr. Exposure
Upper Cone. Level.
                                    Residential Exposure Scenario
2.3 RISK COMMUNICATION

      Risk assessments should be prepared with potential risk managers and stakeholders in mind,
to assure  that appropriate information will be  provided in a format that is understandable and
useable to all interested parties.  An appropriate level of detail for data presentation and reports
should be  identified early in the process because potential risk managers are a diverse group that
may have varying degrees of technical expertise. Presenting risk assessment results in a clear and
concise format increases the likelihood that risk managers will remain engaged in the process and
will contribute input on political, social, and economic issues that are part of the risk management
process.
                                           34

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     This  paper presents example exposure  scenarios  and identifies  the data inputs (i.e.,
environmental concentrations, measures of exposure, and toxicity information) that are needed to
assess  the  potential health risks to workers and residential populations that are exposed to
chemical emissions from  metal  finishing  facilities.  Such risk-based information is  desired by
stakeholders within EPA's CSI Metal Finishing Sector but has not been made widely available to
them.  While some emissions  data for metal finishing facilities are available, translation of that
information into statements about potential health effects of those  emissions  has been limited.
Risk-based information is needed to assist risk managers and stakeholders in identifying important
risks, so that they may prioritize those risks and allocate resources to address them.  Success of
the risk assessment approach in meeting the need of risk managers to understand the health risks
associated  with facility emissions  requires  that risk managers be  informed about  the  risk
assessment process. The  elucidation of the methods of risk assessment as described herein is an
important starting point for the necessary dialog between risk managers and stakeholders involved
with the Metal Finishing Sector, and the risk assessor.
                                            35

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                                   3.  SUMMARY

     Facility-based risk characterization  for workers  and surrounding communities is  a high
priority issue for stakeholders in EPA's  CSI Metal Finishing  Sector.  Platers, environmental
groups, community groups, labor, and regulators all need and want to know what emissions are
coming out and in what amounts from metal finishing operations (EPA, 1997a).  They also want
to know what health risks those emissions create for workers and the surrounding communities.
Potential health  risks from emissions can be described and  quantified by the  process  of risk
assessment.  Risk assessment evaluates information on the hazardous properties of chemicals and
the extent of human  exposure, and characterizes the resulting risks.  EPA  and others use a risk
assessment process formalized by the National Academy of Sciences that  is comprised of four
steps—hazard  identification,   dose-response  assessment,  exposure  assessment,   and  risk
characterization (NRC, 1983; 1994).

     The Research  and  Technology Work Group of the CSI Metal  Finishing Subcommittee
identified the development and application of simple methods to characterize the emissions from
plating operations as a high priority item in its R&D Plan (EPA, 1997a). Specifically, the R&D
Plan recommended characterizing the emissions from plating operations and from them the risks
to workers, surrounding communities, and the environment.  The objectives of this project were
to address the recommendation  of the R&D  Plan by 1) identifying the types  and sources  of
information needed to assess risks to  workers and surrounding communities from metal finishing
facilities (hazard identification and dose-response  assessment),  2) developing a general  facility
model  that describes potential human exposure pathways (exposure assessment), 3) presenting
equations  that characterize the exposure  pathways from emission sources to workers and the
public, and 4) quantifying the lifetime excess cancer risk and potential  for other health hazards
from hexavalent chromium in a screening risk assessment process (risk characterization).

     By explaining the steps performed and the data needed to conduct a risk  assessment it is
hoped  that this paper will  assist those associated with the industry to better understand the risk
assessment process and the questions that can be answered by the process.  Based on the work
reported here, it is concluded that the general methodology for carrying out risk  assessments for
metal finishing workers and surrounding communities is known; that it is  possible to calculate
such risks for a number of worker  and  community scenarios, and that the  methodology has
limitations associated with toxicity information for chemicals used in the metal finishing sector and
with exposure inputs, such as environmental concentrations of chemicals and activity patterns of
potentially exposed individuals.

     Important  needs for  additional  development of this  approach to facility-based risk
characterization for hard chromium plating and other operations are:

       •  communication between risk managers, stakeholders, and risk  assessors to identify
          issues of greatest importance to end users of the risk assessment information;

       •  determination of environmental concentrations of chemical emissions of interest (either
          modeled or measured) for use in risk assessments; and

       •  refinement of exposure information for potentially exposed populations.
                                           36

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                                4. REFERENCES

     Anderson, R.A., T.  Colton, J. Doull, J.G. Marks, and R.G. Smith,  1993.  Designing a
biological monitoring program to assess community exposure to chromium: conclusions of an
expert panel.  Journal of Toxicology and Environmental Health 40:555-583.

     ATSDR, 1993.  Toxicological Profile for Chromium.  Prepared by Syracuse Research
Corporation under subcontract to Clement International Corporation for the Agency for Toxic
Substances  and Disease Registry, Public Health Service, United States Department of Health and
Human Services.

     Bell,  R.W.,  and J.C.  Hipfher,  1997.  Airborne  hexavalent chromium  in  southwestern
Ontario.  J.  Air & Waste Management 47:905-910.

     Browner, Carol M,  1994.  Speech delivered by Carol M. Browner, Administrator, United
States  Environmental Protection Agency,  at  the  Center for National  Policy Newsmaker
Luncheon, Washington, D.C. July 20.

     CAMP, 1995.  Profile for the Metal Finishing Industry-Draft. Prepared for the Cleveland
Advanced Manufacturing  Program (CAMP) under  contract  to the Energy Environment  and
Manufacturing project of the Technology Reinvestment Program (EEM-TRP). Waste Reduction
Institute for Training and Applications Research (WRITAR).

     DTSC  (California  Department  of Toxic Substances  Control),  1994a.   Preliminary
Endangerment Assessment Guidance, January.

     DTSC,  1994b.   California Cancer Potency  Factors,  California  Department  of Toxic
Substances  Control, Standards and Criteria Work Group. 1 November.

     EPA,  1984.  Health Assessment Document for Chromium. Final Report. EPA-600/8-83-
014F. Environmental Criteria and Assessment Office, Research Triangle Park, North Carolina.
NTISPB85-115905.

     EPA,  1986.   Guidelines for Carcinogen Risk Assessment.  51 Federal  Register  33992-
34003.

     EPA,  1989.   Exposure Factors Handbook.   United  States Environmental  Protection
Agency,  Office of Research and Development.  EPA/600/8-89/043. May (a preliminary draft
revision of this document was released for comment in August 1996).

     EPA,  199la.  National Primary Drinking Water Regulations, Final Rule.  Code of Federal
Regulations 40: Parts  141,142, and 143, January 30.

     EPA,  1991b.   Health Effects Assessment Summary Tables, FY-1991. Publ. No. OERR
9200, 6-303 (91-1) United States Environmental Protection Agency, Office of Emergency  and
Remedial Response, Washington, D.C.
                                         37

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     EPA, 1992.  Dermal Exposure Assessment: Principles and Applications, Interim Report.
United  States Environmental  Protection Agency,  Office  of Research  and  Development.
EPA/600/8-91/01 IB.

     EPA, 1993. Introduction to IRIS.  August 18.

     EPA, 1994.   A New  Generation of Environmental Protection.   CSI: Administrator's
Update, Number 12. July 29.

     EPA, 1995a.  Draft Report on Emissions from Metal Finishing Operations.  United States
Environmental Protection Agency, Office of Research and Development. March 31.

     EPA, 1995b.  Health Effects Assessment Summary Tables. United States Environmental
Protection Agency,  Office of Emergency and Remedial Response, Washington, D.C. May.

     EPA, 1995c.  Profile of the Fabricated Metal Products Industry.   Office of Compliance
Sector Notebook Project, United States Environmental Protection Agency, Office of Enforcement
and Compliance Assurance. September.

     EPA, 1995d.  Pollution Prevention Assessment for a Manufacturer of Electroplated Truck
Bumpers. United States Environmental Protection Agency, National Risk Management Research
Laboratory.  September.

     EPA, 1996a.  Proposed Guidelines for Carcinogen Risk Assessment, 61 Federal Register
17960, April 23.

     EPA, 1996b.  Proposed Guidelines for Ecological Risk Assessment, 61 Federal Register
47552, September 9.

     EPA,  1997a.   National  Metal Finishing Environmental R&D  Plan.  Common  Sense
Initiative Metal Finishing Subcommittee. January 7.

     EPA, 1997b.  Discussion Draft, Strategic Goals Program, Part  1: National Performance
Goals, Part 2: Action Plan. Common Sense Initiative, Metal Finishing Sector. July 15.

     EPA,  1997c.   1995 Toxics Release  Inventory  Public  Data  Release.  United  States
Environmental Protection Agency, Office of Prevention, Pesticides and Toxic Substances.  EPA
745-R-97-005. April.

     EPA, 1997d.  Common Sense Initiative. Metal Finishing Sector  Fact Sheet. United States
Environmental Protection Agency. EPA 742-B-96-007. March.

     EPA, 1997e.  Integrated Risk Information System.  National Center for Environmental
Assessment.  Downloaded from National Library of Medicine on-line service. July.
                                         38

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      Finley, B.L., D.M. Proctor, and D.J. Paustenbach, 1992.  An alternative to EPA's proposed
inhalation reference concentrations for hexavalent and trivalent chromium. Regulatory Toxicology
and Pharmacology 16:161-176.

      Finley, B.L., B.D. Kerger, D.G. Dodge, S.M. Meyers, R.O. Richter, and D.J. Paustenbach,
1996.  Assessment of airborne hexavalent chromium in the home following use of contaminated
tapwater. J. Exposure Analysis and Environ. Epidemiol. 6:229-245.

      Freeman, C., and K. Condit, 1995.  The new OSHA regulations for hexavalent chromium.
16th AESF/EPA Pollution Prevention & Control Conference Proceedings. 13-15 February.

      IARC (International Agency for Research on Cancer, 1990.   Chromium and Chromium
Compounds.  IARC Monograph Series, World Health Organization, Volume 49.

      Klaasen, C.D.,  1995.  Casarett and Doull's  Toxicology,  The Basic Science of Poisons,
McGraw-Hill, Health Publications Division, New York.

      Murphy, M., (ed.), 1996.  Metal Finishing: 64th Guidebook and Directory Issue, Vol. 94,
No. 1 A.  Elsevier, New York.

      NCMS (National Center  for Manufacturing  Sciences),  1994.   Pollution Prevention and
Control Technology for Plating Operations. Prepared for the National Center for Manufacturing
Sciences and the National Association of Metal Finishers, George Cushnie.

      NRC (National Research Council),  1983.  Risk Assessment in the Federal Government:
Managing the Process.  National Academy Press, Washington, D.C.

      NRC, 1994.   Science and Judgment  in Risk Assessment.  National Academy Press,
Washington, D.C.

      OSHA  (Occupational  Safety and  Health  Administration),  1995.   Evaluation  of
Epidemiological Data and Risk Assessment for Hexavalent  Chromium.  Prepared for OSHA by
K.S. Crump  Division,  ICF Kaiser. OSHA Hexavalent  Chromium Docket, Docket H-054A,
Exhibit #13-5.

     Presidential/Congressional Commission on Risk Assessment and Risk Management, 1997a.
Final Report, Volume 1, Framework for Environmental Health Risk Management.

     Presidential/Congressional Commission on Risk Assessment and Risk Management, 1997b.
Final Report, Volume 2, Risk Assessment and Risk Management in Regulatory Decision-Making.

     Puri,  I.K.,  1993.   The Metal Products and Machinery Industry - Issues for Pollution
Reduction.  Produced in cooperation with Paul Shapiro, United States Environmental Protection
Agency,  Office of Environmental  Engineering and  Technology  Demonstration  through  an
American Association for the Advancement of Science Summer  Environmental Science and
Engineering Fellowship. August 9.
                                          39

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      Rhomberg, L.R., 1996.  A survey of methods for chemical health risk assessment among
federal regulatory  agencies, prepared  at  the  request  of  the  Presidential/Congressional
 Commission on Risk Assessment and Risk Management.

      Schaum,  J.,  1997.  Personal communication  with John  Schaum, National Center for
 Environmental Assessment, United States Environmental Protection Agency.

      Thistle Publishing, 1996. Risk Assistant™, version 1.1, Alexandria, VA.

      USGS (United States Geological Survey), 1984.  Element Concentrations in Soils and
 Other Surficial Materials of the Conterminous United States.  USGS Professional Paper 1270.
                                          40

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                                            ACRONYMS
AAAS = American Association for the Advancement of
    Science
ABS = dermal absorption factor
AF = soil adherence factor
ADD = average daily dose
AESF = The American Electroplaters and Surface
    Finisher's Society, Inc.
AMSA = Association of Municipal Sewerage Agencies
AT = averaging time
ATSDR = Agency for Toxic Substances and Disease
    Registry
BW = body weight
Ca = concentration in air
Cs = concentration in soil
Cw = concentration in water
CAMP = Cleveland Advanced Manufacturing Program
care = carcinogen
cm = centimeter
CSI = Common Sense Initiative
DTSC = Department of Toxic Substances Control
    (California)
ED = exposure duration
EF = exposure frequency
EPA = Environmental Protection Agency (US)
ET = exposure time
EV = event frequency
HQ = Hazard quotient
hr = hour
LARC = International Agency for Research on Cancer
EVQS = Integrated Management Information System
IR = intake rate
InhR = inhalation rate
IRIS = Integrated Risk Information System
kg = kilogram
Kp = dermal permeability constant
L = liter
LOAEL = lowest-observed-adverse-effect-level
m = meter
m3 = cubic meters
mg = milligram
|o.g = microgram
NOAEL = no-observed-adverse-effect-level
NCEA = National Center for Environmental Assessment
NCMS = National Center for Manufacturing Sciences
ng = nanogram
NRC = National Research Council
NRDC = Natural Resources Defense Council
ORD = Office of Research and Development
OSHA = Occupational Safety and Health
    Administration
R&D = Research and Development
RfC = Reference concentration
RfD = Reference
SF = Cancer slope factor
SIC = Standard Industry Classification
SSA = skin surface area
TWA = time-weighted average
Tw = duration of event
UAW = United Auto Workers
USGS = United States Geological Survey
                                                41

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      APPENDIX A
Output from Risk Assistant™

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RISK*ASSISTANT for Windows Report
R*A Standard Report                                                                         09/28/97
                                                                                               13:18
Approach

The procedures used by  RISK*ASSISTANT  to  calculate  exposures  have been reviewed by the
Office of Health and Environmental  Assessment  of  the U.S.  EPA.Default parameters  for calculating
exposures have been extracted  from  these  U.S.EPA  documents:

     U.S.EPA, Office of Solid  Waste and Emergency Response,Risk Assessment Guidance for
     Superfund,Volume I:  Human Health  Evaluation  Manual,Supplemental Guidance: Standard Default
     Exposure Factors.  Directive 9285.6-03;  Interim Final. March 25, 1991.

     J.Konz, K.Lisi, and E. Friebele,  Exposure Factors  HandbookU.S.EPA, Office of Health and
     EnvironmentalAssessment,  EPA/600/8-89/043; March 1989.

 Aggregation Method Used, in Analysis

 The following table lists the technique  used  to  combine data from multiple samples (i.e. the
 Aggregation Method) for each  environmental  medium  included in the analysis.  For  each class of data
 qualifier that might apply to the  sample set  (non-detects, estimated values, controls not within
 limits, or concentration estimated at a  dilution factor), the approach used  to assign a
 concentration to the qualified data values  is presented.
 Contaminated             Aggregation                                  Treatment  of Qualified Samples
 Medium                   Method                    NonDetect   Estimated   Ctls not within limitsDilution Factor
                                                    (U)          (J)          (R,B,E,M,N,W,*)        (D)

 Four options are available for dealing with qualified  sample data  (i.e. concentration values
 for which a proxy value has been entered, accompanied  by  one of the four classes of data
 qualifiers recognized  by RISK*ASSISTANT.A separate decision  can be made for  each class of qualified
 data. The user may either use all  proxy  values as  entered, use one-half of the entered proxy value,
 exclude (drop) the qualified  data,  or set the concentration  for the qualified data to zero.

 Chemical Concentrations in Contaminated  Media

 The concentration values presented in this  table are expressed using the S.I. (Systeme
 Internationale, also called metric) units most commonly employed in risk assessment.  They may differ
 from the units used in data entry.
 CAS#      Chemical Name
 540-29-9     CHROMIUM  (VI)
       GW        SW         Air     Soil      Sed       Veget     Fruit      Fish      Dairy     Meat
        ug/1      ug/1       ug/cu  m  mg/kg     mg/kg   ug/kg      ug/kg     ug/kg     ug/kg     ug/kg
        0.2                0.001       0.4

NOTE:  scientific notation is  used  for numbers less that 0.000001 and greater than 1000000.
       For example:0.00000021  = 2.1e-7 =  2.1 / 10000000 and 21000000 = 2.1e7  = 2.1 * 10000000.
       GW = Groundwater,  SW =  Surface  Water, Sed  =  Sediment,  Veget = Vegetable.

 The listed concentration in each medium  for a chemical reflects the selection of sample values
 employed in aggregation, the  aggregation method  selected,, and the approach used  for dealing with
 qualified data. Where  concentration data were entered  directly, the assessor should be prepared to
 explain the values that were  chosen.

 Exposure Scenarios

 In RISK*ASSISTANT,every exposure scenario is  associated with a single contaminated medium. While
 some scenarios potentially apply to more than one  medium, any individual assessment must assign a
 scenario to only one contaminated  medium.
 Groundwater
 Drinking Water
 Air
 Indoor Air
 Outdoor Air
 Soil
 Dust/Soil Indoors
 Dust/Soil Outdoors

 The dose and concentration estimates  in  this  assessment,  as  well as any risk estimates that are
 derived from them, refer only to the  specific exposures that have been described. This description
 consists of:

     Contaminant concentrations in  one or more environmental  media.
     For each contaminated medium,  one or more scenarios describing how a person  contacts that
     medium.
     Parameters that describe  each  scenario, both in general,  and for each potential route of
     exposure  (oral, inhalation, or dermal).

 An assessment that incorporates other exposures, or that  does not incorporate all of the exposures


                                                       A-l

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 described in this analysis, will yield different results. This list presents the exposure scenarios
 evaluated for each contaminated medium considered in this assessment.

 Cross-Media Transfer Equations Used to Generate Exposure Estimates

 For some exposure scenarios a contaminant concentration specified in one environmental
 medium must be converted to a concentration in another medium, to which a person is
 exposed.  (For example, in order to evaluate inhalation exposures while showering,
 contaminant concentrations in domestic water must be converted to concentrations in
 bathroom air.)   The following equations were used in this assessment to predict such
 cross-media contaminant transfers in each of the indicated exposure scenarios.
 INHALATION OF PARTICULATES INSIDE THE RESIDENCE   Soil to respirable Particulates

     REFERENCES:
     (1) Wark, K. & Warner, C.F.Air Pollution: Its Origin and Control,Second Ed., New York:
     Harper & Row, 1981.
     (2) Hawley, J.K. 'Assessment of Health Risk from Exposure to Contaminated Soil.' Risk Analysis,
     5,(1985)289.
     EQUATION: C(i)=D*R*f*C(s)

PARAMETERS                                                           User Value
           C(i)  Inhaled Concentration of Contaminant                 Calculated
           C(s)  Concentration in Soil                                Chemical Specific
     R   = Respirable Fraction of Dust                                73.00%
     f   = Proportion of Contaminated Dust                             0.80%
     D   = Dust Concentration                                         56.00 ug per cu.m

 INHALATION OF PARTICULATES OUTSIDE THE RESIDENCE   Soil or Sediment to respirable
 Particulates

     REFERENCES: Wark, K. & Warner, C.F.Air Pollution: Its Origin and Control,Second Ed.,
     New York: Harper & Row, 1981.
     EQUATION: C(i)=D*R*f*C(s)

PARAMETERS                                                           User Value
           C(i)  Inhaled Concentration of Contaminant                 Calculated
           C(s)  Concentration in Soil                                Chemical Specific
     R   = Respirable Fraction of Dust                                73.00%
     f   = Proportion of Contaminated Dust                             1.00%
     D   = Dust Concentration                                         75.00 ug per cu.m


 Concentrations in Media after Transfers

 For some exposure scenarios a contaminant concentration specified in one environmental medium must
 be converted to a concentration in another medium, to which a person is exposed. For example, in
 order to evaluate inhalation exposures while showering, contaminant concentrations in domestic water
 must be converted to concentrations in bathroom air. The values presented in this table are
 concentrations of contaminants in exposure media that have been predicted for specific exposure
 scenarios from concentrations that were specified in other media.
 Chemical Name
 Contaminated Media / Scenario                              Calculated Concentrations
                GW       SW       Air      Soil     Sed     Veget    Fruit     Fish    Dairy    Meat    Derm.Ab.
                ug/1     ug/1     ug/cu m  mg/kg    mg/kg   ug/kg    ug/kg     ug/kg   ug/kg    ug/kg   mg/sq  cm
540-29-9  CHROMIUM (VI)
 Soil
 Dust/Soil Indoors             1.3e-008
 Dust/Soil Outdoors            2.2e-008


NOTE:  scientific notation is used for numbers less that 0.000001 and greater than 1000000.
       For example:0.00000021   2.1e-7 = 2.1 / 10000000 and 21000000 = 2.1e7 = 2.1 * 10000000.
       GW = Groundwater, SW = Surface Water, Sed = Sediment, Veget = Vegetable.
       Derm.Ab.  = Dermal Absorption Rate,  (1) Indicates Outside Model Bounds,  (2) Indicates Missing Data


 Exposure Parameters Used to Generate Exposure Estimates

 The dose (or exposure concentration) values presented in this assessment reflect not only
 the concentrations of contaminants in various environmental media and the exposure pathways
 selected for analysis,  but also the specific numerical parameters applied to each exposure
 scenario.  The following tables summarize the exposure parameters used in this assessment-
 Population:  Avg American(RME)
 General Population Parameters
 Body Weight:             70.00    kg
 Lifetime:                70.00    years
 Exposure Period:           30    years



                                                       A-2

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 Scenario Specific Parameters
 Scenario
 Drinking Water
 Indoor Air
 Outdoor Air
 Dust/Soil Indoors
 Dust/Soil Outdoors

 Scenario
   Event Frequency
        350   events per year
        350   events per year
        350   events per year
        350   events per year
                                       General Parameters
                                                  Event Duration
        350
              events per year
                      21   hours per event
                       3   hours per event
                      21   hours per event
                       3   hours per event
 Drinking Water
 Indoor Air
 Outdoor Air
 Dust/Soil Indoors
 Dust/Soil Outdoors
                  ORAL
       Amount
       Ingested
          2  litersper event
        100
        100
mg per event
mg per event
                  Fraction
                  Contamin.
                    100  %
100
100
   INHALATION
   Breathing
   Rate

0.71  cu.m per hour
1. 67  cu.m per hour
0.71  cu.m per hour
1.67  cu.m per hour
                                                                                         DERMAL
                                                                                         Exposed
                                                                                         Skin Area
 Average Daily Dose or Exposure Concentration
 When an exposure assessment will be used as part of a quantitative risk assessment, a numerical
 estimate of exposure must be calculated. The value employed for this estimate varies, according to
 the route of exposure.

 When evaluating the risk of chronic non-cancer health effects from oral or dermal exposures,  EPA
 employs the Average Daily Dose  (ADD) received during the period of exposure. These are compared to
 Reference Doses (RfDs). When evaluating such effects from inhalation exposure, EPA employs
 contaminant concentrations, which are compared to Reference Concentrations  (RfCs) for continuous
 exposure.
   ADD
   Inh.Conc
                 =Average Daily Dose  (during exposure period) .
                  Units are milligrams of contaminant per kilogram of body weight per day.
                 Concentration of contaminant in inhaled air.
                  Units are milligrams of contaminant per cubic meter of air.
 Chemical                     Oral
     Medium                   ADD
          Scenario            mg/kg/d
18540-29-9  CHROMIUM (VI)
     Groundwater
          Drinking Water      0.000005
    TOTALS                    0.000005
     Air
          Indoor Air
          Outdoor Air
    TOTALS
     Soil
          Dust/Soil Indoors   5.5e-007
          Dust/Soil Outdoors  5.5e-007
    TOTALS                    0.000001
                                 Inhalation
                                 Concentration
                                 mg/cu m
                                 0.000001
                                 0.000001
                                 0.000002

                                 1.3e-008
                                 2.2e-008
                                 3.5e-008
                                             Dermal
                                             ADD
                                             mg/kg/d
NOTE:  scientific notation is used for numbers less that 0.000001 and greater than 1000000.
       For example:0.00000021 = 2.1e-7 = 2.1 / 10000000 and 21000000 = 2.1e7 = 2.1 * 10000000.
       ADD/LADD  values are meaningful up to the second significant digit.

 Lifetime Average Daily Dose or Adjusted Exposure Concentration

 When evaluating carcinogenic risks from exposures that last less than a lifetime, the ADD or
 exposure concentration is adjusted to a dose or concentration that would yield an equivalent
 exposure if exposure continued for the entire lifetime.

 For oral or dermal exposures, this yields the Lifetime Average Daily Dose  (LADD):

     LADD = ADD * (exposure period in years / lifetime in years)

 For inhalation exposures, this yields the Adjusted Concentration:

     Adjusted Concentration = Concentration * (exposure period / lifetime)

 Typically (and in RISK*ASSISTANT), the adjusted concentration will also incorporate
 adjustments for differences between the actual exposure pattern and the assumed pattern of
 continuous lifetime exposure. For example, if exposure only occurred for one hour each day, the
 Adjusted Concentration would be only l/24th of the concentration during that hour.
   LADD
=Lifetime Average Daily Dose.
 Units are milligrams of contaminant per kilogram of body weight per day.
   Adj.Inh.Conc  =Adjusted Inhaled Concentration: Continuous concentration equivalent to
                                                       A-3

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                  exposure concentration; considering frequency and duration of exposure and inhalation rate.
                  Units are micrograms of contaminant per cubic meter.
 Chemical                     Oral
     Medium                   LADD
          Scenario            mg/kg/d
18540-29-9  CHROMIUM (VI)
     Groundwater
          Drinking Water      0.000002
    TOTALS                    0.000002
     Air
          Indoor Air
          Outdoor Air
    TOTALS
     Soil
          Dust/Soil Indoors   2.3e-007
          Dust/Soil Outdoors  2.3e-007
    TOTALS                    4.7e-007
                            Inhalation
                            Adj.Concentration
                            ug/cu m
                            0.000306
                            0.000103
                            0.000409

                            0.000004
                            0.000002
                            0.000006
                                 Dermal
                                 LADD
                                 mg/kg/d
NOTE:  scientific notation is used for numbers less that 0.000001 and greater than 1000000.
       For example:0.00000021 = 2.1e-7 = 2.1 / 10000000 and 21000000 = 2.1e7 = 2.1 * 10000000.
       ADD/LADD  values are meaningful up to the second significant digit.

 Carcinogenic Risk

 For chemicals that may cause cancer if ingested, risk is calculated as a function of oral Slope
 Factor and Dose:
                  -(Oral Slope Factor * Lifetime Average Daily Dose)
     Risk = 1
 If the risk results from breathing the chemical,
 than dose, as follows:
                            the calculation is based on concentration, rather
                  -(Unit Risk * Concentration)
     Risk = 1
 For dermal exposures, the dose absorbed through the skin is used in combination with the oral slope
 factor, using the same equation that is used for calculating risks from oral exposures.
 This may lead to underestimation of dermal risk.

 These estimates represent theoretical excess cancer risk (i.e. risk over background cancer
 incidence) of developing cancer. For example, if the calculated risk is 1 in 1,000,000  (1 e-006),
 this would literally suggest that a person would have a one-in-a-million chance of getting cancer
 because of the specified chemical exposure, in addition to her/his chance of getting cancer from
 other causes.

   Oral Slope         = Slope of the  (carcinogenic) dose-response function,
                        in the low—dose, linear range.
                        Used for oral and dermal exposures.
                        Units are I/(milligram of chemical per kilogram of body weight per day).
   Unit Risk          = Slope of the  (carcinogenic) concentration-response function,
                        in the low-concentration, linear range.
                        Used for inhalation exposures.
                        Units are I/(micrograms of chemical per cubic meter of air).

 Slope Factors and Unit Risks are generally estimated as the 95th percentile confidence  limits using
 the linearized multistage model, when based on animal data  (estimates derived from studies in humans
 often employ mathematical best estimates). As such, they are conservative estimates of  toxic hazard.
 Risks estimated by combining these hazard values with exposure estimates are commonly referred  to  as
 upper-bound risks,  but because exposure estimates may not represent upper-bound estimates, risk
 estimates are not true upper-bound risks.
 Weight of Evidence
     A
     Bl
     B2
     C
     D
     E
 Chemical
     Medium
       Scenario
18540-29-9  CHROMIUM (VI)
 Weight of Evidence: A
     Groundwater
       Drinking Water
          MEDIUM TOTALS
=  EPA class designating overall strength of evidence that
  a substance causes cancer in humans.
= Known human carcinogen.
= Probable human carcinogen, limited human data.
= Probable human carcinogen, inadequate or no human data.
= Possible human carcinogen.
= Not classifiable as human carcinogen.
= Evidence that not carcinogenic in humans.
                  Risk  (Odds): Individual Probability of Getting Cancer
                            from this Exposure Alone
                               Inhalation                     Dermal
         Oral

      No Slope

    Missing Slope
Unit Riskd/(ug/m3) ) :0.012   Source: IRIS & HEAST ( 04/14/ 97&04/14/ 97 )
                                                       A-4

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     Mr
       Indoor Air
       Outdoor Air
          MEDIUM TOTALS
     Soil
       Dust/Soil Indoors  Missing Slope
       Dust/Soil Outdoors Missing Slope
          MEDIUM TOTALS
       ALL MEDIA TOTALS
                                    4 in 1,000,000 (4e-006)
                                    1 in 1,000,000 (le-006)
                                    5 in 1,000,000 (Se-006)

                                    < 1 in 1,000,000 (5e-008)
                                    < 1 in 1,000,000 (3e-008)
                                    < 1 in 1,000,000 (8e-008)
                                    5 in 1,000,000 (5e-006)
NOTE:  scientific notation is used  for completeness.
       For examplerO.00000021 = 2.1e-7 = 2.1  / 10,000,000  (odds of 2 in 10,000,000) and 21,000,000 = 2.1e7 = 2.1
* 10,000,000.

 It is generally assumed that carcinogenic risk is zero only when exposure is zero, and that at low
 doses, the relationship between dose and response can be  approximated by a straight line.

 These estimates represent the theoretical excess cancer risk  (i.e. risk over background
 cancer incidence) of developing cancer. For  example, if the calculated risk is 0.000001  (1 e-006),
 this would literally suggest that  a person would have a one-in-a-million chance of getting cancer
 because of the specified chemical  exposure,  in addition to her/his chance of getting cancer from
 other causes. However, in view of  the large  uncertainties associated with such risk estimates, they
 should always be interpreted as general indicators, rather than precise estimates. EPA generally
 considers risks below 1 in a 1,000,000  (le-6) to be low.

 Hazard Quotient

 For agents that cause non-cancer toxic effects, a Hazard  Quotient (H.Q.) is calculated, which
 compares the expected exposure to  the agent  to an exposure that is assumed not to be associated with
 toxic effects.

 For oral or dermal exposures, the  Average Daily Dose (ADD) is compared to a Reference Dose (RfD):

     H.Q. = Average Daily Dose / Reference Dose

 For inhalation exposures, the inhaled concentration is compared to a Reference Concentration  (RfC):

     H.Q. = Inhaled Concentration / Reference Concentration

 An effort is made to ensure that Reference Doses and Reference Concentrations provide a conservative
 estimate of non-cancer toxic hazards. The uncertainty factors applied to toxicity data are intended
 to take into account differences in sensitivity to toxic  effects within and between species,  and
 differences in toxic effects between chronic and subchronic exposures.

 Definitions  of abbreviations employed in this table:
   RfC
   RfD
 Chemical
     Medium
       Scenario
18540-29-9  CHROMIUM
=Reference Concentration  (inhaled concentration not associated with toxicity).
 Units are milligrams of  contaminant per cubic meter of air.
=Reference Dose  (daily dose not associated with toxicity).
 Units are milligrams of  contaminant per kilogram of body weight per day.
                       Hazard Quotient: Ratio of Average Dose
                       to 'Safe' Daily Dose
                                     Inhalation                 Dermal
                      (VI)
     Groundwater
       Drinking Water
          MEDIUM TOTALS
     Air
       Indoor Air
       Outdoor Air
          MEDIUM TOTALS
     Soil
       Dust/Soil Indoors
              Oral

        RfD (mg/kg/d): 0.005

         0.001096
         0.001096
         0.000110
       Dust/Soil Outdoors 0.000110
                                                        No RfC
                                    Missing RfC
                                    Missing RfC
                                    Missing RfC
                                    Missing RfC
                                                                        Source: IRIS & HEAST(04/14/97&04/14/97)
          MEDIUM TOTALS
       ALL MEDIA TOTALS
         0.000219
         0.001315
NOTE:  scientific notation is used for completeness.
       For example:0.00000021 = 2.1e-7 = 2.1 / 10,000,000  (odds of 2 in 10,000,000) and 21,000,000 = 2.1e7 = 2.1
* 10,000,000.
       HQ/HI values are meaningful up to the first significant digit.

 It is generally assumed that non-cancer toxic effects have some threshold. That  is, up to some
 finite level of exposure, physiological defense mechanisms ensure that no toxic  effect will occur.
 Accordingly, hazard assessment for non-carcinogenic effects involve estimating an  exposure that is
 less than this threshold level. This is done by applying  "uncertainty factors" to  exposures that
 appear to be near this threshold in laboratory toxicology studies. This yields a Reference Dose
                                                       A-5

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 !RfD)  for oral exposures,  or a Reference Concentration (RfC) for inhalation exposures.

 TOTALS FOR ALL CHEMICALS
                                                                      Risk (Odds):Individual Probability of
                              Hazard Quotient                         Getting Cancer from this Exposure Alone
 Oral                         0.001315
 Inhalation                                                           5 in 1,000,000 (5e-006)

 Groundwater                  0.001096
 Air                                                                  5 in 1,000,000 (5e-006)
 Soil                         0.000219

 TOTAL                                                                5 in 1,000,000 (5e-006)

NOTE:  scientific notation is used for completeness.
       For example:0.00000021 = 2.1e-7 = 2.1 / 10,000,000 (odds of 2 in 10,000,000)  and 21,000,000 = 2.1e7 = 2.1
* 10,000,000.
       HQ/HI values  are meaningful up to the first significant digit.

 In some situations,  it is appropriate for the user to calculate combined risks from multiple
 chemicals and multiple routes of exposure. Many chemicals will produce the same toxic effect,
 regardless of the exposure route. For chemicals that cause cancer by several routes of exposure, the
 combined risk from all routes may be more informative than route-specific risk estimates, unless
 there is evidence that carcinogenic risks from different routes reflect different  mechanisms of
 action. Similarly,  for non-cancer toxic effects, differences between routes may only affect toxic
 potency, which will be reflected in the use of route-specific Reference Doses or Reference
 Concentrations.

 Carcinogenic risk estimates for particular chemicals and routes of exposure may be summed directly
 to produce an estimate of total carcinogenic risk. Similarly, Hazard Quotients for chemicals that
 produce toxic effects in the same organ system may be summed to yield a Hazard Index.  Hazard Indices
 < 1.0 are generally considered by EPA to be associated with low risks on non-cancer toxic effects.

 In generating estimates of the combined toxic and carcinogenic risks of different  chemicals, it is
 also important to bear in mind that the risks of exposure to multiple chemicals are not necessarily
 additive. Risks may be less than additive, or synergism may lead to risks that are greater than
 would be predicted by an additive model. Unfortunately, only very limited data are available on the
 risks of exposure to multiple chemicals.

 Carcinogenic risks that exceed 0.000001 (1 e-006), whether for a single chemical,  route of exposure,
 and scenario, or for a combination of chemicals, exposure routes, and scenarios, fall within the
 EPA's range of concern. Depending upon the number of persons exposed to these risks and the
 plausibility of the assumptions underlying the estimate,  some action to control the risks may be
 needed. Risks in excess of 0.0001 (1 e -004) are generally considered unacceptable.

 In generating estimates of the combined toxic and carcinogenic risks of different  chemicals, it is
 also important to bear in mind that the risks of exposure to multiple chemicals are not necessarily
 additive. Risks may be less than additive, or synergism may lead to risks that are greater than
 would be predicted by an additive model. Unfortunately, only very limited data are available on the
 risks of exposure to multiple chemicals.

 Hazard Quotients and Hazard Indices that exceed 1.0, whether for a single chemical, route of
 exposure, and scenario, or for a combination of chemicals,  exposure routes,  and scenarios, indicate
 the possibility of  non-cancer toxic risks from the exposure.

 If a Hazard Index that exceeds 1.0 represents multiple chemicals and/or multiple routes of exposure,
 the assessor should ascertain that exposure to these chemicals/routes will lead to toxic effects in
 the same organ system. It may be appropriate to recalculate a Hazard Index that includes only those
 chemicals and routes  of exposure that have overlapping patterns of toxicity.
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