ENDANGERMENT ASSESSMENT HANDBOOK  .

                                     Errata
Certain changes have been made to the draft Endangerment Assessment Guidance
since this Handbook was written.   These changes should be kept in mind while
reading the Handbook, especially Sections 2.0 and 4.0:

     •  The endangerment assessment is not necessary.to support cost recovery
        for CERCLA Section 104 remedial actions.

     •  The endangerment assessment is normally developed as part of an
        enforcement lead RI/FS.

     •  In evaluation of public  health impacts, human health standards and
        criteria should be included.

     •  At remedial sites subsequently targeted for CERCLA Section 106 or RCRA
        Section 7003 enforcement  action,  all of the elements of an endangerment
        assessment will be provided by completing the contamination assessment,
        public health assessment  and environmental assessment during the RI/FS
        process.

Specific changes to this Handbook include the following:

     1.    Page 4-11, Se'ction 4.3.2, Paragraph 2

          Delete the third sentence which reads:  "Intermedia transport
          processes . . . characterized in the Level 1 endangerment assessment.1

          Delete the last sentence which reads:  "An overview . . . Figure
          4-2."

     2.    Page 4-13. Figure 4-13

          Change the title of the figure to read:  "Figure 4-2  Overview of
          Environmental Fate and  Transport Analysis for Level 2 Endangerment
          Assessments."

     3.    Page 4-14, First Line

          Add this sentence following the first line:   "An overview of the
          environmental fate and  transport analysis for Level 2 endangerment
          assessments is shown in Figure 4-2."

     4.    Page 4-14, First Full  Paragraph, First Sentence

          Add this sentence after the first full sentence:  "Intermedia
          transport processes (e.g.,  adsorption, volatilization, infiltration,
          bioaccumulation) and intramedia transformation processes (e.g.,

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     photolysis, hydrolysis, oxidation and biodegration)  which potentially
     affect migration of the contaminants of concern are  identified and
     characterized in the Level 2 and 3 endangerment assessments."

5.   Page 4-22, Section 4.4.1., Paragraph 2

     Add these sentences at the end of the second paragraph:   "How
     extensive the toxicity profiles are will depend on the amount of
     time available to prepare the profile and the level  of detail of the
     endangerment assessment.  Thus, the toxicity profiles prepared for
     Level 1 endangerment assessments may not be as extensive as the
     profiles prepared for Level 2 or 3 endangerment assessments.  A
     Level 1 toxicity profile would include, at a minimum, identification'
     of applicable standards and guidelines for the contaminants of
     concern.  Table 4-8 provides guidance for the preparation of toxicity
     profiles for endangerment assessments of varying levels of detail."

6.   Page 4-28, Table 4-8

     Change Step 2.1 to read:  "Estimate 'Acceptable Levels'"

7.   Page 4-39, Section 4.5.2, Paragraph 1

     Change the first sentence to read:  "One method that toxicologists
     use to characterize noncarcinogenic risks involves comparing the
     expected exposure level_. (E) to the "acceptable level" (AL)  (USE.PA
     198-5a).  This proposed method has not been adopted as official EPA
     policy."

8.   Page 4-39, Section 4.5.3, Paragraph 2

     Replace the final sentence ("As within .  .  . risks increases.") wi^h
     the following:  "This is an oversimplification of the procedures
     used to estimate noncarcinogenic risks associated with exposure to
     multiple chemicals.  There are many assumptions made in developing
     these calculation procedures which the user should be aware of.
     These assumptions are detailed in the mixture guidelines in Appendix
     3 of this Handbook (USEPA 1985a)."

9.   Page 4-40, Paragraph 2

     Add this sentence at the end of the second paragraph:  "Qualitative
     risk characterization methods  include a comparison of actual or
     potential exposure levels to background levels, analytical  detection
     limits, technically based criteria and standards and health based
     criteria and standards.  Quantitative risk  characterization methods
     include all of the above in addition  to a quantitative estimation  of
     the actual or potential  risks  at the  site."

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                                      pro
PRC Engineering
Suite 600
303 East Wacker Drive
Chicago, IL 60601
312-938-0300
TWX 910-2215112
Cable CONTOWENG
                                      Planning Research Corporation
                           THE ENDANGERMENT ASSESSMENT HANDBOOK
                                       Prepared For
                           U.S. ENVIRONMENTAL PROTECTION AGENCY
                           Office Of Waste Programs  Enforcement
                                 Washington,  D.C.  20460
                    Work Assignment No.
                    Contract No.
                    PRC No.
                    Prepared By

                    Telephone No.
                    EPA Primary Contact
                    Telephone No.
136
68-01-7037
15-1360-00
Life  Systems,  Inc.
(Timothy E. Tyburski)
216/464-3291
R. Charles Morgan
202/475-6113
                              August,  1985

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                                                               £ife Systems, JHC.
                             Submitted to:

                  Office of Waste Programs  Enforcement
                  U.S. Environmental Protection Agency
                            401 M Street,  SW
                          Washington, DC  20460

Attention:  Chief, Health Sciences Section, R.  Charles  Morgan (2  copies).
                               TR-693-24B

                    ENDANGERMENT ASSESSMENT HANDBOOK



                             Prepared Under

                            Program No.  1393

                                   for

                        Subcontract No.  TES EMI-LS

                                  Under

                         Contract No. 68-01-7037



                   PRC,  Environmental Management, Inc.

                             Prime Contractor



                      PRC  Work Assignment  No.  136

                      ICAIR Work Assignment No.  12



                      Contact:   Timothy E.  Tyburski

                        Telephone:   (216) 464-3291



                              August, 1985

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                                                                 £ife Systems, Jnc.
                                 DISCLAIMER
This document has not undergone  final review within EPA and is for internal
Agency use/distribution only.

There has been an EPA Workgroup  review of  the  development of this document
prior to this draft.   This final draft is  being distributed to EPA personnel
for a six-month review period  after which  changes will be made based on the
comments received.

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                                                                  £ife Systems, JHC.
                                  FOREWORD
This Endangerment Assessment Handbook was prepared by ICAIR, Life Systems,
Inc., under U.S. Environmental Protection Agency (EPA) Contract 68-01-7037
during the period February 1, 1985 to August 16, 1985.  The program was
directed by Mr. Timothy E. Tyburski.  The handbook was compiled by Ms. Lee Ann
Smith with technical support from Mr. Kevin Gleason, Ms. Yvonne Hales and
Mr. Jon Hellerstein.

Mr. R. Charles Morgan and Ms. Kathleen Plourd, Health Sciences Section,
Technical Support Branch, Office of Waste Programs Enforcement (OWPE) were the
lead EPA Technical Contacts.  ICAIR would also like to acknowledge the contri-
butions of the EPA Workgroup members to this program:  Cheryl Peterson,
Compliance Branch, OWPE; Linda Southerland, Guidance and Oversight Branch,
OWPE; Libby Clemens, Resource Conservation and Recovery Act (RCRA) Enforcement
Division, OWPE; Kurt Lamber, Physical Sciences Section, Technical Support
Branch, OWPE; Craig Zamuda, Office of Emergency and Remedial Response (OERR);
John Schaum, Exposure Assessment Group, Office of Health and Environmental
Assessment (OHEA); Jim Kohanek, Office of Enforcement and Compliance Monitor-
ing (OECM); Ralph Jennings, EPA Region 4; and Sally Edwards, EPA Region 1.

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                                                                 £ife Systems, Jnc.
                              TABLE OF CONTENTS

                                                                          PAGE

LIST OF FIGURES	    iv

LIST OF TABLES	    iv

LIST OF ACRONYMS	    v

GLOSSARY	    vi

1.0   INTRODUCTION	    1-1

      1.1   Purpose and Scope of the Endangerment Assessment Handbook .    1-1
      1.2   Handbook Organization 	    1-2

2.0   LEGISLATIVE AND PROGRAMMATIC FRAMEWORK  	    2-1

      2.1   Applicable Legislation  	    2-1
      2.2   Role of the Endangerment Assessment in Enforcement Cases  .    2-1

            2.2.1   When to Perform an Endangerment Assessment  ....    2-1
            2.2.2   Who Performs an Endangerment Assessment ......    2-4
            2.2.3   Confidentiality of an Endangerment Assessment .  .  .    2-4

      2.3   Relationship of Enforcement Actions to Superfund Actions  .    2-4

            2.3.1   The RI and FS Processes	    2-5
            2.3.2   Relationship of the Endangerment Assessment
                    Process to the RI and FS Assessment Processes .  .  .    2-8

3.0   OVERVIEW OF THE ENDANGERMENT ASSESSMENT PROCESS 	    3-1

      3.1   Contaminant Identification  . . '.	    3-3
      3.2   Exposure Assessment	    3-3
      3.3   Toxicity Assessment	    3-4
      3.4   Risk Characterization	    3-6

4.0   GUIDELINES FOR CONDUCTING ENDANGERMENT ASSESSMENTS  	    4-1

      4.1   Level of Detail	    4-1

            4.1.1   Level 1 ("Qualitative")	    4-1
            4.1.2   Level 2 ("Semi-Quantitative") 	    4-3
            4.1.3   Level 3 ("Quantitative")  	    4-3

      4.2   Contaminant Identification Guidelines 	    4-4
                                                                 continued-

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                                                                 £ife Systems, Jnc.
Table of Contents - continued

                                                                          PAGE

      4.3   Exposure Assessment Guidelines  	    4-8

            4.3.1   Contaminant Release Analysis  	    4-10
            4.3.2   Environmental Fate and Transport Analysis 	    4-11
            4.3.3   Exposed Population Analysis 	    4-14
            4.3.4   Calculation of Exposure Level and Dose Incurred .  .    4-17
            4.3.5   Exposure Assessment References	    4-19

      4.4   Toxicity Assessment Guidelines  	    4-21

            4.4.1   Toxicological Evaluation  	    4-22
            4.4.2   Dose-Response Assessment  	    4-31
            4.4.3   Toxicity Assessment References  	    4-35

      4.5   Risk Characterization Guidelines	    4-36

            4.5.1   Characterize Carcinogenic Risks	    4-37
            4.5.2   Characterize Noncarcinogenic Risks  	    4-39
            4.5.3   Characterize Environmental Risks	• •  •    4-40
            4.5.4   Characterize Public Health Risks  	    4-40
            4.5.5   Risk Characterization References  .  .	    4-40

5.0   PREPARATION OF THE ENDANGERMENT ASSESSMENT DOCUMENT 	    5-1

      5.1   Section 1.0  Introduction	    5-3

            5.1.1   Section 1.1  Site Description and History	    5-5
            5.1.2   Section 1.2  Contaminants Found at the Site ....    5-5

      5.2   Section 2.0  Environmental Fate and Transport	    5-6
      5.3   Section 3.0  Exposure Evaluation  	    5-6
      5.4   Section 4.0  Toxicity Evaluation  	    5-7
      5.5   Section 5.0  Risk and Impact Evaluation	    5-7
      5.6   Section 6.0  Conclusions	    5-8

6.0   SOURCES OF INFORMATION AND ASSISTANCE	    6-1

      6.1   Endangerment Assessment Process 	    6-1
      6.2   RI and FS Processes .	    6-1
      6.3   Toxicity Profiles 	    6-2
      6.4   EPA Risk and Exposure Assessment Guidelines	    6-2

7.0   REFERENCES	    7-1
                                                                 continued-
                                       ii

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                                                                 £ife Systems, Jnc.
Table of Contents - continued

                                                                          PAGE

APPENDIX

   1      Draft Endangerment Assessment Guidance  	    Ai-i
   2      Examples of Endangerment Assessments   	  	    A2-1
               Part 1.  Level 1  Endangerment Assessment  	    A2-4
               Part 2.  Level 2  Endangerment Assessment  	    A2-5
               Part 3.  Level 3  Endangerment Assessment  	    A2-6
   3      EPA's Proposed Assessment Guidelines   	    A3-1
               Part 1.  Carcinogenic Risk Assessment	    A3-2
               Part 2.  Exposure Assessment	    A3-3
               Part 3.  Mutagenicity Risk Assessment	    A3-4
               Part 4.  Health Assessment of Suspect  Developmental
                        Toxicants	    A3-5
               Part 5.  Health Risk Assessment  of  Chemical Mixtures  .  .    A3-6
   4      Test Protocol Criteria for Animal Assays  	    A4-1
   5      Definition of Toxicological Endpoints 	    A5-1
                                      iii

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                                                                 £ife Systems, Jnc.
                               LIST OF FIGURES
FIGURE                                                                    PAGE

 2-1      Role of the Endangerment Assessment in CERCLA Enforcement
          Cases	    2-3
 2-2      The Remedial Investigation Process  .  	    2-6
 2-3      The Feasibility Study Process 	    2-7
 2-4      The Interrelationship of the Endangerment Assessment
          Document, Remedial Investigation Report and Feasibility
          Study Report	    2-9
 3-1      The Endangerment Assessment Process 	    3-2
 3-2      The Exposure Assessment Process	    3-5
 3-3      The Toxicity Assessment Process 	    3-7
 3-4      The Risk Characterization Process	    3-9
 4-1      Overview of Contaminant Release Analysis  	    4-12
 4-2      Overview of Environmental Fate and Transport Analysis for
          Level 1 Endangerment Assessments  	    4-13
 4-3      Overview of Environmental Fate and Transport Analysis for
          Level 2 and 3 Endangerment Assessments	    4-16
 4-4      Overview of Exposed Population Analysis	    4-18
 4-5      Overview of Process for Calculating Exposure Levels and
          Dose Incurred	    4-20
                               LIST OF TABLES

TABLE                                                             •        PAGE

 4-1      Relationship Between the Endangerment Assessment Handbook
          and the Superfund Public Health Assessment Manual (SPHAM)  .  .    4-2
 4-2      Guidelines for Level of Detail in Endangerment Assessments  .    4-5
 4-3      Site-Specific Documentation Available for the Preparation  of
          Endangerment Assessments	- ...    4-7
 4-4      Exposure Assessment Steps 	    4-9
 4-5      Components of EPA's Graphical Exposure Modeling System (GEMS)    4-15
 4-6      Toxicity Profiles Prepared Specifically for Use at Hazardous
          Waste Sites	    4-23
 4-7      EPA Sources of Toxicity Profiles	  .    4-26
 4-8      Toxicity Assessment Steps 	    4-28
 4-9      Guidelines for Selection of Uncertainty Factors 	    4-33
 4-10     Risk Characterization Steps 	    4-38
 5-1      Endangerment Assessment Document Outline  	    5-2
 5-2      Factors to be Considered in Endangerment Assessments  ....    5-4
                                      iv

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                                                       £ife Systems, Jnc.
                     LIST OF ACRONYMS
ADI       Acceptable Daily Intake
AO        Administrative Order
ATSDR     Agency for Toxic Substances and Disease Registry
CASR      Chemical Activities Status Report
CERCLA    Comprehensive Environmental Response,
          Compensation and Liability Act
ECAO      Environmental Criteria and Assessment Office
EPA       Environmental Protection Agency
FS        Feasibility Study
GEMS      Graphical Exposure Modeling System
HI        Hazard Index
LOAEL     Lowest-Observed-Adverse-Effect Level
NCP       National Contingency Plan
NEIC      National Enforcement Investigations Center
NOAEL     No-Observed^Adverse-Effect Level
NOEL      No-Observed-Effect Level
OAQPS     Office of Air Quality Planning and
          Standards
ODW       Office of Drinking Water
OECM      Office of Enforcement and Compliance Monitoring
OERR      Office of Emergency and Remedial Response
OHEA      Office of Health and Environmental
          Assessment        -__
ORD       Office of Research and Development
OSW       Office of Solid Waste
OTS       Office of Toxic Substances
OWPE      Office of Waste Programs Enforcement
OWRS      Office of Water Regulations and
          Standards              /'
QA/QC     Quality Assurance/Quality Control
RCRA      Resource Conservation and Recovery Act
REM/FIT   Remedial Planning/FieId Investigation Team
RI        Remedial Investigation
SPHAM     Superfund Public Health Assessment Manual
TAT       Technical Assistance Team
TES       Technical Enforcement Support

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                                                                  £ife Systems, Jnc.
                                   GLOSSARY
Acceptable Dally Intake - The amount of toxicant, in mg/kg body weight/day,
that will not cause adverse effects after chronic exposure to the general
human population.

Administrative Action - Any action that a statute or regulation authorizes EPA
to take, but does not involve filing papers with a court and is not part of
prosecuting a case already filed.  Examples of administrative actions are
issuance of orders under Section 106 of CERCLA and Section 7003 of RCRA.

Dose-Response Assessment - The second step in the toxicity assessment process
which involves defining the relationship between the exposure level (dose) of
a chemical and the incidence of the adverse effect (response) in the exposed
populations.

Endangerment Assessment - A site-specific assessment of the actual or
potential danger to public health or welfare or the environment from the
threatened or actual release of a hazardous substance or waste from a site.
The endangerment assessment document is prepared in support of an enforcement
action under CERCLA or RCRA.

Enforcement Action - Any action taken pursuant to Section 106 of CERCLA or
Section 7003 of RCRA to compel responsible parties to respond to hazardous
conditions'.  An enforcement action may include administrative actions and/or
judicial actions.

Exposure Assessment - One of the components of the endangerment assessment
process, the exposure assessment is a four-step process to identify actual or
potential routes of exposure, characterize populations exposed and determine
the extent of the exposure.       /•

Exposure Evaluation - The section of the endangerment assessment document
which reports the results of the exposure assessment process.

Judicial Action - Any action that involves filing papers with a court or is
part of prosecuting a case already filed.  Examples of judicial actions are
actions taken to seek injunctive relief or actions taken when a party fails to
comply with an administrative order.

LC   - Lethal concentration at which 50% of the test organisms die.
—~j(j
LD   - Lethal dose at which 50% of the test organisms die.

Lowest-Observed-Adverse-Effect Level  (LOAEL) - The lowest dose of a chemical
in a study that produces statistically or biologically significant increases
in the frequency or severity of adverse effects between the  exposed population
and an appropriate control.
                                       vi

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                                                                  £ife Systems, Jnc.
No-Observed-Adverse-Effect Level (NOAEL) - That dose of a chemical at which
there are no statistically or biologically significant increases in the
frequency or severity of adverse effects between the exposed population and an
appropriate control.

No-Observed-Effect Level (NOEL) - That dose of a chemical at which there are
no statistically or biologically significant increases in the frequency or
severity of effects between the exposed population and an appropriate control.

Risk Characterization - The final component of the endangerment assessment
process which integrates all of the information developed during the exposure
and toxicity assessments to yield a complete characterization of the actual or
potential risk at a site.

Risk and Impact Evaluation - The section of the endangerment assessment
document which reports the results of the risk characterization process.

Toxicity Assessment - One of the components of the endangerment assessment
process, the toxicity assessment is a two-step process to determine the nature
and extent of health and environmental hazards associated with exposure to
contaminants of concern present at the site.  It consists of toxicological
evaluations and dose-response assessments for contaminants of concern.

Toxicity Evaluation - The section of the endangerment assessment document
which reports the results of the toxicity assessment process.

Toxicity Profile - A summary of the available human health or environmental
toxicity data on a contaminant.  This document considers doses used, routes of
exposure, types of adverse effects manifested and definitive statements of
quantitative indices of toxicity.

Toxicological Evaluation - The first step in the toxicity assessment process /
which is a qualitative evaluation of the scientific data to determine the
nature and severity of actual or potential health and environmental hazards
associated with exposure to a chemical substance.  The end product of the
toxicolpgical evaluation is a toxicity profile for each of the contaminants of
concern.

Unit Cancer Risk - Excess lifetime risk of cancer due to a continuous lifetime
exposure of one unit of carcinogen concentration.
                                      vii

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                                                                  £ife Systems, Jnc.
1.0       INTRODUCTION

Current U.S Environmental Protection Agency (EPA) policy states that an
endangerment assessment is required to support all administrative and judicial
enforcement actions under Section 106(a) of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA) and Section 7003 of
the Resource Conservation and Recovery Act of 1976 (RCRA).

This Handbook makes a distinction between:

       •  The endangerment assessment process which evaluates the collective
          demographic, geographic, physical, chemical and biological factors
          at a site to determine whether there is a significant risk to public
          health or welfare or the environment as a result of a threatened or
          actual release of a hazardous substance or waste; and

       •  The endangerment assessment document which summarizes the findings
          of the assessment process in a concise format and documents EPA's
          assertion that an imminent and substantial endangerment to public
          health or welfare or the environment may exist at a site targeted
          for enforcement actions.

1.1       Purpose and Scope of the Endangerment Assessment Handbook

This Handbook provides guidance to EPA regional, state and contractor personnel
on conducting endangerment assessments and preparing the necessary documentation.
Its primary purpose is to assist individuals in the preparation of endangerment
assessment documents which will satisfy the enforcement needs of each case.
This Handbook is intended only as a supplement to the "Draft Endangerment
Assessment Guidance" prepared and distributed by EPA's Office of Waste Programs
Enforcement (OWPE) (USEPA 1985d) and should be used in conjunction with that
document, which is included in its entirety in Appendix 1 to this Handbook.

The Handbook explains the use of the endangerment assessment as an enforcement
tool and its relationship to the remedial investigation (RI) and feasibility
study (FS) processes at a site.  It provides guidance on how to develop an
endangerment assessment and discusses the timing, scope and level of detail
that are required and how these factors may be affected by site-specific
enforcement concerns.

The Handbook also describes the relationship of the endangerment assessment
document to other documents generated for a site and provides instructions for
preparing the document.  Finally, it identifies key references and other
sources of information and assistance.

A distinction between the endangerment assessment process and endangerment
assessment document is made throughout this Handbook to clarify the difference
between the complex, multi-disciplinary assessment process and the fairly
straightforward task of preparing a document which reports the conclusions of
the assessment process.
                                      1-1

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                                                                  £ife Systems, Jnc.
EPA has recently completed guidance documents for planning and performing RI
and FS studies at Superfund sites:

       •  Guidance on Remedial Investigations Under CERCLA (USEPA 1985c)

       •  Guidance on Feasibility Studies Under CERCLA (USEPA 1985b)

A detailed instruction manual is being developed, designed to accompany the RI
and FS guidance documents, for conducting public health assessments at Super-
fund sites:

       •  Superfund Public Health Assessment Manual (ICF 1985)

Since the endangerment assessment process is similar to the public health and
environmental assessments which are conducted as part of the RI and FS, this
manual should be used as a technical reference when performing endangerment
assessments.  To avoid unnecessary duplication of technical detail provided in
the Superfund manual, this Handbook directs the reader to this manual for
additional information where appropriate.

1.2       Handbook Organization

This Handbook is divided into six sections and five appendices in addition to
this Introduction:

     2.0  Legislative and Programmatic Framework
     3.0  Overview of the Endangerment Assessment Process
     4.0  Guidelines for Conducting Endangerment Assessments
     5.0  Preparation of the Endangerment Assessment Document
     6.0  Sources of Information and Assistance
     7.0  References

     Appendix 1  Draft Endangerment Assessment Guidance
     Appendix 2  Examples of Endangerment Assessments
     Appendix 3  EPA's Proposed Assessment Guidelines
     Appendix 4  Test Protocol Criteria for Animal Assays
     Appendix 5  Definition of Toxicological Endpoints

Section 2.0 provides an overview of the legislative and programmatic framework
in which the endangerment assessment fits.  It summarizes the legislative
background of the endangerment assessment process and discusses when an
endangerment assessment should be prepared and who should prepare it.  The
relationship of the endangerment assessment process to the RI and FS processes
and the role of the endangerment assessment document in enforcement cases is
also discussed in this section.

Section 3.0 provides an overview of the.endangerment assessment process and
its components:  contaminant identification, exposure assessment, toxicity
assessment and risk characterization.  This section briefly describes  the
objectives of each component and the information needed to complete each of
the assessments.
                                       1-2

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                                                                  £ife Systems, Jnc.
Section 4.0 provides guidelines for conducting endangerment assessments.   It
contains a discussion of the levels of detail required in an endangerment
assessment and discusses the steps required to complete the contaminant
identification, exposure assessment, toxicity assessment and risk characteriza-
tion components introduced in Section 3.0.

Section 5.0 describes the format,  scope and content of the endangerment
assessment document.  It provides  specific  instructions for completing each
required section of the document,  sources of information and factors to be
addressed.

Section 6.0 provides information on the points of contact at EPA Headquarters
for additional information on the  endangerment assessment process and the
requirements of an endangerment assessment  document.

Section 7.0 is a list of references cited in this Handbook.
                                      1-3

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                                                                  £ife Systems, Jnc.
2.0       LEGISLATIVE AND PROGRAMMATIC FRAMEWORK

2.1       Applicable Legislation

Section 106(a) of CERCLA states that "... when the President determines that
there may be an imminent and substantial endangerment to public health or
welfare or the environment because of an actual or threatened release of a
hazardous substance from a facility, he may . . . secure such relief as may be
necessary to abate such danger and threat,. . . ."

Section 7003 of RCRA states that "... upon receipt of evidence that the
handling, storage, treatment, transportation or disposal of any solid waste or
hazardous waste may present an imminent and substantial endangerment to health
or the environment, the Administrator may bring suit ... to immediately
restrain any person contributing to such handling, storage, treatment, transporta-
tion, or disposal or to take such other action as may be necessary."

Thus, Section 106(a) of CERCLA authorizes EPA to take judicial or administrative
action to compel responsible parties to respond to hazardous conditions
resulting from an actual or threatened release of a hazardous substance.
Likewise, Section 7003 of RCRA may be used as the authority under which EPA
may issue orders or file civil actions to compel responsible parties to
respond to hazardous conditions resulting from the handling, storage, treatment,
transportation or disposal of solid wastes or hazardous wastes.

2.2       Role of the Endangerment Assessment in Enforcement Cases

Before taking enforcement actions (i.e., judicial actions, administrative
actions) under Section 106(a) of CERCLA or Section 7003 of RCRA, EPA must be
able to properly document and justify its assertion that an imminent and
substantial endangerment to public health or welfare or the environment may
exist.  The endangerment assessment provides this justification and docu-
mentation.

It is important to note at this juncture that "imminent" does not mean immediate
harm, rather, it means an impending risk of harm.  Sufficient justification
for a determination of an imminent endangerment may exist if harm is threatened;
no actual injury need have occurred or be occurring.  Similarly, "endangerment"
means something less than actual harm (USEPA 1985d).

The data collected at a site (i.e., contaminants present, quantities present,
environmental media affected, etc.) does not stand on its own; it must be
interpreted.   The endangerment assessment document provides an interpretation
of the data which supports the "Findings of Fact" sections in the administra-
tive or judicial enforcement documents that may be prepared for a site.

2.2.1     When to Perform an Endangerment Assessment

The endangerment assessment document must be prepared before a CERCLA Section
106(a) or RCRA Section 7003 action is filed or issued.  Therefore, the
endangerment assessment process should be initiated as soon as a site is
                                      2-1

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                                                                  £ife Systems, JHC.
identified as an enforcement site and administrative or judicial actions are
considered.  The requirement for an endangerment assessment document should
not slow down the enforcement process at a site.

Only one endangerment assessment document should be prepared for a site.  The
original document may then be revised, updated or amended throughout the site
development process as additional data become available.

Figure 2-1 illustrates the points in time when an enforcement action under
CERCLA, and the required endangerment assessment, may be initiated at a site.
The endangerment assessment may be performed:

     1.   Before issuance of an administrative order (AO) for removal actions;

     2.   As part of the RI/FS;

     3.   Before issuance of an AO or consent decree for responsible party
          RI/FS or cleanup (i.e., remedial actions);

     4.   Before issuance of an AO to a Federal facility for cleanup; or

     5.   Before any judicial action is taken (i.e., case is filed).

Figure 2-1 also illustrates what site documentation may be available to
provide input to the endangerment assessment.  Finally, since the endangerment
assessment may be performed at varying points in time to support different  •-•-
enforcement actions, the level of detail in the document will vary on a
case-by-case basis.  Figure 2-1 indicates what level of detail may be appro-
priate for endangerment assessments supporting CERCLA enforcement actions
performed at different points of time.  The concept of varying levels of
detail in endangerment assessments is discussed more fully in Section 4.0.

While an endangerment assessment document must be prepared to support both
RCRA Section 7003 actions and CERCLA Section 106 actions, the circumstances
when Section 7003 orders are used and endangerment assessments must be pre-
pared differ under RCRA and CERCLA.  Whereas the CERCLA Section 106 authority
initially relies on the discovery or notification of a release of hazardous
substances, the RCRA Section 7003 authority can be activated when the
Administrator possesses evidence "that the past or present handling, storage,
treatment, transportation or disposal of any solid waste or hazardous waste
may present (emphasis added) an imminent and substantial endangerment to
health or the environment" (42 USC Section 6973).  Additionally, the Section
7003 authority extends to imminent hazards presented by a wider range of
hazardous constituents than CERCLA Section 106 authority.  Section  7003 orders
cover constituents that fall under the definition of "solid wastes"  (RCRA
Section 1004(27)) and "hazardous wastes"  (RCRA Section  1004(5)) while CERCLA
Section 106 orders cover "hazardous substances"  (CERCLA Section 104(14)).

Endangerment assessments must be prepared to support the issuance of an
administrative order or before judicial action is taken under RCRA  Section
7003.  But, unlike the CERCLA program, the RCRA program does not have a
                                       2-2

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                                   Discovery Or Notification
                                        Of Release
                                ti£*&&&&&&^               —.~ ,
                                 Preliminary Assessment And
                                       Site Inspection
                    No Release Or
                  Threat Of Release
      Terminate Activities
                  Removal
              Not Required But
             Remedial Action May
                Be Necessary
 *X Hazard Ranking
  ~ System (HRS)
                   .  No Further
                  Action Necessary
                                    1or2
                                 National Priorities List (NPL)
                                Scoping of Response Actions
                                     1or2
     2\
                       2or3\
                                                    Remedial
                                                Action Necessary
Remedial Investigation/
   Feasibility Study
                                     Remedial Actions
                                       Implemented
   1 \.   Points At Which Endangerment Assessment May
   ^^j   Be Performed (No. Indicates Level of Detail)
          Site Documentation That May Provide
          Input To Endangerment Assessment
                                                                                £ife Systems, Jnc.
            Removal Action
              Appropriate
Removal Actions
                                             Removal Action
                                               Necessary
FIGURE  2-1   ROLE OF THE ENDANGERMENT ASSESSMENT IN  CERCLA  ENFORCEMENT  CASES
                                             2-3

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                                                                 £ife Systems, Jnc.
formalized RI/FS study process.  Hence, the detailed information contained in
an RI/FS study that is available for use in the CERCLA endangerment assessment
may not be readily available to include in an endangerment assessment for
supporting Section 7003 orders.

For more information on Section 7003 orders, please see the "Final Revised
Guidance Memorandum on the Use and Issuance of Administrative Orders under
Section 7003 of the Resource Conservation and Recovery Act (RCRA)," dated
September 26, 1984.

2.2.2     Who Performs an Endangerment Assessment

Agency policy states that the Regions have the responsibility to assure that
endangerment assessments are performed.  For assistance in performing
endangerment assessments, the Regions can draw on technical expertise avail-
able in their Regional offices, OWPE's Technical Support Branch, the Office of
Research and Development (ORD), the Agency for Toxic Substances and Disease
Registry (ATSDR) and/or contractor personnel available through the Technical
Enforcement Support (TES), Remedial Planning/Field Investigation Team (REM/FIT)
or Technical Assistance Team (TAT) contracts.

The only exception to EPA (Regions) performing the endangerment assessment is
if the responsible parties elect to perform the RI/FS pursuant to an AO. In
these cases, they will also, in effect, perform an endangerment assessment
because they will develop many or all of the elements of an endangerment
assessment as part of the RI/FS.  Since 'subsequent enforcement actions (i.e.,
AOs requiring responsible parties to perform cleanup) rely on this endanger-
ment assessment for justification, close Regional oversight should be given to
this responsible party work.

2.2.3     Confidentiality of an Endangerment Assessment

The endangerment assessment document, and all supporting documentation, must
be considered enforcement confidential as long as an enforcement action is
pending.  Document control procedures which should be implemented may include:

       •  Marking the cover page of all documents as "Privileged Work Product
          Prepared in Anticipation of Litigation"
       •  Marking each page of all documents as "Enforcement Confidential"
       •  Limiting the distribution of all documentation
       •  Limiting the number of copies distributed
       •  Utilizing standard chain-of-custody procedures for the documents per
          the National Enforcement Investigations Center (NEIC) manual

The endangerment assessment is no longer considered confidential when the
finalized document is distributed to the public.

2.3       Relationship of Enforcement Actions to Superfund Actions

The Hazardous Substance Response Trust Fund, commonly known as Superfund, was
established by CERCLA to finance the discovery of actual or threatened
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                                                                  &fe Systems, Jnc.
releases of hazardous substances into the environment and the development and
implementation of response actions at these uncontrolled hazardous waste
sites.  To ensure that Superfund is used as effectively as possible, proce-
dures for use of the fund were incorporated into the revised National Contin-
gency Plan (NCP) (USEPA 1985c).

Section 104 of CERCLA authorizes EPA to initiate Superfund-financed response
actions as soon as an actual or threatened release of a hazardous substance is
discovered.  All Superfund-financed response actions must be in accord with
the NCP.

As discussed previously, Section 106(a) of CERCLA authorizes EPA to take any
necessary enforcement actions to compel responsible parties to respond to
hazardous conditions resulting from an actual or threatened release of a
hazardous substance.  Thus, if a potentially responsible party is identified
at any time during the development and implementation of Superfund-financed
response actions at a site, enforcement actions may be taken to compel the
potentially responsible party to conduct the cleanup itself or provide funds
for the government-conducted cleanup (i.e., reimburse Superfund costs).  Any
response actions or remedies resulting from enforcement actions at Superfund
sites must be in accord with the procedures outlined in the NCP.

2.3.1     The RI and FS Processes

The NCP requires that a detailed RI and FS be conducted at each site targeted
for remedial response action under Sections 104 and 1.06 of CERCLA.  The goal
of the RI is to obtain the necessary site data so the potential impacts on
public health or welfare or the environment can be evaluated and remedial
alternatives can be developed and selected.  The goal of the FS is to develop
and evaluate alternative remedial actions (including the no-action alter-
native) in terms of cost, effectiveness and their engineering feasibility.
Thus, the RI emphasizes data collection and site characterization while the FS
emphasizes data analysis and an evaluation of alternative remedial actions.

For Superfund-financed sites, the NCP requires an analysis of impacts on
public health, welfare and the environment.  Therefore, the RI and FS pro-
cesses require an assessment of the contamination at the site and the
potential impacts on public health or the environment from that contamination.
The RI assessments focus on the existing conditions at the site in performing
a baseline assessment or complete site characterization.  Figure 2-2 illus-
trates when the site characterization assessments are performed in the RI
process.  The FS assessments evaluate the potential impacts at the site
associated with each remedial alternative, including the no-action alter-
native.  The no-action alternative analysis is, essentially, a baseline
assessment at the site against which all remedial alternatives are compared.
Figure 2-3 illustrates when this analysis of alternatives is performed in the
FS process.
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                                                           ttfe Systems, JHC.
                     Scoping Remedial
                       Investigation
                        Sampling
                    Plan Development
                       Health And
                     Safety Planning
                       Institutional
                         Issues
              >|    Site Characterization
              •.-I • Contamination Assessment
              y • Public Health Assessment
              ?^ • Environmental Assessment
                    Bench/Pilot-Scale
                        Studies
                        Remedial
                   Investigation Report
     Data and information required
     for this assessment process
     should be used in the preparation
     of the endangerment assessment.
Adapted from EPA 1985c
FIGURE  2-2   THE REMEDIAL INVESTIGATION PROCESS
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                                                                                   £ife Systems, ]nc.
                                      Characterize Problem
                                          and Identify
                                       General Response
                                            Actions
                                          Formulate &
                                            Develop
                                          Alternatives &
                                          Technologies
                                           Technical
                                           Screening
                                       Environmental, Public
                                       Health & Institutional
                                         Cost Screening
   Technical Analysis
                                       Identify Alternative
                                        Remedial Actions
Cost Analysis
                                             ±
                                          Summary of
                                          Alternatives
                                                                                  i
Institutional
 Analysis
                                                          I Environmental.-,;'
                                                         >,',,   Analysis   '  /-;'
                                                          ' yyy f*f'-*   r, ff*fjj.f •. -.''  '
     Data and information required
     for this assessment process
     should be used in the preparation
     of the endangerment assessment.

Adapted  from  EPA 1985b
                                        Final Feasibility
                                            Report
                   FIGURE  2-3   THE  FEASIBILITY STUDY PROCESS
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2.3.2     Relationship of the Endangerment Assessment Process to the RI and FS
          Assessment Processes

The assessments performed during the RI and FS processes are very similar to
the endangerment assessment.  Although the assessments are performed for
different reasons, the information requirements are similar and the assessment
methods used should be consistent.  Therefore, in addition to this Handbook,
the guidance documents and instruction manuals prepared in support of the RI
and FS processes should be utilized when performing endangerment assessments.

Since a Superfund-financed site may become an enforcement site at any time
during the development and implementation of remedial response actions (see
Figure 2-1), documentation prepared for each program (e.g., Superfund and
Enforcement) should be complementary.  Thus, if the RI and FS are essentially
complete when an enforcement action is initiated, the requirement for an
endangerment assessment may be fulfilled by the "Site Characterization" and
"Analysis of No-Action Alternative" sections of the RI and FS reports,
respectively.  In this situation no separate endangerment assessment document
is required.  Conversely, if an endangerment assessment is prepared prior to
completion of the RI and FS reports, it should address all the issues that are
required in the assessment sections of the RI and FS reports.  The objective
should always be to reduce duplication of assessment efforts and documentation
at any given site.  Figure 2-4 illustrates the interrelationship of the
endangerment assessment document required at enforcement sites and the RI and
FS reports required at Superfund sites.
                                       2-8

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                                                                          £ife Systems, Jnc.
       REMEDIAL
     INVESTIGATION


         Site
     Characterization

     • Contamination
      Assessment
     • Public Health
      Assessment
     • Environmental
      Assessment
 ENDANGERMENT
  ASSESSMENT


   Enforcement
    Document


• Exposure Evaluation

• Toxicity Evaluation

• Risk and Impact
 Evaluation
   FEASIBILITY
     STUCV
   Analysis of
No Action Alternative

  • Public Health
     Analysis

  • Environmental
     Analysis
FIGURE 2-4   THE  INTERRELATIONSHIP  OF THE ENDANGERMENT ASSESSMENT DOCUMENT,
         REMEDIAL INVESTIGATION REPORT AND FEASIBILITY STUDY REPORT
                                         2-9

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                                                                         ttfeSystems, Jnc.
       REMEDIAL
     INVESTIGATION


         Site
     Characterization

     • Contamination
      Assessment
     • Public Health
      Assessment
     • Environmental
      Assessment
 ENDANGERMENT
  ASSESSMENT


    Enforcement
    Document


• Exposure Evaluation

• Toxicity Evaluation

• Risk and Impact
 Evaluation
   FEASIBILITY
     STUD/
   Analysis of
No Action Alternative

  • Public Health
     Analysis

  • Environmental
     Analysis
FIGURE 2-4   THE INTERRELATIONSHIP OF THE ENDANGERMENT ASSESSMENT DOCUMENT,
         REMEDIAL  INVESTIGATION REPORT AND  FEASIBILITY STUDY  REPORT
                                         2-9

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                                                                  £ife Systems, JHC.
3.0       OVERVIEW OF THE ENDANGERMENT ASSESSMENT PROCESS

The overall objective of an endangerment assessment is to provide a determination
of the magnitude and probability of actual or potential harm to public health
or welfare or the environment by the threatened or actual release of a hazardous
substance (for a CERCLA action) or a hazardous waste (for a RCRA action).  Tr.
general, this objective may be attained by identifying and characterizing the
following:

     1.   Hazardous substances and/or hazardous wastes present in all relevant
          media (e.g., air, water, soil, sediment, biota);

     2.   Environmental fate and transport mechanisms within specified environ-
          mental media, such as physical, chemical and biological degradation
          processes and hydrogeological evaluations and assessments;

     3.   Exposure pathways and extent of expected exposure;

     4.   Populations at risk;

     5.   Intrinsic toxicological properties of specified hazardous substances
          or hazardous wastes; and

     6.   Extent of expected harm and the likelihood of such harm occurring
          (i.e., risk characterization).
An endangerment assessment is an evaluation and interpretation of the collective
demographic, geographic, physical, chemical and biological factors at a site
which describe the extent of the potential or actual harm.  Thus, the process
of evaluating endangerment is multi-disciplinary, requiring the expertise of
scientists in several technical areas.

The endangerment assessment process is comprised of four separate components
which, collectively, address each of the six key areas identified above.  The
endangerment assessment process is divided into these four components based on
the areas of technical expertise required to perform each.  The four components
of the endangerment assessment process are:

     1.   Contaminant Identification
     2.   Exposure Assessment
     .3.   Toxicity Assessment
     4.   Risk Characterization

Figure 3-1 illustrates the endangerment assessment process and its four
components.  The following sections provide a brief overview of each compon-
ent.  Section 5 of this handbook describes how the information developed
during each component of the endangerment assessment process is presented in a
concise endangerment assessment document.
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                                                           £ife Systems, Jnc.
    i
 Exposure
Assessment
                        Identify Contaminants
                            of Concern
                        Risk Characterization
                          -Endaogenrneot
                           Assessment
                            Document
  Toxicity
Assessment
         FIGURE  3-1   THE ENDANGERMENT ASSESSMENT PROCESS
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 3.1  Contaminant Identification

 The objective of this component is to screen the information available on
 hazardous substances or wastes present at the site and identify contaminants
 of concern.  This screening process is necessary in order to focus subsequent
 efforts in the endangerment assessment process on a few, selected contaminants.

 Contaminants of concern may be selected based on their intrinsic toxicological
 properties or because they are present in large quantities or because of
 potentially critical exposure routes (i.e., being released into a drinking
 water supply).

 "Indicator chemicals" may have been selected as part of the RI/FS.  In this
 case, the endangerment assessment should focus on those chemicals.  If "indi-
 cator chemicals" have not yet been selected, the enforcement team must select
 the contaminants of concern.  The enforcement team may choose to select the
 contaminants based on the methodology for selecting "indicator chemicals"
 discussed in Chapter 4 of the SPHAM (2 CF 1985).  The goal of the selection
 process is to select the contaminants which encompass all of the relevant
 physiochemical and toxicological properties of the contaminants present at the
 site.

 3.2       Exposure Assessment

 The objectives of an exposure assessment are to identify actual or potential
 routes of exposure, characterize the exposed populations and determine the
 extent of the exposure.  These objectives may be attained by performing the
 following four steps:

     1.   Analyze contaminant release
     2.   Analyze environmental fate and transport
     3.   Analyze exposed populations
     4.   Estimate or calculate expected exposure levels (or doses incurred)

 The first step, an analysis of contaminant releases from the hazardous waste
 site, involves characterizing the contaminants of concern at the site and
 determining the amount of each contaminant released to each environmental
medium.

 In the second step the environmental fate and transport of the contaminants
 are analyzed.  The results of these analyses provide information on the
magnitude and extent of environmental contamination.  The exposure routes
 identified during this step will have varying levels of proof supporting their
 evaluation, depending on the amount of field data available at the time the
 exposure assessment is being performed.

 The third step of an exposure assessment involves an analysis of exposed
 populations.  Exposed populations may include human populations, sensitive
 subsets of the human population and/or fish and wildlife populations which may
 be at risk.  This analysis yields data on the magnitude of exposure and
 identifies potential high-risk populations (i.e., children, women of child-
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                                                                  fife Systems, Jnc.
bearing age, endangered or threatened wildlife populations, etc.).  This step
may also involve the application of exposure coefficients.  An exposure
coefficient combines information on the frequency, mode and magnitude of
exposure to yield a value representative of the amount of contaminated medium
contacted per day.

The final s,tep in an exposure assessment integrates the results of the pre-
ceding three steps to yield a qualitative or quantitative estimate of the
expected exposure levels resulting from actual or potential releases of
contaminants from the site.  Figure 3-2 illustrates the exposure assessment
process.

3.3       Toxicity Assessment

The objectives of the toxicity assessment are to determine the nature and
extent of health and environmental hazards associated with exposure to contami-
nants present at the site.  It is a two-step process consisting of:

     1.   Toxicological Evaluation
     2.   Dose-Response Assessment

The first step in the toxicity assessment, the toxicological evaluation, is a
qualitative evaluation of the scientific data to determine the nature and
severity of actual or potential health and environmental hazards associated  .
with exposure to a chemical substance.  The toxicological evaluation involves
a critical evaluation and interpretation of toxicity data from epidemiological,
clinical, animal and jLn vitro studies and results in a toxicity profile for
each contaminant of concern.  Toxicity profiles present a review of the
primary literature on the types of adverse effects manifested (e.g., chronic,
acute, carcinogenic, etc.), doses employed, routes of administration (e.g.,
oral, dermal, inhalation, etc.), the quality and extent of test data, the
reliability of the test data and other factors.  Toxicity profiles provide the
weight-of-evidence that the contaminants of concern pose potential hazards to
human health or the environment.

Once the toxicological evaluation determines that a chemical is likely to
cause a particular adverse effect, the next step is to determine the potency
of the chemical.  The second step in the toxicity assessment, the dose-response
assessment, is a quantitative estimation of risk from exposure to a toxic
chemical.  It defines the relationship between the dose of a chemical and the
incidence of the adverse eff'ect.

The dose-response assessment for noncarcinogenic chemicals utilizes the
quantitative indices of toxicity (e.g., NOEL, NOAEL, LOAEL, LC^, etc.), which
were identified during the toxicological evaluation, and  their respective
margins of safety to determine "acceptable levels" for the contaminants of
concern.  "Acceptable levels" are defined as exposure levels which are not
anticipated to cause adverse effects.  These "acceptable  levels" may be
expressed in a variety of ways such as Acceptable Daily Intakes  (ADIs),
Ambient Air Standards, Water Quality Criteria, etc.
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Contaminant Release
     Analysis
 Environmental Fate
   and Transport
     Analysis
Exposed Populations
     Analysis
   Calculation of
  Exposure Levels
  and Dose Incurred
                                              Exposure
                                             Assessment
      FIGURE 3-2   THE EXPOSURE ASSESSMENT PROCESS
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The dose-response assessment for carcinogenic chemicals provides estimates of
the probability that a specific adverse effect will occur (e.g., unit cancer
risk or carcinogenic potency values).  These estimates of probability are
derived using mathematical models of the dose-response relationship.

The end-product of a toxicity assessment is a qualitative description of thr
toxic properties of the contaminants of concern at the site and a quantitative
index of the toxicity for each contaminant at the site, if the data are
sufficient for such an assessment.

EPA has developed toxicity profiles on a large number of the contaminants that
are found at hazardous waste sites (see Section 4.4 of this Handbook for a
discussion of the available toxicity profiles).  These toxicity profiles
characterize the adverse health and environmental effects that are anticipated
to result from exposure to these contaminants.  Additionally, these profiles
define the "acceptable levels" for noncarcinogenic chemicals and the estimates
of unit cancer risk for carcinogenic chemicals.  Endangerment assessments
should always utilize existing EPA toxicity profiles when they are available.
If there are no appropriate toxicity profiles available for-the contaminants
and exposure routes of concern, then the members of the endangerment assess-
ment team with the appropriate expertise will have to develop toxicity
profiles based on the current scientific literature.

Figure 3-3 illustrates the toxicity assessment process.

3.4       Risk Characterization
                          •
The final component of the endangerment assessment process, risk characteri-
zation, is the process of estimating the incidence of an adverse health or
environmental effect under the various conditions of exposure defined in the
exposure assessment.  This objective is attained by integrating all of the
information developed during the exposure and toxicity assessments to yield a
complete characterization of potential or actual risk.  The risk characteriza-
tion should address all types of potential or actual risks at the site
including:

     1.   Carcinogenic risks
     2.   Noncarcinogenic risks
     3.   Environmental risks
     4.   Risks to public welfare

The final assessment should include a summary of the risks associated with a
site and such factors as the weight-of-evidence associated with each step of
the process, the estimated uncertainty of the component parts,  the distrib-
ution of risk across various sectors of the population, the assumptions
contained within the estimates, etc.

For carcinogens where risk estimation data are available  (e.g., carcinogenic
potency values), crude estimates of the excess cancer risk at a site can be
obtained by multiplying the carcinogenic potency value by the current and
projected chronic exposure levels.  The estimated excess  cancer risks are then
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                                                                    £ife Systems, Jnc.
  Route of Administration
  (Inhalation, dermal, etc.)
 Dose
 (Acute, subchronic, chronic)
   Types of Effects
   (Local, systemic, etc.)
   Reliability of Data
   (Clinical studies versus
   animal studies, etc.)
Mixture Effects
(Synergism, antagonism, etc.)
     Toxicity
   Assessment
1.  Toxicological
   Evaluation
2.  Dose-Response
   Assessment
            FIGURE 3-3   THE  TOXICITY ASSESSMENT PROCESS
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                                                                  £ife Systems, Jnc.
compared to acceptable risk levels defined in regulatory legislation and
guidelines.

For noncarcinogenic effects, projected exposure levels are compared to "accep-
table levels" (e.g., ADI values or established criteria and standards)
identified during the toxicity assessment.  Any time there is an actual or
projected exposure level which exceeds an "acceptable level" for that contam-
inant and exposure route, the risk at the site is considered unacceptable.
The risk characterization should evaluate the risks associated with each
projected exposure route for each contaminant of concern at a site.

Characterization of the environmental risks involves identifying the toxic
effects of exposures to the chemicals of concern to fish or wildlife popu-
lations.  The environmental risk evaluation should also discuss what the
effects of exposure will be on indigenous species, on the food chain .and on
the habitat, since all of these factors affect the environmental quality at a
site.

The risk characterization should also include an evaluation of the potential
or actual risks to public welfare.  Welfare risks may include adverse effects
on property values, future land uses, recreational and commercial activities,
public perception and opinion, quality of life, etc.

Figure 3-4 illustrates the risk characterization process.
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   Toxicity
 Assessment
    Qualitative
  or Quantitative
 Indices of Toxicity
 Exposure
Assessment
Predicted Exposure
 Levels, Doses or
  Environmental
      Levels
                                                                  Risk
                                                             Characterization
                                                          1. Carcinogenic risk
                                                          2. Non-carcinogenic risk
                                                          3. Environmental risk
                                                          4. Risk to public welfare
             FIGURE 3-4  THE  RISK CHARACTERIZATION PROCESS
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4.0       GUIDELINES FOR CONDUCTING ENDANGERMENT ASSESSMENTS

This section provides guidelines for conducting the few components of an
endangerment assessment, beginning with a discussion of the level of detail
required for each type of enforcement action.  Although the steps required for
conducting the exposure and toxicity assessments and risk characterization are
identified, the details of how they are to be performed are not included in
this Handbook.  The "Superfund Public Health Assessment Manual" (ICF 1985),
currently under development as an instruction manual to accompany the RI and
FS guidance documents, will provide details for performing the components of
the endangerment assessment process.

The endangerment assessment process is very similar to the baseline assessments
performed during the RI and FS process.  Although the assessments at Superfund
and enforcement sites are performed for different reasons, the information
requirements for each type of assessment are similar and the assessment methods
used should be consistent.  Therefore, the assessment methodologies detailed
in the RI and FS instruction manuals cited above should be utilized, in
conjunction with this Handbook, when performing endangerment assessments..
Table 4-1 outlines the relationship between the endangerment assessment steps
identified in this Handbook and the appropriate chapters in the RI and FS
instruction manuals.

4.1       Level of.Detail

It is EPA policy that endangerment assessments should be undertaken only to
the extent "necessary and sufficient" to fulfill the requirements of legal
enforcement proceedings.  The endangerment assessment level of detail should
be limited to the amount of information needed to sufficiently demonstrate an
actual or potential imminent and substantial endangerment.

The level of detail required to sufficiently demonstrate endangerment will
vary depending on:

     1.   Type of enforcement action (e.g., AO for removal versus litigation)
     2.   Type of response action (e.g., removal versus remedial action)
     3.   Stage of response action (e.g., RI/FS workplan versus RI/FS
          completed)

The level of detail required to support a particular enforcement action will
ultimately be determined on a case-by-case basis by the litigation team.

The levels of detail required actually represent a continuum from the quali-
tative to the quantitative.  For simplicity's sake, however, three succinct
levels of detail have been defined:  Level 1 (qualitative), Level 2 (semi-
quantitative) and Level 3 (quantitative).

4.1.1     Level 1 ("Qualitative")

Level 1 endangerment assessments are generally prepared to support AOs for
removal actions, a responsible party RI/FS or preliminary scoping activities.
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         TABLE 4-1  RELATIONSHIP BETWEEN THE ENDANGERMENT  ASSESSMENT
                   HANDBOOK AND THE SUPERFUND PUBLIC  HEALTH
                          ASSESSMENT MANUAL (SPHAM)
       Steps Identified in the
   Endangerment Assessment Handbook

1.0  CONTAMINANT IDENTIFICATION

2,.0  EXPOSURE ASSESSMENT

     2.1  Contaminant Release Analysis
     2.2  Environmental Fate Analysis
     2.3  Exposed Population Analysis
     2.4  Calculation of Dose Incurred

3.0  TOXICITY ASSESSMENT

     3.1  Toxicological Evaluation
     3.2  Dose-Response Assessment

4.0  RISK CHARACTERIZATION

     4.1  Noncarcinogenic Risks
     4.2  Carcinogenic Risks
     4.3  Environmental Risks
     4.4  Public Welfare Risks
    Chapters in the
in which the Steps are  Discussed
              5
              5
              5
              6
              7
              7
              8
              8
(a) SPHAM = Superfund Public Health Assessment Manual (ICF 1985)
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Level  1 endangerment assessments are also applicable for those cases when time
becomes a factor in the enforcement action.  An example of a situation in
which  a "quick and dirty" assessment may be necessary is a case where the
responsible party is going to declare bankruptcy and EPA must file an enforce-
ment action very quickly in order to assure the financial liability of the
responsible party.

Basically, the information to satisfy the requirements for a Level 1 endangerment
assessment can be covered by the Action Memorandum developed by the regions to
support emergency removal actions.  It is based entirely on existing data
which  may include the Hazard Ranking System evaluation, preliminary site
assessment and site inspection report (if available).  The "Findings of Fact"
in an  AO for remedial actions may serve as a Level 1 endangerment assessment
and vice versa.

A Level 1 endangerment assessment must characterize the physical description
of the site and identify contaminants detected or suspected to be at the site.
A brief discussion of the toxic properties of the contaminants present should
be sufficient to justify EPA's contention that imminent and significant risk
of harm to human life or health or the environment may exist or exists.

4". 1. 2     Level 2 ("Semi-Quantitative")

A Level 2 endangerment assessment may be developed to support an AO or consent
decree for responsible party cleanup.  It will be based on existing information
on the site, including the Hazard Ranking System evaluation, preliminary site
assessment and site inspection reports.  Additional information that may be
available include the RI/FS workplan and preliminary health effects and
exposure studies.

A Level 2 endangerment assessment must completely characterize, the site
contamination and provide preliminary exposure and toxicity assessments.  The
toxicity assessment will generally rely on existing standards and guidelines
for the contaminants of concern at the site.  The risk characterization will
be "semi-quantitative" in nature and should identify any data gaps and recommend
additional studies, if necessary.

4.1.3     Level 3 ("Quantitative")

A Level 3 endangerment assessment is required for sites targeted for litigation
after  completion of the RI/FS and will be used to support any subsequent AOs
or judicial actions seeking design and construction remedies.

It will be based on all existing data gathered during the RI/FS.  For sites
with enforcement potential, EPA regions should review the RI/FS workplan to
ensure that information developed as part of the RI/FS will be sufficient to
perform a-quantitative endangerment assessment.

A Level 3 endangerment assessment must provide a. detailed characterization of
the site and, when possible, quantitative exposure and toxicity assessments
for the contaminants present.  The Level 3 endangerment assessment differs
                                      4-3

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                                                                  JCifc Systems, Jnc.
from the Level 2 in that actual exposure levels should be developed, using
state-of-the-art modeling techniques.  Likewise, in the absence of existing
standards and guidelines for the contaminants of concern, the Level 3 en-
dangerment assessment should generate quantitative indices of toxicity (e.g.,
"acceptable levels," unit cancer risk estimates, etc.) for use in the charac-
terization of risks at the site.  The risk characterization will be a
quantitative evaluation of the risk assessment values for each probable
exposure scenario.

A Level 3 endangerment assessment may be performed concurrently with the FS
evaluation of the no-action alternative.  The FS may provide input to the
endangerment assessment although the purposes and objectives of the two
documents are different.  In some cases, a quantitative assessment will still
not be possible at the RI/FS stage due to data limitations.

Table 4-2 presents a summary of guidelines for determination of the levels of
detail required for each type of enforcement action.  The guidelines are
flexible and may shift on a case-by-case basis as required to support a
particular enforcement action.  The matrix should help determine what consti-
tutes an adequate endangerment assessment for a particular enforcement action.
Table 4-3 summarizes the site-specific documentation that may be available to
prepare the endangerment assessment document for each level of detail.

4.2       Contaminant Identification Guidelines

The first component of the endangerment assessment process is the identifi-
cation of contaminants of concern.. The objective of this component is to
narrow the field of contaminants at the site to those that either pose the
greatest potential of release or the greatest toxic threats.

Identification of contaminants of concern is an informal screening process
performed with the input of all members of the endangerment assessment team.
The best professional judgment of the endangerment assessment team results in
selection of contaminants of concern which represent a range of the physio-
chemical and toxicological properties of the contaminants at the site.

This screening process corresponds to the "Selection of Indicator Chemicals"
process described in the Superfund Public Health Assessment Manual  (SPHAM)
(ICF 1985).  The Superfund process for selecting indicator chemicals is a
four-step process which evaluates the environmental concentrations and toxi-
cological properties of the contaminants.  The steps of this process are:

     1.   Identify contaminants present at the site.
     2.   Record environmental concentrations from site sampling data.
     3.   Calculate indicator scores for all chemicals (based on concentration
          and toxicity).
     4.   Select indicator chemicals (based on indicator scores).

If indicator chemicals have been selected at a site  (i.e., site was a Super-
fund site prior to the initiation of enforcement actions), they should be used
as the contaminants of concern for the endangerment assessment.  If indicator
                                       4-4

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                        TABLE 4-2  GUIDELINES FOR LEVEL OF DETAIL IN ENDANGERMENT ASSESSMENTS
                                                                                             (a)
      Level of
       Detail

      Level 1
 Enforcement
 *   Action	

AQ for removal
action, AO for
PRP RI/FS, pre-
liminary
scoping.
        Data Base
-P-
i
Ln
      Level 2
Issuance of AO
or consent
decree for
responsible
party cleanup.
May be limited, probably
consisting of information
from the Preliminary Site
Assessment, Site Inspec-
tion Report, and Hazard
Ranking System evalua-
tion, if completed.  No
health studies available;
no demographic studies
available. Preliminary
sampling data will
probably be available on
pollutants present.  Data
on extent of release or
concentrations of
materials at the point of
exposure may be
available.

Remedial Investigation
complete or other quan-
titative data available
on nature/extent of
release.  Data available
on magnitude and demo-
graphics of population at
risk.  Possibly some
preliminary health
effects studies.  Sources
and specific materials
associated with release
are identified.
   Type of Assessment

Qualitative assessment of
exposure routes, popula-
tion at risk and
probability
of harm.  Critical.
pollutants and their
toxicological properties
can be readily identified
and quantity of pollu-
tants estimated.
Reasonable and prudent to
conclude that an exposure
may exist because of the
release.
        Remarks
Semi-quantitative apprais-
al considering specific
exposure routes and
critical pollutants.  The
assessment should
identify any data gaps
and recommend additional
studies, if necessary.
For removal actions where
the normal site ranking
process has not been
completed or undertaken,
information for the
assessment may be
available from record
searches, State-sponsored
investigations, written
reports from inspections
by Government authorities
and notification in
accordance with CERCLA
Section 103.
This assessment must be
able to support legal
action in the event it is
challenged by a recalci-
trant responsible party.
Should be conclusive
enough that responsible
parties will be encour-
aged to make a firm
commitment to complete
remedial action.
                                                                                         continued-
      (a) The guidelines are flexible and may shift on a case-by-case basis as required to support a particular
          enforcement action.

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Table 4-2 -.continued
Level of
 Detail

Level 3
 Enforcement
    Action

Litigation
(site-by-site
basis).
        Data Base
RI and FS complete. All
required geological and
hydrogeological studies
complete.  Health studies
may be available.
   Type of Assessment	

Detailed, quantitative
review to identify
potential health effects,
critical exposure levels
and necessary follow-up
health studies.  Critical
pollutants and exposure
routes identified and
existing exposure levels
defined or estimated.
Constitutes an appraisal
based on the best
expertise and knowledge
and an estimate of the
uncertainty.
        Remarks
This assessment must be
able to support legal
action in the event it is
challenged by a recalci-
trant responsible party.
Should be conclusive
enough that responsible
parties will be encour-
aged to make a firm
commitment to complete
remedial action.

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                                                                  £ife Systems, Jnc.
           TABLE 4-3  SITE-SPECIFIC DOCUMENTATION AVAILABLE FOR THE
                    PREPARATION OF ENDANGERMENT ASSESSMENTS
                                    Availability for Levels of Detail
Site-Specific Documentation

Preliminary Site Assessment

Site Inspection Report

Hazard Ranking System
Evaluation

Remedial Investigation/
Feasibility Study

Epidemiological Studies

Demographic Studies

Sampling Studies

Exposure Studies	

Health Effects Studies

Geological Studies

Hydrogeological Studies
Qualitative
 (Level 1)

 Probable

 Probable

 Probable


 No
   Semi-
Quantitative
 (Level 2)

  Yes

  Yes

  Yes


  Possible
Quantitative
 (Level 3)

  Yes-

  Yes

  Yes


  Yes
No
No
Possible
Possible
No
Possible
Possible
Possible
Possible
Probable
Probable
Possible
Probable
Probable
Possible
Yes
Yes
--.- Yes
Possible
Yes
Yes
                                      4-7

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                                                                  £ife Systems, Jnc.
chemicals have not been selected, the endangerment assessment team will select
the contaminants of concern, possibly based on the methodology discussed in
Chapter 4 of the SPHAM (ICP 1985).

4.3       Exposure Assessment Guidelines

This section of the Handbook is intended to serve as a guide for individuals
responsible for conducting exposure assessments.  It identifies and describes
the necessary steps in an exposure assessment and provides general information
for performing each of the required steps.  This section is not intended to
serve as a definitive guide on how to perform specific exposure assessment
procedures.  For this type of information, the reader is referred to the
SPHAM (IGF 1985).  Additional guidance documents for performing exposure
assessments include Callahan et al. (1983), McNeils et al. (1984), Schultz et
al. (1984) and USEPA (1984).

The exposure assessment should evaluate all existing exposure routes and those
which may reasonably be anticipated to exist in the future.  For example, if
land use development documents indicate that a site located in a currently
rural or industrial area is scheduled for residential development, then the
exposure assessment should develop exposure scenarios evaluating the current
risk, as well as the risks associated with predicted residential use patterns.

The exposure scenarios developed will depend on site-specific technical and
legal considerations.  Generally, an exposure assessment for an endangerment
assessment should present the "worst probable case" exposure scenarios.  The
exposure assessment at a site prior to any removal~or remedial actions may be
significantly different from an exposure assessment at the same site following
completion of the RI/FS (i.e., a removal action at the site may have altered
the exposure routes).  Thus, the exposure assessment should always consider
the type of enforcement action the endangerment assessment is intended to
support.  The best professional judgment of the experts on the endangerment
assessment team will be the basis for establishing whicli exposure scenarios
should be developed for each site.

The objectives of an exposure assessment are to identify actual or potential
routes of exposure, characterize the populations exposed and determine the
extent of the exposure.  These objectives may be attained by performing the
following four steps:

     1.   Analyze contaminant release
     2.   Analyze environmental fate and transport
     3.   Analyze exposed populations
     4.   Estimate or calculate expected exposure levels  (or doses incurred)

This section presents information on conducting each of these analyses.
Table 4-4 identifies the individual steps required to 'complete an exposure
assessment, the endangerment assessment level of detail to which they apply
and the locations in this Handbook where they are discussed.
                                       4-8

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                                                                  £ife Systems, Jnc.
                     TABLE 4-4  EXPOSURE ASSESSMENT STEPS
          Exposure Assessment Step
1.0  Contaminant Release Analysis

     1.1  Identify Information Required
     1.2  Evaluate Contaminant Release to
          Environmental Media
     1.3  Quantify Contaminant Release to
          Environmental Media

2.0  Environmental Fate and Transport
     Analysis

     2.1  Identify Potential Points of
          Environmental Contamination
     2.2  Evaluate Environmental Fate and
          Transport Processes
     2.3  Quantify Environmental Fate and
          Transport Processes

3.0  Exposed Population Analysis

     3.1  Identify Exposed Populations
     3.2  Characterize Populations
     3.3  Analyze Population Activity
     3.4  Identify/Develop Exposure
          Coefficients

4.0  Calculation of Dose Incurred

     4.1  Determine Population Exposure
          Level
     4.2  Estimate Dose Incurred
Level of .
 Detailta)
1   2   3
X

X
X
X
        X
        X
    X

    X
X
    X

    X

    X
X
X





X
X
X

X
X
X
X
X
X
X
X
X
X
                                                                Applicable
                                                             Handbook Sections
                 4.0
          4.3.1
              4.3.2
          4.3.3
              4.3.4
                      5.0
                          5.1
                      5.2
                          5.3
                      5.3
(a) X indicates the level of endangennent assessment (e.g., Level 1, 2 or 3)
    for which this step must be performed.
                                       4-9

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                                                                  &fe Systems, Jnc.
4.3.1     Contaminant Release Analysis

The contaminant release analysis involves the identification of each on-site
source of release for the contaminants of concern.  The results of this
analysis provide the basis for the next step in the exposure assessment
process, environmental fate analysis.

In order to evaluate the probability and extent of contaminant releases from a
hazardous waste site, the following information is required:

     1.   Identity of contaminants at the site
     2.   Physical/chemical properties of the contaminants
     3.   Climatological site parameters
     4.   Hydrogeological site parameters
     5.   Location and manner of waste placement

Each potential source of contaminants must be identified and evaluated to
determine its likely contribution to overall contaminant release.  The nature
of the contaminants involved and the probable magnitude of release are also
evaluated.

Contaminant release analysis for Level 1 endangerment assessments consists of
identifying and characterizing the information identified above.  A qualitative
description of the sources of contaminants and the relative importance of each
source is sufficient for a Level 1 endangerment assessment.
Quantitative analyses of'contaminant releases from hazardous waste sites (for
Level 2 and 3 endangerment assessments) are initiated by an evaluation of the
available data to determine their accuracy and completeness.  Following this
initial evaluation, each source of contaminant release is analyzed and total
releases (i.e., mass loadings) to each environmental medium (e.g., atmosphere,
surface water, soil, ground water) are evaluated and quantified.  Potential
sources of contaminant release to each medium are outlined below:

     1.   Atmospheric Contamination - Emissions of contaminated fugitive dusts
          (airborne wastes and contaminated soil particles) and volatilization
          of contaminants are the most likely sources of atmospheric contamination

     2.   Surface-Water Contamination - Contaminated runoff and overland flow
          of contaminants (from leaks, spills, etc.) are the most likely
          sources of surface water contamination.

     3.   Ground-Water Contamination - The leaching of toxic contaminants from
          contaminated soils or vertical migration of toxics from lagoons and
          ponds are the most likely sources of ground-water contamination.

     4.   Soil Contamination - Sources of surface soil contamination include
          intentional placement of waste on or in the ground, or as a result
          of spills, lagoon failure or contaminated runoff.  Toxic contami-
          nants can also be leached from surface soils to subsurface layers.
                                     4-10

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                                                                  £ife Systems, Jnc.
Schultz et al. (1984) discusses the methods available to evaluate and quantify
each of these factors (e.g., atmospheric, surface-water, ground-water and soil
contamination).

Level 2 endangerment assessments should report the results of any monitoring
studies available for each of these factors.  If there are insufficient
monitoring data available to quantify contaminant releases to these media, the
Level 2 endangerment assessment should present a discussion of the site
characteristics which affect the probability or likelihood of contamination of
each media occurring at the site.

Level 3 endangerment assessments may utilize computer modeling techniques to
arrive at estimates of the average and'maximum contaminant release to each
media.  These quantitative estimates are required for the subsequent calculations
of actual and projected exposure levels at the site.

An overview of the contaminant release analysis process is shown in Figure 4-1.

4.3.2     Environmental Fate and Transport Analysis

The purpose of the environmental fate and transport analysis is to determine
the potential for off-site migration of contaminants from on-site sources
identified during the qualitative release analysis.  The analysis of environ-
mental fate and transport results in identification of probable points of '
contamination associated with a hazardous waste site.  The results of this
analysis provide the basis for the next step in the exposure assessment
process, the exposed population analysis.

A qualitative environmental fate and transport analysis (i.e., Level 1 endanger-
ment assessment) is based on information on the physical/chemical properties
of the contaminants, the manner of their placement at the site and relevant
climatological and hydrogeological site parameters.  This information was
identified during the contaminant release analysis.  Intermedia transport
processes (e.g., adsorption, volatilization, infiltration, bioaccumulation)
and intramedia transformation processes (e.g., photolysis, hydrolysis, oxidation
and biodegradation) which potentially affect migration of the contaminants of
concern are identified and characterized in the Level 1 endangerment assessment.
This information is used to identify potential points of environmental contami-
nation.  An overview of the environmental fate and transport analysis for
Level 1 endangerment assessments is shown in Figure 4-2.

Level 2 and 3 endangerment assessments require a more quantitative environmental
fate and transport analysis to generate estimates of the direction of movement
of contaminants and the ambient concentrations of contaminants in various
environmental media.  The average release rate estimates derived during the
contaminant release analyses are used as input.
                                                                  **
In general, the environmental fate and transport analysis for Level 2 endanger-
ment assessments evaluates the transport pathways within each medium but does
not take into consideration transfer and transformation processes.  The Level
2 endangerment assessment should report any ambient monitoring data and
                                     4-11

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Identify Information
 Required (Level 1)
Evaluate Releases to
   Environmental
   Media (Level 2)
Quantify Releases to
   Environmental
   Media (Level 3)
Contaminant
Identity

Physical/
Chemical
Properties Data

Hydrogeological/
Climatological
Parameters

Waste
Placement
Data
«












Atmospheric ;
Evaluation

Surface Water
Evaluation

Ground Water
Contamination
Evaluation

Soil
Evaluation





Quantify Average
and Maximum Releases
to Atmosphere

Quantify Average
finri Maximum Rplpa^p^
to Surface Water

Quantify Average
and Maximum Releases
to Ground Water

Quantify Average
and Maximum Releases
to Soil






Environmental
Fate and
Transport
Analysis

                      FIGURE 4-1   OVERVIEW OF CONTAMINANT  RELEASE  ANALYSIS

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                                                                      £ife Systems, Jnc.
                              Contaminant Release
                                    Analysis
         Intermedia Transport
             Processes
       (Adsorption, volatilization,
     infiltration, bioaccumulation)
Intramedia Transformation
	Processes	
 (Photolysis, hydrolysis,
oxidation, biodegradation)
                                 Identification of
                                    Points of
                                 Environmental
                                 Contamination
FIGURE 4-2   OVERVIEW OF ENVIRONMENTAL FATE AND TRANSPORT  ANALYSIS FOR
                     LEVEL 1  ENDANGERMENT ASSESSMENTS
                                     4-13

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                                                                  £ife Systems, Jnc.
provide conservative estimates of final ambient concentrations and the extent
of hazardous substance migration.

Level 3 endangerment assessments require more in-depth assessments of environ-
mental fate and transport.  Modeling procedures usually must be applied to
quantify atmospheric fate, surface-water fate, ground-water fate and biotic
pathways.  One relevant set of models for this purpose is the Graphic Exposure
Modeling System (GEMS) (USEPA 1982).  GEMS provides access to models capable
of assessing the fate of contaminants in air, surface water, ground water and
soil.  Table 4-5 identifies the current components of GEMS.  Schultz et al.
(1984) discuss further the available methods for quantitative environmental
fate and transport analyses.

An overview of the environmental fate and transport analysis process for Level
2 and 3 endangerment assessments is shown in Figure 4-3.

4.3.3     Exposed Population Analysis

The exposed population analysis provides an evaluation of the expected degree
of human population contact with contaminants emanating from the site.  The
results of this analysis are used in estimating or calculating exposure levels
and doses incurred by the exposed populations.

The exposed population analysis involves the following four steps:

     1.   Identification of exposed populations
     2.   Characterization of population
     3.   Analyses of population activities
     4.   Development of exposure coefficients

The first step requires comparing data on environmental contamination with
population data in order to identify and enumerate those populations  (human
and environmental) that will potentially or actually be exposed to the contami-
nant (s) of concern.  The second step, population characterization, involves
identifying those groups (e.g., infants, elderly, women of child-bearing age,
endangered or sensitive wildlife species) within the exposed populations which
may experience a greater risk than the average population as a result of a
given exposure level.  The third step, activity analysis, involves an examina-
tion of the activities (e.g., employment, recreation) of potentially or
actually exposed populations in order to define the extent or level of expo-
su're of the previously identified and characterized populations.

The final step of the exposed population analysis is the identification of
exposure coefficients.  The exposure coefficient combines information on the
frequency and magnitude of contact with contaminants to yield a quantitative
value of the amount of contaminated medium contacted per day.  Exposure
coefficients are developed for each exposure route and are used as input in
calculating the dose incurred.  An example of an exposure coefficient would be
the .average daily intake of drinking water or pounds of fish consumed in a
week, etc.  Schultz et al.  (1984) provide lists of exposure coefficients that
may be required for exposure assessments at hazardous waste sites.
                                      4-14

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                                                                  £ife Systems, JHC.
   TABLE 4-5  COMPONENTS OF EPA's GRAPHICAL EXPOSURE MODELING SYSTEM (GEMS)
Models
ATM/SECPOP:
PTMAX:
PTDIS:
BOXMOD:
EXAMS:
SESOIL:
ENPART:
                       Atmospheric transport model (ATM)  and a population
                       distribution retrieval program (SECPOP).

                       Produces analysis of maximum atmospheric concentration
                       as a function of wind speed and atmospheric stability.

                       Calculates downwind atmospheric concentration at ground
                       level at various downwind distances.

                       Interactive simple atmospheric box model for screening
                       chemicals.

                       Evaluates behavior of synthetic organic chemicals in
                       aquatic ecosystems.

                       Long-term environmental fate simulation model for
                       water, sediment and pollutant transport/transformation.
                       Environmental partitioning model.

Physiochemical Property Estimation Programs

SFILES:                Molecular structure diagrams.

CLOGP:                 Estimates octanol-water partition coefficient (log P)

CHEMEST:               Estimates physiochemical properties of organics.

Data Files

GEOECOLOGY DATA BASE:  County-level data on a variety of environmental
                       parameters.
IFD/GAGE:
                       Point source discharges and stream gaging stations.
MASTER AREA REFERENCE  U.S. Census data for small geographic areas.
FILE 1980 CENSUS:

METEOROLOGICAL DATA:   Stability Tubular Array (STAR) data for >300
                       first-order weather stations.
ZIP CODE FILE:
CANONICAL ENVIRON-
MENTS DATA:
                       Associates zip codes with Federal Information Processing
                       System (FIPS) codes.

                       Model input parameters for major U.S. river systems,
                       lakes and reservoirs.
                                     4-15

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 Average Atmospheric
    Release Data
Average Surface Water
    Release Data
Average Ground Water
    Release Data
 Average Soil Release
       Data
 Atmospheric
     Fate
   Analysis
Surface Water
    Fate
   Analysis
Ground Water/
  Soil Fate
  Analysis
    Biotic
   Pathways
   Analysis
  Quantify Average and
 Maximum Atmospheric
    Concentration
 Quantify Average and
   Maximum Surface
 Water Concentration
 Quantify Average and
Maximum Ground Water/
  Soil Concentration
    Quantify Biotic
    Concentrations
    of Contaminants
                                                                                                         Exposed
                                                                                                        Population
                                                                                                         Analysis
             FIGURE 4-3  OVERVIEW OF ENVIRONMENTAL FATE AND TRANSPORT  ANALYSIS  FOR
                           LEVEL  2 AND 3 ENDANGERMENT ASSESSMENTS
                                                                                          ft

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                                                                  jCifc Systems, Jnc.
Level 1 endangerment assessments should identify the exposed populations and
provide a brief characterization of the population.  This is a descriptive
analysis which should not require quantitative census or survey data.  Level 2
and 3 endangerment assessments will utilize available census and survey data
to provide quantitative assessments of the exposed populations.

An overview of the exposed population analysis process is shown in Figure 4-4.

4.3.4     Calculation of Exposure Level and Dose Incurred

Schaum (1984) presents a discussion of the specific exposure assessment
methods that should be used in estimating the dose incurred.  The following
discussion outlines the general steps that are required in performing this
ultimate step in an exposure assessment.

The term "exposure" may be defined as the amount of a contaminant that contacts
the boundaries of an organism (e.g., skin, lungs, or gastrointestinal tract),
while "dose" may be defined as the amount of that contaminant absorbed by the
organism.  The fourth and final step in conducting an exposure assessment
requires a quantitative determination of the dose of contaminants incurred by
receptor populations.  Accomplishing this task involves integrating the
results obtained during the first three steps of the exposure assessment
(Contaminant Release Analysis, Environmental Fate Analysis and Exposed Population
Analysis) to determine the cumulative dose of each contaminant incurred by
each population segment.

In calculating the dose incurred, an exposure coefficient is multiplied by the
chemical-specific environmental concentration values derived during the Contami-
nant Release Analysis.  This calculation provides a route-specific estimate of
the total amount of each contaminant to which the population is exposed on a
daily basis.  Summing the exposures for each exposure route yields a total
daily exposure level for each contaminant.

This exposure value must be adjusted to account for the extent to which each
chemical is transferred across the membranes of the exposed organism (i.e., the
extent of absorption).  This adjustment is accomplished by multiplying total
daily exposure values by an absorption factor.  Absorption factors are generally
available in the toxicity profiles discussed in Section 4.4 of this Handbook.
When empirically derived absorption factors are not available, an absorption
factor of unity is applied, thereby generating a conservative, worst-case
estimate of the dose incurred.  Finally, this whole-body dose estimate (mg/day)
is converted to terms of mg of contaminant/kg of body mass/day by dividing it
by the body mass representative of the receptor population.  EPA's Exposure
Assessment Group has prepared a report which contains ranges of standard
factors (i.e., body mass, surface area, etc.) for use in performing exposure
assessments.  Use of these standard factors promotes consistency among all
exposure assessment activities (Anderson et al. 1984).

Since the risk characterization portion of a quantitative (Level 3) endangerment
assessment requires the development of average daily dose and maximum daily
dose estimates, two calculations of dose incurred must be performed.  Estimates
                                     4-17

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Data on Environmental
  Concentrations of
    Contaminants
 I
I—'
oo
      Available
     Population
       Data
                                 Identification/
                                 Enumeration of
                                   Exposed
                                  Populations
Population
Characteri-
  zation
                                                                                           Activity
                                                                                          Analysis
  Exposure
 Coefficient
Development
Calculation
 of Dose
 Incurred
                                  FIGURE  4-4   OVERVIEW OF EXPOSED POPULATION ANALYSIS
                                                                                                                                           f

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                                                                  £ife Systems, Jnc.
of average daily dose are calculated by multiplying the exposure coefficients
derived during the exposed populations analysis by the average environmental
concentration values.  Estimates of maximum daily dose are calculated by
multiplying the exposure coefficients by the maximum environmental concentration
values.

Level 1 endangerment assessments are qualitative assessments which do not
require a calculation of estimated exposure levels or doses incurred.  Level 2
and 3 endangerment assessments require an integrated exposure assessment which
quantifies exposure via all routes of exposure (inhalation, ingestion and
dermal) and all exposure pathways (e.g., surface water, atmosphere, ground
water, etc.).  The uncertainty associated with the exposure values is a
fuaction of the input parameters throughout the exposure assessment process.
Level 2 and 3 exposure assessments must characterize the uncertainty associ-
ated with the final exposure and dose calculations.  Whitmore (1984) provides
a methodology for characterizing the uncertainty in exposure assessments.  All
exposure calculations for the endangerment assessment must be adequately
documented.  Assumptions made in support of these calculations require justi-
fication in writing as part of the endangerment assessment.

An overview of the process for calculating the dose incurred is shown in
Figure 4-5.

4.3.5     Exposure Assessment References

Anderson E, Browne N, Duletsky~S et al.  GCA Corporation.  1984.  Development
of statistical distributions or ranges of standard factors used in exposure
assessment.  Revised Draft Final Report.  Washington, DC:  U.S. Environmental
Protection Agency, Office of Health and Environmental Assessment, Exposure
Assessment Group.  Contract No. 68-02-3510.

Callahan MA, Johnson RH, McGinnity JL et al. 1983.  Handbook for performing
exposure assessments.  Draft.  Washington, DC:  U.S. Environmental Protection
Agency, Office of Health and Environmental Assessment.

ICF Incorporated.  1985.  Superfund public health assessment manual.  Draft.
Washington, DC:  U.S. Environmental Protection Agency, Office of Emergency and
Remedial Response.  Contract No. 68-01-6872.

McNeils DN, Earth DC, Khare M et al.  Environmental Research Center, Univer-
sity of Nevada at Las Vegas.  1984.  Exposure assessment methodologies for
hazardous waste sites.  Las Vegas, NV:  Office-of Research and Development.
Environmental Monitoring Systems Laboratory.  CR810550-01.

Schaum J.  1984.  Short course on integration of exposure and risk assessment.
Part 3.  Exposure assessment methods.  Paper presented at the Annual Meeting
of the Society for Environmental Toxicology and Chemistry, Arlington, VA.
                                     4-19

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                                                              £ife Systems, Jnc.
Exposure Coefficient
Environmental Concentration
     of Contaminant
                Population Exposure
                      Level
                    Absorption Factor
                                  Estimate of Dose
                                     Incurred
  FIGURE 4-5   OVERVIEW OF PROCESS FOR CALCULATING POPULATION
                EXPOSURE LEVELS  AND DOSE INCURRED
                               4-20

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                                                                  £tfe Systems, Jnc.
 Schultz HL,  Palmer WA,  Dixon GH et  al.   Versar Inc.   1984.   Superfund  exposure
 assessment manual.  Final Draft.  Washington,  DC:   U.S.  Environmental  Protec-
 tion Agency,  Office of  Toxic Substances,  Office of  Solid Waste  and  Emergency
 Response.  Contract Nos.  68-01-6271 and 68-03-3149.

 USEPA.   1984.   U.S. Environmental Protection Agency.   Office of Health and
 Environmental Assessment.  Proposed guidelines for  exposure  assessment.   Fed.
 Regist., Nov.  23,  1984,  49 46314.

 USEPA.   1982.   U.S. Environmental Protection Agency.   Office of Pesticides  and
 Toxic Substances.   Graphical exposure modeling system (GEMS) user's guide.
 Draft.   Washington, DC:   U.S.  Environmental Protection Agency.

 Whitmore RW.   Research  Triangle Institute.   1984.   Methodology  for  character-
 ization of uncertainty  in exposure  assessments. Washington, DC:  U.S.  Environ-
 mental  Protection  Agency, Office  of Health  and Environmental Assessment,
 Exposure Assessment Group.  Contract No.  68-01-6826.

 4.4       Toxicity Assessment  Guidelines

 This section  of the Handbook is intended  to serve as  a guide for individuals
 responsible  for conducting toxicity assessments.  It  identifies and describes
 the necessary steps required in a toxicity  assessment and provides  general
 information  on performing each of the required steps.  The toxicity assessment
 process is discus'sed briefly in the SPHAM (ICF 1985) .  A more detailed
"diseuyylun of the—components of- the toxicity assessment  process is  provided in
 "Toxicology  Handbook:   Principles Related to Hazardous Waste Site
 Investigations" (ICAIR  1985)  which  is currently being prepared  under the
 direction  of  the Health Sciences  Section, OWPE.

 The objectives of  the toxicity assessment are  to determine the  nature  and
 extent  of  health and environmental  hazards  associated with exposure to con-
 taminants  present  at the  site.  The end-product is  a  toxicity profile  for each
 contaminant  of concern.   The toxicity profile  is derived from current
 toxicological literature  on a contaminant.   The profile  includes consider-
 ations  of  doses used, routes of exposure, types of  adverse effects  manifested
 and definitive statements on quantitative indices of  toxicity for the
 contaminant.

 The Office of Emergency and Remedial Response  (OERR)  and OWPE have  prepared
 toxicity profiles  specifically for  use  in assessing  toxicological risk at
 hazardous  waste sites.   The Chemical Profiles  prepared by OWPE  briefly sum-
 marize  .the chemical and physical  properties, fate and transport,  health
 effects and  environmental toxicity  levels for  chemicals  found most  often  at
 hazardous  waste sites.   There  are currently 183 Chemical Profiles available in
 draft form from OWPE.   OERR is preparing  Health Effects  Assessments on the
 most commonly occurring chemicals at hazardous waste  sites.   The Health
 Effects Assessments,  being prepared for OERR by EPA's Environmental Criteria
 and Assessment Office (ECAO),  contain information on  acceptable intake levels
 for sub-chronic and chronic exposure from both ingestion and inhalation
 pathways of  exposure.   There are  currently  58  Health  Effects Assessments
                                      4-21

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                                                                  £ife Systems, Jnc.
available in draft form from OERR.  Table 4-6 lists the chemicals for which
Chemical Profiles and Health Effects Assessments are currently available.

Other EPA offices have also prepared toxicity profiles on numerous chemicals.
The EPA Chemical Activities Status Report (CASK), a guide to EPA activities on
specific chemical substances, provides information on the status of the
activities and a point-of-contact in the appropriate EPA program office
responsible for the preparation of the toxicity profile (USEPA 1984f).  The
types of toxicity profiles included in CASR are listed in Table 4-7.  For
information on the availability of specific toxicity profiles, contact the
program office identified in Table 4-7.

If an acceptable EPA toxicity profile exists for a contaminant at the site in
question, it is unnecessary to re-create one for the Toxicity Assessment.  The
existing profile should be briefly summarized and referenced in the endangerment
assessment document.  However, if the existing profile focuses on a different
exposure route, or is more than three years old, it should be supplemented
with a search of the current literature.

When no toxicity profile is available, or the existing toxicity profile is
inadequate, the toxicologist on the endangerment assessment team must review
the current toxicological literature on the contaminant of concern and prepare
a suitable toxicity profile.  This toxicological review and evaluation process
is known as the toxicity assessment.  It is a two-step process consisting of a  ,
toxicological evaluation and a dose-response assessment.  Table 4-8 summarizes
the steps in the toxicity assessment process and identifies the endangerment
assessment level of detail to which they apply and the locations in this
Handbook where they are discussed.

4.4.1     Toxicological Evaluation

The toxicological evaluation is the first step in the toxicity assessment
process.  It is a qualitative evaluation of the scientific data to determine
the nature and severity of potential health and environmental hazards associated
with exposure to a chemical substance.

The toxicological evaluation involves a critical evaluation and interpretation
of toxicity data from epidemiological, clinical, animal and j.n vitro studies
when human health effects are of concern and of ecotoxicity studies when
environmental effects are of concern.  The toxicological evaluation results in
either a health or environmental toxicity profile (or both) for each contaminant
of concern.  The toxicity profile presents a review of the primary literature
on the types of adverse effects manifested (e.g., chronic, acute, carcinogenic,
etc.), routes of administration (e.g., dermal, oral, inhalation, etc.), dose
employed, the quality and extent of test data, the reliability of the test
data and other factors.

The toxicity profile also identifies any quantitative indices of toxicity
reported in the literature, such as NOEL (no-observed-effect  level), NOAEL
(no-observed-adverse-effect level), LOAEL (lowest-observed-adverse-effect
level), LC   (concentration at which 50 percent of the test organisms die),
                                     4-22

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                                                         £tfe Systems, Jnc.
TABLE 4-6   TOXICITY PROFILES PREPARED SPECIFICALLY FOR USE
                  AT HAZARDOUSE WASTE SITES
            Chemical
     OWPE
Chemical Profile
                                                OERR Health
                                              Effects Assessment
Acenaphthene
Acenaphthylene
Acetic acid
Acetone
Acrolein
Acrylonitrile
Aldrin
Anthracene
Antimony
Arsenic
Asbestos
Barium
Benzene
Benzidine
Benzo (a) anthracene
Benzo(a)pyrene
Benzothiazole
Beryllium
alpha-BHC
beta-BHC
gamma-BHC (lindane)
delta-BHC
Butanol
Butyl 'acetate
Cadir.iuir
Carbon tetrachloride
cls-Chlordane
trans-Chlordane 	 ._.
Chlorine
Chlorobenzene
Chlorobenzilate
Chloroethane
Chloroform
p-Chloro-m-cresol
l-Chloro-3-nitrobenzene
bis ( 2-Chloroethoxy) ethane
•Chromium (total)
Chromium (hexavalent)
Chromium (trivalent)
Chrysene
Coal tars
Cobalt
Copper
Cresol
Cyanides
Cyanuric acid
p,p'-DDD
o,p'-DDD
p.p'-DDE
p,p'-DDT
o.p'-DDT
Dibromochloropropane
1 ,2-Dichlorobenzene
1 ,3-Dichlorobenzene
1 , 4-Dichlorobenzene
1 , 1-Dichloroethane
1 ,2-Dichloroethane
1 , i-Dichloroethylene
1 ,2-cis-Dichloroethylene
1 , 2-trans-Dichloroethylene
2 , 4-Dichlorophenol
2,4-Dichlorophenoxyacetlc acid
1 , 2-Dichloropropane
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X

X
X
X
X
X
X

X
X
X
. X
X
X

X
X
X
X
X
X

X
X

X
X
X
X
X

                                                  continued-
                           4-23

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                                                                            Oft'Systems, Jnc.
Table  4-6 -  continued
                             Chemical
                                                      OWPE
                                                  Chemical Profile
  OERR Health
Effects Assessment
1 ,3-Dlchloropropane
1 ,3-Dichloropropene
Dicofol
Dleldrin
Diethyl benzene
Diethylene glycol
Diethyl phthalate
Dllsobutyl ketone
Dimethylaminoethyl methacrylate
Dimethyl aniline
Dimethylnltroaamine
2,4-Dimethyl pentane
2,4-Dimethylphenol
n-Dloctyl phthalate
1 , 4-Dioxane
Diphenyl ethane
End r in
Ethanol
bis(2-Chloroethyl) ether
Ether
Ethyl acetate
Ethylbenzene
Ethylene glycol
Ethyl hexanedlol
bis-2-Ethylhexyl phthalate
Ethyl toluene
Fluoranthene
Formaldehyde
Glycol ethers
Heptachlor
Heptane
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclohexane
Hexachlorocyclopentadiene
Hexachloroe thane
Hexachlorophene
Hexane
Iron
Isobutyl alcohol
Isopropyl benzene
Isopropyl ether
Lead
Lithium
Magnesium
Manganese
Mercury
Methacrylic acid
Methanol
Methyl chloride
2-Methyl dodecane
Methylene chloride
Methyl ethyl benzene
Methyl ethyl ketone
3-Methyl hexane
Methyl isobutyl ketone
Methyl methacrylate
Methyl parathion
2-Methyl pentane
3-Methyl pentane
2-Methyl- 1-pentene
2-Methyl tetradecane
2-Methyl trldecane
X
X
X.
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
. X
X
x •
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X







X

X
X
X
X
X

X
X
X

X
X



                                                                      continued-
                                          4-24

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                                                                           jjfe Systems, JHC.
Table  4-6 - continued
                                                       OWE          OERR Health
                              Chemical              Chemical Profile  Effects Assessment
Monethanolamine
Naphthalene
Nickel
Nitrocellulose
2-Nltrophenol
Pentachlorophenol
Pentadecane
Phenanthrene
Phenol
Phenyl ether
Phosphoric acid
Phosphorus
Picric acid
Polychlorinated blphenyls (PCBs)
Polychlorinated dibenzo-p-dioxin
Polycyclic aromatic hydrocarbons (PAHs)
Pyrene
Selenium
Silver
Sodium chlorate
Sodium cyanide
Sodium
Stoddard solvent
Sulfuric acid
1 ,2,4,5-Tetrachlorobcnzene
2 , 3 , 7 , 8-Te trachloro-
dihenzo-p-dioxin (TCDD)
1 , J ,2,2-Tetrachloroethane
Tetrachloroethylene .
Tetraethyl lead
Te t rahydro f uran
Tetramethyl benzene
Thallium
Titanium
Toluene
Toxaphene
1 ,?,3-Trichlorobenzene
1 ,2,4-Trichlorobenzene
1 >3,5-Trlchlorobenzene
2,3,6-Trichlorobenzoic acid
1,1,1 -Trlchloroethane
1 ,1,2-Trichloroe thane
Trichloroethylene
Trichlorof luorome thane
2,4, 5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-Trichlorophenoxyacetic acid
2,4,5-Trichlorophenoxy propionic acid
Trlmethylbenzene
1,3, 5-Trimethylbenzene
1 ,2,4-Trimethylbenzene
tris ( 2 , 3-Dibromopropy 1 ) phosphate
Undecane
Vanadium
Vinyl chloride
Xylene
m-Xylene
o-Xylene
p-Xylene
Zinc
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
X
X

X

X
X
X
X
X


X
X
X
                                          4-25

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                                       TABLE 4-7  EPA SOURCES OF TOXICITY PROFILES
            Document
      Criteria Document
      Air
      Criteria Document
      Drinking Water
                                Availability
                         Office of Air Quality
                         Planning and Standards
                         (OAQPS)
                         Office of Drinking Water
                         (ODW)
                                                   Description
i
IsJ
Criteria Document -
Ambient Water Quality
Office of Water Regula-
tions and Standards (OWRS)
      Chemical Hazard
      Information Profile
      (CHIP)

      Chemical Profile
                         Office of Toxic Substances
                         (OTS)
                         Office of Waste Programs'
                         Enforcement (OWPE)
                                                           i
Summary of the latest scientific knowledge on the
effects of varying quantities of a substance in the
air.  Usually prepared for OAQPS by the Office of
Health and Environmental Assessment (OHEA).

Summary of important experimental results from the
literature relevant to the chemistry and health
effects of a specific drinking water contaminant.
Serves as a foundation to support regulatory standards
or guidelines for the acceptable concentration of the
contaminant in the drinking water.

Information on the type and extent of identifiable
toxic effects on health and welfare expected from the
presence of pollutants in any body of water.
Objective of document is to protect most species in a
balanced and healthy aquatic community.  To date, 65
have been completed, covering all priority pollutants.

Summary of readily available information concerning
the health and environmental effects and potential
exposure to a chemical.

Brief summary of the chemical/physical properties,
fate and transport, health effects and environmental
toxicity levels for 202 chemicals identified at
hazardous waste sites.  Currently 183 of the planned
Chemical Profiles are available in draft form.
                                                                                          continued-

-------
      Table 4-7 - continued
            Document
      Health Advisory
       Availability
                     Description
ODW
      Health Assessment
      Document
.P-
i
N>
      Health and Environ-
      mental Effects
      Profile
      Health Effects
      Assessments
Office of Health and
Environmental Assessment
(OHEA)
Office of Solid Waste
(OSW)
Office of Emergency and
Remedial Response (OERR)
Develops toxicological analyses to establish an
acceptable level in drinking water for unregulated
contaminants for various exposure durations.  Used in
transient situations (spills, accidents) therefore,
does not consider chronic exposure data (e.g.,
carcinogenicity).

Inventories the scientific literature and evaluates
key studies. Discusses dose-response relationships so
that the nature of the adverse health response is
evaluated in perspective with observed environmental
levels.  Usually prepared by OHEA for another office.

Profiles are "mini-" criteria documents prepared
usually as summaries of existing water quality
criteria documents.  They serve as a support for the
listing of hazardous wastes in the RCRA program.

Summary of the pertinent health effects information on
58 chemicals found most often at hazardous waste sites,
Developed by the Environmental Criteria and Assessment
Office (ECAO) for OERR.

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           TABLE 4-8  TOXICITY ASSESSMENT STEPS
                                                                 £ife Systems, Jnc.
          Toxicity Assessment Step
1.0  Toxicological Evaluation

     1.1  Prepare Health Toxicity Profile

          a.  Conduct literature search
          b.  Evaluate adequacy of each
              study
          c.  Review studies to obtain
              information on dose, bio-
              logical end points and
              exposure
          d.  Summarize information on
              each contaminant

     1.2  Prepare Environmental Toxicity
          Profile

          a.  Conduct literature search
          b.  Evaluate adequacy of each
              study
          c.  Review studies to obtain~
              information on dose, toxic
              effects and thoroughness
              of study
          d.  Summarize information on
              each contaminant
2.0  Dose-Response Assessment

     2.1  Estimate ADI levels

          a.  Select appropriate quantita-
              tive index of toxicity (e.g.,
              NOEL, NOAEL, LOAEL, etc.)
          b.  Determine uncertainty factor
          c.  Calculate ADI

     2.2  Estimate unit cancer risks

          a.  High-to-low dose extrapolation
          b.  Interspecies extrapolation
                                                Level of.
                                                Detail™
X

X
X
X

X
X

X
X
                 Applicable
              Handbook Sections
                  4.0
4.4.1
4.4.1.1
     4.4.1.2
     X(b) X    4.4.2
          X    4.4.2.1
               4.4.2.2
5.0

5.4
            5.4
                      5.4
                      5.4
                      5.4
(a)  X indicates the level of endangerment assessment (e.g.,  Level 1,  2 or 3)
    for which this step must be performed.
(b)  Generally, a Level 2 endangerment assessment will utilize ADI and unit
    cancer risk values calculated in existing toxicity profiles.   Only a
    Level 3 endangerment assessment will require calculation of new values.
                                     4-28

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                                                                  £ife Systems, JHC.
etc.  It also reports data on mixture effects and discusses the limitations,
if any, of each study that could potentially impact its selection as the basis
for deriving an ADI and unit cancer risk (for humans) or determination of
levels of environmental concern (for aquatic and terrestrial organisms).  In
the development of an endangerment assessment, it may be necessary to use an
interim ADI value (or other index of toxicity) with caveats indicating it may
require updating in the future if the Agency revises the value.

4.4.1.1   Health Toxicity Profile

The first step in preparing a health toxicity profile is to conduct a thorough
search of the current health effects literature on the contaminants of concern
and to identify and acquire candidate studies for the profile.  The next step
is an evaluation of the adequacy of each study for the toxicity assessment.
It is imperative that studies contain sufficient quantitative data to provide
the basis for risk characterization.  Accordingly, the studies should follow
established test protocol criteria for determining biological or toxicological
endpoints.  Parameters to be considered include:  (1) dose levels, (2) duration
and frequency of compound administration, (3) route of compound exposure, (4)
species selection, (5) the number of test animals, etc.  Guidelines for
evaluating test protocol criteria for specific endpoints have been established
by EPA.  These guidelines are summarized in Appendix 4.

The next step in preparing a toxicity profile is to review the studies which
have been determined to be adequate to obtain the following data:  (1) specific
dose levels used, (2) all biological endpoints manifested, (3) route of
exposure or (4) any limitations of the study which may compromise positive or
negative outcomes.  Important data to be considered when reviewing the studies
include the following:

     1.   Dose;  Studies of noncarcinogenic effects should report (a) the dose
          of the test substance at which there are no statistically or bio-
          logically significant increases in the frequency or severity of
          adverse effects between the exposed animals and an appropriate
          control (NOAEL) or (b) the lowest dose of the test substance that
          produces a statistically or biologically significant increase in the
          frequency or severity of adverse effects between the exposed animals
          and an appropriate control (LOAEL).  These values provide the basis
          for deriving the ADI for noncarcinogenic effects.

          Studies' of carcinogenic effects should report the frequency of tumor
          formation as a function of exposure level (dose).  From this dose-
          response data, mathematical models are employed to predict cancer
          frequency rates at very low exposure'levels.

     2.   Biological Endpoints;  Results of a variety of studies report a wide
          range of adverse effects manifested.  These include hepatotoxicity,
          renal toxicity, blood toxicity, neurotoxicity, behavioral toxicity,
          reproductive toxicity, teratogenicity, mutagenicity and carcinogen-
          icity.  Appendix 5 defines these biological endpoints.
                                     4-29

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                                                                  £ife Systems, Jnc.
     3.   Route of Exposure;  The most relevant routes of exposure are oral,
          dermal and inhalation.  Those studies which include the route of
          major concern for human exposure are the most useful.

The final step in the preparation of a toxicity profile is to briefly summarize
the toxicological information on each contaminant of concern at a site.  This
summary should focus on those studies examining the exposure routes of concern
at the site (i.e., oral dose if -contaminants are expected to be found in the
drinking water).

4.4.1.2   Environmental Toxicity Profile

The first step in preparing an environmental toxicity profile is to conduct a
search of the environmental literature on the contaminants of concern and to
identify and acquire candidate toxicity studies on fish and wildlife for the
profile.  The next step is an evaluation of the adequacy of each study for an
environmental toxicity evaluation.  An adequate study includes considerations
of dose levels tested and toxic effects manifested, as well as thoroughness of
reporting environmental parameters  (e.g., temperature, photoperiod, dissolved
oxygen concentration and pH).

The next step is to review the studies which have been determined to be
adequate to obtain the data that should be summarized in the profile.  Important
data to be considered when reviewing the studies include the following:

     1.   Dose;  The studies should report quantitative indices of environmental
          toxicity such as the NOAEL, LOAEL, LC  , etc.  These toxicity values
          may be used in deriving various levels of environmental concern.

     2.   Types of Effects;  Environmental effects include effects of contami-
          nants on growth, reproduction or survival which would either
          temporarily or permanently alter population levels of wild plants
          and animals.  Accordingly, hazardous waste discharges may result in
          fish kills or other deleterious effects such as decreased reproduc-
          tive potential, abnormal  larval growth, systemic pathological
          effects or tumorigenesis.  Environmental effects on birds can be
          manifested in three major forms:  direct mortality/morbidity (via
          bioconcentration in the food chain or volatilization), indirect
          mortality/morbidity (via  elimination of food sources such as phyto-
          plankton) and reproductive effects (such as eggshell thinning).
          Behavioral changes can occur as well (e.g., migratory patterns,
          feeding habits and social population size) .  Other effects include
          bioconcentration in aquatic species all along the food chain (e.g.,
          fat soluble compounds) and aesthetic considerations such as
          impartation of unpleasant taste to water and edible fish/shellfish.

The final step in the preparation of an environmental toxicity profile is to
briefly summarize the toxicological information on each contaminant of concern
at a site.  This summary should focus on those studies examining ecosystems
and/or species which are present at the site.
                                      4-30

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                                                                  £ifc Systems, Jnc.
4.4.2     Dose-Response Assessment

Once the toxicological evaluation determines that a chemical is likely to
cause a particular adverse effect, the next step is to determine the potency
of the chemical.  The second step, then, in the toxicity assessment, the
dose-response assessment, is a quantitative estimation of risk from exposure
to a chemical.  It defines the relationship between the dose of a chemical and
the incidence of the adverse effect.

The objective of the dose-response assessment is to use the quantitative
indices of toxicity (e.g., NOEL, NOAEL, LOAEL, LC5Q, etc.) presented in the
toxicity profiles to determine ADI levels (for noncarcinogens) and unit cancer
risk (for carcinogens) or levels of environmental concern (for aquatic and .
terrestrial organisms).

4.4.2.1   Estimation of Acceptable Daily Intake Levels

The dose-response assessment for noncarcinogenic chemicals produces an estima-
tion of the NOEL, NOAEL or LOAEL and the margin of safety associated under the
prescribed conditions of exposure.  These quantitative indices of toxicity may
be used to derive an exposure level which is considered "acceptable" or which
is not expected to cause adverse effects.  This exposure level may be ex-
pressed in a variety of ways such as the ADI, Ambient Air Standard, Water
Quality Criteria, etc. .The term "acceptable level" will be used in this
Handbook to indicate any such derived criteria, standard or advisory level.

The toxicity profile should identify any quantitative indices of toxicity as
well as any derived "acceptable levels" for noncarcinogens.  A Level 2 endanger-
ment assessment should utilize only available values in characterizing the
risks at a site.  A Level 3 endangerment assessment may require the estimation
of an "acceptable level" for contaminants present at the site.  Following is a
brief discussion of the methodology for deriving an ADI.

A widely accepted procedure for evaluating noncarcinogenic toxic endpoints is
to estimate the ADI.  An ADI is defined as the amount of toxicant, in mg/kg
body weight/day (or in mg/day for a 70-kg person) that is not expected to
result in any adverse effects following chronic exposure to the general human
population.  Adverse effects are considered to be functional impairment or
pathological lesions that may affect the biological integrity of the whole
organism or that reduce an organism's ability to respond to an additional
toxic insult.  It is assumed in an ADI estimation that there are threshold
doses below which no adverse effects will occur.  The ADI is calculated by
dividing the quantitative index of toxicity (e.g., NOEL, NOAEL, LOAEL, etc.)
derived from human or animal toxicity studies, by one or more uncertainty
factors.  The parameters for calculation of the ADI are defined as follows:

     1.   The NOEL (No-Observed-Effect Level) is defined as that dose of a
          chemical at which there are no statistically or biologically signif-
          icant increases in the frequency or severity of effects between the
          exposed population and an appropriate control.
                                     4-31

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                                                                  jCife Systems, Jnc.
     2.   The NOAEL (No-Observed-Adverse-Effect Level) is defined as that dose
          of a chemical at which there are no statistically or biologically
          significant increases in the frequency or severity of adverse effects
          between the exposed population and an appropriate control.  Effects
          are produced at this dose, but they are not considered to be adverse.

     3.   The LOAEL (Lowest-Observed-Adverse-Effect Level) is defined as the
          lowest dose of a chemical in a study or group of studies that
          produces statistically or biologically significant increases in the
          frequency or severity of adverse effects between the exposed popu-
          lation and an appropriate control.

Either the NOEL, NOAEL or the LOAEL may be used in estimating the ADI.  The
formula for calculating the ADI is shown below:

                             = NOEL x Body Weight
                               Uncertainty Factor

If the NOEL is taken to be a safe dose for the species tested, an uncertainty
factor must then be applied to allow for the potentially higher sensitivity of
exposed humans and differences in sensitivity among exposed individuals.
Uncertainty factors are adjustments of the NOEL, NOAEL, or LOAEL reported for
small populations of humans or experimental animals in order to estimate the
comparable NOEL from chronic exposure to a chemical by a large human population
that includes sensitive subgroups.  The size of the uncertainty factor used  .
depends on the severity of the biological effects observed in toxicolpgical
studies.  For example, an uncertainty factor of «iOO might be used for a revers-
ible effect, while an uncertainty factor of 1,000 might be employed if a chemical
causes an irreversible effect such as teratogenicity.

Several considerations that influence the selection of an .uncertainty factor
are the species and strain of the test animals, the quality and sensitivity of
the experimental data, the availability of comparative pharmacokinetic data
and information on the absorption, distribution, biotransformation, binding
and excretion of the test chemical in the animal species and in man.

Table 4-9 summarizes several uncertainty factors currently in use by the EPA
to estimate ADI's for toxicants.

4.4.2.2   Estimation of Unit Cancer Risk

The dose-response assessment for carcinogenic chemicals should provide an
estimation of the probability or range of probabilities that a specific adverse
effect  (i.e., tumor growth) will occur under the prescribed conditions of
exposure.  These estimates of probability are derived using mathematical models
of the dose-response relationship.  One way of expressing this numerical estimate
of risk is as a "unit cancer risk" which is defined as the excess risk due to
a continuous lifetime exposure to one unit of carcinogen concentration.

The toxicity profile should identify any numerical estimates of risk which
have been derived.  Level 2 endangerment assessments should utilize only
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                                                                  £ife Systems, JHC.
           TABLE 4-9  GUIDELINES FOR SELECTION OF UNCERTAINTY FACTORS


	.	Uncertainty Factor ^a> '	.

1.   Use a 10-fold factor when extrapolating from valid experimental results
     from studies on prolonged ingestion by man.  This 10-fold factor protects
     the sensitive members of the human population estimated from data
     garnered on average healthy individuals.

2.   Use a 100-fold factor when extrapolating from valid results of long-term
     feeding studies on experimental animals with results of studies of human
     ingestion not available or scanty (e.g., acute exposure only).  This
     represents an additional 10-fold uncertainty factor in extrapolating data
     from the average animal to the average man.

3.   Use a 1,000-fold factor when extrapolating from less than chronic results
     on experimental animals with no useful long-term or acute human data.
     This represents an additional 10-fold uncertainty factor in extrapolating
     from less-than-chronic to chronic exposures.

4.   Use an additional uncertainty factor of between 1 and 10 depending on the;
     sensitivity of the adverse effect when deriving an ADI from LOAEL.  This '
     uncertainty factor drops the LOAEL into the range of a NOAEL.
(a) In calculating an ADI when no indication of carcinogenicity of a chemical
    exists, these factors are to be applied to the highest valid NOAEL or NOEL
    that does not have a valid LOAEL equal to or below it.  In some cases, an
    additional variable uncertainty factor should be applied.  The EPA has
    recommended that this variable uncertainty factor reflect a scientific
    judgment of the difference between the observed LOAEL and the hypothesized
    NOAEL.  This difference will not necessarily be the same from experiment to
    experiment.  In lieu of specific data, the value of this additional
    uncertainty factor utilized by the EPA ranges from one through ten, based
    on the severity of the adverse effect at the LOAEL.
(b) Uncertainty factors one and two are supported by the FDA and the WHO/FAO;
    uncertainty factors one through three have been established by the NAS
    and are used in a similar form by the FDA; uncertainty factors one through
    four are recommended by the EPA.
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                                                                  £ife Systems, Jnc.
established risk estimates.  Level 3 endangerment assessments may require the
derivation of a quantitative risk estimate for carcinogenic contaminants of
concern at a site.  The following is a brief discussion of the estimation of
unit cancer risk.  For further details on quantitative carcinogenic risk
assessment, the reader is referred to EPA's Proposed Guideline for Carcinogen
Risk Assessment (USEPA 1984).  These Guidelines are attached in their entirety
as Appendix 3, Part 1.

There are three main types of evidence which may be used to determine whether
a substance poses a carcinogenic hazard: (1) epidemiologic data from exposed
human populations, (2) experimental evidence derived from long-term bioassays
of animals and (3) supportive or suggestive evidence derived from studies of
chemical structure or from other short-term tests.  Ideally, this assessment
would be based on epidemiological studies of human populations.  However,
epidemiological studies are often unsatisfactory because it is difficult to
measure individual exposure patterns, it may be impossible to eliminate the
confounding effects of other factors and the time between exposure and occur-
rence of an observable effect may be very long (up to several decades).  Conse-
quently, it is often necessary to rely on tests carried out on laboratory
animals exposed to much higher levels of the toxic agent than humans are
expected to experience.  The results of such tests have to be subjected to two
types of extrapolation:

     1.   The results obtained for laboratory animals at relatively high expo-
          sure levels have to be extrapolated down to predict the effects of
          relatively low exposure on those animals (high-to-low dose extrapo-
          lation) .

     2.   The resulting predicted effects of low-level exposure on laboratory
          animals are then used to predict the effects on human health (inter-
          species extrapolation).

The experimental results are extrapolated from the high, observed doses to
low, expected doses by fitting a mathematical model to the data and using the
model to predict the low-dose response.  The Proposed Guidelines for Carcinogen
Risk Assessment (USEPA 1984b) recommends the use of the linearized multistage
model for high-to-low dose extrapolation unless there is mechanistic, statis-
tical or other biological evidence that indicates the greater suitability of
an alternative extrapolation model or statistical'or biological evidence that
excludes the use of the multistage model.  The point estimate and the 95%
upper confidence limit of excess risk are calculated by using the computer
program GLOBAL 79, developed by Crump and Watson (1979).  This model approxi-
mates the dose-response curve by a straight line with slope determined by the
linear term of the model.  The linearized multistage model estimates a plaus-
ible upper limit to risk and is consistent with some mechanisms of carcino-
genesis.  However, it should be emphasized that such an estimate does not
necessarily represent the actual risk.  USEPA (1984b) provides a discussion of
the application of this model as well as a list of additional references on
quantitative risk assessment.
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                                                                  £ife Systems, JHC.
The results of animal studies, having been extrapolated from high to low dose,
then have to be extrapolated to humans.  Differences in the metabolism of
chemicals between species often creates the greatest problem in obtaining
meaningful extrapolations.  Methods of scaling animal doses to equivalent
human doses have been based on body weight, concentration in the diet and body
surface area.  Additional uncertainty is introduced when the route of
exposures differs from one species to another.

High-to-low dose and interspecies extrapolation involves a series of assumptions.
some of which are impossible to verify, and necessarily involves a high degree
of uncertainty.  Nevertheless, it is important to obtain as realistic an
estimate as possible so that appropriate decisions can be made regarding the
risk of exposure to toxic substances.

4.4.2.3   Interpretation of Unit Cancer Risk
                                                           t
For several reasons, the unit cancer risk estimate based on animal bioassays
is only an approximate indication of the absolute risk in populations exposed
to known carcinogen concentrations.  First, there are important species
differences in uptake, metabolism and organ distribution of carcinogens, as
well as species differences in target site susceptibility, immunological
responses, hormone function, dietary factors and disease.  Second, the concept
of equivalent doses for humans compared to animals on a mg/surface area basis
is virtually without experimental verification regarding carcinogenic response.
Finally, human populations are variable with respect to genetic constitution
and diet, living environment, activity patterns and other cultural factors.

The unit cancer risk estimate can give a rough indication of the relative
potency of a given agent compared with other carcinogens.  The comparative
potency of different agents is more reliable when the comparison is based on
studies in the same test species, strain and sex and by the same route of
exposure, preferably by inhalation.  However, it should be recognized that the
estimation of cancer risks to humans at low levels of exposure is uncertain.
At best, the linear extrapolation model recommended by EPA provides a rough,
but plausible, estimate of the upper-limit of risk (i.e., it is not likely
that the true risk would be much higher than the estimated risk, but it could
very well be considerably lower).

4.4.3     Toxicity Assessment References

ICAIR, Life Systems, Incorporated.  1985.  The hazardous waste site toxicology
handbook.  Draft.  Washington, DC:  U.S. Environmental Protection Agency,
Office of Waste Programs Enforcement.  Contract No. 68-01-7037.

ICF Incorporated.  1985.  Superfund public health assessment manual.  Draft.
Washington, DC:  U.S. Environmental Protection Agency, Office of Emergency and
Remedial Response.  Contract No. 68-01-6872.

ICF Incorporated.  1983a.  Scientific support document:  the scientific basis
for the risk evaluation process.  Draft.  Washington, DC:  U.S. Environmental
Protection Agency, Office of Emergency and Remedial Response.
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                                                                   £ife Systems, Jnc.
 ICF Incorporated.   1983b.   Superfund feasibility  study  guidance,  chapter  4,
 risk evaluation.   Washington,  DC:   U.S.  Environmental Protection  Agency,  Office
 of  Emergency  and  Remedial  Response.

 USEPA.   1985a.  U.S.  Environmental Protection Agency.  Environmental  Criteria
 and Assessment  Office.   Proposed guidelines for the  health risk assessment  ol
 chemical mixtures.  Fed. Regist.,  Jan.  9,  1985, 50 1170.

 USEPA.   1984b.  U.S.  Environmental Protection Agency.  Office  of  Health and
 Environmental Assessment.   Proposed guidelines for carcinogen  risk assessment.
 Fed. Regist., Nov. 23,  1984,  49 46294.

 USEPA.   1984d.  U.S.  Environmental Protection Agency.  Office  of  Health and
 Environmental Assessment.   Proposed guidelines for mutagenicity risk  assessment.
 Fed. Regist., Nov. 23,  1984,  49 46314.

 USEPA.   1984e.  U.S.  Environmental Protection Agency.  Office  of  Health and
 Environmental Assessment.   Proposed guidelines for the  health  assessment  of
 suspect developmental toxicants.  Fed.  Regist., Nov. 23,  1984, 49 46324.

 4.5       Risk  Characterization Guidelines

'The final component of  the endangerment assessment process is  risk characteriza-
 tion.  The objective  of risk characterization is  to estimate the  incidence  of
 an  adverse health or  environmental effect  under the various conditions of
 exposure defined  in the exposure assessment.  It  is performed  by  integrating
 information developed during the exposure  and toxicity  assessments to yield a
 complete characterization  of risk at the site.  Four discrete  steps are required
 to  develop this information:

      1.   Characterize  carcinogenic risks  at the  site
      2.   Characterize  noncarcinogenic risks at the site
      3.   Characterize  environmental risks at the site
      4.   Characterize  public welfare risks at the site

 The final assessment  should include a summary of the risks associated with  a
 site and such factors as the weight-of-evidence associated with each  step of
 the process,  the  estimated uncertainty of  the component parts, the distribution
 of  risk across  various  sectors of the population, the assumptions contained
 within the estimate,  etc.

 Typically, releases from a hazardous waste site result  in exposure to a mixture
 of  chemicals rather than a single compound.  This phenomenon occurs when  a
 series of unrelated compounds, placed in the same area for disposal or  storage,
 eventually come in contact with each other and are released to the environment
 as  a mixture.  The EPA has published "Proposed Guidelines for Health  Risk
 Assessment of Chemical Mixtures" (USEPA 1985a) which provide guidelines  for
 assessing the effects of multiple toxicant or multiple  carcinogen exposure.

 The preferred approach for predicting the  effects of exposure to  mixtures is
 to  use health effects data on the mixture of concern or on a similar  mixture
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                                                                 £ife Systems, Jnc.
(i.e., same components but in slightly different proportions) and adapt the
same assessment procedures as used for single compounds.  Most frequently, the
toxicological properties of the mixtures are poorly characterized.  When
health effects data are not available on an identical or similar mixture, the
risk assessment may be based on the toxic or carcinogenic properties of the
individual components of the mixture.  The use of dose additive models is
recommended by EPA for combining the risk estimates for individual chemicals
in the mixture to estimate the risk for the mixture.

The methodology for risk characterization is based on existing and proposed
guidelines for performing carcinogenic, mutagenic, teratogenic and mixture
risk assessments (USEPA 1984b,d,e=; 1985a).  These guidelines are included in
their entirety as Appendix 3 of this Handbook.  Additional guidance on risk
characterization at hazardous waste sites is contained in the SPHAM (ICF
1985).  Further information on risk assessment in general is available in the
following publications.:  ICF 1983a,b, NAS 1982, Schaum 1984 and USEPA 1984a.

Table 4-10 lists the steps required to complete the risk characterization and
identifies the endangerment assessment level of detail to which they apply and
the locations in this Handbook where they are discussed.

4.5.1     Characterize Carcinogenic Risks

In order to obtain a quantitative estimate of carcinogenic risk, the results
of the dose-response assessment must be"combined with an estimate of the
exposures to which the population is subject.  Depending on the needs of the
endangerment assessment, quantitative estimates of risk can be presented in
one or more of the following ways:

     1.   Unit Cancer Risk - Under an assumption of low-dose linearity the
          unit cancer risk is the excess lifetime risk due to a continuous
          lifetime exposure of/one unit of carcinogen concentration.

     2.   Dose Corresponding to a Given Level of Risk - This approach is use-
          ful when using nonlinear extrapolation models where the unit risk
          differs at various dose levels.

     3.   Individual Risks - Risk is characterized in terms of excess indi-
          vidual lifetime risks.

     4.   Population Risks - Risk is characterized in terms of the excess
          number of cancers produced per year in the exposed population.

In characterizing the risk due to concurrent exposure to several carcinogens,
the risks are combined on the basis of additivity unless there is specific
information to the contrary (USEPA 1985a).  Interactions with enzyme inducers
or inhibitors, cocarcinogens, promoters and initiators should be considered on
a case-by-case basis.
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                                                                JCifc Systems, Jnc.
TABLE 4-10 RISK CHARACTERIZATION

1.0



2.0

3.0



4.0
Risk Characterization Step
Characterize carcinogenic risk
1.1 Compare site-specific exposure
levels to estimates
1.2 Compare site-specific exposure
levels to existing regulatory
guidelines and standards for
carcinogens
1.3 Characterize uncertainties asso-
ciated with risk estimates
Characterize noncarcinogenic risk
2.1 Compare site-specific exposure
levels to "Acceptable Levels"
2.2 Compare site-specific exposure
levels to existing regulatory
guidelines and standards for
noncarcinogens
2.3 Characterize uncertainties
Characterize environmental risk
3.1 Compare site-specific exposure
levels to ecotoxicity data
3.2 Compare estimated environmental
concentrations to existing
environmental concern levels and
regulatory guidelines and stand-
ards
3.3 Characterize uncertainties
Characterize public welfare risk
Level o
Detail
1 2
X X
X
X
X

X X
X
X
X X
X
X

X
X X
STEPS
I)
3
X
X
X
X

X
X
X
X
X
X

X
X


Applicable
Handbook Sections
4.0 5
4.5.1 5
4.5.1 5
4.5.1 5
4.5.1 5

4.5.2 5
4.5.2 5
4.5.2 • 5
4.5.3 5
4.5.3 5
4.5.3 5

4.5.3
4.5.4 5
.0
.5
.5
.5
.5

.5
.5
.5
.5
.5
.5


.5 •
(a)  X indicates  the  level  of  endangerment assessment (e.g., Level 1,  2 or  3)
    for which  this step must  be performed.
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The results of every risk estimation are subject to uncertainties.  These
uncertainties may be due to limitations in the human and animal studies, lack
of adequate exposure data, and the assumptions of the high-to-low dose and
interspecies extrapolation procedures used.  Risk estimates should be pre-
sented together with a summary of the toxicity and exposure assessments to
ensure that the weight-of-evidence that provides a basis for site-specific
risks is adequately described.  All of the key findings of the qualitative
assessment and the interpretative rationale that forms the basis for conclu-
sions should be summarized.  In addition, uncertainties in the evidence as
well as factors that affect the relevance of animal studies to humans should
be discussed.

To characterize carcinogenic risks at the site, compare site-specific exposure
levels for each contaminant at the site to quantitative estimates of risk
identified or developed during the dose-response assessment.  Exposure levels
should also be compared to existing regulatory guidelines and standards for
carcinogens.  The risk characterization should be accompanied by a discussion
of the uncertainties associated with the risk estimate used.

A method for determining incremental risk at a site resulting from exposure to
carcinogens is proposed. by ICF (1985).  Site-specific exposure levels (chronic
daily intake) are multiplied by the quantitative risk estimates (carcinogenic .
potency factors) to obtain an estimate of incremental risk for each chemical.
Total incremental risk at the site is obtained by summing this incremental
risk estimate for each chemical.

4.5.2     Characterize Noncarcinogenic Risks

Characterizing risks from noncarcinogenic compounds involves comparing the
expected exposure level (E) to the "acceptable level" (AL) (USEPA 1985a) .  The
resultant ratio (referred to as the Hazard Index (HI) provides a numerical
indicator of the transition between acceptable and unacceptable exposure levels.
(Note:  When making this comparison (E/AL) , it is important to ensure that the
units for the exposure level and the "acceptable level" are the same.  It may
be necessary to apply a scaling factor or exposure coefficient to the esti-
mated exposure level, as appropriate, to standardize the units in the ratio.)
Thus, when HI >1 (where HI = E/AL), there is a potential health risk to the
exposed populations.

EPA guidelines assume dose additivity for exposure to multiple noncarcinogens.
Therefore, the HI of a mixture may be defined as:
     HI = EI/ALI + E2/AL2 + . . . E±/AL±

As with single chemicals, any time the HI approaches unity, concern for potential
risks increases.

This assumption of additivity is most properly applied to compounds that induce
the same effect by the same mechanism.  Thus, it may be desirable to group the
compounds by type of critical effect and derive a separate HI for each group
to avoid overestimating risk at a site.
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                                                                  £ife Systems, Jnc.
For the purposes of the endangennent assessment, an HI should be estimated for
each contaminant of concern and each exposure scenario using all "acceptable
levels" identified in the toxicity profile.  The resulting HI scores (or sum
of HI scores) characterizes the risk to human populations from the noncarcin-
ogenic chemicals at the site.  ICF (1985) proposes a similar methodology for
characterizing noncarcinogenic risk.

The noncarcinogenic risk characterization should include an explanation of the
"acceptable levels" which were used, a determination of the "acceptability" of
the risks and a discussion of the uncertainties associated with the assessment.

4.5.3     Characterize Environmental Risks

For ecological risks, the ecotoxicity assessment and the environmental exposure
assessment are integrated to quantify the probability that adverse effects may
occur, will occur or are occurring as a result of exposure.  The methods used
to integrate such information can vary from a simple comparison of exposure
and toxicity data (quotient or ratio approach) to more complex methods, which
utilize comparative toxicology/exposure and effects models.  Estimated environ-
mental concentrations of contaminants at the site should be compared to existing
environmental .concern levels and existing regulatory guidelines and standards.

The ecological risk characterization should include an explanation of the
extrapolations that have been made, a determination or estimation of the
ecological significance of any adverse effects and a discussion of the uncer-
tainties associated with the assessment.

4.5.4     Characterize Public Welfare Risks

Risks to public welfare are not easily quantifiable.  Obvious impacts would
include a decrease in property values, adverse impacts on recreational facilities
(i.e., lakes, streams, wildlife areas, etc.), decreases in commercial fisheries,
etc.  Health and environmental risks could, directly or indirectly, have adverse
effects on the public welfare.  Risks to public welfare should be a considered
throughout the endangerment assessment process and characterized in the endanger-
ment assessment document.

4.5.5     Risk Characterization References

ICF Incorporated.  1985.  Superfund public health assessment manual.  Draft.
Washington, DC:  U.S. Environmental Protection Agency, Office of Emergency and
Remedial Response.  Contract No. 68-01-6872.

ICF Incorporated.  1983a.  Scientific support document:  the scientific basis
for the risk evaluation process.  Draft.  Washington, DC:  U.S. Environmental
Protection Agency, Office of Emergency and Remedial Response.

ICF Incorporated.  1983b.  Superfund feasibility study guidance, Chapter 4,
risk evaluation.  Washington, DC:  U.S.  Environmental Protection Agency,
Office of Emergency and Remedial Response.
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                                                                  £ife Systems, Jnc.
NAS.  1982.  National Academy of Sciences, National Research Council.  Risk
and decision making:  perspectives and research.  Washington, DC:  National
Academy Press.

Schaum J.  1984.  Short course on integration of exposure and risk assessment.
Part 3.  Exposure assessment methods.  Paper presented at the Annual Meeting
of Society for Environmental Toxicology and Chemistry, Arlington, VA.

USEPA.  1985a.  U.S. Environmental Protection Agency.  Environmental Criteria
and Assessment Office.  Proposed guidelines for the health risk assessment of
chemical mixtures.  F.ed. Regist., Jan. 9, 1985, 50 1170.

USEPA.  1984a.  U.S. Environmental Protection Agency.  Risk assessment and
management:  framework for decision making.  Washington, DC:  U.S. Environmental
Protection Agency.

USEPA.  1984b.  U.S. Environmental Protection Agency.  Office of Health and
Environmental Assessment.  Proposed guidelines for carcinogen risk assessment.
Fed. Regist., Nov. 23, 1984, 49 46294.

USEPA.  1984d.  U.S. Environmental Protection Agency.  Office of Health and
Environmental Assessment.  Proposed guidelines for mutagenicity risk assessment.
Fed. Regist., Nov. 23, 1984, 49 46314.

USEPA.  1984e.  U.S. Environmental Protection Agency.  Office of Health and
Environmental Assessment.  Proposed guidelines for the health assessment of
suspect developmental toxicants.  Fed. Regist., Nov. 23, 1984, 49 46324.
                                     4-41

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                                                                  £ife Systems, Jnc.
5.0       PREPARATION OF THE. ENDANGERMENT ASSESSMENT DOCUMENT

This section presents and discusses the content and recommended format for the
endangerment assessment document.  This format has been designed to:

     1.   Ensure that all major issues are adequately addressed.
     2.   Ensure adequate documentation and support for EPA's enforcement
          actions.
     3.   Produce comparable documents from different sites.
     4.   Promote high-quality documents.

The recommended format consolidates information from the individual assess-
ments into a single, concise document.  Thus, the endangerment assessment
document is an "executive summary" of the endangerment assessment process
which fully characterizes the site and supports the EPA's contention that an
endangerment may exist at the site.

The endangerment assessment document should not repeat site information
reported elsewhere.  The author should reference existing documents, such as
the RI and FS reports, which contain detailed site or assessment information,
and maintain complete records and notes during the assessment process.  These
can be used, if necessary, to substantiate the conclusions reported in the
endangerment assessment document.  Referencing existing documents should aid
in keeping the endangerment assessment document brief.  The length of the
document will vary depending on the site characteristics and the point in time
the assessment is being made (i.e., the-amount of data available).  As a rule,
the average endangerment assessment document should not exceed 20 typewritten
pages excluding Appendices.  Appendix 2 provides examples of Level 1, 2 and 3
endangerment assessment documents.

Table 5-1 presents the recommended endangerment assessment document outline.
This outline should be followed when preparing all endangerment assessments,
no matter what level of detail.  Obviously, a Level 1 document will not be as
lengthy as a Level 2 or 3; however, all data requirements must be addressed.
The endangerment assessment document should contain seven major sections:

     Section 1.0' is an introduction briefly describing the site, site history
     and contaminants found at the site.

     Section 2.0 identifies the environmental fate and transport of contami-
     nants at the site.

     Section 3.0 evaluates the results of the exposure assessment.

     Section 4.0 evaluates the results of the toxicity assessment.

     Section 5.0 evaluates the results of the risk characterization of the
     site.

     Section 6.0 draws conclusions based on expected exposures and toxic
     properties of contaminants of concern at the site.
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                                                     £ife'Systems, Jnc.
TABLE 5-1  ENDANGERMENT ASSESSMENT DOCUMENT OUTLINE


       Disclaimer

       1.0  Introduction

            1.1  Site description and history
            1.2  Contaminants found at site

       2.0  Environmental Fate and Transport

            2.1  Factors affecting migration
            2.2  Movement and environment fate

       3.0  Exposure Evaluation

            3.1  Routes of exposure
            3.2  Populations exposed
            3.3  Extent of exposure

       4.0  Toxicity Evaluation

       5.0  Risk and Impact Evaluation

            5.1	Human Health
            5.2  Environmental
            5.3  Public Welfare

       6.0  Conclusions

       7.0  References

       Appendices (documentation)
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                                                                  £tfc Systems, Jnc.
     Section 7.0 is a list of references used in preparing the endangennent
     assessment document.  Appendices should consist of any support documenta-
     tion.

Table 5-2 presents a summary of the key factors that should be addressed in
each section of the document at each level of detail.

All draft endangennent assessment documents should include a Disclaimer
indicating that the document has not yet been approved by EPA and is not
available for public distribution.  The disclaimer may read:

     "This document has not been peer and administratively reviewed within EPA
     and is for internal Agency use/distribution only"

Draft endangerment assessments should also be clearly marked as being "Enforce-
ment Confidential."  When the endangerment assessment is final (i.e., EPA and
responsible parties have agreed to release it to the public or the litigation
is settled) the Disclaimer and "Enforcement Confidential" should be removed
from the document.

The following are instructions for preparing each of the major sections of the
endangerment assessment document.

5.1       Section 1.0  Introduction

The" purpose of this section of the endangerment assessment document is to~
acquaint the reader with the site characteristics and contaminants present at
the site.

Sections 1.0 and 2.0 are important in establishing the "point in time" at
which the endangerment assessment was performed.  Since an endangerment
assessment may be performed at varying points in time, the degree of endanger-
ment may vary.  It is helpful to illustrate, to the best extent possible
(based on the information available at the time the endangerment assessment is
being performed) what types of chemicals and what quantities were disposed of
at the site, the manner of disposal, and any prior actions taken at the site,
to help provide a setting for the "point in time" concept.  This setting
should also be carefully segregated from other parts of the endangerment
assessment in a separate introductory section.  Care should also be taken not
to mix the manner of disposal information with exposure scenarios.  Environ-
mental fate information and any removal actions must be taken into account in
order to clearly set forth exposure to chemicals being evaluated.

Preparation of the Introduction and subsequent sections of the endangerment
assessment document begins with a thorough review of the available documen-
tation on the site.  Notes should be taken as the documents are reviewed,
focusing on the pertinent factors identified on Table 5-2.  This section
contains two subsections:  Site Description and Site History and Contaminants
Found at the Site.
                                      5-3

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                                                      TABLE  5-2     FACTORS  TO  BE   CONSIDERED  IN  ENDANGERMENT  ASSESSMENTS
                                                     Level 1
                    Level of Detail
                         Level 2
                                                                                                                                                   Level 3
Cn
1.0 Introduction

1.1 Site Description and Site History
    a. geographic location
    b. management practices/site use/site modifications
    c. chronological survey
    d. facility description/containment systems
    e. substances brought on site (identity, quantity, form manner
      of disposal

1.2 Contaminants found at site
    a. identity of substances detected

2.0 Environmental Fate and Transport
    a. identity of possible transport pathways

3.0 Exposure Evaluation
    a. identity of potential exposure routes
    b. identity of populations at risk

4.0 Toxicity Evaluation
    a. characterize key toxicological properties

5.0 Risk and Impact Evaluation
    a. risk may exist because of potential exposure to toxic
      chemicals

6.0 Conclusions

7.0 References
1.0 Introduction

1.1 Site Description and Site History
   a. geographic location
   b. management practices/site use/site modifications
   c. chronological survey
   d. facility description/containment systems
   e. substances brought on site (identity, quantity, form and
     manner of disposal)

1.2 Contaminants found at site
   a. identity of substances detected
   b. concentration of substances detected
   c. analytical methodology and QA/QC

2.0 Environmental Fate and Transport
   a. physical-chemical properties of specified
     chemicals/substances (e.g., soil/sediment adsorption
     coefficients, vapor pressures, solubility, etc.) [preliminary]
   b. photodegradation rates, decomposition rates, hydrolysis
     rates, chemical transformations, etc. (preliminary]
   c. local topography [preliminary]
   d. description of the hydrological setting and flow system
     [preliminary]
   e. soil analyses  [preliminary]
   f. climatic factors, other factors affecting fate and transport
     [preliminary]

3.0 Exposure Evaluation
   a. demographic profile of populations at risk including
     subpopulation at special risk [preliminary]
   b. background chemical exposures [preliminary]
   c. life style and occupation histories [preliminary]
   d. population macro- and micro-environments [preliminary]
   e. exposure routes [preliminary)
   f. magnitude, source, and probability of exposure to specified
     substances [preliminary]

4.0 Toxicity Evaluation
   a. metabolism [preliminary]
   b. acute toxicity [preliminary]
   c. subchronic toxicity [preliminary]
   d. chronic toxicity [preliminary]
   e. carcinogenicity [preliminary]
   f. mutagenicity [preliminary]
   g. teratogenicity/reproductive effects [preliminary]
   h. other health effects as relevant including neurotoxicity,
     immuno-depressant activity, allergic reactions, etc.
     [preliminary]
   i. epidemiological evidence (chemical specific or site specific)
     [preliminary]             i
   j. aquatic/non-human terrestrial species
     toxicity/environmental quality impairment [preliminary]

5.0 Risk and Impact Evaluation
   a. qualitative description of risk to public health, welfare and
     the environment

6.0 Conclusions

7.0 References
1.0 Introduction

1.1 Site Description and Site History
   a. geographic location
   b. management practices/site use/site modifications
   c. chronological survey
   d. facility description/containment systems
   e. substances brought on site (identity, quantity, form and
     manner of disposal

1 .2 Contaminants found at site
   a. identity of substances detected
   b. concentration of substances detected
   c. analytical methodology and QA/QC
   d. survey of environmental monitoring studies (detailed
     discussion of environmental media and contamination
     levels)

2.0 Environmental Fate and Transport
   a. physical-chemical properties of specified
     chemicals/substances (e.g., soil/sediment adsorption
     coefficients, vapor pressures, solubility, etc.) [final]
   b. photodegradation rates, decomposition rates, hydrolysis
     rates, chemical transformations, etc. (final)
   c. local topography [final]
   d. description of the hydrological setting and flow system
     [final]
   e. soil analyses [final]
   f. climatic factors, other factors affecting fate and transport
     [final]
   g. prediction of  fate and transport (where necessary using
    -modeling methods)

3.0 Exposure Evaluations
   a. demographic profile of populations at risk including
     subpopulation at  special risk [final]
   b. background chemical exposures [final]
   c. life style and  occupation histories [final]
   d. population macro- and micro-environments [final)
   e. exposure routes [final]
   f. magnitude, source, and probability of exposure to specified
     substances [final]

4.0 Toxicity Evaluation
   a. metabolism (final]
   b. acute toxicity [final]
   c. subchronic toxicity (final]
   d. chronic toxicity [final]
   e. carcinogenicity [final]
   f. mutagenicity [final]
   g. teratogenicity/reproductive effects [final]
   h. other health effects as relevant including neurotoxicity,
     immuno-depressant activity, allergic reactions, etc. [final]
   i. epidemiological evidence (chemical specific or site specific)
     [final]
   j. aquatic/non-human terrestrial species
     toxicity/environmental quality impairment (final)

5.0 Risk and Impact Evaluation
   a. carcinogenic risk assessment
   b. probability of non-carcinogenic human health effects
   c. non-human species risk assessment
   d. environmental impacts/ecosystem alterations

6.0 Conclusions

                                                                                                                                                     7.0 References

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                                                                  £ife Systems, Jnc.
 5.1.1      Section  1.1   Site  Description  and  Site  History

 This subsection  should  summarize background  site  description  and history
 information.   The  purpose  of this  section  is to provide a  framework  in  time
 and place  for  the  endangerment  assessment.   A map of  the site should also  be
 included in  this introductory section.

 Review the background material  on  the  site,  being alert for chronological
 events, such as  removal actions, which may have significantly altered the  site
 characteristics  or probable  exposure routes.  Refer to the available documents
 (i.e.,  RI  and  FS reports)  for detailed information and maps of the site.

 The site history information presented in  this subsection must be clearly
 referenced.  Identify and  cite  any affidavits, inspection reports, surveys,
 etc. that  have been previously  prepared  on this site.  This documentation  of
 previous events  is critical  in  an  enforcement document, especially if it is to
 support a  judicial action.

 5.1.2      Section  1.2   Contaminants Found at  the  Site

 This subsection  should  identify and, to  the  extent possible,  quantify the
 contaminants present at the  site.  A primary  objective of this section  is  to
 focus  the  remaining sections  of the endangerment  assessment document on the
 contaminants of  concern which are  present in  significant quantities.

 To complete this section,  review all available monitoring reports.   Level  1
 assessments will probably  not have monitoring data available  so contaminant
 identification information must be developed  from the disposal logs  at  the
 site.  Level 2 assessments will have preliminary  monitoring data available
 from the RI, and Level  3 assessments should have  the complete  RI to  work from.
 A critical evaluation of the  analytical methodology and QA/QC  (quality  assur-
 ance/quality control) procedures for the sampling  effort should be included in
 all Level  3 assessments.

 The QA/QC procedures that were  used during the data collection and analysis
 phases must be discussed in Level  3 endangerment  assessments because the
 existence of, or lack of,  QA/QC data is .very  important in determining how
 valid the conclusions based on  the sampling data  are.  If the  QA/QC  procedures
 are known, they should be documented;  if the QA/QC procedures  are not known or
 the data are unavailable,  this  should be stated.  This discussion and evalu-
 ation of the QA/QC procedures is in keeping with  the concept  that the
 endangerment assessment is an interpretive document.  It provides a  critical
 evaluation of the  available site information in order to reach a justifiable
 conclusion regarding the potential for endangerment at a site.

 This section should contain information on the identity, quantity and form of
 contaminants present at the site and the concentrations of contaminants in the
environmental media.   Level 1 assessments will typically identify contaminants
present and, possibly,  quantities disposed of.  Level 2 and 3 assessments will
provide more quantitative information on the concentrations of contaminants at
 the site.
                                      5-5

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                                                                  J^ife Systems, Jnc.
5.2       Section 2.0  Environmental Fate and Transport

The purpose of this section is to describe the potential for off-site migra-
tion of contaminants and provide estimates of the direction of movement of
contaminants and ambient concentrations of contaminants in various environ-
mental media.  This section of the endangerment assessment should summarize
the results of the environmental fate analysis portion of the exposure
assessment.

The discussion should include information on any factors which may signifi-
cantly affect the environmental fate and transport of contaminants released
from the site.  The assumptions upon which the environmental fate analysis was
based should be stated, as well as any limitations of the environmental fate
analysis.  Again, bear in mind that if the environmental fate and transport
characteristics at the site have been fully characterized in existing docu-
mentation, it is not necessary to repeat that information in this document.
Cross-referencing existing documents will satisfy the requirements of this
section.

A Level 1 environmental fate and transport analysis may only go as far as
identifying possible transport pathways.  A Level 2 analysis should char-
acterize the physical and chemical and properties of the contaminants, trans-
formation processes (e.g., photodegradation, decomposition and hydrolysis) and
site factors which affect transport such as local topography, the hydrological
setting, climatological setting and geological setting of the site.  A Level 3
analysis will continue this characterization through a prediction of fate and
transport pathways, using modeling methods when necessary.  This level of
detail is necessary to provide input to the quantitative Exposure Evaluation
characteristic of a Level 3 endangerment assessment.

5.3       Section 3.0  Exposure Evaluation

The purpose of this section is to identify actual or potential routes of
exposure, characterize the populations exposed and determine the extent of the
exposure.  Section 3.0 should.evaluate the results of the exposure assessment
and may contain up to three separate subsections:  Populations Exposed, Routes
of Exposure and Extent of Exposure.  The information presented should basic-
ally be a summary of the results of the Exposed Population Analysis and
Estimation/Calculation of Dose Incurred steps of the exposure assessment.
Information on expected doses incurred should include a summation of the  total
dose of each contaminant received as a result of exposures by multiple routes.

This section should also identify anticipated or potential pathways of expo-
sure.  The exposure routes should be presented in the order of those routes
with the highest amount of proof first  (i.e., most field data supporting  the
exposure route, highest level of confidence, etc.).  This assures that EPA
presents its strongest, most  defensible case first in the endangerment assess-
ment document.

The Exposure Evaluation for a Level 1 endangerment assessment will identify
potential exposure routes and populations at risk.  It is not necessary  to
                                       5-6

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                                                                  £ife Systems, JHC.
quantify the exposure or populations in a Level 1 endangerment assessment.  A
Level 2 Exposure Evaluation will compile all the demographic data available on
the site; this information will have been collected during the RI and FS
studies,  Based on this data, a s.eries of exposure estimates may be presented.
The Level 3 Exposure Evaluation may use available modeling methods to predict
the extent of future exposure at the site.  It is important that this section
include a discussion of all the assumptions upon which the calculations of
exposure were based.  Data limitations should also be discussed.

A summary table identifying exposed populations, exposure routes and extent of
exposure is an ideal way to summarize the exposure assessment information.
Keep in mind that the Exposure Evaluation should define as many of the factors
listed in Table 5-2 as possible.  If a factor cannot be defined, identify the
data gap but do not attempt to collect additional data for the sole purpose of
completing the endangerment assessment.  Such original data collection is
beyond the scope of the endangerment assessment effort.

5.4       Section 4.0  Toxicity Evaluation

The purpose of Section 4.0 is to provide the toxicological weight-of-evidence
that the contaminants at the site pose actual or potential risks to public
health or the environment.  This section, which evaluates the results of the
toxicity assessment, will comprise the bulk of the endangerment assessment
document, since the toxic properties of contaminants are usually not com-
pletely characterized in any other documents prepared for the site.

Toxicological factors identified in Table 5-2 should be defined for each of
the contaminants of concern.  If there are a large number of contaminants
being evaluated, then a tabular summary of the toxic properties of each
contaminant, is appropriate.  As discussed previously, this information should
be derived from existing toxicity profiles or the primary literature.

The Toxicity Evaluation for a Level 1 assessment should be a brief character-
ization of the key toxicological properties for the contaminants at the site
with the greatest risk of potential exposure.  The Level 2 and 3 assessments
should identify any quantitative indices of toxicity (e.g., NOEL, NOAEL, LC Q,
etc.), derived "acceptable levels" (e.g., ADIs, recommended standards, cri-
teria, etc.) or unit cancer risk estimates available from the literature.  A
Level 3 assessment may go on to calculate ADIs and unit cancer risk estimates
for contaminants at the site when these values are not available in the
current literature.  The studies that provide the basis for the quantitative
indices of toxicity and risk estimations should be identified and discussed in
this section as well as any assumptions or data gaps.

5.5       Section 5.0  Risk and Impact Evaluation

The purpose of this section is to integrate the findings of the exposure and
toxicity assessments to estimate site-specific risks.  Section 5.0 evaluates
and summarizes the information developed during the risk characterization
process.
                                      5-7

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                                                                  £ife Systems, Jnc.
 The  results  of  the  exposure  assessment  should  be  summarized  in a  tabular form
 for  each medium,  population  group  and route  of exposure  for  which dose  esti-
 mates  have been calculated.   The risk estimates are  then tabulated  in dupli-
 cate tables  that  report  the  probability of harm or margins of safety.   These
 data should  be  accompanied by a statement of the  nature  and  severity of the
 risks,  the major  assumptions used,  the  uncertainties that result  and the
 guidelines and  standards that may  be exceeded  by  potential exposure values and
 the  associated  risks.

 It may be sufficient  for a Level  1 Risk and  Impact Evaluation to  simply state
 that risk may exist because  of potential exposure to toxic chemicals.   A Level
 2 Risk and Impact Evaluation should contain  a  qualitative description of
 potential adverse effects and a quantitative estimate of risk based on  exist-
 ing  guidelines  and  standards (e.g., Ambient  Water Quality Criteria, Drinking
 Water  Standards,  etc.).   A Level 3 Risk and  Impact Evaluation should provide a
 quantitative risk assessment for all carcinogenic and noncarcinogenic chemi-
 cals and an  evaluation and summary of the adverse effects on public health or
 welfare or the  environment.

 5.6       Section 6.0 Conclusions

 The  purpose  of  Section 6.0 is to present the results of  the  entire  endanger-
-ment assessment process  in a very  brief statement of the problems that  could
 occur  at a sdte if  no action is taken.   This section should  also  contain a
 clear  explanation as  to  whether the site may present an  endangerment based on
 the  risk assessment that was-performed.

 Data gaps, assumptions and uncertainties that  affect the risk assessment
 should be  fully qualified in the  conclusion  section.  The endangerment  assess-
 ment document  should  not address  risk management  options at  the  site.   Rather,
 this document  should  clearly and  objectively state  the existing  and potential
 risks  to public health or welfare  or  the environment that may exist at  the
 site.
                                       5-8

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                                                                  £ife'Systems, Jnc.
6.0       SOURCES OF INFORMATION AND ASSISTANCE

The bibliographies provided at the end of Sections 4.3, 4.4 and 4.5 of this
Handbook are a primary source of information on the endangerment assessment
process and its component parts.  Additional guidance and assistance may be
obtained from the points of contact identified in this section.

6.1       Endangerment Assessment Process

The primary points of contact for specific questions on the endangerment
assessment process and the enforcement requirements at a site are:

          R. Charles Morgan, Chief
          Health Sciences Section
          Office of Waste Programs Enforcement
          USEPA
          401 M Street, SW
          Washington, DC  20460
          Telephone:  (202) 382-5611

          Kathleen Plourd
          Health Sciences Section
          Office of Waste Program Enforcement
          401 M Street, SW
          USEPA
          Washington, DC  20460
          Telephone:  (202) 382-5646

Additional questions or comments on the endangerment assessment process or
this Handbook may be directed to:

          Lee Ann Smith or
          Timothy E. Tyburski
          ICAIR Life Systems, Inc.
          24755 Highpoint Road
          Cleveland, OH  44.122
          Telephone:  (216) 464-3291

6.2       RI and FS Processes

The primary point of contact for specific questions on Superfund requirements
at a site and the RI and FS guidance documents and instruction manuals is:

          Craig Zamuda
          Office of Emergency and Remedial Response
          USEPA
          401 M Street, SW
          Washington, DC  20460
          Telephone:  (202) 382-2470
                                      6-1

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                                                                  £ife Systems, Jnc.
6.3       Toxicity Profiles

Questions on the availability of toxicity profiles prepared specifically for
use at hazardous waste sites should be addressed to the OWPE and OERR contacts
identified above.  Mr. R. Charles Morgan or Ms. Kathleen Plourd should be
contacted for information on the OWPE Chemical Profiles; Craig Zamuda is the
point of contact for the OERR Health Effects Assessments.

6.4       EPA Risk and Exposure Assessment Guidelines

The EPA has recently published a series of draft guidelines for risk and
exposure assessment.  These draft guidelines are reproduced in their entirety
as Appendix 3 of this Handbook.  Each of the draft guidelines contain a
complete reference list as well as a point of contact at EPA for questions on
the individual assessment processes.  The point of contact at EPA for each set
of assessment guidelines is identified below:

          Carcinogen Risk Assessment

          Dr. Robert McGaughy
          Carcinogen Assessment Group (RD-689)
          Office of Health and Environmental Assessment
          USEPA
          401 M Street, SW
          Washington, DC  20460
          (202) 382-5952

          Exposure Assessment

          Dr. James W. Falco
          Exposure Assessment Group (RD-689)
          Office of Health and Environmental Assessment
          USEPA
          401 M Street, SW
          Washington, DC  20460
          (202) 475-8909

          Mutagenicity Risk Assessment

          Dr.'David Jacobson-Kram
          Reproductive Effects Assessment Group (RD-689)
          Office of Health and Environmental Assessment
          USEPA
          401 M Street, SW
          Washington, DC  20460
          (202) 382-7336
                                       6-2

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                                                        £ife Systems, Jnc.
Health Assessment of Suspect Developmental Toxicants

Dr. Carole A. Kiimnel
Reproductive Effects Assessment Group (RD-689)
Office of Health and Environmental Assessment
USEPA
401 M Street, SW
Washington, DC  20460
(202) 382-7331

Health Risk Assessment of Chemical Mixtures

Dr. Richard Hertzberg
Environmental Criteria and Assessment Office
USEPA
26 West St. Clair
Cincinnati, OH  45268
(513) 684-7531
                            6-3

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                                                                 £ifc Systems, Jnc.
7.0       REFERENCES

Anderson E, Browne N, Duletsky S et al.  GCA Corporation.  1984.  Development
of statistical distribution or ranges of standard factors used in exposure
assessment.  Revised Draft Final Report.  Washington, DC:  U.S. Environmental
Protection Agency, Office of Health and Environmental Assessment, Exposure
Assessment Group.  Contract No. 68-02-3510.

Callahan MA, Johnson RH, McGinnity JL et al. 1983.  Handbook for performing
exposure assessments.  Draft.  Washington, DC:   U.S. Environmental Protection
Agency, Office of Health and Environmental Assessment.

ICAIR, Life Systems, Inc. 1985.  Toxicology handbook:  Principles related to
hazardous waste site investigations.  Draft.  Washington, DC:  U.S. Environ-
mental Protection Agency, Office of Waste Programs Enforcement.  Contract No.
68-01-7037.

ICF Incorporated.  1985.  Superfund public health assessment manual.  Draft.
Washington, DC:  U.S. Environmental Protection Agency, Office of Emergency and
Remedial Response.  Contract No. 68-01-6872.

ICF Incorporated.  1983a.  Scientific support document:  the scientific basis
for the risk evaluation process.  Draft.  Washington, DC:  U.S. Environmental
Protection Agency, Office of Emergency and Remedial Response.

ICF~~Tnc6rporate"d. " 1983b.  Superfund feasibility study guidance, chapter 4,
risk evaluation.  Washington, DC:  U.S. Environmental Protection Agency,
Office of Emergency and Remedial Response.

McNeils DN, Earth DC, Khare M et al.  Environmental Research Center, Univer-
sity of Nevada at Las Vegas.  1984.  Exposure assessment methodologies for
hazardous waste sites.  Las Vegas, NV:  Office of Research and Development.
Environmental Monitoring Systems Laboratory.  CR810550-01.

Morgan RC, Clemens R, Davis BD et al.  1984.  Endangerment assessments for
superfund enforcement actions.  Washington, DC:  U.S. Environmental Protection
Agency, Office of Waste Programs Enforcement.

NAS.  1982.  National Academy of Sciences, National Research Council.  Risk
and decision making:  perspectives and research.  Washington, DC:  National
Academy Press.

Nisbet ICT.  Clement Associates, Inc.  1984.  Seminar presentation on endan-
germent assessment.  Final Report.  Washington, DC:  U.S. Environmental
Protection Agency, Office of Waste Programs Enforcement.  Contract No.
68-01-6769.

Schaum J.  1984.  Short course on integration of exposure and risk assessment.
Part 3.  Exposure assessment methods.  Paper presented at the Annual Meeting
of Society for Environmental Toxicology and Chemistry, Arlington, VA.
                                      7-1

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                                                                  JCifc Systems, Jnc.
Schultz HL, Palmer WA, Dixon GH et al.  Versar Inc.  1984. 'Superfund exposure
assessment manual.  Final Draft.  Washington, DC:  U.S. Environmental Protec-
tion Agency, Office of Toxic Substances, Office of Solid Waste and Emergency
Response.  Contract Nos. 68-01-6271 and 68-03-3149.

USEPA.  1985a.  U.S. Environmental Protection Agency.  Environmental Criteria
and Assessment Office.  Proposed guidelines for the health risk assessment of
chemical mixtures.  Fed. Regist., Jan. 9, 1985, 50 1170.

USEPA.  1985b.  U.S. Environmental Protection Agency.  Office of Emergency and
Remedial Response.  Guidance on feasibility studies under CERCLA.  Draft.
Washington, DC:  U.S. Environmental Protection Agency.

USEPA.  1985c;  U.S. Environmental Protection Agency.  Office of Emergency and
Remedial Response.  Guidance on remedial investigations under CERCLA.  Final
Draft.  Washington, DC:  U.S. Environmental Protection Agency.

USEPA.  1985d.  U.S. Environmental Protection Agency.  Office of Waste Pro-
grams Enforcement.  Draft endangerment assessment guidance.  Memorandum from
Jack W. McGraw.  Washington, DC:  U.S. Environmental Protection Agency.
May 28, 1985.

USEPA.  1984a.  U.S. Environmental Protection Agency.  Risk assessment and
management:  framework for decision making.  Washington-, DC:   U.S. Environ-
mental Protection Agency.

USEPA.  1984b.  U.S. Environmental Protection Agency.  Office of Health and
Environmental Assessment.  Proposed guidelines for carcinogen risk assessment.
Fed. Regist., Nov. 23, 1984, 49 46294.

USEPA.  1984c.  U.S. Environmental Protection Agency.  Office of Health and
Environmental Assessment.  Proposed guidelines for exposure assessment.  Fed.
Regist., Nov. 23, 1984, 49 46304.

USEPA.  1984d.  U.S. Environmental Protection Agency.  Office of Health and
Environmental Assessment.  Proposed guidelines for mutagenicity risk assess-
ment.  Fed. Regist., Nov. 23, 1984, 49 46314.

USEPA.  1984e.  U.S. Environmental Protection Agency.  Office of Health and
Environmental Assessment.  Proposed guidelines for the health assessment of
suspect developmental toxicants.  Fed. Regist., Nov. 23,  1984, 49 46324.

USEPA.  1984f.  U.S. Environmental Protection Agency.  Office of Pesticides
and Toxic Substances.  Chemical activities status report, fourth edition,
volume 2.  Washington, DC:  U.S. Environmental Protection Agency.  EPA 560/
TIIS-84-0016.

USEPA.  1982.  U.S. Environmental Protection Agency.  Office of Pesticides and
Toxic Substances.  Graphical exposure modeling system  (GEMS) user's guide.
Draft.  Washington, DC:  U.S. Environmental Protection Agency.
                                      7-2

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                                                                 £ife Systems, Jnc.
Whitmore RW.   1984.   Research Triangle  Institute.  Methodology for character-
ization of uncertainty in exposure  assessments.  Washington, DC:  U.S.
Environmental Protection Agency,  Office of Health and Environmental Assess-
ment, Exposure Assessment Group.  Contract No. 68-01-6826.
                                      7-3

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                                           £ifc Systematic.
             APPENDIX 1
DRAFT ENDANGERMENT ASSESSMENT GUIDANCE
                Al-1

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     WASHINGTON, D.C. 20460

                                                      DRAFT
                          SEP 2 0 1985

                                                      OFFICE OF
                                             SOLID WASTE AND EMERGENCY RESPONSE


 MEMORANDUM

 SUBJECT:  Endangerment Assessment  Guidance

 FROM:     J.  Winston Porter
           Assistant Administrator

 TO:       Addressees


 PURPOSE

      This memorandum clarifies the requirement  that an
 endangerment  assessment be  developed  to support all administra-
 tive and judicial  enforcement actions under  Section 106 of  the
 Comprehensive Environmental Response, Compensation, and Liability
 Act (CERCLA)  and Section 7003 of the  Resource Conservation  and      _
 Recovery Act  (RCRA).   Before taking enforcement action  under
 these provisions t<5 abate the hazards or potential hazards  at  a
 site, the Environmental Protection Agency (EPA) must  be able to
 properly document  and  justify its  assertion  that  an imminent and
 substantial endangerment to public health cr welfare  or the
 environment may  exist.   The' endangerment a; .essment provides this
 documentation and  justification.   The endancjerment assessment  is
 not necessary to support cost recovery for Section 104  remedial
 actions.

      This memorandum also provides guidance  on  the content,
 timing, level of detail, format, and  resources  required for the
 preparation of endangerment assessments.

 WHAT IS AN ENDANGERMENT ASSESSMENT

      An endangerment assessment  is a  determination of the
 magnitude and probability of actual or potential  harm to public
 health or welfare  or the environment  by the  threatened  or actual
.release of a  hazardous  substance  (for a CERCLA  action)  or a
 hazardous waste  (for a RCRA action).

      An endangerment assessment  evaluates the collective
 demographic,  geographic, physical, chemical,  and  biological
 factors which describe  the  extent  of  the impacts  of a potential
 or actual release  of a hazardous substance and/or hazardous
 waste.

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                               -2-
DRAFT
     In general, the endangerment assessment should identify and
 characterize:

     (a)  Hazardous substances and/or hazardous wastes present
          in all relevant environmental media (e.g.,  air,  water,
          soil, sediment, biota);

     (b)  Environmental fate and transport mechanisms within
          specified environmental media, such as physical, chemical
          and biological degradation processes and hydrogeological
          evaluations and. assessments;

     (c)  Intrinsic toxicological properties or human health
          standards and criteria of specified hazardous substances
          or hazardous wastes;

     (d)  Exposure pathways and extent of expected or potential
          exposure;

     (e)  Populations at risk; and,

     (f)  Extent of expected harm and the likelihood  of such harm
          occurring (i.e.,  risk characterization).

WHY PERFORM AN ENDANGERMENT ASSESSMENT

     Under Section 106(a) of CERCLA, if the President determines
that there may be an imminent and substantial endangerment to
public health or welfare or the environment from an actual or-
threatened release of a hazardous substance, the President may
secure such relief as may be necessary to abate such danger or
threat*  Such relief may be in the form of a judicial action or
an administrative order to compel responsible parties to respond
to hazardous conditions.

     Before an order can be issued under §106 of CERCLA, EPA
must be able to document and justify its assertion that an
imminent and substantial endangerment to public health or welfare
or the environment may exist.   The endangerment assessment
provides this documentation and justification.  It is the basis
for the findings of fact in administrative orders, consent
decrees, and complaints.

    •In situations dealing with hazardous wastes or solid wastes
under RCRA, rather than hazardous substances under CERCLA, Section
7003 of RCRA may be used as the authority under which EPA may
issue orders or file civil actions !_/'.  Section 7003 of RCRA
requires a similar finding of  imminent and substantial endanger-
ment and, therefore, EPA must  also document and justify such an
assertion with an endangerment assessment before taking enforcement
action.
I/ "Final Revised Guidance Memorandum on the Use and Issuance of
Administrative Orders Under Section 7003 of the Resource Conserva-
tion and Recovery Act", September 26, 1984 signed by Courtney Price
and Lee Thomas.

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                                 -3-
                                                          DRAFT
      It  is  important  to  note  that "imminent" does not mean immediate
 harm.  Rathor/.it means  an  impending risk of harm.  Sufficient.
 justification  for a determination of an imminent endangerment may
 exist  if harm  is threatened;  no actual injury need have occurred
 or be  occurring.  Similarly,  "endangerment" means something less
 than actual harm.


 WHEN TO  PERFORM AN ENDANGERMENT ASSESSMENT

      At  remedial sites subsequently targeted for CERCLA §106 or
 RCRA §7003  enforcement action, all of the elements of an endanger-
 ment assessment will  be  provided by completing the contamination
 assessment,  public health evaluation, and environmental assessment
 during the  RI/FS process.   As such, these assessments are equivalent
 to the endangerment assessment for enforcement sites.  The informa-
 tion from the  contamination assessment, public health evaluation,
 and environmental assessment  will be considered sufficient to
 issue  an order although  additional work may be needed prior to
 litigation  (See Attachment  1  and the RI/FS guidance documents
 referenced  on  Page 6  of  this  guidance).

     Where  an  RI/FS has  not been initiated or completed, an
 endangerment assessment  must  be prepared to justify an adminis-
 trative  order  or judicial action under CERCLA §106 or RCRA §7003.
 For example, orders issued  to govern responsible party conduct of
 an RI/FS or to compel responsible party performance of immediate
 response actions will require an endangerment assessment prior to
 issuance.   In  both cases, the endangerment assessments will demon-
 strate that there may be an imminent and substantial endangerment
 which  justifies either further investigative action to determine
 the appropriate remedy for  a  site or an immediate response action.

      In  isolated cases,  EPA has negotiated with potentially
 responsible parties for  the site remedy.before it has developed
 the RI/FS.   In these  few cases, an endangerment assessment must be
 developed independently  of  the RI/FS and completed prior to issuance
 of the order or decree for  remedial action.

     An  endangerment  assessment is required for all future RCRA
 §7003  actions, as well as older RCRA §7003 cases to which CERCLA
 §106 authority has been  or  will be added. An endangerment assess-
 ment is  not  required  for older RCRA §7003 cases already filed by
.the Department of, Justice without an endangerment assessment.  The
 litigation  team, however, may determine on a case-by-case basis
 that the preparation  of  an  endangerment assessment or its equivalent
 would  substantially strengthen the government's case.

     Endangerment assessments must be prepared for all RCRA §7003
 or CERCLA §106 orders issued  to another Federal agency for cleanup
 of  a Federally-owned  facility.  Normally, EPA will seek response
 action at a  Federal facility  through a site-specific compliance
 agreement with the appropriate Federal agency or other responsible
 parties.  If,  however, a compliance agreement is not complied with
 by Federal  owners or  responsible parties, EPA may issue an order.

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                                -4-

 WHAT LEVEL OF DETAIL
DRAFT
      The determination that an imminent and  substantial  »ndanger-
 ment to public health or welfare  or the environment may  exist  is
 a legal prerequisite that must be met before an  order  can  be
 issued.  It is EPA policy that endangerment  assessments  should
 be undertaken only to the extent  "necessary  and  sufficient" to
 fulfill th<3 requirements of lc-::al enforcement proceedings.  At
 any site, there is the potential  for conducting  studies  beyond
 the level of detail needed for enforcement actions.  The level
 of detail of the endangerment assessment should  be limited to
 the amount of information needed  to sufficiently demonstrate an
 actual or potential im-ninent and  substantial endangerment.  The
 level of detail to sufficiently demonstrate  endangerment will
 vary from case to case based on the following factors:

      0 the type of enforcement action (e.g.,  AO  for removal
        vs litigation);

      0 the type of response action (e.g., removal vs remedial);
        and

      0 the stage of response action (e.g., RI/FS workplan  vs
        RI/FS completed).

      The level of detail  required to support a particular  enforce-
 ment action will ultimately be determined on a cas.e-by-case
 basis by Regional program personnel in consultation with Regional.
 Counsel.   As a general guide,  the matrix on  page 5 defines these
 levels of detail based on the factors listed above.  The matrix
•should help the Regions to both (1) determine what constitutes an *
 adequate endangerment assessment  for a particular enforcement
 action, and (2) plan their intramural and extramural resources
 accordingly.

      When endangerment assessments are developed to support
 administrative orders  for private party RI/FS or immediate
 removal actions,  information already available about the site
 will generally be sufficient.   Where sites are targeted  for
 enforcement action after  completion of an RI/FS,  the endangerment
 assessments developed  as  part of  the RI/FS will  be more  detailed
 and  generally more quantitative as they will be  based  on informa-
 tion obtained from the remedial investigation.   Such endangerment
 assessments will be used  to support any subsequent CERCLA  §106
 orders or judicial actions seeking design and construction of
 site remedies.

      The information gathered in  an RI/FS is generally similar
 to the type of information needed for an endangerment  assessment.
 However,  RI/FS and endangerment assessments  are  developed  for
 different purposes.   RI/FS are used to determine appropriate
 response actions under CERCLA §104, while endangerment assessments
 are  used for enforcement  actions  under CERCLA §106 or  RCRA §7003.
 For  sites with CERCLA §106 or RCRA §7003 enforcement potential,
 Regions should review the RI/FS workplan to  determine  whether
 information developed  as  part of  the RI/FS will  be sufficient
 for  an endangerment assessment.   In certain  complex cases,
 additional  information may be needed and a separate enOangerment
 assessment  workplan may be required.

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                                    GUIDELINES FDR LEVELS Ob1 L
Complexity

T,evel 1
Level II
Level III
ffile:—
             Type of
             Action
             .AO for removal
             action, AO for
             private party
             RI/FS, prelimi-
             nary .scoping
           Issuance of AO
           or consent decree
           for pri'Mte party
           cleanup
           Litigation
           (site-by-site
           basis)
Data Base

May bo United, probably
consisting of information
from the Preliminary Site
Assessment, Site Inspection
Report, and Hazard Ranking
System evaluation, if completed.
No health studies available;
no demographic studies avail-
able.  Preliminary sampling
data will probably be available
on pollutants present.  Data  on
extent of release or concentra-
tions of materials at the point
of exposure may be available.
Remedial Investigation complete
or other quantitative data
available on nature/extent of
release.  Data may be available
on magnitude and demographics
of population at risk.       . '
Possibly some preliminary
health effects studies.
Sources and specific
materials associated with
release are identified.

RI and FS complete.  All
required geological, hydro-
geological, and health
studies complete.
Type of Assessment

Qualitative assessment
of exposure routes, popu-
lation at risk, and
probability of harm occurring.
Critical pollutants and
their toxicological pro-
perties can be readily
identified and quantity
of pollutants estimated.
Reasonable and prudent to
conclude that an exposure
may exist because'  •  the
release.
Semi-quantitative appraisal
considering specific exposure
routes and critical pollu-
tants.  The assessment should
be able to identify any data
gaps anl recommend additional
studies, if necessary.
basis as
                flexible and may shift on a case-by-case
               ired to ^support a particular enforcement
Detailed, quantitative
review to identify potential .
health effects, critical
exposure levels, and necessary
follow-up health studies.
Critical pollutants and routes
identified, and existing expo-
sures defined or estimated.
This will constitute an
appraisal to the best of
expertise and knowledge and an
estimate of the uncertainty.
        UKAn

Remarks

For removal actions
where the normal site
ranking process has
not been completed
or undertaken, in-
formation for the
assessment may be
available from record
searches, State spon-
sored investigations,
written reports from
inspections by
government authori-
ties, and notifica-
tion in accordance
with CERCLA §103.

This assessment must
be able to support
legal action in the
event that it is
challenged by a
recalcitrant PRP.
Should be conclusive
enough that PRPs will
be encouraged to make
a firm commitment to
complete remedial
action, but not
necessarily detailed
and complete if
based on RI/FS.
                                                                                                    May require endanger-
                                                                                                    ment assessment work
                                                                                                    in addition to infor-
                                                                                                    mation generated
                                                                                                    during RI/FS.

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                              -6-
DRAFT
     The endangerment assessment should evaluate  the  adequacy,
accuracy, precision,  comprehensiveness, reliability,  and  overall
quality of identified information and  data.

     Emergency actions do not require  the  same  depth  of. assess-
ment as planned or remedial  activities.  By  definition, an
immediate and significant risk of harm to  human life  or health
or the environment will be present in  an emergency, making
the assessment of endangerment easier  to prepare.   Further,
EPA is justifying only the need for immediate  action,  not the
long-terra remedial solution.   Thus, th-3 endangerment  assessment
may be much briefer,  although the P.=gions  should  attempt  to
use as much available information as feasible.   The Action
Memorandum supporting the emergency action will normally  be
considered adequate to serve  as an endangerment assessment  in
support of an enforcement action under §106  of  CERCLA for an
immediate response.

     Attachment 2 is  an abstract of a  detailed  paper  on "Endan-
germenjt Assessments for Superfund Enforcement  Actions", prepared
by. Technical" Support  Branch,  CERCLA Enforcement Division, the
Office of Waste Programs Enforcement (OWPE).   This  paper,
previously distributed to the Regions,  will  provide technical
assistance in preparing qualitative and quantitative  assessments.
OWPE is also preparing a handbook on preparation of endangerment
assessments.

     Methodologies used for performance of such aspects of  the
endangerment assessment as exposure and risk assessment should
be consistent with the concepts and methods  currently in  use  by
the EPA Office of Research and Development (ORD).

     Attachment 3 shows how the various toxicity, exposure, and
risk evaluations.are  used to  define the overall problems  and
hazards (endangerment) at a site.  Although  the use of these
evaluations is possible at every sitet the need for a detailed
analysis, as outlined, is likely to be appropriate  at only  a
limited number of sites to sufficiently demonstrate an actual
or potential imminent and substantial  endangerment.

     The Office of Emergency  and Remedial Response  (OERR) has
developed guidance manuals covering the performance of remedial
investigations and feasibility studies.  The chapters listed
below from these documents and the OWPE handbook will provide
guidance in preparing endangerment assessments:

Guidance on Remedial  Investigations Under CERCLA (OERR, May 1985)

     Chapter 7 - Site Characterization
     Chapter 9 - Remedial Investigation Report Format

Guidance on Feasibility Studies Under CERCLA (OERR, April 1985)

     Chapter 5 - Evaluate Protection of Public Health Requirements

Handbook on Preparation of Endanqerment Assessments (OWPE -
     Technical Support Branch, Summer 1985)

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                                                    DRAFT
                               -7-
     At.tachiuent 4 is a list of references that can be ussd in
preparation of the endangerment assessment.


FORMAT

     The endangerment assessment generally should follow a
standard framework as provided in Attachment 5 and use qualitative
and/or quantitative terms as appropriate.

     The Action Memorandum will normally be  considered adequate
to serve as the endangerment assessment document in support of an
order under §106 for an emergency action.

     The endangerment assessment document may be the order itself
(where the order contains all of the elements of an endangerment
assessment) or a separate document.  In deciding whether to
develop a separate document or to include the elements of the
endangerment assessment in the order, Regions should consider the
following factors:

     1.  Are the responsible parties more likely to consent to
an order if the endangerment assessment is part of the body of
the order, or a separate document?

     2.  Is the order likely to be issued unilaterally or on
consent?  A separate document will, of course, be more important
in "adversarial settings.                ~"~

     We strongly urge that the endangerment  assessment in support
of an administrative order for private party c.;. :-anup be a separate
document.  Where all of the elements of an endangerment assessment
are in the RI/FS documents, a separate document may consist simply
of a brief statement cross-referencing the appropriate elements
of the RI/FS.


WHO SHOULD PERFORM AN ENDANGERMENT ASSESSMENT

     The Regions have the responsibility to  assure that endanger-
ment assessments are performed.  The Regions can draw on technical
expertise available in their Regional offices, OWPE - Technical
Support Branch, ORD, the Agency for Toxic Substances and Disease
Registry (see MOU between ATSDR and EPA), and/or contractor
personnel available through the Technical Enforcement Support
(TSS) or REM/FIT and TAT contracts.

     Endangerment assessments used to justify administrative
orders or judicial actions issued or filed before development
of the RI/FS should normally be drafted by Regional personnel
with the assistance of the TES contractor.  The Regions and TES
contractor also have the lead in preparation of endangerment
assessments for older cases where an RI/FS has not been completed.

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                               -8-
                                                    DRAFT
     If responsible parties elect to perform the RI/FS,  they:will,
in effect, perform an endangerment assessment because they will
develop many or all of the elements of an endangerment assessment
as part of the RI/FS.  Regions should review the RI/FS workplan to
determine whether information developed as part of the RI/FS will
be suffici-ent to show that an imrriio.e.-it and substantial endangerment
may exist.  Because subsequent enforcenent actions will rely on
the endangerment assessment developed as part of the RI/FS, close
Regional oversight should be given to. this responsible party work.

     The authority for determinations of imminent and substantial
endangerment relating to emergency response actions costing up to
one million dollars has been delegated to the Regions, subject to
the directives issued by the Office of Solid Waste and Emergency
Response.  (See Delegation 14-1-A, Selection and Performance of
Removal Actions Costing Up to $1,000,000 and the Memorandum
"Waiver of Advance Concurrence Requirements for Certain Consent
Administrative Orders, Gene A. Lucero, January 3, 1985).

     When exercising the authority to determine that an imminent
and substantial endangerment exists for the purposes of taking
enforcement action, the Region must consult with OWPE as outlined
in the November 30, 1984 Regional Assignment Memo (also see the
Memorandum "Superfund Delegations of Authority - ACTION MEMORANDUM",
Howard Messner, April 4, 1984).   In contacting OWPE, Regional
staff should be prepared to discuss the .details of the endangerment
assessment for each determination.  In certain cases involving
complex health and environmental endangerment issues, OWPE may
request a copy of .the draft endangerment assessment for review.
OWPE will complete a review of this document within 14 days of
receipt, to ensure consistent, timely response.


USE OF THIS GUIDANCE

     The policy and procedures set forth here, and internal
office procedures adopted in conjunction with this document,
are intended for the guidance of staff personnel, attorneys,
and other employees of the U.S.  Environmental Protection Agency.
They do not constitute rulemaking by the Agency, and may not be
relied upon to create a right or benefit, substantive or
procedural, enforceable at law or in equity, by any person.
The Agency may take any action at variance with the policies or
procedures contained in.this memorandum or which are not in
compliance with internal office  procedures that may be adopted
pursuant to those materials.

     If you have^any -questions or concerns regarding this guidance,
please have your "staff contact Chuck Morgan (FTS-475-6690), Chief
of the Environmental Health Sciences Section of OWPE or Linda
Southerland (FTS-382-2035) of the Guidance and Oversight Branch.

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                                                                                             schment  1


                                                                                      RI/FS Process
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                           Attachment 2

    ENDANGERMENT ASSESSMENTS FOR SUPL'RFUND 'ENFORCEMENT


R. Charles Morgan2
Robert Clemens
Thomas T. Evans
Jerald A. Fagliano
Joseph A. LiVolsi, Jr.
Abraham L. Mittelman
J. Roy Murphy
Jean C. Parker
Kenneth Partymiller

Support Branch, Office of Waste Programs Enforcement, U.S. EPA

ABSTRACT

    The Comprehensive Environmental Response, Compensation and
Liablity Act of 1980 (CERCr\) gave the Environmental Protection Agency
(EPA) new responsibilities  md powers to take actions in response
to releases of hazardous substances into the environment which may '
present an imminent and substantial endangerment to  the._environrnent,
or the public health or welfare.

     In an action to abate an endangerment, an assessment is made
of the hazards or potential hazards at a site according to methods
outlined in the National Contingency Plan.  Information needed
to perform an endangerment assessment includes the site history '
and management practices, identification and quantification of
hazardous substances at a site, and their likely transport and
fate.  Estimates of actual or potential human and environmental
exposures are compared to toxicological data to describe the kind
and degree of endangerment.

     This paper discusses the many factors that should be considered
in an endangerment assessment and streses the need for strict
quality assurance and sound scientific judgment.
  The information presented in the paper is based on the technical
  enforcement case development experiences of the authors.

  Contact to whom comments should be addressed:
  (WH-527), 401 M. Street, S.W. Washington, D.C.  20460

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                           Attachment 3

             Data Collection/Problem Characterization


Data Collection/Problem Characterization

I. Site Characterization

   A. physical description of the site
   B. geographical location
   C. demographic surroundings
   D. type of facility (landfill, incinerator, impoundment)
   E. management practices

II. Contaminants Found at the Site

   A. identity/type
   B. quantity
   C. form
   D. manner of disposal
   E. ambient levels

III. Factors Affecting Migration

   A. topography
   B. soil parameters
   C. geological parameters
   D. hydrological characteristics
   E. climate

IV.  Environmental Fate of Contaminants

   A. physical and chemical degradation'characteristics
   B. movement between environmental media
   C. hydrogeological/geochemical characteristics
   D. evidence migration

V. Hazard Identification (site/population specific)

   A. Toxicological evaluation, e.g.

      - organ toxicity, carcinogenic
      - mutagenic, teratogenic
      - neurotoxic, etc.

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                               -2-
   B. Impact Evaluation (actual)
           •^» .
      1. Environmental impacts

         a. determination of need
         b. literature searches
         c. lab tests
         d. food chain studies
         e) environmental effect observation
            - stressed vegetation
            - wildlife or aquatic life morbidity/mortality
            - domestic animal morbidity/mortalilty
         f) natural resource damages

      2. Public Health Impacts (actual)

         a) health assessment/advisory (short-term)

            1. determination of need?
            2. literature searches
            3. lab tests,  pi"~>t biological testing
            4. testing of fo "i chain contamination
            5. health assessment document
            6. health advisories

         b) human health studies (long-term)

            - epidemiological studies
            - clinical studies
            - registries

         c) human health standards and criteria
Data Interpretation

I. Dose-Response Assessment (predictive")

   A.  quantitative component of cancer mathematical
      modeling- probability

   B.  ADI calculations for non-carcinogens

II. Exposure Assessment

   A.  locate potential populations at risk of exposure
   B.  determine routes and pathways of exposure
      for each in various environmental media,
      and environmental transport and fate data

   C.  calculate maximum short-term dose and average
      dose expected over a lifetime

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                               -3-
III.  Risk Characterization (predictive)
           .•> .
   A. combining exposure, hazard and dose-response
      assessments for a specific site

   B. estimation of the magnitude of the public health
      problem at a particular site including Medical
      Panel concerns.

Risk Management
process of evaluating and selecting options; environmental,
economic, social and political consequences may be considered

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                       Attachment 4
                       BIBLIOGRAPHY
Proposed Guidelines for Carcinogen Risk Assessment, EPA,  49
     FR 84-30724 November 23, 1984.

Proposed Guidelines for Exposure Assessment, EPA, 49 FR 84-30723
     November 23, 1984.

Proposed Guidelines for Mutagenicity Risk Assessment, EPA, 49
     FR 84-30722 November 23, 1984.

Proposed Guidelines for the Health Assessment of Suspect Develop-
     mental Toxicants, EPA, 49 FR 84-30721 November 23, 1984.

Proposed Guidelines for the Health Risk Assessment of Chemical
     Mixtures, EPA, 50 FR 85-589 January 9, 1985.

Remedial Investigations Guidance Document, February 1985.

Interim Procedures and Guidelines for Health Risk and Economic
     Impact Assessments for Suspected Carcinogens, EPA, 41
     FR 24102 May 25, 1976.

Scientific Bases for Identification of Potential Carcinogens
     and Estimation of Risks, Report by the Work Group on
     Risk Assessment of the Interagency Regulatory Liaison
     Group, 44 FR 39858 July 6, 1979.

Guidelines and Methodology Used in the Preparation of Health
     Assessment Chapters of the Consent Decree Water Criteria
     Documents, Appendix C of Water Quality Criteria Documents:
     EPA, 45 FR 79347 November 28, 1980.

Appendix £: Response to Comments on the Human Health Effects
     Methodology for Deriving Ambient Water Quality Criteria,
     45 FR 79368.

Endangerment Assessments for Superfund Enforcement Actions,
     HMCRI Compendium of Papers, November, 1984.

Risk Assessment and Management: Framework for Decision Making
     U.S. EPA, December 1984.


*  Further references are forthcoming in the Feasibility Study
Guidance Document, the Superfund Exposure Assessment Manual,
the Superfund Public Health Evaluation Process: Procedures
Manual, the Superfund Risk Evaluation Manual, and the Office
of Research and Development Handbook for Performing Exposure
Assessments.

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                                             £tfe Systems, Jnc.
              APPENDIX 2






   EXAMPLES OF ENDANGERMENT- ASSESSMENT









Part 1 - Level 1 Endangerment Assessment




Part 2 - Level 2 Endangerment Assessment




Part 3 - Leyel 3 Endangerment Assessment
                 A2-1

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                                                                 jCife'Systems, Jnc.
                                   PREFACE
The following examples of Level 1, 2 and 3 endangennent assessments are based
on data from a real enforcement case.  They were prepared exclusively for
illustrative purposes and are not intended to definitively reflect current
endangerment posed by the site.  It was necessary to selectively include
information from a substantial number of documents in the EPA's case files to
reflect the scope and type of information that typically would be available at
the times Level 1, 2 or 3 assessment documents are prepared.  As a result,
some data were considered not to exist during preparation of the Level 1 or 2
examples which were subsequently used to prepare the Level 3 example.  Some
descriptions and information in these example documents may not fully reflect
actual site conditions at the present time but are intended to represent
conditions that may have existed at the time each assessment would have been
prepared.

Although a substantial information base was available, some key information
was still not available.  The' example endangerment assessment documents
illustrate several approaches to deal with an incomplete or a less than ideal
data base.  The scope, quality and type of information available and site
specific features influenced the level of detail, content, length and focus of
the example endangerment assessment documents..  The example endangerment
assessments focused on a single.chemical (dioxin) due to its extreme toxicity.
The type of monitoring data available and existing exposure assessment and
risk assessment documents precluded addressing multiple chemicals in the
example endangerment assessments.  More information on other contaminants may
become ,available to enable expansion of the scope of these assessments.
Future revisions of these examples endangerment assessments or preparation of
real endangerment documents on other sites may require addressing several
chemicals of concern.  These documents should contain correspondingly less
detailed toxicity information for individual chemicals (relative to the amount
of information provided on dioxin in the example documents) to keep the entire
document's length of a manageable size.

The Vertac site is probably more complex than the typical site since it
contains several landfill areas,  drum storage areas, discharges to surface
waters, spill areas, drainage ditches and adjacent residences.  Several
removal and remedial actions implemented at the site further complicate the
example.

Existing exposure evaluation documents for the Vertac site have focused on
dioxin exposures via consumption of contaminated fish or inhalation of
airborne dioxin contaminated dust.   Assessments of direct dermal exposures,
direct ingestion (i.e. pica in children) and ingestion of contaminated
drinking water were limited by the available information and the resources
available and the schedule for completion of the examples.  Future revisions
of the example endangerment assessments may address these routes in more
detail (i.e., in the Levels 2 and 3 example) and possibly consider exposures
to other contaminants as appropriate.  This may include rough exposure
calculations in the Level 2 example and some original exposure modeling for
the Level 3 example as appropriate data become available.
                                     A2-2

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                                                                 £ife Systems, Jnc.
The risk and impact evaluation may require expansion in future  revisions
pending results of the exposure evaluations.   This is especially relevant  for
the Level 3 example which should ideally provide quantitative assessments  for
direct dermal and ingestion exposures, and ingestion of contaminated  drinking
water.  The risk and impact evaluation may also need to address adverse
effects posed by other contaminants from'the  site.
                                     A2-3

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                                            £ifc Systems, Jnc.
PART 1  - LEVEL 1 ENDANGERMENT ASSESSMENT
                A2-4

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                                                              jCife Systems, Jnc.
                             Submitted to:

                  Office of Waste Programs  Enforcement
                  U.S.  Environmental Protection Agency
                            401 M Street,  SW
                         Washington, DC  20460

Attention:   Chief, Health Sciences Section,  R.  Charles  Morgan (2  copies)
                  VERTAC SITE ENDANGERMENT ASSESSMENT

                            (Level 1  Example)
                             Prepared  Under

                           •Program No.  1393

                                  for

                        Contract  No. 68-01-7037
                         Work Assignment No.  12

                      PRC Work Assignment  No.  136
                     Contact:   Timothy  E.  Tyburski

                       Telephone:   (216)  464-3291
                             July  25,  1985

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                                                                 £ifc Systems, Jnc.
                                 DISCLAIMER
This document has not  been peer  and administratively reviewed within  EPA and
is for internal Agency use/distribution only.

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                                                                 &fe Systems, Jnc.
                              TABLE  OF  CONTENTS
                                                                         PAGE

1.0   INTRODUCTION	     1

      1.1   Site Description and  History	     1
      1.2   Contaminants Found On-Sire   	     1

2.0   ENVIRONMENTAL FATE AND TRANSPORT	     1

3.0   EXPOSURE EVALUATION	'    3

      3.1   Routes of  Exposure	     3
      3.2   Populations  Exposed 	  	     4

4.0   TOXICITY EVALUATION 	     5

5.0   RISK AND IMPACT  EVALUATION	     6

6.0   CONCLUSIONS	     6

7.0   REFERENCES.	'.7



                               LIST OF  FIGURES


FIGURE                                                                   PAGE

  1         Vertac Site  Map	' .    2

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1.0       INTRODUCTION

The disposal of chemical waste and discharges of process wastewater at the
Vertac hazardous waste site over a 30-year period has resulted in contami-
nation of soils, groundwater and surface waters.  This contamination may
endanger human health, welfare and the environment.

1.1       Site Description and History

The Vertac site (about 93 acres), located in Jacksonville, AR, is currently
used to manufacture the herbicide 2,4-dichlorophenoxyacetic acid (2,4-D).
Munitions and numerous pesticides including DDT, aldrin, dieldrin, toxaphene,
2,4-D, 2,4,5-trichlorophenoxyacetic acid (2,4,5-T) and 2,4,5-trichlorophenoxy-
propionic acid (Silvex or 2,4,5-TP) and Agent Orange have been previously
manufactured on site.  The site is bounded by the Rocky Branch Creek and the
East Branch of the Rocky Branch Creek, an old artillery booster line and an
adjacent housing subdivision (see Figure 1).  The creek flows to Bayou Meto, a
tributary of the Arkansas River.

1.2       Contaminants Found On-Site

The site contains about 30,000 yd  of chlorinated phenols, benzene and toluene
wastes in the Reasor-Hill Landfill, 20,000 yd  of materials (containing
dioxin) in the equalization basin, 100,000 yd  of toluene still bottoms in the
Hercules-Transvaal Landfill and 3,000 drums of 2,4,5-T still bottoms and
contaminated soils .in a roofed and diked warehouse.  Discharges of process
wastewaters, disposal of pesticide manufacturing wastes, reactor spills and
other plant operations have caused the actual or potential release of the
following contaminants:

            •  2,3,7,8-TCDD     •  Chlorophenols
            •  2,4,5-T          •  Chlorobenzenes
            •  2,4-D            •  Toluene.
            •  2,4,5-TP         •  Methanol

This endangerment assessment focuses on dioxin because it is the most highly
toxic substance at this facility and is very persistent in soils and aquatic
systems.  Dioxin (2,3,7,8-tetrachlorodibenzo-p-dioxin or 2,3,7,8-TCDD) has
been detected as an impurity in waste products from the manufacture 'of 2,4,5-T
and Agent Orange, in soils on-site and in sediments and fish tissues from
ad-jacent surface waters.

2.0       ENVIRONMENTAL FATE AND TRANSPORT

Dioxin is very persistent  (estimated half-life of  10 years) in the environment
and resists biodegradation, photodegradation, oxidation and hydrolysis  (USEPA
1984).  Dioxin is adsorbed on particles  (suspended or sediments) and soils and
is only slightly soluble  (0.2 ug/L) in water  (USEPA 1984).  Since dioxin tends
to remain bound to soils,  the vertical migration of dioxin in soil is usually
minimal.  The primary route of  transport is via horizontal transfer of dioxin
adsorbed to soils and dust particles.  Wind erosion and surface runoff erosion

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                                                                   jCife Systems, fac.
                                                   ROOFED  DRUM
                                                   STORAGE AREA
                                                OLD DRUM
                                                STORAGE SIT
                              HERCULES-TRANSVAAL
                  COOLING
                    POND
                                            BLOW-OUT AREA
                                                n
Barrier Walls
                                     ASOR-HILL
                                     ANOF1LL
                               Barrier Walls
                               x
General Drainage Ditch
   —French Drai
Interceptor Dice
                                                    BRAOEN STREET
        Adapted  from Walton 1982 as cited  in JRB  (1983)
                             FIGURE 1   VERTAC SITE MAP

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                                                                  £ife Systems, fac.
processes are anticipated to be the primary mechanisms of natural horizontal
transport.  Vertical migration of dioxin through the soil is unlikely to occur
unless the capacity of the soils are saturated or dioxin is solvated by
organic solvents (NRCC 1981).  Dioxin solvated by organic solvents may be more
readily transported through soil to the groundwater.

Dioxin released to aquatic systems bioaccumulates in a number of species and
may accumulate up to four orders of magnitude above environmental concentra-
tions  (Isensee and Jones 1975) .  Bioaccumulation and bioconcentration factors
for dioxin are being reassessed by the U.S. Environmental Protection Agency.
Anthropogenic activities involving disturbance of soils and frequent vehicular
movement  (associated with routine on-site land fill operations) are expected
to cause  emission of dust potentially bearing dioxin.  Wet and dry deposition
of this dust may contaminate surface soils and surface water bodies (Rocky
Branch Creek, Bayou Meto and Lake Dupree) adjacent to the site.

The direct discharge of process wastewaters to the cooling pond and transport
of dioxin on suspended particles has caused substantial contamination of the
Rocky Branch Creek and Bayou Meto.  Flooding of the Rocky Branch Creek south
of the Vertac site has potentially transported dioxin-particulate to Lake
Dupree, a man-made recreational lake about 1.3 miles south of Vertac.

3.0       EXPOSURE EVALUATION

3.1       Routes of Exposure

The potential routes of exposure are:

      1.   Consumption of contaminated fish from the Bayou Meto and Rocky
          Branch Creek.

      2.   Consumption of groundwater or surface water downgradient of the
          Vertac site.

      3.   Inhalation of dust-contaminated with dioxin that becomes airborne
          due to wind erosion  or anthropogenic activities.

      4.   Direct contact with  waters, sediments or soils adjacent to the site
          that have been contaminated by surface runoff, erosion processes and
          direct releases.  Direct contact includes direct dermal exposures as
          well as direct ingestion exposures  (i.e. pica in children).

The route of primary concern is anticipated to be consumption of contaminated
fish  from the Bayou Meto because of the probability for dioxin to bioaccumulate
in fish  (as  indicated by the high bioconcentration factors).  Preliminary
environmental monitoring data  has detected high concentrations of dioxin in
fish  from Lake Dupree  (810  ppt) and Bayou Meto  (300 ppt)  (Schaum and  Faico
1982).   Bayou Meto was  classified as a warm water fishery according to  the
1975 .Arkansas Water Quality  Standards and was considered suitable for desir-
able  species of  fish, wildlife and other aquatic and  semi-aquatic life  and

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                                                                   JCife Systems, foe.
potentially as raw water source for public water supplies.  However, pollution
problems in Bayou Meto and its tributaries (including  the Rocky Branch Creek)
date back to  1955 when massive fish kills were  first reported  to be associated
with releases of contaminants from the Vertac site.

3.2       Populations Exposed

The population that consumes fish caught from the Bayou Meto is potentially
exposed to high concentrations (about 300 ppt)  of dioxin  (Schaum and Falco
1982).  Individuals who may consume large (5 to 16 Ib/year) amounts of fish
from the Bayou have the highest exposure potential.  Complaints of "medicinal"
taste and odor problems in fish caught from the Bayou  registered with the
Arkansas Game and Fish Commission indicate that there  have been chronic
pollutional problems and provide evidence of real exposure potential via this
route.  Further complaints about taste and odor of fish from the Bayou regis-
tered in 1963 and in 1965 were also traced to contaminants released from the
Vertac site.                                      '

Insufficient data on the prevailing wind direction, wind speed and geograph-
ical features affecting wind patterns are available to determine which
populations are at an increased exposure potential for airborne dust.  The
population living in the subdivision to the south of the Vertac site is
potentially at risk for exposure to dioxin-dust emissions.  The size of the
population living near the site has not been determined.  It is assumed that
the proximity of the population to the site subjects the nearest residents to
an~increased risk of exposure, to dioxin since~~airborne dust concentrations are
expected to be greatest close to the site and to diminish with increasing
distance from the site.  People that are homebound during the daytime, and
especially those that are outside during site activities that create dust
emissions are expected to be at highest risk; however, the concentration
indoors and outdoors may equalize over time.

Preliminary contacts with state and local permitting agencies have not identi--
fied a substantial number of domestic or industrial wells within the vicinity
of the site.  Populations that consume groundwater may be at increased risk of
exposure to dioxin or other contaminants that may percolate into the water
table and migrate off-site.

Off-site migration via wind and water erosion processes or direct releases
creates the potential for direct contact exposures.  Populations that are in
close proximity to the site (i..e., in the housing subdivision) and/or people
that may use the area for recreation are expected to be at higher risk for
direct contact exposures.

Aquatic organisms, avian species and terrestrial organisms may be exposed to
dioxin and other contaminants released from the site.  Preliminary monitoring
data on fish indicate substantial dioxin exposures have occurred and resulted
in bioaccumulation of high dioxin levels in tissues.  Aquatic species that are
benthic feeders are expected to be at higher  risk due  to high concentrations
of dioxin detected in sediments of the Rocky  Branch Creek, Bayou Meto and Lake
Dupree.

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4.0       TOXICITY EVALUATION

Dioxin is a highly toxic compound which causes liver damage, skin  lesions
(chloracne), renal function impairment, hematologic effects, adrenal atrophy,
reproductive system damage, immunosuppression, fetotoxicity, teratogenicity
and cancer in laboratory animals.  The effects of greatest concern associated
with exposure to dioxin are liver damage, thymic atrophy, fetotoxicity,
teratogenicity and carcinogenicity.  McConnell et al.  (1978a,b) observed that
orally administered dioxin induced mortality in various laboratory animals at
doses (LD50) ranging from 0.6 Ug/kg to about 280 ug/kg.

Chronic toxicity studies identify the live:r as the primary organ affected by
dioxin (Kociba et al. 1978, 1979, NTP 1980).  Oral administration of dioxin
doses in less than 0.1 ug/kg/day produced hepatitis in rodents.

Dioxin has been experimentally shown to produce fetal abnormalities and
teratologic effects in mice, rats and rabbits.  Cleft palet and kidney abnor-
malities were observed in offspring from dams (mice) receiving very low doses
of dioxin (0.1 ug/kg/day) for nine to ten days during gestation (Smith et al.
1976).  Hemorrhages edema and kidney abnormalities have also been reported in
fetal rats (Courtney and Moore 1971) and bone and soft tissue malformations in
fetal rabbits (Giavini et al. 1982) following maternal exposure to dioxin.  A
study in rhesus monkeys observed a statistically significant increase in early
abortions in animals exposed to dioxin (McNulty 1978).
Conflicting evidence is available '^roncerning the potential teratogenicity of
dioxin in humans.  Some epidemiological studies show a positive association"
between exposures to the herbicide 2,4,5-T (which contains dioxin as an
impurity) and the occurrence of birth defects or abortions while other studies
have found no association.

Numerous studies in laboratory animals 'indicate that dioxin is a potent
carcinogen when administered via ingestion or dermal exposure (Van Miller
1977, Toth et al. 1978, Kociba et al. 1978 and NTP 1980a,b).  The U.S. EPA
Carcinogen Assessment Group has identified dioxin as the most potent chemical
carcinogen evaluated to date using animal tumorigenesis models.

A substantial number of studies indicate an association between expo-
s.ure to dioxin and development of cancer in humans, however, human data are
not available to definitively demonstrate that dioxin causes cancer.  Most of
the studies examined people who were occupationally exposed to dioxin along
with phenoxyherbicides (2,4-D, 2,4,5-T and chlorophenols).  Soft-tissue
carcinomas were observed in workers exposed to phenoxy acids (Hardell 1977)
and malignant lymphomas in workers exposed to phenoxy acids and chlorophenols
(Hardell et al. 1981).  Other epidemiological studies (Zack and Suskind 1980,
Cook et al. 1980, Smith 1982, 1983) also found increased tumor frequencies in
dioxin exposed populations.  However, since dioxin was usually a contaminant
of pheynoxy acids and/or chlorophenols, human exposures were always to multi-
ple chemicals.  Therefore, the evidence for human carcinogenicity is only
suggestive due to problems associated with the evaluation of risks from
chemical mixtures.

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The toxic properties of the other site contaminants, 2,4,5-T, 2,4-D, Silvex,
chlorophenols, chlorobenzenes, toluene and methanol, are summarized in NAS
(1977, 1980, 1983).

5.0       RISK AND IMPACT EVALUATION

Contamination from the Vertac site presents endangerment to human health and
the environment due to exposure potential and toxicity.  Consumption of
contaminated fish from the Bayou Meto may substantially increase the cancer
risks in humans due co dioxin exposures.  Preliminary data indicate an
apparent lack of exposure potential via groundwater; however, groundwater
contamination with dioxin or more environmentally mobile chemicals is probable
and may preclude future use of groundwater as a drinking water resource.
Residents adjacent to the Vertac site in the housing subdivision are poten-
tially subjected to dioxin exposure via inhalation of contaminated dust and
are therefore subjected to an increased risk of cancer.  Potential exposures
via direct contact with contaminated soils and sediments caused by offsite
erosion and/or release of dioxin presents increased risks of cancer and
various acute and chronic effects, such as chloracne, to populations that may
garden, play or be in contact with soils or sediments.

Release of dioxin from the Vertac site also poses potential risks to aquatic
and terrestrial species because of its tendency to bioaccumulate in aquatic
organisms.  Contaminant releases from the Vertac facility have caused massive
fish kills (acute toxicity) and may potentially cause chronic toxicity.

Contamination from the Vertac site also has a major impact on the public
welfare since it is probable that surface waters may not be useable for
fishing and/or recreation.  Additionally, properties adjacent to the site
which are contaminated or may be contaminated will potentially have decreased
values.

6.0       CONCLUSIONS

On-site disposal of large quantities of pesticide manufacturing waste, dis-
charges of process wastewaters, spills and other plant operations at the
Vertac site have caused substantial chemical contamination both on-site and
off-site.  The actual or potential release of dioxin and other toxicants to-
the environment may present a substantial endangerment to humans, aquatic
organisms, terrestrial organisms and avian species.  The most significant
threat to human health may be due to the potential consumption of dioxin that
accumulates in fish caught from the Bayou Meto, although other routes may be
important for other individuals.  Potential dioxin exposures via direct
contact (direct dermal exposure on direct ingestion) with contaminated soils
and sediments may potentially endanger human health.  The contamination of
groundwater may preclude its use as a drinking water resource.  Residents
adjacent Co the site n:ay be exposed to dioxin via inhalation of dust—emissions
from anthropogenic activities at the site or from wind erosion.  Adverse
health effects including cancer have or potentially may occur in populations
exposed to dioxin from the Vertac site'.  The release of dioxin to aquatic
systems and soils may lead to bioaccumulation in organisms throughout the food

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                                                                   £ife Systems,
 chain  and  present  risk to the  environment.   The  potential  loss  of  fishing  in
 the  Bayou  Meto,  decrease  in value  of property  adjacent  to  the site and  the
 loss of  groundwater  as a  potential drinking  water  resource impact  the public
 welfare.

•7.0        REFERENCES

 Cook RR, Townsend  JC,  Ott MG,  Silverstein LG.   1980.  Mortality experience  of
 employees  exposed  to 2,3,7,8-tetrachlorodibenzo-p-dioxin  (TCDD).   J. Occup.
 Med. 22:530-532.   .

 Courtney KD,  Moore JA.  1971.   Teratology studies  with  2,4,5-T  and 2,3,7,8-TCDD.
 Toxicol. Appl.  Pharmacol. 20:396-403.

 Falco  J, Schaum J.  1984.  Assessment of risk  caused  by remedial actions
 considered for  Vertac  Chemical Corporation site, Jacksonville,  Arkansas.
 Washington,  DC:  U.S.  Environmental Protection Agency.  EPA-600-X-84-351,
 pp.  1-35.   December  1984.

 Giavini  E, Prati M,  Vismara C.  1982.   Rabbit  teratology  study  with
 2,3,7,8-tetrachlorodibenzo-p-dioxin.  Environ. Res. 29:74-78.

 Hardell  L.  1977.  Soft-tissue sarcomas and  exposure  to phenoxy acids:  A
 clinical observation.   Lakartidningen 74:2753-5754.

 Hardell  L, Eriksson  M.  1981.   Soft-tissue sarcomas,  phenoxy herbicides and
 chlorinated phenols.  Lancet ii:250.

 Isensee  AR,  Jones  GE.   1975.  Distribution of  2,3,7,8-tetrachlorodibenzo-p-
 dioxin (TCDD) in aquatic  model ecosystem.  Environ. Sci.  Technol.  9:668-672.

 Kociba RJ, Keyes DG, Beyer JE, et  al. 1978.  Results  of a two-year chronic
 toxicity and oncogenicity study of 2,3,7,8-tetrachlorodibenzo-p-dioxin  in
 rats.   Toxicol.  Appl.  Pharmacol. 46(2):279-303.

 Kociba RJ, Keyes DG, Beyer JE, Carreon RM, Gehring PJ.   1979.   Long-term
 toxicologic studies  of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)  in
 laboratory animal's.   Ann. NY Acad. Science 320:397-404.

 McConnell  EE, Moore  JA, Dalgard DW.  1978a.  Toxicity of  2,3,7,8-tetrachloro-
 dibenzo-p-dioxin in  rhesus monkeys (Macacas  mulatta)  following  a single oral
 dose.   Toxicol.  Appl.  Pharmacol. 43:175-187.

 McConnell  EE, Moore  JA, Baseman JK, Harris MW.  1978b.  The comparative
 toxicity of chlorinated dibenzo-p-dioxins  in mice  and guinea pigs. Toxicol.
 Appl.  Pharmacol. 44:335-356.

 McNulty W.  1978.   Direct testimony before  the administrator,  U.S. Environ-
 mental Protection  Agency, FIFRA Docket No.  415,  et al., EPA Exhibit No. 106.

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                                                                  fife Systems, Jnc.
NAS.  1977.  National Academy of Sciences.  Drinking water and health, Vol. 1.
Washington, DC:  National Academy of Sciences.

NAS.  1980.  National Academy of Sciences.  Drinking water and health, Vol. 3.
Washington, DC:  National Academy Press.

NAS.  1983.  National Academy of Sciences.  Drinking water and health, Vol. 5.
Washington, DC:  National Academy Press.

NTP.  1982a.  National Toxicology Program.  Carcinogenesis bioassay of
2,3,7,8-tetrachlorodibenzo-p-dioxin in Osborne-Mendel rats and B6C3F1 mice
(Gavage Study).  Tech. Rpt. Ser. No. 209.  NIH.  Pub. No. 82-1765.

NTP.  1982b.  National Toxicology Program.  Carcinogenesis bioassay of
2,3,7,8-tetrachlorodibenzo-p-dioxin in Swiss-Webster mice (dermal study).
Tech. Rpt. Ser. No. 201.  NIH Pub. No. 82-1757.

NTP.  1980.  National Toxicology Program.  Bioassay of l.,2,3,7,8- and
1,2,3,7,8,9-hexachlorodibenzo-p-dioxin (gavage) for possible carcinogenicity.
DHHS Publication No. (NIH) 80-1754.  Research Triangle Park, NC:  National
Toxicology Program.

NRCC. 1981.  National Research Council of Canada.  Polychlorinated
dibenzo-p-dioxins:  Criteria for their effects on man and his environment.
Pub. No. NRCC 18574, ISSN 0316-0114.. Ottawa, .Canada:  NRCC/CNRC Assoc*. Com, .
Scientific Criteria for Environ. Qual. pp. 251.        •—

Schaum J, Falco J.  1982.  Exposure analysis of Vertac facility.  Washington,
DC:  U.S. Environmental Protection Agency.  OHEA-E-50.  pp.  1-38.  April 5.

Smith AH, Fisher DO, Pearce N, Teague CA.  1982.  Do agricultural chemicals
cause soft-tissue sarcoma?  Initial findings of a case-control study in New
Zealand.  Community Health Studies 6:114-119.

Smith AH, Fisher DO, Giles HJ, Pearce N.  1983.  The New Zealand soft tissue
sarcoma case-control study:  Interview findings concerning phenoxy-acetic acid
exposure.  Chemosphere 12:565-571.

Smith FA, Schwetz BA, Nitschke KD.  1976.  Teratogenicity of 2,3,7,8-tetra-
chlorodibenzo-p-dioxin' in CF-1 mice.  Toxicol. Appl. Pharmacol. 38:517-523.

Toth K, Sugar J, Somfai-Relle S, Bence J.  1978.  Carcinogenic bioassay of the
herbicide, 2,4,5-trichlorophenoxyethanol (TCPE) with different 2,3,7,8-tetra-
chlorodibenzo-p-dioxin (dioxin) content in Swiss mice.  Prog. Biochem. Pharmacol.
14:82-93.

JSEPA.  1984.  U.S. Environmental Protection Agency.  'Office of water
Regulations and Standards.  Ambient water quality criteria for 2,3,7,8-tetra-
chloro-dibenzo-p-dioxin.  Washington, DC:  U.S. Environmental Protection
Agency.  EPA/440/5-84-007.  February 1984.

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                                                                  £ifc Systems, Jnc.
Van Miller JP, Lalich JJ, Allen JR.   1977.   Increased  incidence of neoplasms
in rats exposed to low levels of 2,3,7,8-tetrachlorodibenzo-p-dioxin.
Chemosphere 6:537-544.

Zack JA, Suskind RR.  1980.  The mortality  experience  of workers exposed to
tetrachlorodibenzodioxin in a trichlorophenol process  accident.
J. Occup. Med. 22:11-14.

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                                         tifeSystems.Jnc.
PART 2 - LEVEL 2 ENDANGERMENT ASSESSMENT
               A2-5

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                                                               jCife Systems, Jttc.
                             Submitted to:

                  Office of Waste Programs  Enforcement
                  U.S. Environmental Protection Agency
                            401 M Street, SW
                          Washington, DC 20460

Attention:  Chief, Health Sciences Section,  R.  Charles Morgan (2 copies)
                   VERTAC SITE ENDANGERMENT ASSESSMENT

                             (Level 2 Example)
                             Prepared Under


                            Program No.  1393

                                   for

                         Contract No. 68-01-7037


                         Work Assignment No. 12


                       PRC Work Assignment No.  136
                       Contact:   Timothy E.  Tyburski

                        Telephone:   (216)  464-3291
                              July 25,  1985

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                                                               &fe Systems, Jnc.
                                 DISCLAIMER
This document has  not been peer and administratively reviewed within EPA and
is for internal Agency use/distribution only.

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                                                                  £ife Systems, Jnc.
                               TABLE OF CONTENTS

                                                                         PAGE

LIST OF FIGURES	iii

LIST OF TABLES	iii

1.0  INTRODUCTION	1-1

     1.1    Site Description and History	1-1
     1.2    Contaminants Found  at the Site	1-3

2.0  ENVIRONMENTAL FATE AND TRANSPORT	2-1

     2.1    Factors Affecting Migration  	   2-1

            2.1.1   Geology	2-1
            2.1.2   Hydrology	2-1
            2.1.3   Hydrogeology	2-2
            2.1.4   Climatology	  .  .  .   2-3

     2.2    Environmental Fate  and Transport  of Dioxin	2-3

            2.2.1   Environmental Fate	   2-3
            2.2.2   Environmental Transport	  .  .  .  .  .   2-4

     2.3    Contaminant Movement On Site and  Off  Site	2-5

3.0  EXPOSURE EVALUATION 	   3-1

     3.1    Routes of Exposure	3-1

            3.1.1   Fish Consumption	3-1
            3.1.2   Groundwater	3-1
            3.1.3   Airborne Dust	3-1
            3.1.4   Direct Contact with Contaminated Soils/Sediment   .  .   3-2

     3.2    Populations Exposed	3-2

            3.2.1   Fish Consumption	3-2
            3.2.2   Groundwater	3-2
            3.2.3   Airborne Dust	3-2
            3.2.4   Direct Contact	3-3

     3.3    Extent of Exposure	3-3

            3.3.1   Fish Consumption	3-3
            3.3.2   Groundwater	3-4

                                                            continued-

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Table of Contents - continued

                                                                         PAGE

            3.3.3   Airborne Dust	3-4
            3.3.4   Direct Contact	3-^

4.0  TOXICITY EVALUATION 	 4-1

     4.1    Pharmacokinetics 	 4-1
     4.2    Acute Toxicity	4-1

            4.2.1   Toxicity in Humans	4-1
            4.2.2   Toxicity in Laboratory Animals 	 4-2
            4.2.3   Toxicity in Aquatic Species  ".....	4-4

     4.3    Subchronic and Chronic Toxicity  	 4-4

            4.3.1   Toxicity in Humans	 4-4
            4.3.2   Toxicity in Laboratory Animals .•	4-4
            4.3.3   Toxicity in Aquatic Species  	 4-6

     4.4    Teratogenicity, Reproductive Effects and Fetotoxicity  .  .  . 4-7

            4.4.1   Effects of Humans	4-7
       	4.4.2   Effects in Laboratory Animals	4-7

     4.5    Mutagenicity   	4-8
     4.6    Carcinogenicity  .•	4-8

            4.6.1   Carcinogeni.city in Humans	4-8
            4.6.2   Carcinogenicity in Laboratory Animals  	 4-10

     4.7    Quantitative Indices of Toxicity 	 4-14

            4.7.1   Noncarcinogenic Effects Indices  	 4-14
            4.7.2   Carcinogenic Effects Indices 	 4-14

5.0  RISK AND IMPACT EVALUATION  .	 5-1

     5.1    Human Health	5-1
     5.2    Environmental	5-3
     5.3    Public Welfare	5-1

6.0  CONCLUSIONS	6-1

7.0  REFERENCES	.7-1
                                       ii

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                                                                  Jjfc Systems, Jnc.
FIGURE
                                LIST OF FIGURES
                                                             PAGE
 1-1
Vertac Site Map	1-2
                                LIST OF TABLES
TABLE

 1-1


 4-1

 4-2


 4-3
                                                             PAGE

Ranges of Dioxin Contamination Detected On-Site  at
the Vertac Facility and in Adjacent Water Bodies 	  1-5
Effects of Dioxin in Animals Following Acute Exposure
.  4-3
NOAEL and LOAEL'Values Obtained From Subchronic  and
Chronic Oral Toxicity Studies of Dioxin  	  	  4-5

Summary of Carcinogenic Effects of Dioxin  .'	  4-11
                                      iii

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1.0         INTRODUCTION

Disposal of chemical wastes and discharges of process wastewater over a
30-yr period has resulted in contamination of soils, groundwater and surface
waters at the Vertac Chemical Corporation herbicide manufacturing facility in
Jacksonville, AR.  The release or potential release of contaminants from tMs
site may endanger human health, welfare and the environment.  Human health is
at risk due to the potential for consumption of contaminated fish, inhalation
of airborne contaminants, direct contact with contaminanted soils/sediments
and ingestion of contaminated groundwatar.  Contaminants relaased to surface
waters have been bioaccumulated to substantial levels in fish and other
aquatic species.

1.1         Site Description and History

The Vertac hazardous waste site is located in northwest Jacksonville, AR
(Pulaski County), approximately 20 mi northeast of Little Rock.  The site
(about 93 acres in size) is bounded by Marshall Road to the east and the
Missouri-Pacific Railroad to the west.  The old artillery booster line is on
the northern boundary and an adjacent housing development is to the south.
The Rocky Branch Creek flows along the western edge of the site and the East
Branch of the Rocky Branch Creek flows to the east of the site.  The cooling
pond located along the western edge of the site was formed by construction of
an earthen dam across the Rocky Branch Creek.  The Rocky Branch Creek flows
into Bayou Meto (a tributary o,f the Arkansas River) about two miles south of
the Vertac site.  There is a fence around the entire site with a main gate
facing Marshall Road.  Figure 1-1 demonstrates, the site features and      •
boundaries.

The site is a herbicide manufacturing plant owned by the Vertac Chemical
Corporation which currently produces 2,4-dichlorophenoxyacetic acid (2,4-D).
The site has been used since the 1930s by a variety of companies for the
manufacture of munitions and pesticides including DDT, aldrin, dieldrin,
toxaphene, 2,4-D, 2,4,5-trichlorophenoxyacetic acid (2,4,5-T), 2,4,5-tri-
chlorophenoxypropionic acid (Silvex or 2,4,5-TP) and Agent Orange (a mixture
of 2,4-D and 2,4,5-T).  The herbicides 2,4,5-T and Agent Orange are known to
contain 2,3,7,8-tetrachlorodibenzo-p-dioxin (hereafter referred to as dioxin,
2,3,7,8-TCDD or TCDD) as an impurity.  Waste disposal, cooling water dis-
charges and other plant operations apparently resulted in on-site and off-site
releases of pesticides and herbicides manufactured on site, chemicals used in
manufacturing processes and manufacturing impurities/by-products, including
TCDD.

Estimates of the quantity and types of contaminated materials at the Vertac
site were reported (JRB 1983) as follows:
                                       3          3
     !.     Thirty thousand (30,000) yd   (22,300 m ) of chlorinated phenols,
            benzene and toluene wastes within the Reasor-Hill landfill.

                                       3          3
     2.     Twenty thousand (20,000) yd   (15,200 m ) of still bottoms, contam-
            inated with 2,3,7,8-TCDD, presently contained in the equalization
                                       1-1

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                                                                  £ife Systems, Jnc.
                                                   ROOFED DRUM
                                                   STORAGE AREA
                                                OLD  DRUM
                                                STORAGE SIT
                              HERCULES-TRANSVAAL
                  COOLING
                    POND
                                            BLOW-OUT AREA
                                                O
Central Drainage  Ditch
Interceptor
                                                    BRAOEN STREET
                  Adapted from Walton 1982 as cited in JRB  (1983)
                           FIGURE 1-1  VERTAC  SITE MAP
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                                                                  £ife Systems, Jnc.
            basin wastewater treatment system.  This amount includes the clay
            cap placed on the basin at closure.
                                             3          3
     3.     One hundred thousand (100,000) yd  (76,000 m ) of material, includ-
            ing toluene still bottoms, in the Hercules-Transvaal landfill area.

     4.     Three thousand (3,000) drums  (55 gallons each) of 2,4,5-T still
            bottoms (repacked in 85 gallon overpack drums) and contaminated
            soils from the former above-ground storage area, stored in the
            concrete diked warehouse.

The U.S. Environmental Protection Agency  (USEPA) has initiated enforcement
actions against the site owners and required a number of remedial actions to
be implemented.  The major remedial actions completed as of 1984 are
summarized below:

     1.     The Reasor-Hill landfill was  capped with clay, covered with soil
            and seeded with grass.  Clay  barrier walls were installed on three
            sides and the downgradient side was left open.
                                   \
     2.     The Hercules-Transvaal landfill was capped with clay, covered with
            soil and seeded with grass.   No barrier walls were installed.

     3.     The former above-ground drum  storage area was capped with clay,
            covered with soil and  seeded.  The old dcums were repacked and
            placed in the roofed storage_ warehouse.
             •
     4.     Two-thirds of the blow-out area (where spills from reactors had
            occurred) was paved with asphalt and the remainder was capped with
            clay, covered with soil and seeded.

     5.     The equalization basin has been ^subjected to extensive remedial
            actions including dewatering  and "lime solidification of sludges,
            installation of clay barrier  walls, installation of a "French drain"
            on the downgradient side, capping with clay, covering with soil and
            seeding.

Under  the proposed remedial action  (Alternative IV), the Reasor-Hill Landfill
and North Burial Area  (includes old drum  storage sites and Hercules-Transvaal
Landfill) will be excavated and contaminated materials/soils will be redis-
posed  of in a new on-site secure landfill in an area to the north of and over-
lapping with the North Burial Area.  This proposed remedial action will
involve excavation of 50,000 yd  of soil  from  the Reasor-Hill Landfill and
100,000 yd  from North Burial Areas.

1.2         Contaminants Found at  the Site

Contaminants found at  the site include pesticides and herbicides manufactured
on site, chemicals used  in  the manufacture of  DDT, aldrin,  dieldrin, toxaphene,
2,4-D,  2,4,5-T,  2,4,5-TP  (Silvex)  and Agent Orange  (2,4-D and  2,4,5-T  mixture).
Dioxin, an impurity resulting from synthesis  of 2,4,5-T,  is also present at
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                                                                  £ife Systems, Jnc.
the Vertac facility.  Environmental monitoring surveys from the period of 1978
to 1983 have detected chemical contaminants in groundwater, surface water,
soils and sediments.  The USEPA Office of Waste Programs Enforcement has
identified the following "indicator" chemicals for the Vertac site on the
basis of their toxic properties, presence in large quantities or potential and
actual releases to the environment:

     •  2,3,7,8-TCDD                   •  Chlorophenols
     •  2,4,5-T                        •  Chlorobenzenes
     •  2,4-D                          •  Toluene
     •  2,4,5-TP                       •  Methanol

This endangerment assessment will focus on dioxin because it is the most
highly toxic substance at the facility and is very persistent in soils and
aquatic systems.  Dioxin has been detected in waste products, groundwater and
soils on site and in sediments and fish tissue in adjacent surface waters (see
Table 1-1).  Refer to CH2M Hill (1984a), JRB (1983) and Walton et al. (1982)
for data on individual sampling sites, dates and maps indicating sampling
locations and groundwater monitoring wells.  A site map showing these
locations (which is normally provided in an endangerment assessment) is not
included because of the complexity of the several monitoring studies performed
at this site.  The values presented in Table 1-1 are a composite of the
available monitoring data from the period 1979 to 1983.

These data have not been subjected to a comprehensive quality assurance and
quality control review but a preliminary -review of available data reports
indicates tha-t quality control and quality assurance procedures were
implemented.  These procedures included the chain of custody, split samples,
replicate analyses, sample spiking with an internal radiolabelled dioxin
standard, routine instrument calibration, methodological (extraction) blanks,
adherence to recommended sample holding times and storage temperature, etc.
                                      1-4

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                                          TABLE  1-1    RANGES OF DIOXIN CONTAMINATION  DETECTED ON-SITE
                                                AT  THE  VERTAC FACILITY  AND  IN ADJACENT WATER  BODIES
 i
Ul


Sample Type
Sediments











Soils







Surface
Waters

Ground
Water


Wastes




Fish





Location/Description
Equalization basin
Cooling pond
Drainage ditches, on-slte
On-slte groundwater monitoring
well
Rocky Branch Creek
Rocky Branch Creek, on-slce
Sewer and Interceptors off-site
Creek bed adjacent to private
residences
Lake Dupree

Surface soils on-slte
,
Hercules-Transvaal area/surface
dirt
Reasor Hill landfill/dirt
Reaaor Hill landfill/mud
Reasor Hill landfill area
Blow-out area
Rocky Branch Creek, on-slte
Discharge In combined sewer
at Braden and Alta Lane
Monitoring wells down gradient
of Hercules-Transvaal
Landfill
Monitoring wells, on-slte
Toluene still bottoms disposed
on-alte
Seeps from Reasor Hill
Equalization basin liquid
Equalization basin discharge
Caught In Bayou Meto

Caught in Lake Dupree


Dloxln
Concentration, ppb
0.061 to 1.200
0.216 to 102.0
0.800 to 14.1
NDIB' to 12.1

0.500
0.216 to 17.4
18.4 to 11.4
1

0.150

ND<">
100 Co 14 000

559

1.42
0.505
NR1 '
0.99 to 45
ND
0.017

"High"


ND to <0.03
17.000

0.045 to 5.5
445
<10
<0.025 to 0.100

0.810

,
Total Number of
Samplea Analyzed
5
18
6
4

NA'C' '
5
1
NA

1

NA
NA '

i

i
i
NA
2
1
1

NA


15
NA

1
1
1
6

1

Nunbcr
with Dloxin
Not Detected
0
0
0
2

NA(C)
0
0
NA

0

NA
NA

0

0
0
NA
0
1
0

NA


21
NA

0
0
0
0

0

Detected Dloxln
Concentrations, ppb
Mean 1 SD(n)(a)
460.2 t 459.1 (5)
18.2 t 24.2 (18)
16.1 ! 12.9 (6)
10.0 1 1.0 (2)

NA
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                                                                  &fe Systems, he.
 2.0       ENVIRONMENTAL FATE AND TRANSPORT   "

 2.1       Factors Affecting Migration

 2.1.1     Geology

 The Vertac site is situated very near or possibly on the fall line of  the
 Interior Highlands and Coastal Plain physiographic regions.  The geologic maps
 show that the Vertac site is slightly to the west of the fall 1'ine suggesting
 that it is in the Interior Highlands but evidence (the northern part of  the
 site contains clays of the Midway Group which are present in the Coastal
 Plain) suggests it is also in the Coastal Plain or in the transition zone.
 The surface soils near the eastern portion of the site are sedimentary.  The
 subsoils are part of the Atoka Formation characteristics of the Interior
 Highlands.

 The site is underlain by the consolidated rock of the Atoka Formation  which
 surfaces in the Interior Highlands and underlies the sediments of the  Coastal
 Plain.  The Vertac site is located on the south flank of a. westward plunging
 syncline.  The bedrock is alternating gray to black shales and sandstones of
 the Atoka Formation which dips to the northeast at a rate of about 30  degrees.
 There are many discrepancies regarding the strike and dip of the rock  strata
 on-site since the site is so close to the fall line.  The overlying unweathered
 bedrock in ascending order is weathered bedrock approximately five feet  thick,
 clays and alluvium.

 The soil is classified as a Leadvale-Urban land complex with a 1 to 3% slope.
 The Leadvale Urban land complex are areas of Leadvale soils that have  been
modified by urban development.  The Leadvale soils are moderately well-drained,
 nearly level and gentle-sloping soils in valleys.  They are formed mainly of
 loamy sediment washed from uplands composed of sandstone, shale and in some
 areas from weathered siltstone.  The Leadvale soils have moderately low
 permeability and maintain a medium level of available water capacity.  The
 level of runoff from the Leadvale Urban land complex is medium and the erosion
hazard is moderate if the soils are not protected by vegetation.  Soil borings
 indicate the presence of yellowish brown silty sands in the northeast  corner
 of the site and yellowish brown or tan silty clays in the southeast portion of
 the site (CH2M HilL 1984a).

 2.1.2     Hydrology

 Surface drainage patterns.at the Vertac site are predominantly westerly and
 easterly.  The western 55 acres drain directly to the Rocky Branch Creek.  The
Rocky Branch Creek enters the Vertac site at the northwest boundary and flows
 into a man-made cooling pond.  About 700,000 gallons/day of process waste-
waters enter the cooling pond.  Waters from the cooling pond flow out  a
 concrete outlet structure at the southwest extremity of the pond.  A central
ditch (no longer present) acted as a surface drainage channel from the plant
production area and flowed into the cooling pond.  The combined flow of
surface runoff and process waters enters Rocky Branch Creek and flows  south
about two miles to Bayou Meto.
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                                                                  £ifc Systems, Jnc.
The eastern 38 acres of the site drain east to numerous small ditches caused
by natural erosion.  Along adjacent driveways and roads are a few man-made
ditches.  The catch basins located on the eastern portion of the site drain to
a storm sewer which empties into an open ditch near the main plant entrance.
All surface runoff east of the drainage divide eventually flows into the East
Branch, of the Rocky Branch Creek.  Most of this runoff is carried by the "E*si-
Ditch" to the East Branch.  The East Branch flows into Rocky Branch Creek
south of the Vertac Site.

During heavy spring rains it is not uncommon for the Rocky Branch Creek to
flood the area south of the Vertac Site.  This is important because there is a
manmade recreational lake (Lake Dupree) 1.3 mi south of the Vertac site.  Lake
Dupree and the Rocky Branch Creek are not normally connected but, the low
terrain and tendency for flooding in the area potentially enables contaminants
discharged into Rocky Branch Creek to be deposited in Lake Dupree (JRB 1983).

2.1.3     Hydrogeology

The Interior Highlands are hilly and underlain by consolidated sediments which
dip slightly in £. southeasterly direction.  The consolidated rock of the
Interior Highlands underlies unconsolidated sediments of the Coastal Plain.
Above the lowest level of the water table, the consolidated rock of the
Highlands has been weathered.  Soil and "rotten rock" (i.e., weathered rock)
in this region are present to a.total depth of about 20 ft (maximum).  This
weathered rock area is more permeable and porous chan unweathered rock.  Water
is present in intergranular voids of "rotten rocks" and soil while water is-
only present in joints, fractures and other secondary openings in unweathered
rock.

The sediments of the Coastal Plain vary from high plasticity clays to sands
and gravels with varying permeabilities.  There are three units within the
sediments which are major water sources in some areas of Pulaski County.
Beds of claystone, calcareous sandstone, sandy limestone, marl and conglomerate
(about 7 to 60 ft) comprise one aquifer unit.  Fine to medium sand with some
interbedded clay lenses (about 320 ft thick) comprise another aquifer unit.
Terrace deposits and alluvium (deposited by the Arkansas and Mississippi
rivers) composed of fine-grain top stratum and deeper coarser stratum (about
120 ft) -is the third aquifer unit.  Refer to Walton et al. (1982), CH2M Hill
(1984a) and JRB (1983) for further hydrogeologic information and a
diagram of the locations of aquifers in .the Coastal Plain and Interior High-
land regions.

The general horizontal groundwater flow is from north to south (CH2M Hill
1984a).  Two groundwater divides are evident on site with one running from the
northeast boundary of the site along the east side, across the plant and then
due south.  The second divide runs from the northwest along the western edge
of the cooling pond and south along Rocky Branch.  The contaminated wacer
table flows toward the cooling pond and the Rocky Branch Creek at a rate of
<1 to 10 in/yr (CH2M Hill 1984a).  The vertical groundwater flow rates in
bedrock were calculated to range from 2 x 10~  in/yr to 6.0 in/yr (CH2M Hill
1984a) which indicates potential downward migration of contaminants.
                                       2-2

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                                                                  £ife Systems, Jnc.
Little is known about the hydrogeology of bedrock deposits at the Vertac site
and the structure of bedrock has not been evaluated.

The Rocky Branch Creek receives groundwater inflows from the water table from
both the east and west.  These flows have passed under or through the
Reasor-Hill area.  Contaminants entering the groundwater east of.the divide
may eventually enter the Coastal Plain aquifers (off-site) (CH2M Hill 1984a).
The recharge and inflow upgradient of contaminant sources flows toward western
surface water bodies and are conveyed off-site above ground or in the water
table.

2.1.4     Climatology

Precipitation is fairly well distributed throughout the year; however, May is
normally the wettest month.  The annual precipitation averages about 48 in and
about 31% of total precipitation occurs from March through May.  August
through October are the driest months with a total of 3 in of rain.

Winters are mild with average winter temperatures of 41 F and an average
annual snowfall of 5.7 in.  The greatest monthly snowfall reported was 12 in
in January 1966.  The summers are hot with an average daily temperature of
82 F and maximum temperatures of over 100 F occurring frequently in July and
August.

2.2       Environmental Fate and Transport of Dioxin

2.2.1     Environmental Fate
Dioxin is not readily biodegraded.  Dioxin is persistent in freshwater aquatic
environments with a half-life of 550 to 590 days in sediment containing lake
waters (Ward and Matsumufa 1977)'. The biodegradation half-life of dioxin was
estimated to be greater than one year based on theoretical biotransformation
rate values and assumed concentrations of microorganisms (USEPA 1984).  The
biodegradation half-life of 0.5 yr for dioxin in soils was based on data from
a rural Missouri incident involving accidental spraying of dioxin contaminated
oils (IARC 1977).  Recent data suggest that the half-life may be closer to
10 yr (USEPA 1984).

Dioxin in the presence of organic solvents (Crosby et al. 1971) or other
hydrogen donators is photodegraded (Crosby and Wong 1977).  Insufficient
information is available on reactions of dioxin in aquatic media under
environmental conditions to predict the photodegradation half-life in natural
waters.  Assessment of photodegradation in natural waters is complicated by
the tendency for dioxin to be strongly adsorbed on particles in sediments that
are not exposed to ultraviolet (UV) light.

Information on photodegradation of airborne dioxin adsorbed on particulates is
conflicting.  The importance of photodegradation relative to deposition (dry
or wet) in the fate of airborne dioxin is uncertain but may be important.
Dioxin sorbed to solid surfaces and exposed to the atmosphere yielded negligible
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                                                                  £ife Systems, Jnc.
photodegradation  (Crosby et al. 1971), while photolysis was evident for dioxin
in a condensed phase on glass or silica.

The photodecomposition of dioxin on wet or dry soils under artificial and
natural sunlight  (UV radiation) was observed to be negligible in soils  (Crosby
et al. 1971).  However, photodecomposition may occur when dioxin and other
pesticides (hydrogen donators) are present as a mixture in soils (Crosby and
Wong 1977).

No information on the oxidation of dioxin in aquatic systems was available but
its strong electropositive nature suggests it may be more resistant than
nonchlorinated or less chlorinated aromatics.  The potential for oxidation of
dioxin (sorbed on airborne particulates) by atmospheric compounds  (NO , 0-,
etc.) is unknown.  Hydrolysis is unlikely to occur under environmental  condi-
tions in aquatic systems (USEPA 1984).

Quantitative information on volatilization of dioxin from aquatic  systems is
not available although several references have mentioned volatilization as a
possible loss process (Callahan et al. 1979).  The validity of these estimates
has not been assessed with experimental data.  Volatilization of dioxin
adsorbed on soils is expected to be at a very slow rate due to the extremely
low vapor pressure of dioxin (Falco and Schaum 1984).

Sorption on particles (suspended or sediments) and in microorganisms appears
to be an important fate for dioxin in aqueous environments.  Isenee and Jones
(1975) observed t-ha\—a-g-% -ro-9.9.%—LL^UjMEfcFt^r(Mnq-in*4 adsorbed on. sediments in an
aquatic system and the majority of dioxin not on sediments was in  aquatic
organisms.  Ward and Matsumura (1978) observed that more than 90%  of dioxin in
aquatic medium remained bound to sediments.  The low water solubility and high
octanol/water partition coefficient of dioxin support these observations.

Many aquatic species bioaccumulate dioxin.  In a static experimental test
chamber, the accumulation appeared to be dependent upon initial dioxin  con-
centrations.  The bioconcentration factors (determined experimentally in a
static system) vary with species and may range frpm about 2,000 (algae  or
snail) to 9,000 (catfish) to 26,000 (mosquitofish) (Isenee and Jones 1975,
Isenee 1978).

2.2.2     Environmental Transport

Kearney et al. (1973) examined the mobility of dioxin in five soil types and
observed that decreased mobility was associated with increased organic  content
of soils.  Dioxin was relatively immobile in all test soils and Kearney et al.
(1973) concluded that leaching to underground water supplies would be unlikely,
Matsumura and Benezet (1973) postulated that dioxin transport would be  via
horizontal transfer of contaminated soils and dust particles.

Dioxin does not readily migrate vertically in soils (USEPA 1984).  Nash and
Beall (1980) observed that 80% of dioxin applied to soils in a microagroeco-
system remained in the upper 2 cm of soils and that only trace amounts  were
detected at 8 to  15 cm.  The NRCC (1981) suggested that vertical migration of
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                                                                  &fe Systems, Jnc.
dioxin may result when the sorption capacity of soils are saturated or as a
result of biotic mixing (i.e., action of earthworms or other soil
invertebrates).  Dioxin solvated by organic solvents may be more readily
transported through soils to the groundwater.

Wet and dry deposition of particulate-bound dioxins appear to be.an important
fate-determining process in the transport of airborne dioxins.

2.3       Contaminant Movement On Site and Off Site

The summary of the Vertac site history indicates that contaminants (dioxin and
others) were discharged in untreated wastewaters and process wastes, trans-
ported and released to the Rocky Branch Creek possibly as early as 1955
(JRB 1983).  Dioxin and other contaminants were also released by
seepage from underground burial areas and by erosion of contaminated surface
soils.

Contaminants from the Hercules-Transvaal Landfill have migrated to the process
cooling pond.  The central drainage ditch and surface runoff also transported
dioxin to the cooling pond.  Contaminants that leaked into the cooling pond
and/or settled there probably flowed into the Rocky Branch Creek since the
pond is in its steam course.  Spills and/or valve ruptures of the trichloro-
phenol reactor in the "blow-out" area or other areas released dioxin which may
have percolated underground or have been transported via surface runoff to the
East Branch.  Leachates from the equalization basin along the western edge
of the site also contributed to contamination of the Rocky Branch Creek.
Transport of dioxin to Dupree Lake probably occurred as a result of flooding*
of the Rocky Branch Creek during periods of heavy spring rains.

Implementation of remedial actions involving disturbance of soils and vehi-
cular movement may have promoted contaminant transport particularly during
remediation of the equalization basin.  The remedial actions implemented (clay
caps, barrier walls, French drain, etc.) may reduce the potential for further
contamination by. preventing infiltration of surface .precipitation, runoff and
wind erosion.

There is some uncertainty about the vertical migration of contaminants to
groundwaters. • Unexpectedly, "high" concentrations of dioxin were detected in
groundwater monitoring wells downgradient from the Hercules-Transvaal Landfill
area (JRB 1983).  There is potential for lateral subsurface movement
in this landfill since no barrier walls have been installed.  The closure of
the equalization.basin appears to contain lateral leachate seeps but the
effectiveness over time is uncertain since the French drain and barrier walls
were constructed over weathered rock (with fissures).  Installation of the
above-grade neutralization wastewater treatment system and discharge to the
local wastewater treatment plant has reduced or eliminated the potential for
further release of process waste to the Rocky Branch Creek.

The proposed remedial action (Alternative IV) which involves excavation of
contaminated soils/materials and redisposal in a secure landfill on-site) will
disturb soils and create the ootential release of contaminants as dust
                                      2-5

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                                                                  £ifc Systems, Jnc.
emissions.  Primary sources of dust emissions are expected to be  from vehicle
travel over contaminated soils, loading/unloading operations and  spreading
excavated soil in the new landfill.  The release and movement of  contaminated
dust may be reduced by implementation of dust control measures.   It  is assumed
that "clean-dirt" will be applied to roadways between the excavation sites  and
the secure landfill and covered trucks will be 'used to reduce contaminant
releases.  The wind-only generated dust emissions are expected to be negli-
gible compared to mechanically generated dusts occurring during  truck travel,
loading/unloading and spreading operations.
                                      2-6

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                                                                  £ifo'Systems, JHC.
3.0       EXPOSURE EVALUATION

This section will identify actual and potential routes of exposure, characterize
the populations exposed and determine extent of the exposure to dioxin.

3.1       Routes of Exposure

Potential exposure routes are as follows:

     1.   Consumption of fish from the Bayou Meto and Rocky Branch Creek.

     2.   Consumption of groundwater downgradient of the Vertac site.

     3.   Inhalation of dust-contaminated with dioxin that may become airborne
          due to implementation of remedial action Alternative IV.

     4.   Direct contact with waters, sediments or soils adjacent to the site
          that have been contaminated by surface runoff or erosion processes.
          Direct contact includes direct dermal exposures as well as direct
          ingestion exposures (i.e., pica in children).

3.1.1     Fish Consumption

Consumption of contaminated fish from Bayou Meto is an^exposure route of
primary concern since dioxin readily bioaccumulates in fish.  Environmental
monitoring data indicate that high concentrations of dioxin are found in fish
(<25 to 300 ppt) and sediments (500 ppt) of Bayou Meto (see Table 1-1).
Dioxin released from the site via transport on suspended solids in overland
runoff or sorbed to airborne dust is of particular concern.  Dioxin-bearing
particles accumulate in sediments of receiving waters and bioaccumulate in
fish.  Significant potential human health threats may result from consumption
of contaminated fish from Bayou Meto.  Arkansas officials have banned fishing
on the Bayou Meto; however, the fishing ban is not easily enforced (Falco
1982).  Thus, there appears to be a real potential for dioxin exposure.

3.1.2     Groundwater

Concentrations ranging from ND 0.03 ppb (with a mean ± standard deviation of
0.005 ± 0.010 ppb) of dioxin were detected in groundwater monitoring wells
downgradient from the Hercules-Transvaal landfill area; however, no existing
domestic or industrial wells were reported to be located in areas that are
immediately downgradient from the Vertac site (JRB 1983, Schaum and Falco
1982).  Potential consumption of contaminated groundwater may result in
exposures to dioxin and other contaminants that are both more mobile in the
subsurface soils and more soluble in water.

3.1.3     Airborne Dust

Inhalation exposure to dioxin is likely to be via contaminanted dust rather
than via vapors since dioxin in soils does not volatilize appreciably.
                                      3-1

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                                                                  £iftSystems. Jnc.
Potential exposure to dioxin via inhalation of contaminated dust is not
expected to be substantial since remedial actions implemented (clay capping of
disposal areas and covering the blow-out area) will diminish wind erosion.
However, the potential for exposure to dioxin is substantially increased by
the proposed remedial action (Alternative IV) which will disturb the soil and
create emissions of dioxin-contaminated dust.

3.1.4     Direct Contact with Contaminated Soils/Sediment

Dioxin in contaminated soils may be adsorbed across the skin.  The concentra-
tion in soils and type of soils are expected to affect dermal adsorption.  The
direct contact with contaminated soils,is dependent upon the degree of outdoor
activities such as gardening or playing.  The degree of dermal exposure
depends upon the amount of skin exposure, duration of contact and soil condi-
tions .

Exposure due to direct ingestion depends on age with children aged two to six
years having the greatest exposure potential.  Seasonal variation in weather,
soil conditions and activity patterns  affect the amount of exposure via direct
ingestion of contaminated soils/sediments.

3.2       Populations Exposed

3.2.1     Fish Consumption

Populations with high fish consumption from affected water bodies are at an
increased risk of dioxin exposure.  Data on fish consumption rates and the
number of people that consume fish caught from Bayou Meto were not available.
Human exposure via consumption of fish should not be occurring since there is
a fishing ban for the Bayou Meto; however, there is evidence that the ban is
not easily enforced.  Complaints of "medicinal" taste and odor problems of
fish from Bayou Meto registered with the Arkansas Game and Fish Commission
indicate the there has been chronic pollutional problems, and that people may
have been exposed to dioxin and other  contaminants.

Assuming that most fish from Bayou Meto are likely to be consumed by local
residents, the number of exposed people is probably less than the local
population.  Approximately 476,000 people are in counties that are at least
partially drained by Bayou Meto according to census data.

3.2.2     Groundwater

Data on  the size  (if any) of the population utilizing wells  or consuming
groundwater from other sources contaminated by the site were unavailable.
Walton  et al.  (1982) state that no domestic or industrial water wells were
located  in areas that are immediately  downgradient from the  Vertac site.
Contacts with  state and local permitting  agencies identified only  two domestic
wells within the vicinity of the site  (Walton et al.  1982).  One well  (50 ft
deep) was  1.5 mi west of Vertac and the other well  (15 ft deep) was  about
1.5 mi  southeast of the site.  There is insufficient  data on groundwater
contamination  and off-site flows to determine when the plume may reach  these
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wells, the expected concentrations and the size of the population that may be
exposed.

3.2.3     Airborne Dust

Insufficient data are available to determine the no action endangerment lev=l
and the size of the exposed population.  Monitoring data on ambient concen-
trations of dioxin-contaminated dust emissions from the site are unavailable.

The population at greatest risk of exposure to dioxin via airborne dust would
be workers/observers on-site during the proposed remedial action if an ade-
quate personal protection program was not implemented.  It is recommended that
an adequate personal protection program will be required under the Remedial
Action Plan to eliminate or substantially reduce potential exposures to
on-site personnel.

Insufficient data on prevailing wind direction, wind speed and geographical
features affecting wind patterns are available to determine which populations
are at increased exposure potential-for airborne dust.  Residents of the
subdivision to the south of the site are the nearest potentially exposed
off-site population.  The proximity of this population to the site subjects
this population to an increased risk of exposure to dioxin since airborne dust
concentrations are expected to be greatest near the site and to decrease with
increasing distance from the site.  People that stay at home during the
daytime and especially those that are frequently outside for'long periods-are
expected-to have higher exposures.  This group-may include young children,
nonworking parents and the elderly.  It is assumed that dioxin-contaminated
dust concentrations will tend to be higher outdoors relative to inside a
house.  No quantitative information on the number of residents near the site
and specific behavior patterns is available.

3.2.4     Direct Contact                           /

No quantitative data are available on the size of the population potentially
exposed to dioxin via direct contact with contaminated soils or sediments
on-site or off-site.  The fence around the facility limits accessibility and
reduces potential accidental direct contact exposures on-site.  Detection
of dioxin in surface soils in the subdivision south of Vertac (Braden Street,
West Lane and Alta Cove) (CH2M Hill 1984) suggests that residents may be at
risk for dioxin exposure.  People who garden and play outdoors are expected to
be at higher risk for direct contact exposures.  Since the highest
concentrations of dioxin off-site are found in sediments of the Rocky Branch
Creek, it is anticipated that people who swim, wade or play in and around the
creek may be at increased risk.  Likewise, people who use Lake Dupree for
recreational activities may have increased exposure.

3.3       Extent of Exposure                                                 .•

3.3.1     Fish Consumption

No estimates of actual fish consumption based on local surveys of the Rocky
Branch Creek and Bayou Meco are available.  Limited monitoring data on the
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dioxin content of fish in the Rocky Branch Creek, Bayou Meto and Lake Dupree
are available.  Detection of <25 to 300 ppt of dioxin in fish from Bayou Meto
and 810 ppt in a fish from Lake Dupree suggest that dioxin exposures may
result if such fish were consumed  (Schaum and Falco 1982) .  Estimation of the
extent of exposure is difficult because of limited data on dioxin content of
fish and consumption rates.  This  is further complicated by the fact that
fishing on Bayou Meto is currently banned.

Using the range of reported dioxin concentrations in Bayou Meto (<25 to
300 ppt), exposures, could be estimated as follows:

                    300 ng/kg2.37 kg/yr =
                                             1Q>1 ng/kg/yr


where :
     300 ng/kg = maximum content of dioxin detected in fish from Bayou Meto
     5.2 Ib/yr (2.37 kg/yr or 6.5 g/day) = assumed consumption rate based on
                                           the national average consumption
                                           rate of freshwater fish
     70 kg = assumed body weight of adult

Thus, dioxin exposures from  fish consumption may range from <0.85 to
10.1 ng/kg/yr for Bayou Meto to 27.4 ng/kg/yr for Lake Dupree, assuming that a
70-kg adult consumes 5.2 Ib/yr of fish and that preliminary monitoring data on
fish tissue are representative of the actual content of dioxin in fish.  These
exposure values are based on limited_4ata and much more extensive data are
required to precisely define the magnitude and extent of actual exposures via
contaminated fish consumption.

3.3.2     Groundwater

The extent of dioxin exposure via groundwater has not been determined.  Due to
the apparent lack of water wells and the low solubility of dioxin in water,
it is expected that exposure potential will be minimal.  Using the highest
reported concentration of 0.03 ppb dioxin in groundwater on-site  (CH2M Hill
1984a) and assuming a 70-kg  adult would consume two liters of water per day, a
maximum potential exposure could be calculated as follows:
                               =  °-°009  ^/k8/day  (0.9 ng/kg/day)
                (70-kg)

This  is  a worst  case  scenario.   Insufficient data  on groundwater  flows,
dilution rates and  the  extent  of contamination are available  to calculate
reasonable  conservative exposure estimates.  Using the mean concentration of
dioxin detected  in  wells (0.005  ppb)  and  the above equation,  the  exposure may
be estimated  as  0.0001  yg/kg/day.   Recent monitoring data have not detected
dioxin in any wells on-site  and  therefore suggests that  potential exposure
levels may  be less.

In addition,  actual exposure at  this  level  is unlikely since  Walton  et  al.
 (1982) and  CH2M  Hill  (1984a) state  that data indicate that no existing  wells
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are located within two miles of the site and there is no contamination in any
wells beyond two miles.  Future contamination or installation of new drinking
water wells downgradient of the site may increase the potential and magnitude
of exposures.

3.3.3     Airborne Dust

The extent of the exposure to dioxin via inhalation of contaminated dust from
wind erosion is not anticipated to be significant because of remedial actions
implemented.  No data are available to estimate exposure for no action level
or present endangerment level.  However, data on the actual content of air-
borne dioxin contaminated dust are not available to substantiate this
conclusion.  In addition to air concentrations of dioxin, information on
absorption/retention of dioxin dust particulates in the lung, a respiration
rate (20 m /day usually assumed) and duration of daily exposure would be
required to estimate exposure via dioxin dust inhalation.

Prediction of potential exposures for the proposed remedial action will
require emission modeling to predict air concentrations.  The magnitude of
exposure is anticipated to be greatest on-site at locations in closest
proximity to the remedial action involving excavation, loading/unloading,
transporting and spreading operations.  Dust control measures and personnel
protection programs may eliminate or reduce worker exposure during remedi-
ation.  The-residents closest to the site are expected to potentially be the
off-site population with the greatest extent of exposures.

3.3.4     Direct Contact

No quantitative estimates of the extent of dioxin exposure via direct contact
are available.  Future exposure assessments should address specific subpopu-
lations suspected of having increased exposures due to their behavior or
activities.  For example, children playing in contaminated soils or sediments
of adjacent waterways are probably exposed to dioxin via direct dermal contact
or ingestion.  People who garden in residential areas with dioxin-contaminated
soils also have increased exposure potential via direct contact.  The lack of
information on the dermal absorption, amount of direct soil contact, dioxin
content of soils/sediments, quantity of soil directly ingested and other
factors currently preclude performance of quantitative exposure estimates.
Direct contact is an important route that should be addressed in future
exposure assessments.  The Kimbrough et al. (1977) report on toxicity in six
children dermally exposed to dioxin-contaminated soils in horse-arenas in
eastern Missouri confirms the potential .significance of this route.
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4.0       TOXICITY EVALUATION

Exposure to dioxin can cause thymic atrophy, decreased body weight, liver
damage, skin lesions (chloracne), renal function .impairment, hematologic
effects, adrenal atrophy, reproductive system damage, immunosuppression,
fetotoxic, teratogenic and mutagenic effects and cancer.  Dioxin is an
extremely toxic substance, with an LDrQ value reported as low as 0.6 yg/kg
(guinea pig) following oral administration  (Schwetz et al. 1973).

4.1       Pharmacokinetics

The available information on the pharmacokinetics of dioxin in several mam-
malian species of laboratory animals is summarized by Neal et al.  (1982),
Manara et al. (1982), Gasiewicz et al. (1983), Olson (1983) and USEPA (1984).
The absorption of dioxin via oral and dermal exposure routes has been studied
but data on absorption via inhalation are not available (USEPA 1984).  About
70% to 83% of a single oral (gavage) dose of radiolabeled dioxin (1 Ug/kg or
50 yg/kg) was absorbed when administered by gavage to Sprague-Dawley rats
(Rose et al. 1976, Piper et al. 1973).  With repeated gavage administration of
1 yg/kg/day, absorption was about 80%.  Olson (1983) observed about 74%
absorption in hamsters.receiving a large sublethal dose (650 yg/kg) of radio-
labeled dioxin in corn oil.  Fries and Marrow (1975) reported about 50% to 60%
absorption of dioxin administered to rats in the diet (7 or 20 ppb) for
42 days.  Poiger and Schlatter  (1980) studied the dermal absorption of dioxin
(raethanol vehicle) and estimated (based on hepatic content of dioxin) that the
amount absorbed from dermal application was about 40% of the amount absorbed
from, an equivalent oral dose.  Application of a  soil/water paste decreased
hepatic dioxin content to about 2% of the administered dose.

Dioxin is lipophilic and is predominantly distributed to the liver and adipose
tissues (USEPA 1984) in most laboratory animal species.  Dioxin appears to be
distributed throughout the body without metabolic alteration (Olson et al.
1980).  However, six metabolites of dioxin  in the dog (Poiger et al. 1982) and
two metabolites in the rat  (Sawahata et al. 1982) have been identified.
Excretion and metabolism of dioxin are relatively slow processes in the body
resulting in biological half-lives ranging  from  10 days in hamsters to 43 days
in guinea pigs.  Dioxin accumulates .in tissues with high adipose content
(Nolan et al. 1979, Olson et al. 1980).

4.2       Acute Toxicity

4.2.1     Toxicity in Humans

Acute  exposure of humans to dioxin results  in nausea and vomiting, headache,
and irritation of the  eyes, skin and respiratory tract.  The initial skin
reaction  is a cutaneous reaction resembling a chemical burn, followed several
days-to-weeks after by chloracne  (Taylor  1979).  Chloracne, the  typical human
dermal  reaction to dioxin,  is  a  cutaneous eruption of comedones  (blackheads),
cysts,  and  in severe cases, pustules.  These usually occur  on the  face  and
shoulders as a result  of squamous metaplasia  (transformation of  glandular or
mucosal epithelium into stratified squamous epithelium) of  the dermal glands
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(Crow 1978, Pass! et al. 1981).  Most of the documented acute exposures to
dioxin have been the result of chemical industry accidents involving 2,4,5-T,
which is contaminated with dioxin (Holmestedt 1980, May 1973, Gianotti 1977,
Garattini 1982, Taylor 1979, Crow 1981 and Zack and Suskind 1980).

There are data regarding the health effects of dioxin on children and adults
following accidental releases of the chemical from a plant in Seveso, Italy
(Pochiari et al. 1979).  Reduced peripheral nerve conduction velocities
occurred in both adults and children, with a correlation between the incidence
and the distance from the plant.  Total serum complement activity, lymphocyte
blastogenic response and peripheral blood lymphocytes were elevated in
children exposed in the accident (Tognoni and Bonaccorsi 1982).  The limited
number of studies regarding the immunological effects of dioxin in adults have
not revealed any reduction in immunocapability (May 1982).

Six children dermally exposed to dioxin-contaminated soil (30 ppm, 30 mg/kg
soil) in horse-arenas in eastern Missouri developed headaches, skin lesions
and polyarthralgia (pain in joints) (Kimbrough et al. 1977).  In the most
severe case, epistaxis (nosebleeds) and lethargy were reported.

Numbness of the extremities, skin rashes and irritation, liver dysfunction,
weakness, loss of sex drive and psychological changes have been associated -
with exposure to 2,3,7,8-TCDD and other dioxins, which occur as contaminants.
in Agent Orange, in veterans and residents of Vietnam.  The relationship
between exposure to dioxin and the development .of these symptoms is unknown  •
(Holden 1979, Bogen 1979).	.	    '    ....  --

4.2.2     Tbxicity in Laboratory Animals

McConnell et al. (1978 a,b) observed that dioxin induced mortality in a
variety of laboratory animals (rat, guinea pig,  mouse, rabbit, monkey) at dose
(LD._) levels between 0.6 Ug/kg and 283.7 Mg/kg following oral administration.
The dermal LD_  value in rabbits was 270 Ug/kg (Schwetz et al. 1973).

A summary of studies providing data on the sub-lethal effects of acute expo-
sure to TCDD is presented in Table 4-1.  The effects were reported to occur
following single exposures ranging from 0.1 to 300 Ug/kg in four animal
species (rat, guinea pig, chicken, mouse).  Liver damage is the most consis-
tently reported effect in most species.  Rats receiving a single dose of
100 yg/kg of TCDD showed severe liver damage, thymic atrophy and jaundice
(Gupta et al. 1973).  In the same study, thymic and liver damage of lesser
severity occurred at lower dose levels (25 and 50 Ug/kg).  In another study
(Greig et al. 1973), rats exposed to TCDD (300 Ug/kg) exhibited jaundice,
multinucleated parenchymal cells of the liver and gastric hemorrhage.  Histo-
pathologic liver changes were observed five weeks after single oral doses of
TCDD as low as 50 Ug/kg were administered to male and female CD rats, and one
week after a single dose of 50 Ug/kg was administered to female CD-I mice
(Harris et al. 1973).  Increased liver weights were found in male Wistar rats
seven days after single intraperitoneal doses of 0.1 Ug/kg (Cunningham and
Williams 1972).
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                                TABLE 4-1  EFFECTS OF DIOXIN IN ANIMALS FOLLOWING ACUTE EXPOSURE
i
u>
 Species

Rat



Guinea Pig



Rat



Chicken

Rat

Rat       *

Rat

Mouse

Rat

Rat
Dose (pg/kg)    Route

25, 50 or 100

100

3.0



300



25 - 50

10              Oral

0.1             i.p.

50              Oral

50              Oral

10

10, 25, or 50
                                                        Effects
                                              Reference
Liver damage, thymic atrophy

Jaundice, 43% mortality

Hemorrhage, adrenal atrophy,
cellular depletion of lymphoid
organs, 90% mortality

Weight loss, gastric hemorrhage,
liver damage (cellular changes),
jaundice

Pericardial edema

Hematologic efiects

Increased liver weights

Liver damage

Liver damage

Decreased renal function

Decreased rena}. function
Gupta et al. (1973)



Gupta et al. (1973)



Greig et al. (1973)



Greig et al. (1973)

Weissburg and Zinkl (1973)

Cunningham and Williams (1972)

Harris et al. (1973)

Harris et al. (1973)

Anaizi and Cohen (1978)

Hook et al.  (1978)
       Adapted from NAS (1977),  NTP (1982 a,b)  and Esposito et al.  .(1980).

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4.2.3  '   Toxicity in Aquatic Species

The USEPA (1984) summarizes the available information on the acute toxicity of
dioxin to aquatic organisms.  The 96-hr lethal concentrations (LC5Q) reported
by Miller et al. (1973) and Norris and Miller (1974) were >0.2 yg/L for
Paranais sp. (worm), Physa sp. (snail) and Aedes aegypti (mosquito larvae),
>1 yg/L for Oncorhychus kisutch (coho salmon), >10 yg/L for Poecilia reticulata
(guppy) and >0.24 yg/L for Ictalurus punctatus (fingerling channel catfish).
Helder (1980, 1981 and 1982) observed that the LC«-0 is >0.01 ug/L for Esox
lucius (northern pike embryos) and Salmo gairdneri (rainbow trout yolk-sac
fry) and >0.1 yg/L for the juvenile rainbow trout.

4.3       Subchronic and Chronic Toxicity

4.3.1     Toxicity in Humans

Several epidemiologic studies and case reports involving dioxin exposure in
human subjects have been reported (Esposito et al. 1980).  Effects observed
include skin lesions (chloracne, prophyria cutanea tarda), liver function
impairment and neurological disorders (polyneuropathy, peripheral nerve
damage).   An International Agency for Research on Cancer (IARC 1982) evalua-
tion of human exposure data concluded that these studies are inadequate since
they involve multiple chemical exposures.

4.3.2     Toxicity in Laboratory Animals

Longer exposures to dioxin caused effects similar to those reported "following
acute exposure including thymic atrophy, liver damage, renal function impair-
ment, hematological effects, hormonal alterations, immunosuppression, nervous-
ness and irritability.  Chronic and subchronic studies in many different
strains of laboratory mice and rats indicate that the liver is the primary
organ affected by long-term exposure  (Kociba et al. 1973, 1979, NTP 1980a).  A
summary of major studies providing dose-response effects is presented in
Table 4-2.  Studies providing dose-response data indicating the greatest
sensitivity to dioxin are described below.

Doses as low as 0.1 yg/kg/day caused a slight degree of liver degeneration in
rats in a subchronic 13-wk (5 doses per week) study (Kociba et al.  1976).
Dose levels of 1.0 yg/kg/day increased levels of serum bilirubin and alkaline
phosphatase and caused pathologic changes in the livers of rats.  A no-
observed-adverse-effect level (NOAEL) of 0.01 yg/kg dioxin was reported for
for noncarcinogenic effects in rats.

Increased mortality was observed in female Sprague-Dawley rats maintained  for
two years on a diet that provided a dioxin dose of 0.1 yg/kg/day, while no
increased mortality was observed in male rats at this dose or in animals
receiving doses of 0.01 or 0.001 yg/kg/day (Kociba et al. 1978,  1979).  At
termination of the study, gross and histologic examination indicated that  the
liver was the most severely affected organ, with degenerative, necrotic and
inflammatory changes observed.  Increases in urinary excretion rates of the
metabolites, coproporphyrin and uroporphyriri, in the high and middle dose
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                 TABLE 4-2  NOAEL AND LOAEL VALUES OBTAINED FROM SUBCHRONIC AND CHRONIC ORAL
                                         TOXICITY STUDIES  OF DIOXIN
Species
Rat
Rat
Rat
Rat
.P. Mouse
i
Ol
Monkey
Rat
Rat
Mouse
Duration.
of Exposure
13 wk
13 wk
16 wk
28 wk
13 wk
36 wk
104 wk
104 wk
104 wk
Endpoints
Decreased body weight,
liver pathology
Toxic hepatitis
Elevated porphyrin
levels
Fatty changes in the
liver, decreased body
weight
Toxic hepatitis
Pancytopenia
Degenerative and necrotic
changes in the liver
Toxic hepatitis
Dermatitis and amyloidosis
NOAEL
yig/kg/day
0.01
0.07
0.0014
ND«"
ND
ND
0.001
0.0014
ND
LOAEL '
Mg/kg/day
0.1
0.14
0.014
0.014
0.014
2
0.01
0.007
0.001
Reference
Kociba et al
NTP (1980a)
Goldstein et
. (1976)

al. (1982)
King and Roesler (1974)
NTP (1980a)
Allen et al.
Kociba et al
NTP (1980a)
NTP (1980a)
(1977)
. (1978, 1979)


(a)  ND = Not  determined.

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females were consistent with the observed liver damage.  Primary liver injury
was dose-related with the lowest dose representing a NOAEL for noncarcinogenic
effects.

When dioxin was administered by gavage (by stomach tube) in corn oil-acetone
(9:1) at dose levels of 0, 0.01, 0.05 or 0.5 yg/kg/wk (0.0, 0.001, 0.007 ar.-i
0.07 yg/kg/day), toxic hepatitis was observed in male Osborne-Mendel rats at
incidences of none out of 74 tested (0/74), 1/50, 0/50 and 14/50 and in female
rats at incidences of 0/75, 0/50, 1/50 and 32/49(NT? 1980a).  Other non-
neoplastic lesions were not observed, even though extensive histologic examina-
tions were performed.  The two preceding studies of noncarcinogenic effects
support a NOAEL for rats of sQ.OOl yg/kg/day and a lowest-observed-adverse-
effect level (LOAEL) of 0.05 yg/kg/day.

Non-neoplastic effects.of chronic dioxin exposures were described in studies
investigating the carcinogenic potential of dioxin in mice.  In a National
Toxicology Program (NTP 1980a) bioassay, histologic examinations were per-
formed on B6C3F1 mice treated biweekly with dioxin by gavage in corn oil-
acetone (9:1) for 104 wk followed by an additional 3-wk observation period.
The doses for male animals were 0.0, 0.01, 0.05 and 0.5 pg/kg/wk, and for
female animals, 0.0, 0.04, 0.2 and 2.0 yg/kg/wk.  The only non-neoplastic
adverse effect observed was toxic hepatitis, which occurred in males at
incidences of 0/73, 5/49, 3/49 and 44/50, and in "females at incidences of
0/73, 1/50, 2/48 and 34/47, respectively, in the control, low, medium and high
dose groups.  In another study, weekly administration of .dioxin by gavage at
doses of 0.0, 0.007, 0:7 or 7.0 yg7kg/wk for one year resulted in amyloidosis
(deposition of amyloid, a complex proteinaceous material) of the kidney,
spleen and liver, and dermatitis at the time of death in male Swiss mice (Toth
et al. 1978, 1979).  The incidences of these effects in the control, low,
medium and high dose groups, respectively, were 0/38, 5/44, 10/44 and 17/43.
In the high dose group, the amyloidosis was extensive and considered to be the
cause of early mortality.  Severe toxic effects were observed at doses of
1 yg/kg/day (early mortality) and 0.28 to 0.07 yg/kg/day (toxic hepatitis),
while a LOAEL for dermatitis and amyloidosis of 0.001 yg/kg/day was reported.

4.3.3     Toxicity in Aquatic Species

No standard chronic toxicity assays of dioxin in aquatic species were located
in the available literature (USEPA 1984) but several studies provide informa-
tion indicative of chronic toxicity values.  In a static bioassay, Miller
et al. (1973) indicated that 0.2 yg/L may cause chronic toxicity in Paranais
sp. (worm).  Based on the 55% mortality in coho salmon within 60 days follow-
ing acute (96-hr) exposures to 0.0056 yg/L (Miller et al. 1979), the USEPA
(1984) suggests that 0.0056 yg/L may cause chronic toxicity coho salmon.
Similarly the USEPA (1984) concludes that chronic toxicity values such as
0.001 ug/L (rainbow trout) and 0.01 yg/L (northern pike, coho. salmon, mosquite
fish and channel catfish) can be inferred based on results of acute assays by
Helder (1980, 1981, 1982), Yockim et al. (1978) and Branson et al.  (1983).  A
concentration of 1.3 yg/L may not cause chronic toxicity in Daphnia magna or
Physa (USEPA 1984).
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Limited data are available on the toxicity of dioxin to aquatic plants.
Isensee and Jones  (1975) and Isensee  (1978) observed no adverse effects in
algae (Oedogonium  cardiacum) or duckweek  (Lemna minor) exposed to 1.3  yg/L and
0.71 ug/L (respectively) for 30 days.  Yockim et al. (1978) has also observed
no adverse effects on 0_^ cardiacum exposed to 0.0024 to 0.0042 yg/L of dioxin
for 32 days.

4.4       Teratogenicity, Reproductive Effects and Fetotoxicity

4.4.1     Effects  of Humans

Epidemiological studies have attempted to investigate health effects of dioxin
in humans by indirectly evaluating health effects in populations exposed to
2,4,5-T (which commonly contains dioxin as an impurity).  A positive associa-
tion between 2,4,5-T exposures and increases in birth defects or abortions has
been reported in human populations in Oregon (USEPA 1979), New Zealand (Hanify
et al. 1981) and Australia (Field and Kerr 1979).  A lack of any such  associa-
tion has been reported .in human populations in Arkansas (Nelson et al. 1979),
Hungary (Thomas 1980), New Zealand (Dept. of Health, New Zealand 1980, McQueen
et al. 1977) and Australia (Aldred 1978).

4.4.2     Effects  in Laboratory Animals

Dioxin has been reported to be fetotoxic and teratogenic when administered
alone or in combination with other chemicals.  Several studies have been
identified in- the  available literature based on dioxin exposure alone.
Effects observed were kidney anomalies, intestinal hemorrhage, general edema,
cleft palate and fetal death.  Adverse effects on reproduction were also
reported.

Intestinal hemorrhage, general edema and a reduction in fetal weights were
reported in rats following tne administration of 0.125 ug/kg/day in studies by
Sparschu et al. (1971).  In the same studies, the number of fetuses was
reduced and fetal  death increased at 0.5 yg/kg/day.  No structural malforma-
tions were reported at 0.03 yg/kg/day.  Courtney and Moore (1971) reported
cleft palate and kidney abnormalities in mice borne by dams administered
dioxin at doses of 1.0 yg/kg or 3.0 yg/kg.  Similarly, kidney malformations
were reported by the same authors"in offspring from rats which received
subcutaneous injections of 0.5 ug/kg/day on day 9, 10, or 13 and 14 of
gestation.

Murray et al. (1979) completed a three-generation reproduction study using
Sprague-Dawley rats fed dioxin continuously in the diet (at levels of  0,
0.001, 0.01, and 0.1 yg/kg/day).  Significant decreases were observed  in
fertility, litter  size, gestation survival, postnatal survival, and postnatal
body weight for the 0.01 and 0.1 yg/kg groups.  No apparent adverse effect on
reproduction was seen at the 0.001 yg/kg dose level.

Although Murray et al. (1979) considered the lowest dose tested, 0.001 yg/kg,
to be a NOEL (noncarcinogenic), reevaluation of these data by Nisbet and
Paxton (1982) using different statistical methods indicated that there was a
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reduction in the gestation index, decreased fetal weight, increased liver-
to-body weight ratio, and increased incidence of dilated renal pelvis at the
0.001 JJg/kg dose.  The reevaluation of data suggests that equivocal adverse
effects were seen at the lowest dose (0.001 yg/kg/day) and that this dose
should, therefore, represent a LOAEL.

Schantz et al. (1979) found reductions in fertility and various other toxic
effects in rhesus monkeys fed 55 ppt dioxin in the diet for 20 mo.  This
corresponds to a calculated daily dioxin dose of 0.0015 ug dioxin/kg/day.
These results suggest that monkeys may be somewhat more sensitive than rats,
since the effects in monkeys were more severe and not equivocal.

Luster et al. (1980) examined bone marrow* immunologic parameters, and host
susceptibility in B6C3F1 mice following pre- and postnatal exposure to TCDD.
Doses of 0, 1.0, 5.0 and 15.0 yg/kg bw of dioxin were given to dams on day 14
of gestation and to offspring on days 1, 7, and 14 following birth.  Neonatal
body, liver, spleen, and thymus weights were decreased and bone marrow
toxicity occurred in the 5.0 and 15.0 yg/kg groups.  Red blood cell counts,
hematocrits, and hemoglobin were decreased at the highest dose tested.

4.5       Mutagenicity

Studies on the mutagenicity of dioxin have produced conflicting results.
Dioxin reportedly produces mutagenic effects in Escherichia Coli and       "  .
Salmonella typhimurium TA 1532 (Russian et al. (1972) but not in-£.
typhimurium test strains TA1535, TA100, TA1538, TA98, and TA1537 with or
without metabolic activation (Geiger and Neal 1981).  Green et al. (1977)
observed an increased incidence of chromosomal breaks in female rats dosed
with 4 yg/kg and in males dosed with 2 yg/kg or 4 yg/kg of dioxin twice weekly
for 13 weeks.

4.6       Carcinogenicity                                       /

4.6.1     Carcinogenicity in Humans

Epidemiologic studies of industrial workers and herbicide applicators suggest
that dioxin may be a human carcinogen.  However, since dioxin is usually a
contaminant of phenoxy acids and/or chlorophenols, human exposure is usually
to multiple chemicals.  Therefore, the evidence for human Carcinogenicity from
these studies is only suggestive due to the difficulty of evaluating the risk
of dioxin exposure in the presence of the confounding effects of the other
chemicals (USEPA 1984).

Hardell (1977) observed an unusual occurrence of relatively rare soft-tissue
sarcomas (STS) in 7 of 87 patients seen from 1970 to 1976 at the Department of
Oncology, University Hospital, Umea, Sweden.  All seven had had occupational
exposure to phenoxy acids 10 to 20 yr earlier.  The clustering of these rare
tumors among these patients prompted the author to suggest that epidemio-
logical studies be designed to determine if exposure to phenoxy acids and
their impurities (i.e., dioxins) are related to the occurrence of STS.
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A few occurrences of STS have also been reported among chemical industry
workers in the United States who were exposed to varying levels of 2,4,5-
chlorophenols with dioxin contaminants (Cook et al. 1980, Moes and Selikoff
1981).  Honchar and Halperin (1981) reported that 3 of 105 deaths among
phenoxy acid workers reported by two chemical companies were from STS.

Zack and Suskind (1980) reported a STS death in a cohort study of workers
exposed to dioxin in a trichlorophenol process accident in West Virginia.
This tumor, a fibrous histiocytoma, was considered as a rare event.

In a cohort mortality study of 61 male employees of a trichlorophenol manu-
facturing area who exhibited chloracne following a 1964 exposure incident,
Cook et al. (1980) noted four deaths by the end of his study period, one of
which was due to a fibrosarcoma.

There are numerous other studies reported regarding STSs.  For example, Smith
et al. (1982) conducted an initial case-control study of 102 males identified
from the New Zealand Cancer Registry as having STSs (ICD 171) between 1976 and
1980.  For each case, three controls each with another form of cancer were
matched by age and year of registration.  The selection of cancer controls
from the same registry was done to eliminate recall bias or interviewer bias
or both.

The distribution of tumor types differed considerably from the Hardell and
Eriksson et al. (1981) study to the Smith et al. (1982) study. 'Leiomyo-
sarcomas;- malignant histocytomas, neurogenic sarcomas and myxosarcoma seem to
predominate in the Hardell and Eriksson (1981) study, whereas fibrosarcbmas
and liposarcomas appear prominently in the Smith et al. (1982) study.

Smith et al. (1983) conducted another case-control study of STSs in males that
were reported to the New Zealand Cancer Registry by Public Hospitals between
1976 and 1980.  Smith et al. (1983) remarked that it was surprising that he
found no STS victim who had ever worked full-time in phenoxyacetic acid
herbicide spraying.  Perhaps they have not yet been observed for a long enough
period.  As was pointed out by the author, the findings do not support the
hypothesis that exposure to phenoxyacetic acid herbicides causes STS; however,
neither do they support a negative finding without better documentation
regarding actual exposure and time of actual exposure.

The Michigan Department of Public Health (1983) recently conducted an ecologi-
cal study of soft and connective tissue cancer mortality rates in Midland and
other selected Michigan counties.  They found that mortality rates for this
cancer were 3.8 to 4.0 times the national average for the periods 1960 to 1969
and 1970 to 1978, respectively, for white females in Midland.  These estimates
are based upon five deaths and seven deaths, respectively.  No excess risk was
reported among white males, however.  The Michigan Department of Health
concluded that because of the occurrence of these two sucgessive elevated
rates, it is unlikely to be a chance happening.  At the same time the age-
adjusted male and female cancer mortality rates for Midland were below that of
the State of Michigan for the period 1970 to 1979.  Midland County is the home
of a major chemical company that produced phenoxyacetic acid herbicides until
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recently.  The authors stated that a detailed review of death certificates,
hospital records, residency and occupational histories of the 20 male and
female cases revealed no "commonalities" suggesting a "single causative
agent," although a majority of their spouses had worked at this chemical
facility.  They recommended that a case-control study should be instituted to
evaluate possible influences, such as lifestyles, occupation or location of
residences, on the risk of STS.

4.6.2     Carcinogenicity in Laboratory Animals

The carcinogenic potential of dioxin has been studied extensively in labora-
tory animals.  A summary of the results of selected comprehensive studies is
presented in Table 4-3.  The results of these studies show that dioxin-exposed
animals exhibited malignant lesions involving multiple organ systems including
accessory digestive organs (liver), endocrine (thyroid, adrenal), renal,
reproductive (testes), and nasal structures.  Representative studies are
described below.

Groups of ten male Sprague-Dawley rats were fed a diet containing dioxin for
78 wk at concentrations ranging from 1 ppt to 500 ppt or 1 ppb to 1,000 ppb
(Van Miller et al. (1977).  These dietary levels represent approximate weekly
dose levels of 0.0003 to 0.1 yg/kg or 0.4 to 500 yg/kg.  Animals exposed at
5 ppt, 50 ppt, 500 ppt or 5 ppb showed an overall incidence of neoplasms of
38%-(23/60).  No neoplasms.were reported or observed following exposure to
1 ppt dioxin.  In the 5 ppt group, 5/10 animals had six neoplasms (earduct
carcinoma, lymphocytic leukemia, adenocarcinoma, malignant histiocytoma (with
metastases), angiosarcoma and Leydig-cell adenoma).  Neoplasms were also
observed in the following groups:  at 50 ppt, three in 3/10; at 500 ppt,
four in 4/10; at 1 ppb, five in 4/10; at 5 ppb, ten in 7/10.  Neoplasms were
not observed in the controls.  Rats administered dioxin at 50, 500 or 1,COO ppb
exhibited 100% mortality by the fourth week.

In another study (Kociba et al. 1978), groups of 100 Sprague-Dawley rats
(50 males and 50 females) received diets containing dioxin at 0, 22, 210, or
2,220 ppt (equivalent to a daily dose of 0.0, 0.001, 0.01 and 0.1 yg/kg bw)
for two years. - Administration of 0.01 yg/kg/day increased the incidence of
hepatocellular hyperplastic nodules (female: 18/50 versus 8/86 controls) and
focal alveolar hyperplasia in the lungs (P<0.05).  Dietary intake of
0.1 yg/kg/day increased the incidence of hepatocellular carcinomas (female:
11/49 versus 1/86) and squamous cell carcinomas of the lung (female: 7/49
versus 0/86), hard palate/nasal turbinates (male: 4/50 versus 0/85; female:
4/49 versus 0/86), and tongue.(male: 3/50 versus 0/85) (P<0.05).  Also in-
creased in frequency by the 0.1 yg TCDD/kg/day were adenoma of the adrenal
cortex (male) and hepatocellular hyperplastic nodules (female).

The NTP (1982a) conducted a study for 104 wk using Osborne-Mendel rats and
B6C3F1 mice.  The rats and male mice were administered TCDD at 0, 0.01, 0.05
or 0.5 yg/kg/wk by gavage in two divided doses, and the female mice were given
0, 0.04, 0.2, or 2.0 yg/kg/wk.   Incidences of follicular cell thyroid adenomas
in male rats (P<0.001) and of neoplastic nodules in livers of female rats
(P=0.006) increased significantly.  Dioxin increased the numbers of hepato-
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                            TABLE 4-3  SUMMARY OF CARCINOGENIC EFFECTS OF DIOXIN
Species/Sex
 (Number)
Rat/
  M (50)
  F (50)
    Dose
Rat/M (10)    1 ppt
Rat/M (10)    5-500 ppt
Rat/M (10)    1-5 ppb
0.001 Ug/kg

0.01 Ug/kg

0.1 pg/kg
 Duration
                78 wk
2 yr
Route
             Diet
Diet
             Effects
Reference
         No neoplasm.
                                   Van Miller et al.
                                   (1977)
Ear duct carcinoma, benign tumor
of the kidney and testes,
lymphocytic leukemia, skin
carcinomas and benign muscle
tumors.

Cholangiocarcinoma of liver,
squamous cell tumor of lung,
angiosarcoma in skin, glioblas-
toma in brain, malignant histio-
cytomas in peritoneum.

No significant increase in tumors. Kociba et al.  (1978)

Liver cancer.

Liver cancer, squamous cell car-
cinoma of the lung, hard palate/
nasal turbinates, or tongue
(P=0.05).
Mouse/F (30)  0.015 ug/kg/wk  99-104 wk    Dermal
Mouse/M (30)  0.003 pg/kg/wk  99-104 wk    Dermal
Rat/M (50)    0.5 pg/kg/wk    104 wk
Rat/F (50)    0.5 pg/kg/wk    104 wk
                             Gavage


                             Gavage
                      Fibrosarcoma in integumentary
                      system (8/27, P=0.007).

                      Fibrosarcoma in integumentary
                      system (6/28, P=0.08)

                      Follicular cell adenomas of
                      thyroid (10/50, P=0.001).

                      Neoplastic nodules of the liver
                      (12/49, P=0.006).
                                                                         NTP (1982b)
                                            NTP (1982a)
                                                                                   continued-

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Table 4-3 - continued
Species/Sex
 (Number)
    Dose
Duration    Route
Mouse/M&F     2.0 yg/kg/wk    104 wk
Mouse/F
2.0 yg/kg/wk    104 wk
Mouse/M (39)  0.007 ug/kg/wk  52 wk


Mouse/M (44)  0.7 ug/kg/wk    52 wk

Mouse/M (44)  7.0 yg/kg/wk    52 wk
            Gavage



            Gavage


            Gavage


            Gavage

            Gavage
             Effects
Hepatocellular carcinoma
(17/50. P=0.002 in M);
(6/47, P=0.14 in F).

Follicular cell adenomas of the
thyroid (5/46, P=0.009)
  !
Liver tumors (13/44, P not
specified
                                      Li
                                      Li
Adapted from Esposito et al. (1980), NTP (1982a,b).
   er tumors (21/44, P<0.01)

   er tumors (13/43, P=0.11)
Reference
                                                                         NTP (1982a)
                                                                         Toth et al. (1979)

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cellular carcinomas in male mice (P=0.002) and in females (P=0.014).  The
total liver tumors (carcinomas and adenomas) were increased in males (P<0.001)
and females (P=0.002).  In addition, female mice had increased incidence of
follicular cell thyroid adenomas.  These studies indicate that TCDD is an
animal carcinogen.

Toth et al. (1979) administered doses of 0, 0.007, 0.7 and 7.0 yg/kg/wk of
dioxin to male mice by gavage in a study to determine whether 2,4,5-trichloro-
phenoxyethanol (2,4,5-TCPE), its contaminant (dioxin) or both were carcino-
genic.  The incidence of liver tumors was significantly increased in the dose
group receiving dioxin at the 0.7 yg/kg/wk level.  No significant increased
incidence in liver tumors was observed in the 7.0 yg/kg/wk dose group although
increased mortality in this group probably precluded detection of tumors with
longer latent periods.

The NTP (1982b) conducted a skin painting cancer bioassay of dioxin on Swiss-
Webster mice (50 of each sex/dose).  A dose of 0.001 yg/application (males)
and 0.005 tig/application (females) in acetone suspension was painted on the
skin 3 days/wk for 104 wk.  The vehicle control group (45 mice/sex) was
painted with 0.1 mL acetone 3 times/wk for 104 wk.  The incidence of fibro-
sarcoma in the integumetary system was significantly increased in females
(8/27, P=0.007) but not in males (6/28, P=0.08) compared to the incidence
respective controls (2/41 and 3/42).

DiGiovanni et al. (1977) reported tha-t dioxin was a-tumor initiator in mouse
skin.  However-j—the ro-le of dioxin-as—an initiator needs to be confirmed since
appropriate vehicle and prpmotion-only controls were not included in this
assay.. Several assays (NTP 1982b, Berry et al. 1978, 1979) demonstrated that
dioxin was not a tumor-promoter when applied to mouse skin after unknown
initiator  (DMBA).

Poland and Knutson (1982) reported that dioxin was a tumor promoter when
tested on the skin of mice homozygous for the "hairless" trait but not in mice
heterozygous for this recessive trait.  Pitot et al. (1980) also reported that
dioxin was a promoter for DEN-initiated hepatocarcinogenesis in rats following
parenteral administration of the compounds.  On mouse skin, dioxin was a
complete -carcinogen and possibly a tumor initiator, while no tumor-promoting
activity could be attributed to dioxin in the assays.  In rat liver initiated
with DEN, dioxin was a tumor promoter.

In the mouse skin bioassay, initiation with simultaneous administration of
dioxin and DMBA, however, did not affect tumor yield (DiGiovanni et al. 1977).
Similarly no effect was observed when dioxin was administered either immedi-
ately before (five minutes) or one day after DMBA initiation (Berry et al.
1979, DiGiovanni et al. 1977, Cohen et al. 1979).  When treatment with dioxin
occurred one to ten days before DMBA initiation, dioxin demonstrated a potent
anticarcinogenic action.  Although one to five days prior exposure to dioxin
inhibited  tumor initiation by BaP, 3-MC, and BaP-diol-epoxide, the tumor-
initiating ability of the latter compound was also inhibited when dioxin
exposure occurred either five minutes before or one day after initiation
(DiGiovanni et al. 1980).  The increased AHH activity resulting from dioxin
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 exposure may account for the anticarcinogenic activity by altering the
 metabolism of the initiating compound; however, DiGiovanni et al. (1980)
 suggests that the initiation of the initiating activity of BaP-diol-epoxide
 one day after initiation indicates that more than one mechanism participates
 in the anticarcinogenic activity of dioxin.

 4.7       Quantitative Indices of Toxicity

 4.7.1     Noncarcinogenic Effects Indices

 Recommended exposure limits to dioxin to ensure human safety have been
 established by several agencies.  The National Academy of Sciences (NAS 1977),
 before TCDD was considered to be a carcinogen, suggested an ADI for dioxin of
 0.0001 yg/kg/day based on a 13-wk feeding study in rats (Kociba et al. 1976).
 The reported NOEL in that study (0.01 yg/kg) was divided by an uncertainty
 factor of 100 to determine the ADI.  The NAS then calculated a suggested-
 no-adverse-effeet-level (SNARL) in drinking water of 0.0007 yg/L, based on the
 average weight of a human adult (70 kg) and an average daily intake of water
 of two liters, with water representing 20% of total intake.

 The USEPA (1984) has calculated an ADI of 10~~  yg/kg/day based on noncarcino-
 genic toxicity for comparison to the carcinogenic risk assessment value.  A
 LOAEL based on noncarcinogenic toxic effects and reduced fertility of
 0.001 ug/kg/day and an uncertainty factor of 1,000 were used in the cal-
 culations.  Using a bioaccumulation factor of 5,000, and assuming a daily
 consumptioir-of 6.5 g of fish, a water concentration of 2.0 x 10   Ug/L was
 derived.  It was noted thac this value may not be sufficiently low Co protect
 against the carcinogenic effects of dioxin (USEPA 1984).  The USEPA is
 currently reevaluating the bioconcentration factor for dioxin.

 The USEPA (1984) concluded that insufficient data were available concerning
 adverse effects of dioxin on aquatic life to allow derivation of ambient water
 quality criterion.  Limited information in freshwater species indicate acute
 values may be >0.1 ug/L and chronic values may be <0.01 yg/L (northern pike,
 coho salmon, mosquito fish and channel catfish) and <0.001 yg/L (rainbow
 trout).

-4.7.2     Carcinogenic Effects Indices

 Since there is no recognized safe concentration for a human carcinogen, and
 dioxin is a suspected human carcinogen, the recommended concentration of
 dioxin in water is zero (USEPA 1984).  The USEPA calculated a range_o>f   _fi
 concentrations for dioxin corresponding to cancer risk levels of 10   , 10
 and 10  .  These calculations used a linearized multistage model and were
 based on animal bioassay data. -The recommended criteria which may result in
 an increased cancer risk of 10  , 10   or 10   are 1.3 x 10~ , 1.3 x  10~  and
 1.3 x 10 ' yg/L, respectively.  These criteria are beiow the limit of
 detection of TCDD in water (approximately 3 x 10~  yg/L) by current analytical
 methods.
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The Food and Drug Administration (FDA)  issued a health advisory  stating that
fish with residues of dioxin ^50 ppt should not be  consumed,  but fish with
residues of < 25 ppt pose no serious health concern (USEPA 1984). The Centers
for Disease Control (CDC) has established 1 ppb as  a level of concern for
dioxin in residential soils at Times Beach, MO.
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5.0       RISK AND IMPACT EVALUATION

5.1       Human Health

Dioxin contamination from the Vertac site presents endangerment to human
health.  Ingestion of fish from Bayou Meto or Lake Dupree that have bio-
accumulated dioxin will substantially increase cancer risks in humans.
Limited monitoring data indicate that dioxin has bioaccumulated in fish to
levels that are up to 16 times greater than the FDA's health advisory value of
^50 ppt for dioxin residue in fish.  Thus, fish are considered unsafe for
human consumption.  The efficacy of the fishing ban on Bayou Meto is uncertain
since it is not easily enforced. : Individuals that may consume large quanti-
ties of fish from Lake Dupree, Bayou Meto or the Rocky Branch Creek are
considered at higher risk.

Groundwater contaminated with dioxin potentially poses an unacceptable cancer
risk to humans.  The actual risk via the groundwater route is probably minimal
due to an apparent lack of exposure potential.  However, this route could
result in substantial carcinogenic risk if groundwater contaminated at 0.03 ppb
dioxin (the highest detected level in groundwater on-site) were consumed.
Assuming the 70-kg human would consume two liters of water per day then the
dose would be 0.0009 yg/kg/day (0.9 ng/kg/day).  Consumption of a dioxin dose
of 0.9 ng/kg/day over a lifetime poses unacceptable carcinogenic risk exceed-
ing the 10~  risk associated with consumption of water with a dioxin concen-
tration of 1.3 x 10   ug/L (3.7 x 10   Og/kg/day or 0.0000037 ng/kg/day).
Consumption of drinking wa-t-er containing 0.005 ppb dioxin (the mean detected
concentration) would result in a dose of 0.0001 ug/kg/day (0.1 ng/kg/da_y)
which would also pose unacceptable carcinogenic risk exceeding the 10   level.
The lower bound estimate of induced cancers is zero since consumption may not
occur and because recent analyses have not detected dioxin in groundwater
monitoring wells.
                              /'
Other potential risks to human health may result from inhalation exposures to
dioxin-contaminated dust from natural wind erosion and/or from the proposed
remedial action (Alternative IV) involving excavation, loading/unloading,
transporting and spreading dioxin-contaminated soils and materials at the
Vertac site.  Monitoring data on wind-generated dioxin contaminated dust
emissions were not available to estimate exposures and to assess human health
risks for a no action alternative or the present endangerment level.  The
health risk associated with exposures via wind-erosion is anticipated to be
minimal relative to that associated with the remedial action (Falco and Schaum
1984).  The residents to the south of the site are expected to be at greatest
risk due to their proximity to the site (Falco and Schaum 1984).  The risk
associated with inhalation of dioxin-contaminated dusts will decline with
distance from the site.

The potential for direct contact with contaminated soils and sediments poses
human health risks.  Monitoring data indicate that levels of dioxins in soils
and sediments off-site exceed the CDC's 1 ppb level of concern for residential
soils established for Times Beach, MO.
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5.2       Environmental

There are potential risks to aquatic and terrestrial species related to dioxin
releases from the Vertac site.  The absence of benthic life, several massive
fish kills and reported "medicinal" taste and odor of fish caught from Bayou
Meto (receiving waters of the Rocky Branch Creek) reflect the impact of
contaminants released from the Vertac site on aquatic life (JRB. 1983).  The
limited environmental monitoring data for sediments in the Rocky Branch Creek,
Bayou Meto and Lake Dupree indicate substantial dioxin contamination has
occurred.  Analyses of- fish tissues demonstrates that dioxin has been bio-
accumulated to substantial levels  (up to 300 ppt in Bayou Meto and 810 ppt in
Lake Dupree) but the health significance of such tissue levels and potential
impact on survival, growth, development and reproduction of aquatic life
remains unknown.  The absence of ambient water quality criteria and especially
criteria for dioxin levels in sediments impedes performance of a quantitative
assessment of potential effects on aquatic organisms.

There is a paucity of monitoring data on the concentration of dioxin in
surface waters offsite.  The only data available indicate that dioxin was not
detected in water from the Rocky Branch Creek.  Therefore, it is not possible
to compare dioxin concentrations in receiving water to levels causing acute
toxicity (>1.0 ppb) in certain freshwater species or chronic toxicity in the
rainbow trout (<0.001 ppb) or in several other fish species (<0.01 ppb).

The high content of dioxin in" sediments (500 ppt ave) in the Rocky Branch
Creek and poten-6-ial for release to the water column suggests 'that aquatic
organisms may be at risk.  No existing guidelines or standards are available  -.
to determine risks to avian or terrestrial organisms.  The potential impact of
contamination on such species is of concern since the Bayou Meto area serves
as an important water fowl resting area and contains about 70,000 acres of
wetlands.  Limited data are available on the avian species and terrestrial
species present in the area.  Contamination of the Bayou Meto and accumulation
of dioxin in the aquatic food chain may endanger predator (avian or terres-
trial) species.

5.3       Public Welfare

The major socioeconomic impact of  the release of dioxin from the Vertac site
has been the loss of adjacent surface waters for fishing and recreation.  For
example, the release of dioxin to  the Rocky Branch Creek and Bayou Meto and
transport to Lake Dupree during flooding has caused fish to accumulate
(810 ppt) dioxin in excess of the  FDA health advisory value of ^50 ppt.  Thus,
fish from Lake Dupree may be unfit for human consumption.  This contamination
of fish has required the Arkansas  public health officials to issue a fishing
ban for the Bayou Meto area.  An additional impact on public .welfare may be a
potential decrease of property values immediately adjacent to the site  (i.e.,
especially residential property values) and the loss of groundwater aquifers
as a potential source of drinking  water.
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6.0       CONCLUSIONS

The most significant endangerment of human health is due to the potential
consumption of dioxin-contaminated fish from Bayou Meto.  Limited environ-
mental monitoring data indicate that residues of dioxin in fish from Bayou
Meto and Lake Dupree may exceed the FDA's health advisory value of ^50 ppt
dioxin by about 16 times.  Populations that consume large quantities of fish
from Bayou Meto, Rocky Branch or Lake Dupree are expected to have increased
cancer risk.  The fishing ban for Bayou Meto may reduce this threat to human
health, but its efficacy is unknown since it is not easily enforced.

The contamination of groundwater represents another substantial potential
threat to human health.  There is a real potential for offsite migration of
contaminants to groundwater.  A maximum concentration of 0.03 ppb and a mean
of 0.005 ppb of dioxin have been detected in onsite groundwater monitoring
wells.  Actual exposures to humans via this route is currently considered
unlikely since no permitted domestic and industrial wells were located in the
area immediately downgradient of the site.  Human health may be endangered if
water wells are drilled in the future and used for drinking water purposes.
Assuming humans may potentially consume groundwater in the future, the result-
ing dose of dioxin would increase risk of cancer substantially above the 10
level.  Further groundwater monitoring data are necessary to verify and
characterize the magnitude and extent of any offsite contamination.

Exposure to dioxin via inhalation of dust-emissions from .the proposed remedial
action is anticipated to present_an increased cancer jrisk for residents near
the Vertac site.  Risks associated with inhalation of dioxin-contaminated dust
will diminish with distance from the site.  Demographic information on the
size of this population was unavailable.  Risks associated with wind-generated
dust emissions are expected to be minimal due to remedial actions already
implemented.  Detection of dioxin in soils and sediments in excess of the
CDC's 1 ppb health concern level for residential soils (established for Times
Beach, MO) indicates potential risks associated with direct contact (dermal
and ingestion) exposures.

Assessment of risks to aquatic and terrestrial organisms was difficult due to
limited environmental monitoring data and the unavailability of established
ambient water criteria.  Massive fish kills, dioxin bioaccumulated in fish and
the absence of benthic life suggest potential impacts on aquatic life.

Loss of fishing in the Bayou Meto area impacts the public welfare.  Addi-
tionally decrease of property values adjacent to the site or along the bayou
may impact the economic stability of the area.  Contamination of groundwater
may prevent its future use as a drinking water resource.
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7.0       REFERENCES

Aldred JE.  1978.  Report of the Consultative Council on Congenital
Abnormalities in the Yarrom District.  Minister of Health, Melbourne,
Victoria, Australia.

Allen JR, Barsotti DA, Van Miller JP, Abrahamson LJ, Lalich JJ.  1977.
Morphological changes in monkeys consuming a diet containing low levels of
TCDD.  Food Cosmet. Toxicol. 15:401.

Anaizi NH, Cohen J.  1978.  The effects of TCDD on the renal tubular secretion
of phenolsulfonphthalein.  J. Pharmacol. Exp. Ther. 207(3):748-755.

Bogen G.  1979.  Symptoms of Vietnam veterans exposed to Agent Orange.   J. Am.
Med. Assoc. 242:2391.

Branson DR, Takahashi IT, Parker WM, Blau GE.  1983.  Bioconcentration
kinetics of 2,3,7,8-tetrachlorodibenzo-p-dioxin in rainbow trout.  Abstract.
Midland, MI:  Dow Chemical U.S.A.  September 28.

Callahan MA, Slimak MW, Gable NW, et al.  1979.  Water related environmental
fate of 129 priority pollutants.  Washington, DC:  U.S. Environmental
Protection Agency.  EPA-440/4-79-029.

Caramaschi F, del Crono G, Favarett C, Giambelluca SE, Montesarchio E,  Fara
GM.  1981.  Chloracne following environmental contamination by TCDD in Seveso,
Italy. Int. J. Epidemiol.  10:135-143.

Cook RR, Townsend JC, Ott MG, Silverstein LG.  1980.  Mortality experience of
employees exposed to 2,3,7,8-tetrachlorodibenzo-p-dioxin  (TCDD).  J. Occup.
Med. 22:530-532.

CH2M Hill.  1984a.  Onsite feasibility study appendicies:  Vertac facility.
Site No. 66-GL04.0 Draft.  EPA Contract No. 68-01-6692.  Washington, DC:  U.S.
Environmental Protection Agency.  March 31.

CH2M Hill.  1984b.  Onsite feasibility study appendicies:  Vertac facility.
Site'No. 66-GL04.0 Draft.  EPA Contract No. 68-01-6692.  Washington, DC:  U.S.
Environmental Protection Agency.  April 11.

Courtney KD, Moore JA.  1971.  Teratology studies with 2,4,5-T and 2,3,7,8-TCDD.
Toxicol. Appl. Pharmacol. 20:396-403.

Cowherd C, Muleski G, Englehart P, Gillette D.  1984.  Rapid assessment of
exposure to particulate emissions from surface contamination sites.  EPA
Contract No. 68-01-3116.  April 20.

Crosby DG, Wong AS, Plimmer JR, Woolson EA.  1971.  Photodecomposition of
chlorinated dibenzo-p-dioxins.  Science 173:748-749.
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                                                                  Jtift'Systems, JHC.
Crosby DG, Wong AS.  1977.  Environmental degradation of 2,3,7,8-tetrachloro-
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Crow K.  1978.  Chloracne:  the chemical disease.  New Sci. 78:78-80.

Crow K.  1981.  Chloracne and its potential clinical implications;  Clin. E.-vy.
Dermatol. 6:243-257.

Cunningham HM, Williams DT.  1972.  Effect of 2,3,7,8-tetrachloro-
dibenzo-p-dioxin on growth rate and the synthesis of lipids and proteins in
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Department of Health, New Zealand.  1980.  Report to the administrator of
health of an investigation into allegations of an association between human
congenital defects and. 2,4,5-T spraying in and around Kuite, New Zealand.  NZ
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Esposito MP, Tiernan TO, Dryden FE.  1980.  Dioxins.  Industrial Environmental
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Falco JW.  1982.  Exposure and risk analysis of Vertac facility, Jacksonville
Arkansas.  Memorandum to L. Miller.  Washington, DC:  U.S. Environmental
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Falco J, Schaum J.  1984.  Assessment of risk caused by remedial actions
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Field B, Kerr C.  1979.  Herbicide use and incidence of neural-tube defects.
Lancet 1:1341-1342.

Fries GF, Marrow GS.  1975.  Retention and excretion of 2,3,7,8-tetrachloro-
dibenzo-p-dioxin by rats.  J. Agric. Food Chem. 23:265-269.

Gasiewicz TA, Olson, JR, Geiger LE, Neal RA.  1983.  Absorption, distribution
and metabolism of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) in experimental
animals.  In:  Tucker RE, Young AL, Gray AP, ed.  Human and environmental
risks of chlorinated dioxins and related compounds.  New York:  Plenum Press,
pp. 495-525.

Geiger LE, Neal RA.  1981.  Mutagenicity testing of 2,3,7,8-tetrachloro-
dibenzo-p-dioxin in histidine auxotrophs of Salmonella typhimurium.  Toxicol.
Appl. Pharmacol. 59(1):125-129.

Cianotti F.  1977.  Chioracne due to tetrachlpro-2,3,7,3-dibenzc-p-dioxin in
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                                                                  Jtife Systems, jnc.
Goldstein JA, Linko P, Bergman H.  1982. 'Induction of porphyria in the rat by
chronic versus acute exposure to 2,3,7,8-tetrachlorodibenzo-p-dioxin.
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Green S, Moreland F, Shen C.  1977.  Cytogenetic effects of 2,3,7,8-TCDD on
rat bone marrow cells.  Food and Drug Administration Bylines 6:292-294.

Greig JB, Jones G, Butler WH, Barnes JM.  1973.  Toxic effects of
2,3,7,8-TCDD. Food Cosmet. Toxicol. 11:585-595.

Gupta BN, Vos JG, Moore JA, Zinkl JG, Bullock BC.  1973.  Pathologic effects
of 2,3,7,8-tetrachlorodibenzo-p-dioxin in laboratory animals.  Environ. Health
Perspect. 5:125-140.

Hamaker JW.  1978.  Interpretation of soil leaching experiments, republished
in Volume I of Chemicals, Human Health and the Environment, p. 24.

Hanify JA, Metcalf C, Nobbs L, Worsley JR.  1981.  Aerial spraying of 2,4,5-T
and human birth malformations:  An epidemiological investigation.  Science
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clinical observation.  Lakartidningen. 74:2753-5754.

Hardell L, Eriksson M.  1981.  Soft-tissue sarcomas, phenoxy herbicides and
chlorinated phenols.  Lancet ii:250.

Harris MW, Moore JA, Vos JG, Gupta BN.  1973.  General biological effects of
TCDD in laboratory animals.  Environ. Health Perspect. 5:101-109.

Helder T.  1980.  Effects of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) on
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Helder T.  1981.  Effects of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) on
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Holden C.  1979.  Agent Orange furor continues to build.  Science 205:770-772.

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Honchar PA, Halperin WE.  1981.  2,4,5-T, trichlorophenol and soft tissue
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                                                                   jtjfe'Systems, Jnc.
 Hook  JB,  et  al.  1978.  Renal effects of  2,3,7,8-TCDD.  Environ.  Sci. Res.
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 Huetter R, Phillippi M.   1982.  Studies  on microbial metabolism  of TCDD under
 laboratory conditions.  Pergamon  Ser. Environ. Sci. 5:87-93.

 Hussain SL,  Ehrenberg L,  Lofroth  G, Gejvall T.   1972.  Mutagenic effects of
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 IARC.   1977.   International Agency for Research  on Cancer.  IARC Monographs  on
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 Ideo  G, Bellati  G, Bellouono A, Mocarelli P, Marocchi A, Brambilla P.   1982.
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 Isensee AR,  Jones  GE.  1975.  Distribution of 2,3,7,8-tetrachlorodibenzo-p-
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 Kearney PC,  Woolson EA, Ellington CP, Jr.  1972.  Persistence and metabolism
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                                                                  £ife Systems, Jnc.
Kociba RJ, Keeler PA, Park CN, Gehring PJ.  1976.  2,3,7,8-tetrachloro-
dibenzo-p-dioxin (TCDD)-Results of a 13-week oral toxicity study in rats.
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Kociba RJ, Keyes DG, Beyer JE, et al. 1978.  Results of a two-year chronic
toxicity and oncogenicity study of 2,3,7,8-tetrachlorodibenzo-p-dioxin in
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Kociba RJ, Keyes DG, Beyer JE, Carreon RM, Gehring PJ.  1979.  Long-term
toxicologic studies of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) in
laboratory animals.  Ann. NY Acad. Science 320:397-404.

Luster MI, Boorman GA, Dean JH, et al.  1980.  Examination of bone marrow,
immunologic parameters and host susceptibility.following pre- and postnatal
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Immunopharmacol. 2(4):301-310.

Manara L, Coccia P, Croci T.   1982.  Persistent  tissue levels of TCDD in the
mouse and their reduction as related to prevention of toxicity.  Drug Metab.
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Matsumura F, Benezet HJ.  1973.  Studies on the  bioaccumulation and microbial
degration of 2,3,7,8-tetrachlorodibenzo-p-dioxin.  Environ. Health Perspect.
5:253-258.

Matsumura F. Quensen J. Tsushimoto G.  1983.  Microbial degradation of TCDD in
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environmental  risks of chlorinated dioxins and related compounds.  New York:
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May  G.  1973.  Chloracne from  the accidental production of tetrachlorodi-
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McConnell EE,  Moore JA, Dalgard DW.   1978a.  Toxicity of 2,3,7,8-tetrachloro-
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McConnell EE,  Moore JA, Haseman JK,  Harris MW.   1978b.  The  comparative
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Michigan  Department  of Public  Health.   1983.   Evaluation of  soft and
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                                                                  fife'Systems, JHC.
Miller RA, Norris LA, Hawkes CL.  1973.  Toxicity of 2,3,7,8-tetrachlorodibenzo-
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Miller RA, Norris LA, Loper BR.  1979.  The response of coho salmon and
guppies to 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) in water.  Trans. Am.
Fish. Soc. 108:401-407.

Moore JA, Gupta BN, Vos JG.  1976.   Toxicity of 2,3,7,8-tetrachlorodibenzo-
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Moses M, Selikoff I.  1981.  Soft tissue sarcomas, phenoxy herbicides and
chlorinated phenols.  Lancet i:1370.

Murray FJ, et al.  1978.  Three generation reproduction study of rats
ingesting TCDD.  Toxicpl. Appl. Pharmacol. 41:200-201.

Murray FJ, Smith FA, Nitschke KD, Humiston CG, Kociba RJ, Schwetz BA.  1979.
Three-generation reproduction study  of rats given 2,3,7,8-tetrachloro-
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NAS.  1977.  National Academy of Sciences.  Drinking water and health.
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Nash RG, Beall ML, Jr.  1980.  Distribution of Silvex, 2,4-D, and TCDD applied
to turf in chambers and field plots.  J. Agric. Food Chem. 28:614-623.

Neal RA, Olson JR, Gasiewicz TA, Geiger LE.  1982.  The toxicokinetics of
2,3,7,8-tetrachlorodibenzo-p-dioxin. in mammalian systems.  Drug Metab. Rev.
13:355-385.

Nelson CJ, Holson JF, Green HG, Gaylor DW.  1979.  Retrospective study of the
relationship, between agricultural use of 2,4,5-T and cleft palate occurrence
in Arkansas.- Teratology 19:377-384.

Nisbit ICT,.Paxton MB.  1982.  Statistical aspects of three-generation studies
of the reproductive toxicity of TCDD and 2,4,5-T.  Am. Stat. 36:290-298.

Nolan RJ, Smith FA, Hefner JG.  1979.  Elimination and tisaue distribution of
2,3,7,8-tetrachlorodibenzo-p-dioxin  (TCDD) in female guinea pigs following a
single oral dose.  Toxicol. Appl. Pharmacol. 48:A162.

Norris LA, Miller RA.  1974.  The toxicity of 2,3,7,8-tetrachloro-dibenzo-p-
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Contain. Toxicol. 12:76-80.

NTP.  1982a.   National Toxicology Program.  Carcinogenesis bioassay of
2,3,7,3-cetrachiorodibenzo-p-dioxin  in Osborne-Mendel rats and 36C3F1 mice
(Gavage Study).  Tech. Rpt. Ser. No. 209.  NIH.  Pub. No. 82-1765.
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                                                                  &{e Systems, JHC.
NTP.  1982b.  National Toxicology Program.  Carcinogenesis bioassay of
2,3,7,8-tetrachlorodibenzo-p-dioxin in Swiss-Webster mice (dermal study).
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NRCC. 1981.  National Research Council of Canada.  Polychlorinated
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Olson JR, Bittner WE.  1983.  Comparative metabolism and elimination of
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD).  The Toxicologist 3:103.

Olson JR, Gasiewicz TA, Neal RA.  1980.  Tissue distribution, excretion, and
metabolism of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) in the Golden Syrian
hamster.  Toxicol. Appl. Pharmacol. 56:78-85.

Passi S, Nazzaro-Porro M, Boniforti L, Gianotti F.  1981.  Analysis of lipids
and dioxin in chloracne due to tetrachloro-2,3,7,8-p-dibenzodioxin.  Br. J.
Dermatol. 105:137-143.

Perwak J, Eschenxoeder A, et al.  1980.  An exposure and risk assessment for
2,3,7,8-TCDD.  Interim draft report.  Washington, DC:  U.S. Environmental
Protection Agency, pp. 48-57.  EPA Contract No. 68-01-3857,

Piper WN, Rose RQ, Gehring PJ.   1973.  Excretion and tissue distribution of
2,3,7,8-tetrachlorodibenzo-p-dioxin in the rat.  Environ. Health Perspect.
5:241-244.

Pitot HC, Goldsworthy T, Poland  H.  1980.  Promotion by 2,3,7,8-tetrachloro-
dibenzo-p-dioxin of hepatocarcinogenesis from diethylnitrosamine.  Cancer Res.
40:3616-3620.

Pocchiari F, Silano V, Zampieri  A.  1979.  Human health effects from
accidental.release of tetrachlorodibenzo-p-dioxin (TCDD) at Seveso, Italy.
Ann. NY Acad. Sci. 320:311-320.

Poiger H, Schlatter C.   1980.  Influence of solvents and adsorbents on dermal
and intestinal absorption of TCDD.  Food Cosmet. Toxicol. 18:477-481.

Poiger H, Weber H, Schlatter C.   1982.  Special aspects of metabolism and
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Pocchiari F, eds.  Chlorinated dioxins and related compounds.  Impact on the
environment.  New  York:  Pergamon Press, pp. 317-325.
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                                                                  &fe Systems, J
Poland A, Knutson JC.  1982.  2,3,7,8-Tetrachlorodibenzo-p-dioxin and related
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Sawahata T, Olson JR, Neal RA.  1982.  Identification of metabolities
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Toth K, Somfai-Relle S, Sugar J, Bence J.  1979.  Carcinogenicity testing of
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Publishing Corp.
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                                                                 £ifc Systems, Jnc.
Young AL, Kang HK,  Shepard BM.   1983.   Chlorinated dioxins as herbicide
contaminants.   Environ.  Sci.  Technol.  17:530A-539A.

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J. Occup. Med. 22:11-14.
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                         Attachment 5


1. Physical Description of the Site and Site History

   a.  geographic location
   b.  management practices/site use/site modifications
   c.  chronological survey
   d.  facility description/containment systems
   e.  substances brought on site (identity, quantity,  form
       manner of disposal)

2. Site Contamination/Off-Site Contamination

   a. identity of substances detected
   b. concentration of substances detected
   c. analytical methodology and QA/QC
  . d. survey of environmental monitoring studies (detailed
      discussion of environmental media and contamination
      levels)

3. Environmental Fate and Transport

   a. physical-chemical properties of specified chemicals/
      substances (e.g., soil/sediment adsorption coefficients,
      vapor pressures, solubility, etc.)  .
   b. photodegradation rates, decomposition rates,  hydrolysis' rates,
      chemical-transformations, etc.    •
   c. local topography
   d. description of the hydrological setting and flow system
   e. soil analyses
   f. climatic factors, other factors affecting fate and
      transport
  . g. prediction of fate and transport (where necessary using
      modeling methods)

4. Toxicological Properties (hazard identification)

   a. metabolism
   b. acute toxicity
   c. subchronic toxicity
   d. chronic toxicity
   e. carcinogenicity
   f. mutagenicity
   g. teratogencity/reproductive effects
   h. other health effects as relevant including neurotoxicity,
      immuno-depressant activity, allergic reactions, etc.
   i. epidemiological evidence (chemical specific or site
      specific)
   j. aquatic/non-human terrestrial species toxicity/
      environmental quality impairment
   k. human health standards and criteria

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                          -2-
5. Exposure Assessment

   a. demographic profile of populations at risk including
      subpopulation at special risk
   b. background chemical exposures
   c. life style and occupation histories
   d. population macro-and micro-environments
   e. exposure routes
   f. magnitude, source, and probability of exposure
      to specified substances

6. Risk Evaluation and.Impact Evaluation

   a. carcinogenic risk assessment
   b. probability of non-carcinogenic human health
      effects
   c. non-human species risk assessment
   d. environmental impacts/ecosystem alterations

7. Conclusions

8. Documentation (Appendices)

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                                             iCife Systems, Jnc.
PART 3 - LEVEL  3  ENDANGERMF.NT ASSESSMENT
                  A2-6

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                                                               £ift Systems, JHC.
                             Submitted to:

                  Office of Waste Programs  Enforcement
                  U.S. Environmental Protection Agency
                            401 M Street,  SW
                          Washington,  DC  20460

Attention:  Chief, Health Sciences Section,  R.  Charles Morgan  (2  cop-ies)
                   VERTAC SITE ENDANGERMENT  ASSESSMENT

                             (Level 3  Example)
                             Prepared  Under


                      	Program No.-1S93-

                                   for

                         Contract No.  68-01-7037


                         Work Assignment  No.  12


                       PRC Work Assignment No. 136
                       Contact:   Timothy  E. Tyburski

                        Telephone:   (216)  464-3291
                              July  25,  1985

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                                                               JLifc bystems, M.
                                 DISCLAIMER
This document  has not been peer and administratively reviewed within EPA and
is for internal  Agency use/distribution only.

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                                                                  £ife Systems, Jnc.
                               TABLE OF CONTENTS

                                                                         PAGE

LIST OF FIGURES	-	ill

LIST OF TABLES	' .  iii

1.0  INTRODUCTION	1-1

     1.1    Site Description and History	1-1
     1.2    Contaminants Found at the Site	, .  1-3

2.0  ENVIRONMENTAL FATE AND TRANSPORT	  2-1

     2.1    Factors Affecting Migration  	  2-1

            2.1.1   Geology  	 ..........  2-1
            2.1.2   Hydrology	•	2-1
            2.1.3   Hydrogeology	2-2
            2.1.4   Climatology	 .	2-3

     2.2    Environmental Fate and Transport of Dioxin	2-3

            2.2.1   Environmental Fate	2-3
            2.2.2   Environmental Transport  ...	—T .  .  . .  2-5

     2.3    Contaminant Movement On Site and Off Site	2-6

3.0  EXPOSURE EVALUATION	3-1

     3.1    Routes of Exposure	/.  . .  3-1

            3.1.1   Fish Consumption	3-1
            3.1.2   Groundwater	3-1
            3.1.3   Airborne Dust	3-2
            3.1.4   Direct Contact with Contaminated  Soils/Sediment  . .  3-2

     3.2    Populations Exposed  	  3-2

            3.2.1   Fish Consumption	3-2
            3.2.2   Groundwater	3-3
            3.2.3   Airborne Dust	3-3
            3.2.4   Direct Contact	3-5

     3.3    Extent of Exposure	3-5

            3.3.1   Fish Consumption	3-5
            3.3.2   Groundwater	3-5

                                                            continued-

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                                                                  £ife Systems, Jnc.
Table of Contents - continued

                                                                         PAGE

            3.3.3   Airborne Dust	3-7
            3.3.4   Direct Contact	3-7

4.0  TOXICITY EVALUATION 	  4-1

     4.1    Pharmacokinetics	4-1
     4.2    Acute Toxicity	4-1

            4.2.1   Toxicity in Humans	 .  .	4-1
            4.2.2   Toxicity in Laboratory Animals 	  4-2
            4.2.3   Toxicity in Aquatic Species  	  4-3

     4.3    Subchronic and Chronic Toxicity  	  4-3

            4.3.1   Toxicity in Humans . •	-. .  4-3
            4.3.2   Toxicity in Laboratory Animals 	  4-3
            4.3.3   Toxicity in Aquatic Species  	  4-7

     4.4    Teratogenicity, Reproductive Effects and Fetotoxicity  .-. .  4-7

            4.4.1   Effects of Humans	•.*....  4-7
          -—4-;-4-. 2   Effects in Laboratory Animals  . —»-	4-8

     4.5    Mutagenicity	4-9
     4.6    Carcinogenicity	4-9

            4.6.1   Carcinogenicity in Humans-  	  4-9
            4.6.2   Carcinogenicity in Laboratory Animals/ .......  4-11

     4.7    Quantitative Indices of Toxicity 	  4-15

            4.7.1   Noncarcinogenic Effects Indices  	  4-15
            4.7.2   Carcinogenic Effects Indices 	  4-15

5.0 • RISK AND IMPACT EVALUATION	"...  5-1

     5.1    Human Health	.5-1

            5.1.1   QRA for Consumption of Contaminated Fish	5-1
            5.1.2   QRA for Contaminated Groundwater	5-1
            .5.1.3   QRA for Airborne Dust	5-3
            5.1.4   QRA for Direct Contact	  5-3

     5.2    Environmental	5-3
     5.3    Public Welfare	5-5

6.0  CONCLUSIONS	6-1

7.0  REFERENCES	7-1
                                      ii

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                                                                  ttfcSystems, JMC.
                               . LIST OF FIGURES

FIGURE                         .                                          PAGE


 1-1        Vertac Site Map	1-2

 3-1        Minimum and Maximum Accumulative Exposure (ng/kg/day)
            Immediately South of the Vertac Property (Resulting
            From the Combination of Phases 1 and 2 Activities)  	  3-8

 5-1        Minimum and Maximum Accumulative Upper .Bound Risk
            Estimate Immediately South of the Vertac Property
            (Resulting from the Combination of Phase 1  and 2
            Activities	5-4
                                LIST OF TABLES
TABLE   '                .                                                 PAGE
 1-1        Ranges of Dioxin Contamination Detected On-Site at
            the Vertac Facility and in Adjacent Water Bodies 	  1-5

 3-1        Estimates of Population Size Exposed and Effects
            of Assumptions Regarding Fish Consumption Rate
            and .Fish Catch Rate	3-4

 3-2        Dioxin Concentration in Sediment,  Dioxin Concentration
            in Fish and Human Exposure by River Mile	3-6

 4-1        Effects of Dioxin in Animals Following Acute Exposure  .  .  .  4-4

 4-2        NOAEL and LOAEL Values Obtained From Subchronic and
            Chronic Oral Toxicity Studies of Dioxin  	  4-5

 4-3 „       Summary of Carcinogenic Effects of Dioxin	'.  .  4-12

 5-1        Human Exposure and Upper-Limit Cancer Risk Estimates
            by River Mile	5-2
                                     iii

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                                                                  jCife Systems, JMC.
 1.0       INTRODUCTION

 Disposal of  chemical wastes  and  discharges  of process wastewater over a
 30-yr period has  resulted  in contamination  of soils, groundwater and surface
 waters at the Vertac Chemical Corporation herbicide manufacturing  facility  in
 Jacksonville, AR.  The  release or  potential release of contaminants from  this
 site may endanger human health,  welfare and the  environment.  Human health  is
 at risk due  to  the potential for consumption of  contaminated  fish, inhalation
 of airborne  contaminants,  direct contact with contaminanted soils/sediments
 and ingestion of  contaminated groundwater.   Contaminants released  to surface
 waters have  been  bioaccumulated  to substantial levels in fish and  other
 aquatic species.

 1 • 1       Site  Description and History

 The Vertac hazardous waste site  is located  in northwest Jacksonville, AR
 (Pulaski County), approximately  20 mi northeast  of Little  Rock.  The site
 (about 93 acres in size) is  bounded by Marshall  Road to the east and the
 Missouri-Pacific  Railroad  to the west.  The old  artillery  booster  line is on
 the northern boundary and  an adjacent housing development  is  to the south.
 The Rocky Branch  Creek  flows along the western edge of the site and the East
 Branch of the Rocky Branch Creek flows to the east.of the  site.  The cooling
 pond located along the  western edge of the  site  was formed by construction  of
 an earthen dam  across the  Rocky  Branch Creek.  The Rocky Branch Creek flows
 into Bayou Meto (a tributary of  the Arkansas River) about  two miles south of
"the Vertac site.  There is a fence around the entire site  with a main gate
 facing Marshall Road.".  Figure 1-1  demonstrates the site features and
 boundaries.

 The site is  a herbicide manufacturing plant owned by the Vertac Chemical
 Corporation  which currently  produces 2,4-dichlorophenoxyacetic acid (2,4-D).
 The site has been used  since the 1930s by a variety of companies for the
 manufacture  of munitions and pesticides including DDT, aldrin, dieldrin,
 toxaphene, 2,4-D, 2,4,5-trichlorophenoxyacetic acid (2,4,5-T), 2,4,5-tri-
 chlorophenoxypropionic  acid  (Silvex or 2,4,5-TP) and Agent Orange  (a mixture
 of 2,4-D and 2,4,5-T).   The  herbicides 2,4,5-T and Agent Orange are known to
 contain 2,3,7,8-tetrachlorodibenzo-p-dioxin (hereafter referred to as dioxin
 2,3,7,8-TCDD or TCDD) as an  impurity.  Waste disposal, cooling water dis-
 charges and  other plant operations apparently resulted in  on-site  and off-site
 releases of  pesticides  and herbicides manufactured on site, chemicals used  in
 manufacturing processes and  manufacturing impurities/by-products,  including
 TCDD.

 Estimates of the  quantity  and types of contaminated materials at the Vertac
 site were reported (JRB 1983)  as follows:

                                     3           3
     1.   Thirty  thousand  (30,000)  yd  (22,800 m ) of chlorinated  phenols,
          benzene and  toluene wastes within  the Reasor-Hill  landfill.

          Twenty thousand  (20,000) yd   (15,200 m  )  of  still  bottoms,  contau
          nated with 2,3,7,8-TCDD, presently  contained  in  the  equalization
                                       1-1

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                                                                  £ifc Systems, Jnc.
                                                   ROOFED DRUM
                                                   STORAGE AREA
                                                OLD DRUM
                                                STORAGE SIT
                              HERCULES-TRANSVAAL
                  COOLING
                    POND
                                            BLOW-OUT AREA
                                                n
Barrier Walls
                                     ASOR-HILL
                                     ANOFILL
                               Barrier Walls
Central Drainage  Dicch
     French Drai
Interceptor Dice
                                                    BRAOEN STREET
                  Adapted from Walton 1982 as cited in JRB  (1983)
                           FIGURE 1-1   VERTAC  SITE MAP
                                       1-2

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                                                                  £ife Systems, Jnc.
          basin wastewater treatment system.  This amount includes the clay
          cap placed on the basin at closure.
                                           3          3
     3.   One hundred thousand (100,000) yd  (76,000 m ) of material, includ-
          ing toluene still bottoms, in the Hercules-Transvaal landfill area.

     4.   Three thousand (3,000) drums'  (55 gallons each) of 2,4,5-T still
          bottoms (repacked in 85 gallon overpack drums) and contaminated
          soils from the former above-ground storage area, stored in the
          concrete diked warehouse.

The U.S. Environmental Protection Agency (USEPA) has initiated enforcement
actions.against the site owners and required a number of remedial actions to
be implemented.  The major remedial actions completed as of 1984 are
summarized below:

     1.   The Reaspr-Hill landfill was  capped with clay, covered with soil
          and seeded with grass.  Clay  barrier walls were installed on three
          sides and the downgradient side was left open.

     2.   The Hercules-Transvaal landfill was capped with clay, covered with
          soil and seeded with grass.   No barrier walls were -installed.

     3.   The former above-ground drum  storage area was capped with clay,
          covered with soil and seeded.  The old drums were repacked and
          placed in the roofed storage  warehouse.

     4-.   Two-thirds of the blow-out area (where spills from reactors had
          occurred) was paved with asphalt and the remainder was capped with
          clay, covered with soil and seeded.

     5.   The equalization basin has been subjected to extensive remedial
          actions including dewatering  and lime solidification of sludges,
          installation of clay barrier  walls, installation of a "French drain"
          on the downgradient side, capping with clay, covering with soil and
          seeding.

Under  the proposed remedial action  (Alternative IV), the Reasor-Hill Landfill
and North Burial Area (includes old drum storage sites and Hercules-Transvaal
Landfill) will be excavated and contaminated materials/soils will be redis-
posed  of in a new on-site secure landfill in an area to the north of and over-
lapping with the North Burial Area.  This proposed remedial action will
involve excavation of 50,000 yd  of soil from the Reasor-Hill Landfill and
100,000 yd  from North Burial Areas.

1.2       Contaminants Found at the Site
                                                         •«
Contaminants found at the site include  pesticides and herbicides manufactured
on site, chemicals used in the manufacture of DDT, aldrin, dieldrin, toxaphene,
2,4-D,  2,4,5-T, 2,4,5-TP (Silvex) and Agent Orange (2,4-D and 2,4,5-T mixture).
Dioxin, an impurity resulting from  synthesis of 2,4,5-T, is also present at
                                       1-3

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                                                                  Jjfe Systems, Jnc.
the Vertac facility.  Environmental monitoring surveys from the period of 1978
to 1983 have detected chemical contaminants in groundwater, surface water,
soils and sediments.  The USEPA Office of Waste Programs Enforcement .has
identified the following "indicator" chemicals for the Vertac site on the
basis of their toxic properties, presence in large quantities or potential and
actual releases to the environment:

     •  2,3,7,8-TCDD                   •  Chlorophenols
     •  2,4,5-T                        •  Chlorobenzenes
     •  2,4-D                          •  Toluene.
     •  2,4,5-TP                       •  Methanol

This endangerment assessment will focus on dioxin because it is the most
highly toxic substance at the facility and is very persistent in soils and
aquatic systems.  Dioxin has been detected in waste products, groundwater and
soils on site and in sediments and fish tissue in adjacent surface waters (see
Table 1-1).  Refer to CH2M Hill (1984a), JRB (1983) and Walton et al. (1982)
for data on individual sampling sites and dates and maps indicating sampling
locations and groundwater monitoring wells. .A site map showing these
locations (which is normally provided in an endangerment assessment) is not
included because of the complexity of the several monitoring studies performed
at this site.  The values presented in Table 1-1 are a composite of the
available monitoring data from the period 1979 to 1983.

These data have not been subjected to a comprehensive quality assurance and
quality control review but a preliminary review .of available data reports
indicates that quality control and quality assurance procedures were
implemented.  These procedures included the chain of custody, split samples,
replicate analyses, sample spiking with an internal radiolabelled dioxin.
standard, routine instrument calibration, methodological (extraction) blanks,
adherence to recommended sample holding times and storage temperatures, etc.
                                      1-4

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                                         TABLE 1-1   RANGES  OF  DIOXIN CONTAMINATION  DETECTED ON-SITE
                                              AT THE  VERTAC  FACILITY  AND  IN  ADJACENT WATER  BODIES
 i
Ln


Sample Type
Sediment n










Soils








Surface
Waters

Ground
Water



Wastes




Fish





Locat ion/Description
Equalization basin
Cooling pond
Drainage ditches, on-slte
On-slte groundwater monitoring
we.ll
Rocky Branch Creek
Rocky Branch Creek, on-slte
Sewer and interceptors off-site
Creek bed adjacent to private
residences
Lake Dupree

Surface soils on-slte
Surface soils on-slte

Hercules-Transvaal area/surface
dirt
Reasor Hill landfill/dirt
Reasor Hill landfill/mud
Reasor Hill landfill area
Blow-out area
Rocky Branch Creek, on-slte
Discharge in combined sewer
at Braden and Alta Lane
Monitoring wells down gradient
of Hercules-Transvaal
Landfill
Monitoring wells, on-slte

Toluene still bottoms disposed
on-slte
Seeps from Reasor Hill
Equalization basin liquid
Equalization basin discharge
Caught In Bayou Meto

Caught in Lake Dupree


Dloxln
Concentration, ppb
0.063 to 1,200
0.236 to 102.0
0.800 to 34.1
NDID' to 12.1
0.500
0.236 to 17.4
18.4 to 33.4
1

0.150

ND(d>
100 to 14.000

559

3.42
0.505
NR1*'
0.99 to 45
ND
0.017

"High"


ND to <0.03

37,000

0.045 to 5.5
445
<10
<0.025 to 0.300 '

0.810


Total Number of
Samplea Analyzed
5
18
6
4
NA(c)
5
3
NA

1

NA
NA

1

1
1
NA1
2
1
1

NA


35
*
NA

3
1
1
6

1


Number
with JJloxin
Not Detected
0
0
0
2
NA(c)
0
0
NA

0

NA
NA

0

0
0
NA
0
|
0

NA


21

NA

0
0
0
0

0

Detected Dloxln
Concentratlona, ppb
/ \
Mean t SD(nr
460.2 t 459.1 (5)
18.2 i 24.2 (18)
16.1 t 12.9 (6)
10.0 i 3.0 (2)
NA(C>
4.1 i 7.5 (5)
28.3 i 8.6 (3)
NA

NA

NA
NA

NA

NA
NA
NA
22.5 t 31.7 (2)
NA
NA

NA


0.005 t 0.010 (13)

NA

2.4 1 2.7 (3)
NA
NA
0.087 1 0.110 (6)

NA



Reference
CH2M Hill (I984a)
CH2M Hill (1984a)
CH2M Hill (I984a)
CH2H Hill (1984a)
Falco (1982)
CH2M Hill (1984a)
CH2M Hill (1984a)
JRB (1983)

Schaum and Falco
(1982)
JRB (1983)
Falco anJ Schaum
(1984)
CH2M Hill (1984a)

CH2M Hill (1984a)
CII2H Hill (1984a)
JRB (1983)
CH2M Hill (1984a)
CH2M Hill (I984a)
CH2M Hill (1984a)

JRB (1983)


CH2M Hill (1984a)

JRB (1983)

CH2M Hill (1984a)
CH2M Hill (1984a)
CH2M Hill (I984a)
Schaum and Falco
(1982)
Schaum and Falco
(1982)
                 (a) The mean and standard deviation of samples with detected levels of  dloxln were calculated.  Samplea with
                    "not detected" (ND) levels of dloxln were not used in the calculations.  The value in parentheses Is the
                    number of samples with detected dloxln  levels used In the calculations.
                 (b) ND » Not detected.  Detection limit was not reported.
                 (c) NA • Not applicable due to insufficient information.,
                 (d) Not detected in measurable quantity. Detection limits 50 to  100 ppt.
                 (e) NR •• detected but concentration not reported.
                                                                                                                                                                     £>
                                                                                                                                                                     fr

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                                                                  £ife Systems, Jnc.
2.0       ENVIRONMENTAL FATE AND TRANSPORT

2.1       Factors Affecting Migration

2.1.1     Geology

The Vertac site is situated very near or possibly on the fall line of the
Interior Highlands and Coastal Plain physiographic regions.  The geologic maps
show that the Vertac site is slightly to the west of the fall line suggesting
that it is in the Interior Highlands but evidence (the northern part of the
site contains clays of the Midway Group which are present in the Coastal
Plain) suggests it is also in the Coastal Plain or in the transition zone.
The surface soils near the eastern portion of the site are sedimentary.  The
subsoils are part of the Atoka Formation characteristics of the Interior
Highlands.

The site is underlain by the consolidated rock of the Atoka Formation which
surfaces in the Interior Highlands and underlies the sediments of the Coastal
Plain.  The Vertac site is located on the south flank of a westward plunging
syncline.  The bedrock is alternating gray to black shales and sandstones of
the Atoka Formation which dips to the northeast at a rate of about 30 degrees.
There are many discrepancies regarding the strike and dip of the rock strata
on-site since the site is so close to the fall line.  The overlying unweathered
bedrock in ascending order is weathered bedrock approximately five feet thick,
clays and alluvium.
The soil is classified as a Leadvale-Urban land complex with a 1 to 3% slope.
The Leadvale Urban land complex are areas of Leadvale soils that have been
modified by urban development.  The Leadvale soils are moderately well-drained,
nearly level and gentle-sloping soils in valleys.  They are formed mainly of
loamy sediment washed from uplands composed of sandstone, shale and in some
areas from weathered siltstone.  The Leadvale soils have moderately low
permeability and maintain a medium level of available water capacity.  The
level of runoff from the Leadvale Urban land complex is medium and the erosion
hazard is moderate if the soils are not protected by vegetation.  Soil borings
indicate the presence of yellowish brown silty sands in the northeast corner
of the site and yellowish brown of tan silty clays in the southeast portion of
the site (CH2M Hill 1984a).

2.1.2     Hydrology

Surface drainage patterns at the Vertac site are predominantly westerly and
easterly.  The western 55 acres drain directly to the Rocky Branch Creek.  The
Rocky Branch Creek enters the Vertac site at the northwest boundary and flows
into a man-made cooling pond.  About 700,000 gallons/day of process waste-
waters enter the cooling pond.  Waters from the cooling pond flow out a
concrete outlet structure at the southwest extremity of the pond.  A cantrsl
ditch (no longer present) acted as a surface drainage channel from the plant
production area and flowed into the cooling pond.  The combined flow of
surface runoff and process waters enters Rocky Branch Creek and flows south
about two miles to Bayou Meto.
                                      2-1

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                                                                  £ife Systems, Jnc.
The eastern 38 acres of the site drain east to numerous small ditches caused
by natural erosion.  Along adjacent driveways and roads are a few man-made
ditches.  The catch basins located on the eastern portion of the site drain to
a storm sewer which empties into an open ditch near the main plant entrance.
All surface runoff east of the drainage divide eventually flows into the East
Branch of the Rocky Branch Creek.  Most of this runoff is carried by the "K?.r.t
Ditch" to the East Branch.  The East Branch flows into Rocky Branch Creek
south of the Vertac Site.

During heavy spring rains it is not uncommon for the Rocky Branch Creek to
flood the area south of the .Vertac Site.  This is important because there is a
manmade recreational lake (Lake Dupree) 1.3 mi south of the Vertac site.  Lake
Dupree and the Rocky Branch Creek are not normally connected but, the low
terrain and tendency for flooding in the area potentially enables contaminants
discharged into Rocky Branch Creek to be"deposited in Lake Dupree (JRB 1983).

2.1.3     Hydrogeology

The Interior Highlands are hilly and underlain by consolidated sediments which
dip slightly in a southeasterly direction.  The consolidated rock of the
Interior Highlands underlies unconsolidated sediments of the Coastal Plain.
Above the lowest level of the water table, the consolidated rock of the
Highlands has been weathered.  Soil and "rotten rock" (i.e., weathered rock)
in this region are present to a total depth of about 20 ft (maximum).  This
weathered rock.area is more permeable and porous than unweathered rock.  Water
Is prpsent -tji -intprgrannlar voids of "rotten rocks" and soil, while water is
only present in joints, fractures and other secondary openings in unweathered
rock.

The sediments of the Coastal Plain vary from high plasticity clays to sands
and gravels with varying permeabilities.  There are three units within the
sediments which are major water sources in some areas of Pulaski County.
Beds of claystone, calcareous sandstone, sandy limestone, marl and conglomerate
(about 7 to 60 ft) comprise one aquifer unit.  Fine to medium sand with some
interbedded clay lenses (about 320 ft thick) comprise another aquifer unit.
Terrace deposits and alluvium (deposited by the Arkansas and Mississippi
rivers) composed of fine-grain top stratum and deeper coarser stratum (about
120 ft) is the third aquifer unit.  Refer to Walton et al. (1982), CH2M Hill
(1984a) and JRB (1983) for further hydrogeologic information and a diagram of
the locations of aquifers in the Coastal Plain and Interior Highland regions.

The general horizontal groundwater flow is from north to south (CH2M Hill
1984a).  Two groundwater divides are evident on site with one running from the
northeast boundary of the site along the east side, across the plant and then
due south.  The second divide runs from the northwest along the western edge
of the cooling pond and south along Rocky Branch.  The contaminated water
cable flows toward the cooling pond and the Rocky Branch Creek at a rate of
<1 to 10 in/yr (CH2M Hill 1984a).  The vertical groundwater flow rates in
bedrock were calculated to range from 2 x 10   in/yr to 6.0 in/yr (CH2M Hill
1984a) which indicates potential downward migration of contaminants.  Little
                                       2-2

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                                                                  £ife Systems, J
is known about the hydrogeology of bedrock deposits at the Vertac site and the
structure of bedrock has not been evaluated.

The Rocky Branch Creek received groundwater inflows from the water table from
both the east and west.  These flows have passed under or through the
Reasor-Hill area.  Contaminants entering the groundwater east of the divide
may eventually enter the Coastal Plain aquifers (off-site) (CH2M Hill 1984a).
The recharge and inflow upgradient of contaminant sources flows toward western
surface water bodies and are conveyed off-site above ground or in the water
table.

2.1.4     Climatology

Precipitation is fairly well distributed throughout the year; however, May is
normally the wettest month.  The annual precipitation averages about 48 in and
about 31% of total precipitation occurs from March through May.  August
through October are the driest months with a total of 3 in of rain.

Winters are mild with average winter temperatures of 41 F and an average
annual snowfall of 5.7 in.  The greatest monthly snowfall reported was 12 in
in January 1966.  The summers are hot with an average daily temperature of
82 F and maximum temperatures of over 100 F occurring frequently in July and
August.

2.2       Environmental Fate and Transport of Dioxin

2.2.1     Environmental Fate          •

2.2.1.1   Biodegradation

Dioxin is not readily biodegraded.  Few microbial strains (5/100) capable of
degrading persistent pesticides could degrade dioxin slightly (USEPA 1980).
Dioxin is persistent in freshwater aquatic environments with a half-life of
550 to 590 days in sediment containing lake waters (Ward and Matsumura 1977).
The biodegradation half-life of dioxin was estimated to be greater than one
year based on theoretical biotransformation rate values and assumed concentra-
tions of microorganisms (USEPA 1984).  The biodegradation half-life of 0.5 yr
for dioxin in soils was based on data from a rural Missouri incident involving
accidental spraying of dioxin contaminated oils (IARC 1977).  Recent data
suggest that the half-life may be closer to -10 yr (USEPA 1984).

2.2.1.2   Photodegradation

Dioxin is in the presence of organic solvents (Crosby et al. 1971) or other
hydrogen donatprs is photodegraded (Crosby and Wong 1977).  Insufficient
information is available on reactions of dioxin in aquatic media under environ-
mencai'conditions to predict the photodegradation half-life in natural waters.
However, photolysis is expected to be an important fate process when hydrogen
donating substrates are present (USEPA 1984).  Assessment of photodegradation
in natural waters is complicated by the tendency for dioxin to be strongly
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                                                                  Ofc Systems, Jnc.
adsorbed on particles in sediments that are not exposed to ultraviolet (UV)
light.

Information on photodegradation of airborne dioxin adsorbed on particulates is
conflicting.  The importance of photodegradation relative to deposition (dry
or wet) in the fate of airborne dioxin is uncertain but may be important.
Dioxin sorbed to solid surfaces and exposed to the atmosphere yielded neglig-
ible photodegradation (Crosby et al. 1971), while photolysis was evident for
dioxin in a condensed phase on glass or silica.

The photodecomposition of dioxin on wet or dry soils under artificial and
natural sunlight (UV radiation) was observed to be negligible in soils (Crosby
et al. 1971).  However, photodecomposition may occur when dioxin and other
pesticides (hydrogen donators) are present as a mixture in soils (Crosby and
Wong  1977).

2.2.1.3   Oxidation and Hydrolysis

No information on the oxidation of dioxin in aquatic systems was available but
its strong electropositive nature suggests it may be more resistant than
nonchlorinated or less chlorinated aromatics.  The potential for oxidation of
dioxin (sorbed on airborne particulates) by atmospheric compounds  (NO , 0_,
etc.) is unknown.  Hydrolysis is unlikely to occur under environmental condi-
tions in aquatic systems  (USEPA 1984).

2.2.1.4   Volatilization 	                   '                  .__
                            •
Quantitative  information on volatilization of dioxin from aquatic  systems  is
not available although several references have mentioned volatilization as a
possible loss process (Callahan et al. 1979).  Matsumura et al.  (1983) ob-
served that dioxin may undergo water-mediated evaporation in an aquatic
system.  Based on theoretical models,  the volatilization half-life was pre-
dicted, to be  about 5.5 yr from a pond  and  12 yr  from a lake.  The  validity of
these estimates has not been assessed  with experimental data.  Volatilization
of dioxin adsorbed on soils is expected to be at a very slow rate  due to the
extremely low'vapor pressure of dioxin (Falco and Schaum 1984).

2.2.1.5   Sorption

Sorption on particles  (suspended or sediments) and in microorganisms appears
to be an important fate for dioxin in  aqueous environments.  Isenee and Jones
(1975) observed that 85%  to 99% of dioxin  remained adsorbed on sediments in an
aquatic system and the majority of dioxin  not on sediments was in  aquatic
organisms.  Ward and Matsumura  (1978)  observed that more than 90%  of dioxin in
aquatic medium remained bound to sediments.  The low water solubility and  high
octanol/water partition coefficient of dioxin support  these observations.

The  half-life of dioxin in  soils has been  reported to be 1 to 3  yr (Kearney et
al.  1972),  about 330 days  (dry  conditions),  190  days  (wet conditions)  (U.S.
Air  Forces  study cited  in USEPA  1984)  and  10 yr  (Young  1983).
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2.2.1.6   Bioaccumulation

Many aquatic species bioaccumulate dioxin.  In a static experimental test
chamber, the accumulation appeared to be dependent upon initial dioxin con-
centrations.  The bioconcentration factors (determined experimentally in a
static system) vary with species and may range from about 2,000 (algae or
snail) to 9,000 (catfish) to 26,000 (mosquitofish) (Isenee and Jones 1975,
Isenee 1978).

Schaum and'Falco (1982) derived a fish-sediment distribution coefficient (Kps)
to reflect bioaccumulation of dioxin in fish and enable calculation of
potential concentrations in fish from sediment concentrations.  Coefficients
were derived on the basis of actual monitoring data and on the basis of
biota-water and organic matter-water distribution equations from published
literature. 'Limited data on dioxin concentrations in fish (810 ppt in a bass)
and in sediments (150 ppt) in Lake Dupree were used to calculate the
distribution coefficient as follows:

                                   810
                             *
                              TS   150 ppt    <

This KS value probably underestimates the K.   in the .catfish population
inhabiting the Bayou, since catfish and other benthic feeders tend to bioac-
cumulate dioxin to a greater extent than nonbenthic feeders.  The alternative
KF  of 550 was calculated based on an assumed organic carbon content (0.5%) in
accordance with the relationships defined by Perwak et al.  (1980) and Hamaker
(1978).  The discrepancy .between the K   values based on monitoring data (5.4)
and that derived from biota-water and organic matter-water distribution
relationships (550) may be explained by uncertainty in actual organic content
of sediments, species differences, insufficient residence time for fish or
dioxin to reach equilibrium, or non-equilibrium due to dynamic flow conditions
in the Bayou.  Thus, the uncertainty regarding the K__ coefficient adds great
uncertainty to estimates of human exposure levels.

2.2.2     Environmental Transport

Schaum and Falco (1982) calculated the dioxin load to Bayou Meto based on an
environmental transport model.  The estimated mean sediment yield rate for the
upper Bayou Meto water shed of 0.63/yr/acre was assumed to be constant throughout
the watershed and applicable to the Rocky Branch Creek.  The assumption was
considered valid because factors (rainfall,- slope steepness, cover, etc.)
affecting erosion appear roughly the same throughout the area.  The trapping
efficiency of the cooling pond was calculated to range from 0.46 to 0.71.
Minimum and maximum sediment loads of 550 tons/yr and 620 tons/yr were calcu-
lated.  Using the 500 ppt dioxin concentration of sediments near the mouth of
Rocky Branch Creek, the minimum and maximum dioxin loads to Bayou Meto were
calculated co be 2.7 x 10~7 and 3.1 x 10   tons/yr.  Nonpoint source pollution
data and U.S. Geological Service (USGS) data on the Arkansas River basin
sediment loads were used were used to calculate dioxin concentrations at seven
different points along Bayou Meto.  Calculations assumed steady-state sediment
movement since data on the variability of sediment storage and removal rates
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  in the bayou were unavailable.  The uncertainty associated with variations in
  sediment storage/removal rates were considered insignificant relative to
  uncertainties associated with the fish-sediment distribution coefficient.

  Kearney et al.  (1973) examined the mobility of dioxin in five soil types and
  observed that decreased mobility was associated with increased organic content
  of soils.  Dioxin was relatively immobile in all test soils and Kearney et al.
  (1973) concluded that leaching to underground water supplies would be unlikely.
  Matsumura and Benezet (1973) postulated that dioxin transport would be via
  horizontal transfer of contaminated soils and dust particles.  Dioxin does not
  readily migrate vertically in soils (USEPA 1984).  Nash and Beall  (1980)
  observed that 80% of dioxin applied to soils in a microagroecosystem remained
  in the upper 2  cm of soils and that only trace amounts were detected at 8 to
  15 cm.  The NRCC (1981) suggested that vertical migration of dioxin may result
  when the sorption capacity of soils are saturated or as a result of biotic
  mixing (i.e., action of earthworms or other soil invertebrates).  Dioxin
  solvated by organic solvents may be mo.re readily transported through soils to
  the groundwater.

  Wet and dry deposition of particulate-bound dioxins appear to be an important
  fate-determining process in the transport of airborne dioxins.•

  2.3       -Contaminant Movement On Site and Off Site

  The summary of  the Vertac site history indicates that contaminants (dioxin and
  others) were discharged in untreated wastewaters and process wastes, trans-
  ported and released to the Rocky Branch Creek possibly as early.as 1955
  (JRB  1983).  Dioxin and other contaminants were also released by seepage from
  underground burial areas and by erosion of contaminated surface soils.

  Contaminants from the Hercules-Transvaal Landfill have migrated to the process
/ cooling pond.   The central drainage ditch and surface runoff also  transported
  dioxin to the cooling pond.  Contaminants that leaked into the cooling pond
  and/or settled  there probably flowed into the Rocky Branch Creek since the
  pond  is in its  steam, course.  Spills and/or valve ruptures of the  trichloro-
  phenol reactor  in the "blow-out" area or other areas released dioxin which may
  have  percolated underground or have been transported via surface runoff  to the
  East  Branch.  Leachates from the equalization basin along the western edge
  of the site also contributed to contamination of the Rocky Branch  Creek.
  Transport of dioxin  to Dupree Lake probably occurred as a result of flooding
  of the Rocky Branch  Creek during periods of heavy spring ra.ins.

  Implementation  of remedial actions involving disturbance of  Soils  and vehi-
  cular movement  may have promoted contaminant transport particularly during
  remediation of  the equalization basin.  The remedial actions implemented  (clay
  caps, barrier walls, French drain, etc.) may reduce the potential  for further
  contamination by preventing infiltration of surface precipitation, runoff and
  wind  erosion.   There is some uncertainty about the vertical  migration of
  contaminants  to groundwaters.  Unexpectedly, "high" concentrations of dioxin
  were  detected in groundwater monitoring wells downgradient  from  the Hercules-
  Transvaal Landfill area  (JRB  1983) .  There  is potential for  lateral subsurface
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movement in this landfill since no barrier walls have been installed.  The
closure of the equalization basin appears to contain lateral leachate seeps
but the effectiveness over time is uncertain since the French drain and
barrier walls were constructed over weathered rock (with fissures).  Installa-
tion of the above-grade neutralization wastewater treatment system and dis-
charge to the local wastewater treatment plant has reduced or eliminated the
potential for further release of process waste to the Rocky Branch Creek.

The proposed remedial action (Alternative IV) which involves excavation of
contaminated soils/materials and redisposal in a secure landfill on-site) will
disturb soils and create the potential release of contaminants as dust emis-
sions.  The release and movement of contaminated dust may be reduced by
implementation of dust control measures.  Falco and Schaum (1984) determined
that primary sources of dust emissions would result from vehicle travel over
contaminated soils, loading/unloading operations and spreading excavated soil
in the new on-site secure landfill.  A front-end loader will be used to
excavate material and load it into dump trucks.  Material will be transported
in the trucks on existing roadways where materials will be dumped and spread
with a bulldozer in the secure landfill on site.  It is assumed that "clean-
dirt" will be applied to roadways between the excavation sites and the secure
landfill and covered trucks will be used to reduce contaminant releases.  The
wind-only generated dust emissions were assumed to be negligible compared to
mechanically generated dusts occurring during truck travel, loading/unloading
and spreading operations.  The estimated duration of the proposed excavation/
remedial actions and associated dust emissions is 190 days for the Reasor-Hill.
site and 380 days for the North Burial Area.
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3.0       EXPOSURE EVALUATION

This section will identify actual and potential routes of exposure, characterize
the populations exposed and determine extent, of the exposure to dioxin.  The
results of exposure assessments for the proposed on-site remedial action and
for consumption of fish from off-site contamination of receiving waters are
summarized.

3.1       Routes of Exposure

Potential exposure routes are as follows:

     1.   Consumption of fish from the Bayou Meto and Rocky Branch Creek.

     2.   Consumption of groundwater downgradient of the Vertac site.

     3.   Inhalation of dust-contaminated with dioxin that may become airborne
          due to implementation of remedial action Alternative IV.

     4.   Direct contact with waters, sediments or soils adjacent to the site
          that have been contaminated by surface runoff or erosion processes.
          Direct contact includes direct dermal exposures as well as direct
          ingestion exposures (i.e. pica in children).

3.1.1     Fish Consumption

Environmental monitoring data indicate that the high concentrations of dioxin
are found in fish (<25 to 300 ppt) and sediments (500 ppt) of Bayou Meto
(Schaum and Falco 1982).  Significant potential human health threats may
result from consumption of contaminated fish from Bayou Meto.  Arkansas
officials have banned fishing on the Bayou Meto; however, the fishing ban  is
not easily enforced (Falco 1982).  Thus, there appears to be a real potential
for dioxin exposure.  Schaum and Falco (1982) concluded that consumption of
dioxin contaminated fish represented the most important potential exposure
route and estimated the amount of dioxin bioaccumulating in fish at various
distances downstream from the site.  This exposure assessment calculated
bioaccumulation in fish, estimated potential human consumption rates and
derived the resulting exposure levels.

Dioxin released from the site via transport on suspended solids in overland
runoff or sorbed to airborne dust is of particular concern.  Dioxin-bearing
particles accumulate in sediments of receiving waters and bioaccumulate  in
fish.  Monitoring data indicate that 500 ppt of dioxin are present in  the
Rocky Branch Creek sediments.  Schaum and Falco  (1982) have calculated the
dioxin load to Bayou Meto based on this concentration  (500 ppt), modeled
sediment redistribution to Bayou Meto and applied the  fish-sediment  distri-
bution coefficient to calculate dioxin concentrations  in fish.
                            *                                  •         *

3.1.2     Croundwater

Concentrations ranging  from ND to 0.03 ppb  (with a mean  ± standard deviation
of  0.005 ± 0.010 ppb) of dioxin were detected  in grour.dwater monitoring  wells
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                                                                  £ift Systems, JHC.
downgradient from the Hercules-Transvaal landfill area; however, no existing
domestic or industrial wells were reported to be located in areas that are
immediately downgradient from the Vertac site (JRB  1983, Schaum and Falco
1982).  The exposure assessment by Schaum and Falco  (1982) did not evaluate
human exposure via consumption of contaminated groundwater but noted that this
route may represent a long-terra threat and should be analyzed further.
Subsequent groundwater exposure assessments should  consider dioxin and other
contaminants, that are both more mobile in the subsurface soils and more
soluble in water, to characterize the importance of  this route.

3.1.3     Airborne Dust

Schaum and Falco (1982) recognized that dioxin would probably be present on
dust particles but would be unlikely to volatilize  appreciably and be detected
as a vapor in ambient air offsite.  This potential  exposure route was not
•examined by Schaum and Falco (1982) since remedial  actions implemented (clay
capping of disposal areas and covering the blow-out  area) were expected to
diminish releases of dioxin-contaminated dust via wind erosion.

The potential for exposure to dioxin via inhalation  of contaminated dust is
increased by the proposed remedial action (Alternative IV).  Falco and Schaum
(1982) assessed the exposure potential associated with remedial actions that
disturb the soil and create potential dust emissions.

3.1.4     Direct Contact with Contaminated Soils/Sediment

Dioxin in contaminated soils may be adsorbed across  the skin.  The concentra-
tion in soils and type of soils are expected to affect dermal adsorption.  The
direct contact with contaminated soils is dependent  upon the degree of outdoor
activities such as gardening or playing.  The degree of dermal exposure
depends upon the amount of skin exposure, duration  of contact and soil condi-
tions.
                /

Exposure due to direct ingestion depends on age with children aged two to six
years having the greatest exposure potential.  Seasonal variation in weather,
soil conditions and activity patterns affect the amount of exposure via direct
ingestion of contaminated soils/sediments.

3.2       Populations Exposed

3.2.1     Fish Consumption

Populations with high fish consumption from affected water bodies are at an
increased risk of dioxin exposure.  Schaum and Falco  (1982) stated that the
number of people exposed to dioxin via consumption  of fish caught from Bayou
Meto cannot be estimated precisely.  Exposure via consumption of fish should
not be occurring since there is a fishing ban for Che Bayou Meto; however,
there is evidence that the ban is not easily enforced.  Schaum and Falco
(1982) estimated the number of people potentially exposed if such a ban was
not in effect.  The predicted fish catch from the Bayou Meto was divided by an
estimate of the individual's consumption rate to estimate the size of
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population exposed.  Both the fish catch and consumption rates were difficult
to assess accurately.  The national average consumption of nonmarine fish (5.2
Ib/yr) was used in the calculations; however, fish consumption rates may vary
by up to threefold between the average and the 95th percentile.  The consump-
tion rate of fish from the Bayou Meto (only) is probably less than the amount
predicted since the 5.2 Ib/yr statistic represents the individual's total
consumption which is likely to reflect fish caught from many sources.  The
mean catch rate (62 Ib/acre/yr) was based on the rate from an off-stream
reservoir which may differ from that in the Bayou Meto.  The total catch
(160,000 Ib/yr) was estimated by multiplying the mean catch rate by the river
surface area (2,600 acres based on an assumed mean width of 150 ft and length
of 144 mi).  Schaum and Falco (1982) illustrate how the exposed population
size may vary according to assumptions made regarding the consumption and
catch rates (see Table 3-1).

Assuming that most fish from Bayou Meto are likely to be consumed by local
residents, Schaum and Falco (1982) concluded that the number of exposed people
is probably less than the local population.  Approximately 476,000 people are
in counties, that are at least partially drained by Bayou Meto according to
census data.

3.2.2     Groundwater

Walton et al. (1982) states that no domestic or industrial water wells were
located in areas that are immediately downgradient from the Vertac site.
Contacts with state and local permitting agencies identified only two domestic
wells within the .vicinity of the site (Walton et al. 1982).

One well (50 ft deep) was 1.5 mi west of Vertac and the other well (15 ft
deep) was about 1.5 mi southeast of the site.  Data on the size (if any) of
the population utilizing these wells or consuming groundwater from other
sources contaminated by the site was unavailable.  There are insufficient data
on groundwater contamination and off-site flows to determine when the plume
may reach these wells and the expected concentrations.

3.2.3     Airborne Dust

The population at greatest risk to exposure to dioxin via airborne dust would
be workers/observers on-site during the proposed remedial action .if an ade-
quate personal protection program was not implemented.  It is assumed that an
adequate personal protection program will be required under the Remedial
Action Plan to eliminate or substantially reduce potential exposures to
on-site personnel.

Insufficient data on prevailing wind direction, wind speed and geographical
features affecting wind patterns are available to determine which populations
are at an increased exposure potential for airborne dust'.  Residents of  the
subdivision to the south of the site are the nearest potentially exposed
off-site population  (Falco and Schaum 1984).  The proximity of this population
to the site is assumed to subject this population to an increased risk of
exposure to dioxin since airborne dust concentrations are expected to be
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              TABLE 3-1  ESTIMATES OF POPULATION SIZE EXPOSED AND
                     EFFECTS OF ASSUMPTIONS REGARDING FISH
                     CONSUMPTION RATE AND FISH CATCH RATE
    Consumption Rate,

   Ib/individual/year

          2.5

          5.2

          7.5

         10.0

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                                                                  £ifc Systems, fac.
greatest near the site and to decrease with increasing distance from the site.
People that stay at home during the daytime and especially those that are
frequently outside for long periods are expected to have higher exposures.
This group may include young children, nonworking parents and the elderly.  It
is assumed that dioxin-contaminated dust concentrations will tend to be higher
outdoors relative to inside a house.  No quantitative information on the
number of residents near the site and specific behavior patterns is available.

3.2.4     Direct Contact

No quantitative data are available on the size of the population potentially
exposed to dioxin via direct contact with contaminated soils or sediments
on-site or off-site.  The fence around the facility limits accessibility and
reduces potential accidental direct contact exposures on-site.  Detection
of dioxin in surface soils in the subdivision south of Vertac (Braden Street,
West Lane and Alta Cove) (CH2M Hill 1984) suggests that residents may be at
risk for dioxin exposure.  People who garden and play outdoors are expected to
be at higher risk for direct contact exposures.  Since the highest
concentrations of dioxin off-site are found in sediments of the Rocky Branch
Creek, it is anticipated that people who swim, wade .or play in and around the
creek may be at increased risk.  Likewise, people who use Lake Dupree for
recreational activities may have increased exposure.

3.3       Extent of Exposure

3.3.1     -Fish Consumption

No estimates of actual fish consumption based on local surveys of the Rocky
Branch Creek and Bayou Meto are available.  Schaum and Falco  (1982) estimated
that the annual human exposures to dioxin from consumption of contaminated
fish could range from 110 ng/kg of body weight (bw) for fish  caught near the
confluence of Bayou Meto and the Rocky Branch Creek to as low as 0.09 ng/kg/bw
for fish caught from Bayou Meto (mouth).  Table 3-2 identifies ranges of
predicted dioxin exposures from consuming fish caught at various points along
the Bayou Meto as presented by Schaum and Falco (1982).  The  concentration of
dioxin in sediment  (C ) was calculated by dividing dioxin load by total
sediment load.  The range of values reflects the assumed range of trapping
efficiencies (0.41  to 0.71).  The concentration of dioxin in  fish was cal-
culated by multiplying C  by the sediment fish distribution coefficient
(assumed range of 5.4 toS550).  The calculated human exposure assumes a 70-kg
human consumes 5.2  Ib (6.5 g/day) of fish per year.  Estimates of human
exposure based on the available monitoring data are in agreement with pre-
dictions based on the environmental transport model.  There is much uncer-
tainty associated with the predicted exposures.  Factors previously discussed
(such as utilization of an estimated dioxin sediment load, fish-sediment
distribution coefficients, unavailability of actual fish consumption rates,
etc.) contribute to the uncertainty.  This uncertainty is compounded by the
fact that fishing on Bayou Meto is currently banned.

The Schaum and Falco  (1982) exposure assessment provides a means to bound the
possible range of exposure but the limited data are not sufficient  to produce
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                               TABLE 3-2   DIOXIN  CONCENTRATION  IN SEDIMENT,  DIOXIN  CONCENTRATION
                                            IN  FISH,  AND  HUMAN  EXPOSURE  BY RIVER MILE
                         Concentration  of
                   Dioxin In  Sediment  (C   ppt)
u>
i
River .
Mileta)
132
100
75
54
34
16
0
Based on
Calculations
5.2-6.0
3.1-3.5
2.6-3.0
0.83-0,94
0.71-0.80
0.62-0.70
0.49-0.56
Based on ^
Monitoring ( }
500
<70
<85
<80
<30
<2?c)
NA^ '
     Concentration of
Dioxin in Fish (C,, ppt)
Based on
Calculations
28-3,300
17-1,900
14-1,600
4.5-520
3.8-440
3.3-390
2.6-310
Based on
Monitoring
300
112
30
<30
<25
<25
NA

(b)







        Estimated
Human Exposure, ng/kg/yr
  Based on     Based on
Calculations  Monitoring
  0.96-110
  0.56-65
  0.48-56
  0.15-18
  0.13-15
  0.11-13
  0.09-10
                                               10.1
                                                3.79
                                                1.0
                                                NA
                                                NA
                                                NA
                                                NA
       (a)  River mile  defined  as  the  number of  miles  upstream from the  mouth of  Bayou Meto.
       (b)  All C_ and  C  monitoring data  were gathered  by  Arkansas Department of Pollution Control and Ecology
           in  1981.
       (c)  NA  = No data available.

       Adapted froiu Schaum and Falco  (1982).

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a statistically valid estimate of the error range.  The predicted exposure
values are based on very limited data and much more extensive data are
required to precisely define the magnitude and extent of dioxin exposure via
contaminated fish consumption.

3.3.2     Groundwater

The extent of dioxin exposure via groundwater has not been determined.  Due to
the apparent lack of water wells and the low solubility of dioxin in water, it
is expected that exposure potential will be minimal.  Using the highest
reported concentration of 0.03 ppb dioxin in groundwater on-site (CH2M Hil]
1984a) and assuming a 70-kg adult would consume two liters of water per day, a
maximum potential exposure could be calculated as follows:
                      2       = °-°009
                (70-kg)

This is a worst case scenario.  Insufficient data on groundwater flows,
dilution ra-tes  and the extent of contamination are available to calculate
reasonable conservative exposure estimates.  Using the mean concentration of
dioxin detected in wells  (0.005 ppb) and the above equation, the exposure may
be estimated as OiOOOl yg/kg/day.  Recent monitoring data have not detected
dioxin in any wells on-site and therefore suggest that exposure levels may be
less.

In addition, -actual exposure at _this -level is unlikely since Walton et al.
(1982) and CH2M Hill (1984a) state that data indicate that no existing wells
are located within two miles of the  site and there is no contamination in any
wells beyond two miles.   Future contamination or installation of new drinking
water wells downgradient  of the site may increase the potential and magnitude
of exposures .

3.3.3     Airborne Dust

Falco and Schaum  (1984) assessed potential exposures to dioxin via inhalation
of dust^emissions associated with the proposed remedial action (Alternative
IV) .  The two phased remedial action involves excavation initially, at Reasor-
Hill Landfill (Phase 1) and finally  at the North Burial area (Phase 2).  The
exposure assessment predicted possible off-site emission rates, used disper-
sion models  to  determine  resulting off -site air concentrations of dioxin and
calculated inhalation exposures.  The range of exposure estimates is due to
the uncertainty in the concentration of dioxin in the material (soil) to be
excavated (assumed to range from 0.1 to 14 ppm) .  Exposure estimates assume
that no dust control measures are implemented during remediation.

Falco and Schaum  (1984) used standard equations to predict dust emissions
resulting from  vehicular  travel, loading/unloading and spreading operations.
Assumptions  regarding the silt content of soils, soil moisture content,
particulate  size, number  of precipitation days, average wind speed and vehicle
characteristicsqwere required. ? The  predicted emission rates for dioxin  ranged
from  1.55 x  10    to 2.17  x 10   g/sec for Phase 1 and from 2.3 x 10~  to 3.8 x
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                                                                  £ife Systems, JHC.
 JO   for Phase 2.  The ambient air concentrations of dioxin were calculated
with the method developed by Cowherd et al.  (1984) for specific ground-level
area sources of particulate emissions.  Implementation of the model relied on
assumptions of comparability between meteorological conditions at the Vertac
site and conditions used to develop the model and comparability between size
of the source in the model and the size of the source at Vertac.  Falco and
Schaum (1984) determined the average air concentrations and plotted isopleths
for the site.  The average lifetime exposure levels (via inhalation) were
calculated for each dioxin-concentration isopleth based on assumed respiration
rate, exposure duration, body weight and lifetime expectancy.  This assessment
also assumed that all inhaled dioxin-particulate inhaled into the body is
retained and absorbed.  Since the exposure concentrations reflect respirable
dust-sized particulates (<10 u), virtually all inhaled particulates will be
retained by the lung.  Figure 3-1 illustrates isopleths for the combined phase
exposure levels for the area outside the site's southern boundary where the
nearest residents are located.

3.3.4     Direct Contact

No quantitative estimates of the extent of dioxin exposure via direct contact
are available.  Future exposure assessments should address specific subpopu-
lations suspected of having increased exposures due to their behavior or
activities.  For example, children playing in contaminated soils or sediments
of adjacent waterways are. probably exposed to dioxin via direct dermal contact
or ingestion.  People who garden in residential areas with dioxin-contaminaced
soils also have increased exposure potential via direct contact.  The lack of
information on the dermal absorption, amount of direct soil contact, dioxin
content of soils/sediments, quantity of soil directly ingested and other
factors currently preclude performance of quantitative exposure estimates.
Direct contact is an important route that should be addressed in future
exposure assessments.  The Kimbrough et al. (1977)  report on toxicity in six
children dermally exposed to dioxin-contaminated soils in horse-arenas in
eastern Missouri confirms the potential significance of this route.
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(Crow 1978, Passi et al. 1981).  Most of the documented acute exposures to
dioxin have been the result of chemical industry accidents involving 2,4,5-T,
which is contaminated with dioxin.

The first cases of chloracne associated with exposure to dioxins occurred
following an explosion in a chemical plant producing 2,4,5-T in 1949 (Holm-
stedt 1980).  Zack and Suskind (1980) reported nausea, headaches, fatigue,
muscular aches and pains, and chloracne as the frequent complaints among the
228 workers exposed.  Chemical tests revealed elevated lipid levels and
prolonged prothrombin times.  Residual chloracne, peripheral neuropathy,
fatigue and severe aches and pains persisted for up to two years.  Other
reports of adverse effects in humans following acute exposure to. dioxin as a
result of industrial accidents are provided by Holmestedt (1980), May  (1973,
Gianotti (1977), Garattini (1982), Taylor (1979) and Crow (1981).

The Lombardy Regional Authority has compiled extensive data regarding  the
health effects of dioxin on children and adults following accidental releases
of the chemical from a plant in Seveso, Italy (Pochiari et al. 1979).  Reduced
peripheral nerve conduction velocities occurred in both adults and children,
with a correlation between the incidence and the distance from the plant.
Total serum complement activity, lymphocyte blastogenic response and
peripheral blood lymphocytes were elevated in children exposed in the  accident
(Tognoni and Bonaccorsi 1982).  The limited number of studies regarding the
immunological effects of dioxin in adults have not revealed any reduction in
immunocapability (May 1982).

Caramaschi et al.  (1981) reported an increase in the frequency of headaches,
eye irritation, gastrointestinal tract symptoms and abnormal g-GT, serum GPT
and aminolevulinic acid levels in children living in the Seveso area who
developed chloracne.  Increased urinary glucaric acid levels, indicative of
increased microsomal enzyme activity, were found in children three years after
the accident (Ideo et al.  1982).

Six children dermally exposed to dioxin-contaminated soil (30 ppm, 30  mg/kg
soil) in horse-arenas in eastern Missouri developed headaches, skin lesions
and polyarthralgia  (pain in joints)  (Kimbrough et al. 1977).  In the most
severe case, epistaxis  (nosebleeds) and lethargy were reported.

Numbness of the extremities, skin rashes and irritation, liver dysfunction,
weakness, loss of  sex drive and psychological changes have been associated
with exposure to 2,3,7,8-TCDD and other dioxins, which occur as contaminants
in Agent Orange, in veterans and residents of Vietnam.  The relationship
between exposure to dioxin and the development of these symptoms is unknown
(Holden 1979, Bogen 1979).

4.2.2     Toxicity  in Laboratory Animals

McConnell et al.  (1978  a,b) observed  that dioxin induced mortality in  a
variety of  laboratory animals  (rat,  guinea pig, mouse, rabbit, monkey) at dose
(LD 0) levels between 0.6  ug/kg and  283.7 ug/kg following oral administration.
The dermal  LD   value in rabbits was  270 Ug/kg  (Schwetz et al.  1973).
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A summary of studies providing data on the sub-lethal effects of acute expo-
sure to TCDD is presented in Table 4-1.  The effects were reported to occur
following single exposures ranging from 0.1 to 300 yg/kg in four animal
species (rat, guinea pig, chicken, mouse).  Liver damage is the most consis-
tently reported effect in most species.  Rats receiving a single dose of
100 yg/kg of TCDD showed severe liver damage, thyraic atrophy and jaundice
(Gupta et al. 1973).  In the same study, thymic and liver damage of lesser
severity occurred at lower dose levels (25 and 50 yg/kg).  In another study
(Greig et al. 1973), rats exposed to TCDD (300 yg/kg) exhibited jaundice,
multinucleated parenchymal cells of the liver and gastric hemorrhage.  Histo-
pathologic liver changes were 'observed five weeks after single oral doses of
TCDD as low as 50 yg/kg were administered to male and female CD rats, and one
week after a single dose of 50 yg/kg was administered to female CD-I mice
(Harris et al. 1973).  Increased liver weights were found in male Wistar rats
seven days after single intraperitoneal doses of 0.1 yg/kg (Cunningham and
Williams 1972).

4.2.3     Toxici'ty in Aquatic Species

The USEPA (1984) summarizes the available information on the acute toxicity of
dioxin to aquatic organisms.  The 96-hr lethal concentrations (LC5n) reported
by Miller et al. (1973) and Norris and Miller (1974) were >0.2 yg7L for.
Paranais sp. (worm), Physa sp. (snail) and Aedes aegypti (mosquito larvae),
>1 yg/L for Oncorhychus kisutch (coho salmon), >10 yg/L for Poecilia reticulata
(guppy) and >0.24 yg/L for.Ictalurus punctatus (fingerling channel catfish).
Helder (1980, 1981 and 1982) observed that the LC5Q is >0.01 yg/L for Esox
lucius (northern pike embryos) and Salmo gairdneri (rainbow trout yolk-sac
fry) and >0.1 yg/L for the juvenile rainbow trout.

4.3       Subchronic and Chronic Toxicity

4.3.1     Toxicity in Humans

Several epidemiologic studies and case reports involving dioxin exposure in
human subjects have been reported (Esposito et al. 1980).  Effects observed
include skin lesions (chloracne, prophyria cutanea tarda), liver function
impairment and neurological disorders "(polyneuropathy, peripheral nerve
damage).  An International Agency for Research on Cancer (IARC 1982) evalua-
tion of human exposure data concluded that these studies are inadequate since
they involve multiple chemical exposures.

4.3.2     Toxicity in Laboratory Animals

Longer exposures to dioxin caused effects similar to those reported following
acute exposure including thymic atrophy, liver damage, renal function impair-
ment, hematological effects, hormonal alterations, immunosuppression, nervous-
ness and irritability.  Chronic'and subchronic.. studies in many different
strains of laboratory mice and rats indicate that the liver is the primary
organ affected by long-term exposure (Kociba et al. 1973, 1979, NTP 1980a).  A
summary of major studies providing dose-response effects is presented in
                                     4-3

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                                TABLE 4-1  EFFECTS OF DIOXIN IN ANIMALS FOLLOWING ACUTE EXPOSURE
-e-
 Species

Rat



Guinea Pig



Rat



Chicken

Rat       *

Rat

Rat

Mouse

Rat

Rat
Dose (tJg/kg)    Route

25, 50 or 100

100

3.0



300



25 - 50

10              Oral

0.1             i.p.

50   ,           Oral

50              Oral

10

10, 25, or 50
                                                        Effects
                                              Reference
Liver damage, thymic atrophy

Jaundice, 43% mortality

Hemorrhage, adrenal atrophy,
cellular depletion of lymphoid
organs, 90% mortality

Weight loss, gastric hemorrhage,
liver damage (cellular changes),
jaundice

Pericardial edema,

Hematologic effects

Increased liver weights

Liver damage

Liver damage

Decreased renal function

Decreased renal function
Gupta .et al. (1973)



Gupta et al. (1973)



Greig et al. (1973)



Greig et al. (1973)

Weissburg and Zinkl (1973)

Cunningham and Williams  (1972)

Harris et al. (1973)

Harris et al. (1973)

Anaizi and Cohen (1978)

Hook et al. (1978)
       Adapted from NAS (1977), NTP (1982 a,b) and Esposito et al. (1980).

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Table 4-2.  Studies providing dose-response data indicating the greatest
sensitivity to dioxin are described below.

Doses as low as 0.1 yg/kg/day caused a slight degree of liver degeneration in
rats in a subchronic 13-wk (5 doses per week) study (Kociba et al.  1976).
Dose levels of 1.0 yg/kg/day increased levels of serum bilirubin and alkaline
phosphatase and caused pathologic changes in the livers of rats.  A no-
observed-adverse-effect level (NOAEL) of 0.01 yg/kg dioxin was reported for
noncarcinogenic effects in rats.

Increased mortality was observed in female Sprague-Dawley rats maintained for
two years on a diet that provided a dioxin dose of 0.1 yg/kg/day, while no
increased mortality was observed in male rats at this dose or in animals
receiving doses of 0.01 or 0.001 yg/kg/day (Kociba et al. 1978, 1979).  At
termination of the study, gross and histologic examination indicated that the
liver was the most severely affected organ, with degenerative, necrotic and
inflammatory changes observed.  Increases in urinary excretion rates of the
metabolites, coproporphyrin and uroporphyrin, in the high and middle dose
females were consistent with the observed liver damage.  Primary liver injury
was dose-related with the lowest dose representing a NOAEL (noncarcinogenic).

When dioxin was administered by gavage (by stomach tube) in corn oil-acetone
(9:1) at dose levels of 0, 0.01, 0.05 or 0.5 yg/kg/wk (0.0, 0.001, 0.007 and
0.07 lag/kg/day), toxic hepatitis was observed in male Osborne-Mendel rats at
incidences of none out of Ik tested (0/74), 1/50, 0/50 and 14/50 and in female
rats at incidents nf 0/75, 0/5CU-..1/50. and 32/4~9(NTP 1980a) .  Other non-
neoplastic lesions were not observed, even though extensive histologic examina-
tions were performed.  The two preceding studies support a NOAEL for noncar-
cinogenic effects in rats of sO.001 yg/kg/day and a lowest-observed-adverse-
effect level (LOAEL) of 0.05 yg/kg/day.

Non-neoplastic effects of chronic dioxin exposures were described in studies
investigating the carcinogenic potential of dioxin in mice.  In a National
Toxicology Program (NTP 1980a) bioassay, histologic examinations were per-
formed on B6C3F1 mice treated biweekly with dioxin by gavage in corn oil-
acetone (9:1) for 104 wk followed by an additional 3-wk observation period.
The doses for male animals were 0.0, 0.01, 0.05 and 0.5 yg/kg/wk, and for
female animals, 0.0, 0.04, 0.2 and 2.0 yg/kg/wk.  The only non-neoplastic
adverse effect observed was toxic hepatitis, which occurred in males at
incidences of 0/73, 5/49, 3/49 and 44/50, and in females at incidences of
0/73, 1/50, 2/48 and 34/47, respectively, in the control, low, medium and high
dose groups.  In another study, weekly administration of dioxin by gavage at
doses of 0.0, 0.007, 0.7 or 7.0 yg/kg/wk for one year resulted in amyloidosis
(disposition of amyloid, a complex proteinaceous material) of the kidney,
spleen and liver, and dermatitis at the time of death in male Swiss mice (Toth
et al. 1978, 1979).  The incidences of these effects in the control, low,
medium and high dose groups, respectively, were 0/38, 5/44, iO/44 and 17/43.
In the high dose group, the amyloidosis was extensive and considered to be the
cause of early mortality.  Severe toxic effects were observed at doses of
1 yg/kg/day (early mortality) and 0.28 to 0.07 yg/kg/day (toxic hepatitis),
while a LOAEL for dermatitis and amyloidosis of 0.001 yg/kg/day was reported.
                                     4-5

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                 TABLE 4-2  NOAEL AND LOAEL VALUES OBTAINED FROM SUBCHRONIC AND CHRONIC ORAL
                                         TOXICITY STUDIES OF DIOXIN
Species
Rat:
Rat
Rat:
Rat
Mouse
Monkey
Rat
Rat
Mouse
Duration
of Exposure
13 wk
13 wk
16 wk
28 wk
13 wk
36 wk
104 wk
104 wk
104 wk
Endpoints
Decreased body weight,
liver pathology
Toxic hepatitis
Elevated porphyrin
levels
i
NOAEL
ug/kg/day
0.01
0.07
0.0014
Fatty changes in the ND
liver, decreased body
weight
t
Toxic hepatitis ND
Pancytopenia ND
Degenerative and necrotic 0.001
changes in the liver
Toxic hepatitis 0.0014
Dermatitis and amyloldosis ND
LOAEL
ug/kg/day
0.1
0.14
0.014
0.014
0.014
2
0.01
0.007
0.001
Reference
Kociba et al
NTP (1980a)
Goldstein et
. (1976)

al. (1982)
King and Roesler (1974)
NTP (1980a)
Allen et al.
Kociba et al
NTP (1980a)
NTP (1980a)
(1977)
. (1978, 1979)


(a)  ND = Not  determined.

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4.3.3     Toxicity in Aquatic Species

No standard chronic toxicity assays of dioxin in aquatic species were located
in the available literature (USEPA 1984) but several studies provide informa-
tion indicative of chronic toxicity values.  In a static bioassay, Miller
et al. (1973) indicated that 0.2 yg/L may cause chronic toxicity in Paranais
sp. (worm).  Based on the 55% mortality in coho salmon within 60 days follow-
ing acute (96-hr) exposures to 0.0056 yg/L (Miller et al. 1979), the USEPA
(1984) suggests that 0.0056 yg/L may cause chronic toxicity coho salmon.
Similarly the USEPA.(1984) concludes that chronic toxicity values such as
0.001 yg/L (rainbow trout) and 0.01 yg/L (northern pike, coho salmon, mosquite
fish and channel catfish) can be inferred based on results of acute assays by
Helder (1980, 1981, 1982), Yockim et al. (1978) and Branson et al. (1983).  A
concentration of 1;3 yg/L may not cause chronic toxicity in Daphnia magna or
Physa (USEPA 1984).

Limited data are available on the toxicity of dioxin to aquatic plants.
Isensee and Jones (1975) and Isensee (1978) observed no adverse effects in
algae (Oedogoriium cardiacum) or duckweek (Lemna minor) exposed to 1.3 yg/L and
0.71 yg/L (respectively) for 30 days.  Yockim et al. (1978) has also observed
no adverse effects on £._ cardiacum exposed to 0.0024 to 0.0042 yg/L of dioxin
for 32 days.

4.4       Teratogenicity, Reproductive Effects and Fetotoxicity

4.4.1     Effects.of Humans            —

Epidemiological studies have attempted to investigate health effects of dioxin
in humans by  indirectly evaluating health effects in populations exposed to
2,4,5-T (which commonly contains dioxin as an impurity).  A positive associa-
tion between 2,4,5-T exposures and increases in birth defects or abortions has
been reported in human populations in Oregon (USEPA 1979), New Zealand (Hanify
et al. 1981)  and Australia (Field and Kerr 1979).  A lack of any such associa-
tion has been reported in human populations in Arkansas (Nelson et al. 1979),
Hungary (Thomas 1980), New Zealand (Dept. of Health, New Zealand 1980, McQueen
et al. 1977)  and Australia (Aldred 1978).

Thomas (1980) used an approach similar to that of Field and Kerr (1979) for
analyzing data from Hungary.  One major difference, however, is that Thomas
(1980) compared the incidence of stillbirths, cleft lip, cleft palate, spina
bifida, anencephalus and cystic kidney disease in all of Hungary between 1976
and 1980 with 2,4,5-T use in all of Hungary in 1975.  Because Hungary requires
compulsory notification of malformations diagnosed from birth to age one year;
because a relatively large percentage (55%) of the Hungarian population lives
in rural areas where 2,4,5-T exposure may be expected to be greatest; and
because annual use of 2,4,5-T in Hungary had risen from 46,000 kg in 1969 to
1,200,000 kg in 1975, Thomas (1980) considered Hungary to be "...probably che
best country  in which to examine possible health effects of this herbicide."
In any event, all indices of birth defect rates decreased or remained stable
over the period of study.
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Epidemiologic studies to determine the reproductive effects in individuals
exposed to dioxin and 2,4,5-T following the accidental contamination of a
populated area around Seveso, Italy, have not been completed.

4.4.2     Effects in Laboratory Animals

Dioxin has been reported to be fetotoxic and teratogenic when administered
alone or in combination with other chemicals.  Several studies have been
identified in the available literature based on dioxin exposure alone.
Effects observed were kidney anomalies, intestinal hemorrhage, general edema,
cleft palate and fetal death.  Adverse effects on reproduction were also
reported.

Intestinal hemorrhage, general edema and a reduction in fetal weights were
reported in rats following the administration of 0.125 yg/kg/day in studies by
Sparschu et al. (1971).  In the same studies, the number of fetuses was
reduced and fetal death increased at 0.5 yg/kg/day.  No structural malforma-
tions were reported at 0.03 ug/kg/day.  Courtney and Moore (1971) reported
cleft palate and kidney abnormalities in mice borne by dams administered
dioxin at doses of 1.0 yg/kg or 3.0 yg/kg.  Similarly, kidney malformations
were reported by the same authors in offspring from rats which received
subcutaneous injections of 0.5 yg/kg/day on day 9, 10, or 13 and 14 of
gestation.

Murray et al. (1979) completed a three-generation reproduction study using
Sprague-Dawley rats fed dioxin-continuously in the diet (at levels of 0,
0.001, 0.01, and 0.1 yg/kg/day). . Significant decreases were observed in
fertility, litter size, gestation survival, postnatal survival, and postnatal
body weight for the 0.01 and 0.1 yg/kg groups.  No apparent adverse effect on
reproduction was seen at the 0.001 yg/kg dose level.

Although Murray.et al. (1979) considered the lowest dose tested, 0.001 yg/kg,
to be a NOEL (noncarcinogenic), reevaluation of these data by Nisbet and
Paxton (1982) using different statistical methods indicated that there was a
reduction in the gestation index, decreased fetal weight, increased liver-
to-body weight ratio, and increased incidence of dilated renal pelvis at the
0.001 yg/kg dose.  The reevaluation of data suggests that equivocal adverse
effects were seen at the lowest dose (0.001 yg/kg/day) and that, this dose
should, therefore, represent a LOAEL.

Schantz et al.  (1979) found reductions in fertility and various other toxic
effects in rhesus monkeys fed 55 ppt dioxin in the diet for 20 mo.  This
corresponds to a calculated daily dioxin dose of 0.0015 yg dioxin/kg/day.
These results suggest that monkeys may be somewhat more sensitive than rats,
since the effects in monkeys were more severe and not equivocal.

Luster et al. (1980) examined bone marrow, immunologic parameters, and host
susceptibility  in B6C3F1 mice following pre- and postnatal exposure to TCDD.
Doses of 0, 1.0, 5.0 and 15.0 yg/kg bw of dioxin were given to dams on day 14
of gestation and to offspring on days 1, 7, and 14 following birth.  Neonatal
body, liver, spleen, and thymus weights were decreased and bone marrow
                                      4-8

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                                                                  £ife Systems, he.
toxicity occurred In the 5.0 and 15.0 Ug/kg groups.  Red blood cell counts,
hematocrits, and hemoglobin were decreased at the highest dose tested.

4.5       Mutagenicity

Studies on the mutagenicity of dioxin have produced conflicting results.
Dioxin reportedly produces mutagenic effects in various bacterial systems.
However, results were negative in tests employing other indicator test
systems, including cytogenetic (chromosome analysis) tests and dominant lethal
assays.  Hussain et al. (1972) reported that dioxin (2 ug/mL) increased the
incidence of reverse mutations in Escherichia coli.  Similarly, dioxin  (dose
not specified) was reported to be mutagenic without metabolic activation in
Salmonella typhimurium test strain TA 1532.  Green et al. (1977) gave 0.25,
0..5, 1.0, 2.0, or 4.0 Ug/kg of dioxin (dissolved in 1 part acetone: 9 parts
corn oil) by gavage to male and female Osborne-Mendel rats twice weekly for
13 wk and observed an increased incidence of chromosomal breaks in female rats
dosed with 4 ug/kg and in males dosed with 2 Ug/kg or 4 ug/kg.

Mutagenic effects (with or without metabolic activation) were not detected
when Geiger and Neal (1981) examined the mutagenicity of dioxin (up to
20 ug/plate) using the £. typhimurium test strains TA1535, TA100, TA1538,
TA98, and TA1537.

4.6       Carcinogenicity

4.6.1     Carcinogenicity in Humans   .                                    _-
                 •
Epidemiologic studies of industrial workers and herbicide applicators suggest
that dioxin may be a human carcinogen.  However, since dioxin is usually a
contaminant of phenoxy acids and/or chlorophenols, human exposure is usually
to multiple chemicals.  Therefore, the evidence for human carcinogenicity from
these studies is only suggestive due to the difficulty of evaluating the risk
of dioxin exposure in the presence of the confounding effects of the other
chemicals (USEPA 1984).

Observations of an unusual occurrence of relatively rare soft-tissue sarcomas
(STSs) were first made by Hardell (1977).  Of some 87 patients seen from 1970
to 1976 at the Department of Oncology, University Hospital, Umea, Sweden,
seven individuals with soft-tissue sarcomas were identified.  All seven had
had occupational exposure to phenoxy acids 10 to 20 yr earlier.  The tumors
were two leiomyosarcomas;-one liposarcoma; one rhabdomyosarcoma; one myxofibro-
sarcoma; and .two additional sarcomas of which the histopathology was uncertain,
but one was probably a neurofibrosarcoma and the other a rhabdomyosarcoma.
The clustering of this rare tumor type among these patients prompted the
author to suggest that epidemiological studies be designed to determine if
exposure to phenoxy acids and their impurities (i.e., dioxins) are related to
the occurrence of STS.

A few occurrences of soft tissue sarcoma have also been reported among
chemical industry workers in the United States who were exposed to varying
levels of 2,4,5-chlorophenols with dioxin contaminants (Cook et al. 1980, Moes
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and Selikoff 1981).  Honchar and Halperin (1981) reported that 3 of 105 deaths
among phenoxy acid workers reported by two chemical companies were from STS.

Zack and Suskind  (1980) reported a STS death in a cohort study of workers
exposed to dioxin in a trichlorophe-nol process accident in West Virginia.
This tumor, a fibrous histiocytoma, was considered as a rare event.

In a cohort mortality study of 61 male employees of a trichlorophenol manu-
facturing area who exhibited chloracne following a 1964 exposure incident,
Cook et al. (1980) noted four deaths by the end of his study period, one of
which was due to a fibrosarcoma.

There are numerous other studies reported regarding STSs.  For example, Smith
et al. (1982) conducted an initial case-control study of 102 males identified
from the New Zealand Cancer Registry as having STSs (ICD 171) between 1976 and
1980.  For each case, three controls each with another form of cancer were
matched by age and year of registration.  The selection of cancer controls
from the same registry was done to eliminate recall bias or interviewer bias
or both.

The distribution of tumor types differed considerably from the Hardell and
Eriksson et al. (1981) study to the Smith et al. (1982) study.  Leiomyo-
sarcomas, malignant histocytomas, neurogenic sarcomas and myxosarcoma seem to
predominate in the Hardell and Eriksson (1981) study, whereas fibrosarcomas  .
and.liposarcomas appear prominently.in the Smith et al. (1982) study.

Smith et al. (1983) conducted another case-control study of STSs in males that
were reported to  the New Zealand Cancer Registry by Public Hospitals"between
1976 and 1980.  Smith et al. (1983) remarked that it was surprising that he '
found no STS victim who had ever worked full-time in phenoxyacetic acid
herbicide spraying.  Perhaps they have not yet been observed for a long enough
period.  As was pointed out by the author, the findings do not support the
hypothesis that exposure to phenoxyacetic acid herbicides causes STS; however,
neither do they support a negative finding without better documentation
regarding actual  exposure and time of actual exposure.

The Michigan Department of Public Health (1983) recently conducted an ecological
study of soft and connective tissue cancer mortality rates in Midland and
other selected Michigan counties.  They found that mortality rates for this
cancer were 3,8 to 4.0 times the national average for the periods  1960 to 1969
and  1970 to 1978, respectively, for white females in Midland.  These estimates
are based upon five deaths and seven deaths, respectively.- No excess risk was
reported among white males, however.  The Michigan Department of Health
concluded that because of the occurrence of these two successive elevated
rates, it is unlikely to be a chance happening.  At the same time  the age-
adjusted male and female cancer mortality rates for Midland were below that  of
the  Scate of Michigan for the period  1970 to 1979.  Midland County is the home
of  a major chemical company that produced phenoxyacetic acid herbicides until
recently.  The authors stated that a detailed review of death certificates,
hospital records, residency and occupational histories of  the 20 male and
female cases revealed no "commonalities" suggesting a "single causative
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agent," although a majority of their spouses had worked at this chemical
facility.  They recommended that a case-control study should be instituted to
evaluate possible influences, such as lifestyles, occupation or location of
residences, on the risk of STS.

4.6.2     Carcinogenicity in Laboratory Animals

The carcinogenic potential of dioxin has been studied extensively in labora-
tory animals.  A summary of the results of selected comprehensive studies is
presented in Table 4-3.  The results of these studies show that dioxin-exposed
animals exhibited malignant lesions involving multiple organ systems including
accessory digestive organs (liver), endocrine (thyroid, adrenal), renal,
reproductive (testes), and nasal structures.  Representative studies are
described below.

Groups of ten male Sprague-Dawley rats were fed a diet containing dioxin for
78 wk at concentrations ranging from 1 ppt to 500 ppt or 1 ppb to 1,000 ppb
(Van Miller et al. (1977).  These dietary levels represent approximate weekly
dose levels of 0.0003 to 0.1 yg/kg or 0.4 to 500 yg/kg.  Animals exposed at
5 ppt, 50 ppt, 500 ppt or 5 ppb showed an overall incidence of neoplasms of
38% (23/60).  No neoplasms were reported or observed following exposure to
1 ppt dioxin.  In the 5 ppt group, 5/10 animals had six neoplasms (earduct
carcinoma, lymphocytic leukemia, adenocarcinoma, malignant histiocytoma (with
metastases), angiosarcoina and Leydig-cell adenoma).  Neoplasms were also.
observed in the following groups:  at 50 ppt, three in 3/10; at. 500 ppt,
four in 4Y10; at 1 ppb, five in 4/1.0; at 5 ppb, ten in 7/10.  Neoplasms were
not observed in the controls.  Rats administered dioxin at 50, 500 or 1,000 ppb
exhibited 100% mortality by the fourth week.

In another study (Kociba et al. 1978), groups of 100 Sprague-Dawley rats
(50 males and 50 females) received diets containing dioxin at 0, 22, 210, or
2,220 ppt (equivalent to a daily dose of 0.0, 0.001, 0.01 and 0.1 yg/kg bw)
for two years.  Administration of 0.01 yg/kg/day increased the incidence of
hepatocellular hyperplastic nodules (female: 18/50 versus 8/86 controls) and
focal alveolar hyperplasia in the lungs (P<0.05).  Dietary intake of
0.1 yg/kg/day increased the incidence of hepatocellular carcinomas (female:
11/49 versus 1/86) and squamous cell carcinomas of the lung (female: 7/49
versus 0/86), hard palate/nasal turbinates (male: 4/50 versus 0/85; female:
4/49 versus 0/86), and tongue (male: 3/50 versus 0/85) (P<0.05).  Also in-
creased in frequency by the 0.1 yg TCDD/kg/day were adenoma of the adrenal
cortex (male) and hepatocellular hyperplastic nodules (female).

The NTP (1982a) conducted a study for 104 wk using Osborne-Mendel rats and
B6C3F1 mice.  The rats and male mice were administered TCDD at 0, 0.01, 0.05
or 0.5 yg/kg/wk by gavage in two divided doses, and the female mice were given
0, 0.04, 0.2, or 2.0 yg/kg/wk.  Incidences of follicular cell thyroid adenomas
in male rats (F<0.001) and of neoplastic nodules in livers of female rats
(P=0.006) increased significantly.  Dioxin increased the numbers of hepato-
cellular carcinomas in male mice (P=0.002) and in females (P=0.014).  The
total liver tumors (carcinomas and adenomas) were increased in males (P<0.001)
                                     4-11

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                            TABLE 4-3  SUMMARY OF CARCINOGENIC EFFECTS OF DIOXIN
Species/Sex
 (Number)
Rat/
  M (50)
  I- (50)
    Dose
Rat/M (10)    1 ppt
Rat/M (10)    5-500 ppt
Rac/M (10)    1-5 ppb
0.001 pg/kg

0.01 Kg/kg

0.1 Mg/kg
 Duration    Route
                78 wk
2 yr
                      Effects
Reference
             Diet     No neoplasm.
                                            Van Miller et al.
                                            (1977)
         Ear duct carcinoma, benign tumor
         of the kidney and testes,
         lymphocytic leukemia, skin
         carcinomas and benign muscle
         tumors.

         Cholangiocarcinoma of liver,
         squamous cell tumor of lung,
         angiosarcoma in skin, glioblas-
         toma in brain, malignant histio-
         cytomas in peritoneum.
         *
Diet     No significant increase in tumors. Kociba et al.  (1978)

         Liver cancer.

         Liver cancer, squamous cell car-
         cinoma of the lung, hard palate/
         nasal turbinates, or tongue
         (P=0.05).
Mouse/F (30)  0.015 pg/kg/wk  99-104 wk    Dermal
Mouse/M (30)  0.003 pg/kg/wk  99-104 wk    Dermal
Rat/M (50)    0.5 pg/kg/wk    104 wk
Rat/F (50)    0.5 pg/kg/wk    104 wk
                             Gavage


                             Gavage
                      Fibrosarcoma in integumentary
                      system (8/27, P=0.007).

                      Fibrosarcoma in integumentary
                      system (6/28, P=0.08)

                      Follicular cell adenomas of
                      thyroid (10/50, P=0.001).

                      Neoplastic nodules of the liver
                      (12/49, P=0.006).
                                                                         NTP (1982b)
                                            NTP  (1982a)
                                                                                   continued-

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       Table 4-3 - continued
.£>
i
       Species/Sex
        (Number)
    Dose
Duration    Route
       Mouse/M&F     2.0 pg/kg/wk    104 wk
       Mouse/F
2.0 pg/kg/wk    104 wk
       Mouse/M (39)  0.007 pg/kg/wk  52 wk


       Mouse/M (44)  0.7 pg/kg/wk    52'wk

       Mouse/M (44)  7.0 pg/kg/wk    52 wk
            Gavage



            Gavage


            Gavage


            Gavage

            Gavage
             Effects
Hepatocellular carcinoma
(17/50, P=0.002 in M);
(6/47, P=0.14 in F).

Follicular cell adenomas of the
thyroid (5/46,. P=0.009)

Liver tumors (13/44, P not
specified

Liver tumors (21/44, P<0.01)

Liver tumors (13/43, P=0.11)
Reference
                                                                         NTP (1982a)
                                                                         Toth et al.  (1979)
       Adapted from Esposito et al. (1980), NTP (1982a,b).

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                                                                  £ifc Systems, fac.
and females (P=0.002).  In addition, female mice had increased incidence of
follicular cell thyroid adenomas.  These studies indicate that TCDD is an
animal carcinogen.

Toth et al. (1979) administered doses of 0, 0.007, 0.7 and 7.0 yg/kg/wk of
dioxin to male mice by gavage in a study to determine whether 2,4,5-trichlor.->-
phenoxyethanol (2,4,5-TCPE), its contaminant (dioxin) or both were carcino-
genic.  The incidence of liver tumors was significantly increased in the dose
group receiving dioxin at the 0.7 pg/kg/wk level.  No significant increased
incidence in liver tumors was observed in the 7.0 pg/kg/wk dose group although
increased mortality in this group probably precluded detection of tumors with
longer latent periods.

The NTP (1982b) conducted a skin painting cancer bioassay of dioxin on Swiss-
Webster mice (50 of each sex/dose).  A dose of 0.001 pg/application (males)
and 0.005 pg/application (females) in acetone suspension was painted on the
skin 3 days/wk for 104 wk.  The vehicle control group (45 mice/sex) was
painted with 0.1 mL acetone 3 times/wk for 104 wk.  The incidence of fibro-
sarcoma in the integumetary system was significantly increased in females
(8/27, P=0,007) but not in males (6/28, P=0.08) compared to the incidence
respective controls (2/41 and 3/42).

DiGiovanni et al.  (1977) reported that dioxin was a tumor initiator in mouse
skin.  However, the role of dioxin as an initiator needs to be confirmed since
appropriate vehicle and promotion-only controls were not included in this
assay.  'Several assays (NTP 1982b, Berry et al. 1978, 1979) demonstrated that
dioxin was not a tumor-promoter when applied to mouse skin after unknown
initiator  (DMBA).

Poland and Knutson (1982) reported that dioxin was a tumor promoter when
tested on the skin of mice homozygous for the "hairless" trait but not in mice
heterozygous for this recessive trait.  Pitot et al. (1980) also reported that
dioxin was a promoter for DEN-initiated hepatocarcinogenesis in rats following
parenteral administration of the compounds.  On mouse skin, dioxin was a
complete carcinogen and possibly a tumor initiator, while no tumor-promoting
activity could be attributed to dioxin in the assays.  In rat liver initiated
with DEN, dioxin was a tumor promoter.

In the mouse skin bioassay, initiation with simultaneous administration of
dioxin and DMBA, however, did not affect tumor yield (DiGiovanni et al. 1977).
Similarly no effect was observed when dioxin was administered either immedi-
ately before (five minutes) or one day after DMBA initiation (B,erry et al.
1979, DiGiovanni et al. 1977, Cohen et al. 1979).  When treatment with dioxin
occurred one to ten days before DMBA initiation, dioxin demonstrated a potent
anticarcinogenic action.  Although one to five days prior exposure to dioxin
inhibited  tumor initiation by BaP, 3-MC, and BaP-diol-epoxide, the tumor-
initiating ability of the latter compound was also inhibited when dioxin
exposure occurred either five minutes before or one day after initiacion
(DiGiovanni et al. 1980).  The increased AHH activity resulting from dioxin
exposure may account for the anticarcinogenic activity by altering the
metabolism of the  initiating compound; however, DiGiovanni et al.  (1980)
                                      4-14

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                                                                  £ife Systems, Jttc.
suggests that the initiation of the initiating activity of BaP-diol-epoxide
one day after initiation indicates that more than one mechanism participates
in the anticarcinogenic activity of dioxin.

4.7       Quantitative Indices of Toxicity.

4.7.1     Noncarcinogenic Effects Indices

Recommended exposure limits to dioxin to ensure human safety have been
established by several agencies.  The'National Academy of Sciences  (NAS 1977),
before TCDD was considered to be a carcinogen, suggested an ADI for dioxin of
0.0001 ug/kg/day based on a 13-wk feeding study in rats (Kociba et  al. 1976).
The reported NOEL in that study (0.01 ug/kg) was divided by an uncertainty
factor of 100 to determine the ADI.  The NAS then calculated a suggested-
no-adverse-effeet-level (SNARL) in drinking water of 0.0007 ug/L, based on the
average weight of a human adult (70 kg) and an average daily intake of water
of two liters, with water representing 20% of total intake.

The USEPA (1984) has calculated an ADI of 10~  ug/kg/day based on noncarcino-
genic toxicity for comparison to the carcinogenic risk assessment value.  A
LOAEL based on noncarcinogenic toxic effects and reduced fertility  of
0.001 ug/kg/day and an uncertainty factor of 1,000 were used in the calcula-
tions.  Using a bioaccumulation factor of 5,000, and assuming a_daily
consumption of 6.5 g of fish, a water concentration of 2.0 x 10   Ug/L was
derived.  It was noted that this value'may not be sufficiently low  to protect
against the carcinogenic effects of dioxin (USEPA 1984).  The USEPA is cur-
rently reevaluating the bioconcentration factor for dioxin.

The USEPA (1984) concluded that insufficient data were available concerning
adverse effects of d.ioxin on aquatic life to allow derivation of ambient water
quality criterion.  Limited information in freshwater species indicate acute
values may be >0.1 ug/L and chronic values may be <0.01 Ug/L (northern pike,
coho salmon, mosquito fish and channel catfish) and <0.001 Ug/L ,(rainbow
trout).

4.7.2     Carcinogenic Effects Indices

Since there is no recognized safe "concentration for a human carcinogen, and
dioxin is a suspected human carcinogen", the recommended concentration of
dioxin in water is zero (USEPA 1984).  The USEPA calculated a range_pf   _,
concentrations for dioxin corresponding to cancer risk levels of 10  ; 10
and 10  .  These calculations used a linearized multistage model and were
based on animal bioassay data. ..The recommended criteria which may  result in
an increased cancer risk of 10  , 10~  or 10~  are 1.3 x 10~ , 1.3  x  10   and
1.3 x 10   Ug/Lj respectively.  These criteria are below the limit  of
detection of TCDD in water (.approximately 3 x 10~  ug/L) by current analytical
methods.

The Food and Drug Administration (FDA) issued a health advisory stating that
fish with residues of dioxin >50 ppt should not be consumed, but fish with
residues of < 25 ppt pose no Serious health concern (USEPA 1984). The Centers
                                     4-15

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                                                                Jttfc Systems, Jnc.
for Disease Control  (CDC) has established 1 ppb  as  a  level of concern for
dioxin in residential  soils at Times Beach, MO.
                                    -4-16

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                                                                  £ife Systems, JHC.
5.0       RISK AND IMPACT EVALUATION

5.1       Human Health

Quantitative risk assessments (QRA) for exposures to dioxin via consumption of
contaminated fish and via inhalation of air-borne dust have focused on carrir.c -
genie effects (Falco 1982, Falco and Schaum 1984).  Both risk assessments are
based on limited data and required numerous assumptions (previously discussed
in Section 3.0) to address data gaps.  Falco (1982) emphasizes that the
limited data -are not sufficient to produce a statistically valid estimate of
errors but the assessments provide a means to bound possible exposures and
associated risks.

5.1.1     QRA for Consumption of Contaminated Fish

Falco (1982) estimated the upper limit individual cancer risk to range from
10   to 10   due to consumption of dioxin contaminated fish from Bayou Meto.
These cancer risks are based on potential exposures which were estimated to
range from 0.09 ng/kg/yr to 110 ng/kg/yr.  The QRA was based on the Kociba
et al. (1978) study in which dioxin induced a statistically significant
increase in the incidence of tumors in the liver, lung and hard palate or
nasal turbinates.  The linerized multi-staged model was employed with an
assumed continuous exposure during the course of a lifetime (70 yr).  The
upper lifetime cancer risks were estimated for consumption of fish-caught from
various distances from the site along the length of Bayou Meto.  The upper
limit cancer risk estimate is greater than 10   for consumption of fish from
the mouth of Bayou Meto which is approximately 130 mi downstream from the
Vertac site.  Falco (1982) emphasized that the actual risk may range anywhere
between 0 (the lower bound) to upper limit risk estimates presented in Table 5-1
Consumption of fish at a rate greater than the assumed average rate (5.2 Ib/yr)
increases the upper limit of individual cancer risk.  For example, individuals
with consumption rates at the expected,upper ,95th percentile (16 Ib/yr) would
have cancer risks ranging from 3 x 10~  to 3.2 x 10   corresponding to the
range of estimated contamination levels (2.6 to 3,300 ppt dioxin)  in fish from
Bayou Meto.

Falco and Schaum (1982) estimated that the number of people potentially
exposed annually would be 30,000 if one assumes an average consumption rate
and average catch rate.  Since the upper cancer risk for this group ranges
from 10   to 10   (depending upon the range of dioxin contamination levels in
fish), the corresponding upper bound estimate of induced cancers under this
scenario could range from 3 cases (1 case every 25 yr) to 3,000 cases
(43 cancers/yr) (assuming continuous exposure for 70 yr).

5.1.2     QRA for Contaminated Groundwater

No QRA for dioxin exposures due to contaminated groundwater has been per-
formed.  The actual risk via the groundwater route is probably minimal due to
the apparent lack of exposure potential.  However, this route may  pose unac-
ceptable carcinogenic risk if groundwater contaminated at 0.03 ppb dioxin (the
highest detected level in groundwater on-site) were consumed.  Assuming the
                                      5-1

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                                                                  &fe Systems, JHC.
            TABLE  5-1   HUMAN EXPOSURE AND UPPER-LIMIT CANCER RISK
                           ESTIMATES BY RIVER MILE
      River
      Mile

      132
      100
      75
      54
      34
      16
      0
                  Exposure,  ng/kg/yr
   Based on
Calculations
                     (b)
   0.96-110
   0.56-65
   0.48-56
   0.15-18
   0.13-15
   0.11-13
   0.09-10
                            Based on
                          Monitoring
                                    (c)
                              10.1
                              3.79
                              1.0
  Upper-Limit Lifetime ,
Cancer Risk Estimates	
                 Based on
                Monitoring
  Based on
Calculations
                                         0.0012
                                         0.00065
                                         0.00056
                                         0.00017
                                         0.00015
                                         0.00013
                                         0.00010
                                                   0.122
                                                   0.073
                                                   0.063
                                                   0.021
                                                   0.017
                                                   0.015
                                                   0.012
                  0.01
                  0.0044
                  0.0012
(a)  Calculated Exposure = (C  x
where C
           concentration of T
                    ^,-
                    CDD
                       x consumption rate)/70 kg body weight
                                     in sediment and
(b)
                                                      -,,
                                                       sediment fish
distribution coefficient.  Consumption rate assumed"3 5.2 Ib/yr
(2.37 kg/yr); low values assume K   = 5.4; high values assume K,,,, = 550.
                       K
                       (C
Exposures based on monitoring = (C" x consumption rate)/70 kg body
                                  r
    weight where C^ = measured concentration of TCDD in fish (only available at
    river miles 132, 100 and 75).  Consumption rate assumed = 5.2 Ib/yr
    (2.37 kg/yr).
(c) Upper Limit Risk = 1 - e              x exposure) where exposure is in
    units of ng/kg/day.  The risk could always approach-zero as a lower bound.
                                      5-2

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                                                                   JCifc Systems, JHC.
70-kg human would consume two liters of water per day then the dose would be
0.0009 yg/kg/day (0.9 ng/kg/day) .  Consumption of a dioxin dose of 0.9,-ng/kg/day
over a lifetime poses unacceptable carcinogenic risk exceeding the 10   risk  ,
associated withqconsumption of water with a dioxin concentration of 1.3 x 10
yg/L (3.7 x 10~  yg/kg/day or 0.0000037 ng/kg/day).  Consumption of drinking
water containing 0.005 ppb dioxin (the mean detected concentration) would
result in a dose of 0.0001 yg/kg/day (0.1 ng/kg/day) which would also pose
unacceptable carcinogenic risk exceeding the 10   level.  The lower bound
estimate is zero since consumption may not occur and because recent analyses
have not detected dioxin in groundwater monitoring wells.

5.1.3          QRA for Airborne Dust

Falco and Schaum (1984) performed a QRA for inhalation exposure to dust
(sorbed on dioxin) associated with the proposed remedial action (Alterna-
tive IV) .  The predicted upper bound cancer risk associated with the  remedial
action ranges from 5 x 10   to 7.4 x 10   for the nearest residents to the
Vertac site.  This risk estimate assumes no dust control measures are
implemented^  The wide range of risk estimates is due to uncertainty  in the
concentration of dioxin in materials to be excavated (0.1 to 14 ppm).  Falco
and Schaum (1984) calculated cancer risk with an adjusted cancer potency
factor.  The cancer potency factor (95% upper limit of the linear coefficient
in the dose response model) of 0.156 (ng/kg/day)~  was adjusted to account for
differences in absorption via oral exposure versus inhalation exposure routes.
Assuming an approximate oral absorption rate of about 50%, the potency factor
based on a dose administered in feed.was multiplied by a facto_r of two to
yield the potency 0.312 (ng/kg/day)   based on an absorbed dose..  Based on
predicted exposure levels, carcinogenic risk levels were calculated and
plotted (see Figure'5-1) for the nearest residents of the Vertac site.  There
is no demographic information available on the number of residents within the
isopleths on Figure 5-1.  The upperbound estimates of risk associated with
inhalation of dioxin-contaminated dust will decline with distance from the
site.  Sources of uncertainty are associated with parameter value assumptions
such as the dioxin concentration in soils, silt content, volume of excavated
soil, moisture content of soils, % dioxin absorption in lungs versus gastro-
intestinal tract and the cancer potency estimates.  In addition emission
factor equations and dispersion models have associated uncertainties.  Thus,
information necessary to analyze uncertainty on a statistical basis is
unavailable but the estimated range of risks appears representative of these
type of calculations (Falco and Schaum 1984).

5.1.4     QRA for Direct Contact

No QRA for dioxin exposures via direct contact with contaminated soils and
sediments is available.  However, the levels of dioxin in soils and sediments
offsite exceed the CDC's 1 ppb level of concern for residential soils
established for Times Beach, MO.

5.2       Environmental

No QRA for aquatic or terrestrial life in the environment adjacent to or
contaminated by the Vertac site is available.  There are potential risks to
                                      5-3

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                                                                £ife Systems, Jnc.
                                                2.3 x  10   to 6.1 x  10
                                                4.5 x  10   to 6.8 x 10
                                                5 x  10~8 to 7.4 x 10"6
Scale:  1 in = 145 meters

       Center of Dust Emission Source

                    = Property Line
Adapted from Falco and Schaum (1984)
   FIGURE 5-1  MINIMUM AND MAXIMUM ACCUMULATIVE UPPER BOUND RISK ESTIMATE
        IMMEDIATELY SOUTH OF THE VERTAC PROPERTY (RESULTING FROM THE
                   COMBINATION OF PHASE 1 AND 2 ACTIVITIES)
                                      5-4

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                                                                   £ifc Systems, JHC.
 aquatic  and  terrestrial  species  related  to dioxin  releases  from  the  Vertac
 site.  The absence of benthic  life,  several massive  fish  kills and reported
 "medicinal"  taste and odor of  fish caught from  Bayou Meto (receiving waters
 of  the Rocky  Branch  Creek) reflect the impact of contaminants released  from
 the Vertac site on aquatic life  (JRB 1983).  The limited  environmental  moni-
 toring data  for sediments in the Rocky Branch Creek, Bayou  Meto  and  Lake
 Dupree indicate substantial dioxin contamination has occurred.   Analyses  of
 fish tissues  demonstrates that dioxin has been  bioaccumulated to substantial
 levels (up to  300 ppt in Bayou Meto  and  810 ppt in Lake Dupree)  but  the health
 significance  of such tissue levels and potential impact on  survival, growth,
 development  and reproduction of aquatic  life remains unknown.  The absence of
 ambient  water  quality criteria and especially criteria for.  dioxin levels  in
 sediments impedes performance of a QRA for aquatic organisms.

 There is a paucity of monitoring data on the concentration  of dioxin in
 surface  waters offsite.  The only data available indicate that dioxin was not
 detected in water from the Rocky Branch  Creek.  Therefore,  it is not possible
 to compare dioxin concentrations in  receiving water  to levels causing acute
 toxicity (>1.0 ppb)  in certain freshwater species  or chronic toxicity in  the
 rainbow  trout  (<0.001 ppb) or in several other  fish  species (<0.01 ppb).

 The high content of  dioxin in sediments  (500 ppt ave) in  the Rocky Branch
 Creek and potential  for release to the water column  suggests that aquatic
 organisms may be at  risk.  No existing guidelines  or standards are available
 'to determine risks to avian 'or terrestrial organisms-,  The  potential impact of
.contamination on such species is of  concern since  the Bayou Meto area serves
 as an important water fowl resting area  and contains about  70,000 acres of
 wetlands.  Limited data are available on the avian species  and terrestrial
 species present in the area.  Contamination of  the Bayou  Meto and accumulation
 of dioxin in the aquatic food chain  may  endanger predator (avian or
 terrestrial) species.

 5.3       Public Welfare

 The major socioeconomic impact of the release of dioxin from the Vertac site
 has been the loss of adjacent surface waters for fishing  and recreation.  For
 example, the release of dioxin to the Rocky Branch Creek  and Bayou Meto and
 transport to Lake Dupree during flooding has caused  fish  to accumulate  (810 ppt)
 dioxin in excess of  the FDA health advisory value  of ^50  ppt.  Thus, fish from
 Lake Dupree may be unfit for human consumption.  This contamination  of  fish
 has required the Arkansas public health  officials  to issue  a fishing ban  for
 the Bayou Meto area.  An additional  impact on public welfare may be  a poten-
 tial decrease of property values immediately adjacent to  the site (i.e.,
 especially residential property values)  and the loss of groundwater  aquifers
 as a potential source of drinking water.
                                      5-5

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                                                                 JttfcSystems,
6.0     '  CONCLUSIONS

The most significant endangerment of human health is due to the potential
consumption of dioxin-contaminated fish from Bayou Meto.  Falco and Schaum
(1982) estimated that chronic (lifetime) consumption of contaminated fish from
Bayou Meto may lead to an upper limit individual cancer risk ranging from
1/10,000 to 1/10.  Under this scenario  (assuming 30,000 people are exposed
based on an average catch rate and an average consumption rate) the estimated
upper bound of induced cancers may range from 3 cases (1 case/25 yr) to
3,000 cases (43 cases/yr).  However, the lower, bound estimate of induced
cancers is zero regardless of consumption rate and fish catch size.  The
fishing ban for Bayou Meto may reduce this threat to human health, but its
efficacy is unknown since it is not:easily enforced.

The contamination of groundwater represents another substantial potential
threat to human health.  There is a real potential for offsite migration of
contaminants to groundwater.  A maximum of 0.03 ppb and a mean of 0.005 ppb of
dioxin have been detected in on-site groundwater monitoring well.  Actual
exposures to humans via this route is currently considered unlikely since no
permitted domestic and industrial wells were located in the area immediately
downgradient of the site.  Human health may be endangered if water wells are
drilled in the future and used for drinking water purposes.  However * assuming
humans may potentially consume groundwater in the future, the resulting dose
of dioxin would increase risk of cancer substantially above the 10   level.
Further groundwater monitoring data are necessary to verify and characterize
the magnitude and extent of any offsite contamination.

Exposure to dioxin via dust-emissions from the proposed remedial action
(Alternative IV) was estimated to present an upperbound cancer risk ranging
from 5.8 x 10~  to 7.4 x 10   for residents near the Vertac site (within about
300 meters).  Demographic information on the size of this population was un-
available and therefore, an estimate of number of excess cancers is not
possible.                       /

The potential for direct contact with contaminated soils and sediments poses
human health risks.  Monitoring data indicate that levels of dioxins in soils
and sediments off-site exceed the CDC's 1 ppb level of concern for residential
soils (established for Times Beach, MO).

No quantitative assessment of risk to aquatic and terrestrial organisms was
available.  Limited environmental'monitoring data and the unavailability of
established ambient water criteria preclude such an assessment.  The data
demonstrate that dioxin is present in the sediments and bioaccumulates in fish
above the FDA's health advisory value of ^50 ppt.

Loss of fishing in the Bayou Meto area  impacts the public welfare.  Addi-
tionally decrease of property values adjacent to the site or along  the bayou
may impact the economic stability of the area.  Contamination of groundwater
may prevent its future use as a drinking water resource.
                                       6-1

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                                                                  £ife Systems, fac.
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Allen JR, Barsotti DA, Van Miller JP, Abrahamson LJ, Lalich JJ.  1977.
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Anaiz.i NH, Cohen J.  1978.  The effects of TCDD on the renal tubular secretion
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Bogen G.  1979.  Symptoms of Vietnam veterans exposed to Agent Orange.  J. Am.
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Branson DR, Takahashi IT, Parker WM, Blau GE.  1983.  Bioconcentratior
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CH2M Hill.  1984a.  Onsite feasibility study appendicies:  Vertac facility.
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Courtney KD, Moore JA.  1971.  Teratology studies with 2,4,5-T and 2,3,7,8-TCDD.
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risks of chlorinated dioxins and related compounds.  New York:  Plenum Press,
pp.  495-525.

Geiger LE, Neal RA.   1981.  Mutagenicity testing of 2,3,7,8-tetrachloro-
dibenzo-p-dioxin in histidine auxotrophs of Salmonella typhimurium.  Toxicol.
Appl. Pharmacol. 59(1):125-129.

Gianotti F.   1977.  Chloracne due to  tetrachloro-2,3,7,8-dibenzo-p-dioxin in
children.  Ann. Dermatol. Venereol. 104:825-829.
                                       7-2

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                                                                  £ife Systems,
Goldstein JA, Linko P, Bergman H.  1982.  Induction of porphyria in the rat by
chronic versus acute exposure to 2,3,7,8-tetrachlorodibenzo-p-dioxin.
Biochem. Pharmacol. 31(8):1607-1613.

Green S, Moreland F, Shen C.  1977i  Cytogenetic effects of 2,3,7,8-TCDD on
rat bone marrow cells.  Food and Drug Administration Bylines 6:292-294.

Creig JB, Jones G, Butler WH, Barnes JM.  1973.  Toxic effects of
2,3,7,8-TCDD. Food Cosmet. Toxicol. 11:585-595.

Gupta BN, Vos JG, Moore JA,  Zinkl JG, Bullock BC.  1973.  Pathologic effects
of 2,3,7,8-tetrachlorodibenzo-p-dioxin in laboratory animals.  Environ. Health
Perspect. 5:125-140.

Hamaker JW.  1978.  Interpretation of soil leaching experiments, republished
in Volume I of Chemicals, Human Health and the Environment, p. 24.

Hanify JA, Metcalf C, Nobbs L, Worsley JR.  1981.  Aerial spraying of 2,4,5-T
and human birth malformations:  An epidemiological investigation.  Science
212:349-351.

Hardell L.  1977.  Soft-tissue sarcomas and exposure to phenoxy acids:  A
clinical observation.  Lakartidningen. 74:2753-5754.

Hardell L, Eriksson M.  '1981.  Soft-tissue sarcomas, phenoxy herbicides.and
chlorinated phenols.  Lancet ii:250.

Harris MW, Moore JA, Vos JG, Gupta BN.  1973.  General biological effects of
TCDD in laboratory animals.   Environ. Health Perspect. 5:101-109.

Helder T.  1980.  Effects of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) on
early life stages of the pike (Esox lucius L.).  Sci. Total Environ.
14:255-264.

Helder T.  1981.  Effects of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) on
early life stages of rainbow trout (Salmo gairdneri, Richardson).  Toxicology
19:101-112.

Helder T.  1982.  Effects of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) on
early life stages of two fresh-water fish species.  In:  Hutzinger 0, Frei RW,
Merian E, Pocchiari F, eds.   Chlorinated dioxins and related compounds.  New
York:  Pergamon Press, pp. 455-462.

Holden C.  1979.  Agent Orange furor continues to build.  Science 205:770-772.

Holmstedt B.  1980.  Prolegomena to Seveso Ecclesiastes I 18.  Arch. Toxicol.
44:211-230.

Honchar PA, Halperin WE.  1981.  2,4,5-T, trichlorophenol and soft tissue
sarcoma.  Lancet 1:268-269.
                                      7-3

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                                                                   £ife Systems, Jnc.
Hook  JB,  et  al.  1978.   Renal  effects  of  2,3,7,8-TCDD.   Environ.  Sci. Res.
12:381-388.

Huetter  R, Phillippi M.   1982.   Studies  on  raicrobial metabolism  of  TCDD under
laboratory conditions.  -Pergamon Ser.  Environ.  Sci. 5:87-93.

Hussain  SL,  Ehrenberg  L,  Lofroth G, Gejvall T.   1972.   Mutagenic effects of
TCDD  on  bacterial  systems.  Ambio 1:32-33.

IARC.   1977.   International Agency  for Research on  Cancer.   IARC Monographs  on
the evaluation of  the  carcinogenic  risk  of  chemicals to man.   Some  fumigants,
the herbicides 2,4-D arid  2,4,5-T,  chlorinated  dibenzodioxins  and miscellaneous
industrial chemicals,  Vol.  15.   Lyon,  France:   International  Agency for
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IARC.   1982.   International Agency  for Research on  Cancer.   IARC monographs  or.
the evaluation of  carcinogenic  risk of chemicals to humans.   Suppl  4.  IARC
Lyon.  France.

Ideo  G,  Bellati G, Bellouono.A,  Mocarelli P, Marocchi  A,  Brambilla  P.   1982.
Increased urinary  D-glucaric  acid excretion by  children living in an area
polluted with  tetrachlorodibenzoparadioxin  (TCDD).  Clin.  Chim.  Acta.
120:273-283.

Isensee  AR,  Jones  GE.   1975.  -Distribution  of  2,3,7,8-tetrachlorodibenzo-p-
•dioxin (TCDD)  in aquatic  model  ecosystem.   Environ. Sci.  Technol. 9:668-672.

Isensee  AR.   1978. Bioaccumulation of 2,3,7,8-tetrachlorodibenzo-paradioxin.
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Ecol.  Bull.  (Stokholm)  27:250-262.

JRB.   1983.   JRB Associates.   Draft case studies:  Vertac  Chemical  Corpora-
tion,  Jacksonville, AR.   pp.  1-73.

Kearney  PC,  Woolson EA,  Ellington CP, Jr.   1972.  Persistence and metabolism
of chlorodioxins in soils.  Environ.  Sci. Technol.  6:1017-1019.

Kerney PC, et  al.   1973.   TCDD  in the environment:  Sources,  fate and
decontamination.  Environ.  Health Perspect. 5:273-277.

Kimbrough RD,  Carter  CD,  Liddle JA, Cline RE.   1977.   Epidemiology  and
pathology of a tetrachlorodibenzodioxin  poisoning episode.   Arch. Environ.
Health 32:77-86.

King  ME, Roesler AR.   1974.  Subacute intubation study on rats with the
compound 2,3,7,8-tetrachlorodioxin.  United States  Environmental Protection
Agency.   NTIS  PB-257-677, p.  27. *

Kociba RJ,  Keeler PA,  Park CN,  Gehring PJ.   1976.  2,3,7,8-tetrachloro-
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Toxicol. Appl. Pharmacol. 35:553-574.
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                                                                  jCife Systems, Me.
Kociba RJ, Keyes DG, Beyer JE, et al. 1978.  Results of a two-year chronic
toxicity and oncogenicity study of 2,3,7,8-tetrachlorodibenzo-p-dioxin in
rats.  Toxicol. Appl. Pharmacol. 46(2):279-303.

Kociba RJ, Keyes DG, Beyer JE, Carreon RM, Gehring PJ.  1979.  Long-term
toxicologic studies of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) in
laboratory animals.  Ann. NY Acad. Science 320:397-404.

Luster MI, Boorman GA, Dean JH, et al.  1980.  Examination of bone marrow,
immunologic parameters and host susceptibility following pre- and postnatal
exposure to 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD).  Int. J.
Immunopharmacol. 2(4):301-310.

Manara L, Coccia P, Croci T.  1982.  Persistent tissue levels of TCDD in the
mouse and their reduction as related to prevention of toxicity.  Drug Metab.
Rev. 13:423-446.

Matsumura F, Benezet HJ.  1973.  Studies on the bioaccumulation and microbial
degration of 2,3,7,8-tetrachlorodibenzo-p-dioxin.  Environ. Health Perspect.
5:253-258.

Matsumura F, Quensen J, Tsushimoto G.  1983.  Microbial degradation of TCDD in
a model ecosystem.  In:  Tucker, RE, Young AL, Gray AP ed.  Human and
environmental risks of chlorinated dioxins and related compounds.  New York:
Plenum Press, pp. 191-219.

May G.  1973.  Chloracne from the accidental production of tetrachlorodi-
benzodioxin.  Br. J. Ind. Med. 30*276-283.

May G.  1982.  Tetrachlorodibenzodioxin:  A survey of subjects ten years after
exposure.  Br. J. Ind. Med. 39:128-135.

McConnell EE, Moore JA, Dalgard DW.  1978a.  Toxicity of 2,3,7,8-tetrachloro-
dibenzo-p-dioxin in rhesus monkeys (Macacas mulatta) following a single oral
dose.  Toxicol. Appl. Pharmacol. 43:.175-187.

McConnell EE, Moore JA, Baseman JK, Harris MW.  1978b.  The comparative
toxicity of chlorinated dibenzo-p-dioxins in mice and guinea pigs.  Toxicol.
Appl. Pharmacol. 44:335-356.

McQueen, EG, Veale AM, Alexander WS, Bates MN. .1977.  2,4,5-T and human birth
defects.  Report of the Division of Public Health, New Zealand Dept. Health.

Michigan Department of Public Health.  1983.  Evaluation of soft and
connective tissue cancer mortality rates for Midland and other selected
Michigan counties compared nationally and statewide.  Michigan Dept. Public
Heaich, May 4.

Miller RA, Norris LA, Hawkes CL.  1973.  Toxicity of 2,3,7,8-tetrachlorodibenzo-
p-dioxin (TCDD) in aquatic organisms.  Environ. Health Perspect. 5:177-186.
                                      7-5

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                                                                   Life Systems, Jnc.
 Miller RA,  Norris  LA,  Loper BR.   1979.   The  response  of  coho. salmon  and
 guppies to  2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) in water.   Trans.  Am.
 Fish.  Soc.  108:401-407.

 Moore  JA, Gupta BN,  Vos  JG.  1976.   Toxicity of 2,3,7,8-tetrachlorodibenzo-
 furan  - preliminary  results.  Proc.  Natl.  Conf. PCB's, November,  77-80.

 Moses  M, Selikoff  I.   1981.  Soft tissue sarcomas,  phenoxy  herbicides  and
 chlorinated phenols.   Lancet i:1370.

 Murray FJ,  et  al.   1978.   Three  generation reproduction  study of  rats
 ingesting TCDD. Toxicol.  Appl.  Pharmacol. 41:200-201.

 Murray FJ,  .Smith FA,  Nitschke KD, Humiston CG, Kociba RJ, Schwetz BA.   1979.
 Three-generation reproduction study  of  rats  given 2,3,7,8-tetrachloro-
 dibenzo-p-dioxin (TCDD)  in the diet.  Toxicol. Appl.  Pharmacol.  50:241-251.

 NAS.    1977.  National Academy of Sciences.   Drinking water and  health.
 Washington, DC: National  Academy of Sciences.

 Nash RG, Beall ML, Jr.  1980.  Distribution  of Silvex, 2,4-D, and TCDD applied
 to turf in  chambers  and  field plots.  J. Agric. Food'.Chem.  28:614-623.

 Neal RA,' Olson JR, Gasiewicz TA, Geiger LE.   1982.   The  toxicokinetics of
 2,3,7,8-tetrachlorodibenzo-p-dioxin  in  mammalian systems.  Drug  Metab.-Rey.
 13:355-385.  __

• Nelson CJ,  Holson'JF,  Green HG,  Gaylor  DW.  1979.  Retrospective  study of  the
 relationship between agricultural use of 2,4,5-T and  cleft  palate occurrence
 in Arkansas.  Teratology 19:377-384.

 Nisbit ICT, Paxton MB.  1982.  Statistical aspects  of three-generation studies
'of the reproductive  toxicity of TCDD and 2,4,5-T.  Am. Stat. 36:290-298.

 Nolan  RJ,  Smith FA,  Hefner JG.  1979.  Elimination  and tissue distribution of
 2,3,7,8-tetrachlorodibenzo-p-dioxin  (TCDD) in female  guinea pigs following a
 single oral dose.   Toxicol. Appl. Pharmacol. 48:A162.

 Norris LA,  Miller  RA.   1974.  The toxicity of 2-,3,7,8-tetrachloro-dibenzo-p-
 dioxin (TCDD)  in guppies (Poecilia reticulatus Peters).   Bull. Environ.
 Contam. Toxicol. 12:76-80.

 NTP.   1982a.  National Toxicology Program.  Carcinogenesis bioassay  of
 2,3,7,8-tetrachlorodibenzo-p-dioxin  in  Osborne-Mendel rats and B6C3F1  mice
 (Gavage Study). Tech. Rpt. Ser. No.  209.   NIH.  Pub. No. 82-1765.

 NTP.   1982b.  National Toxicology Program.  Carcinogenesis bioassay  of
 2,3,7,3-tetrachlorodibenzo-p-dioxin  in  Swiss-Webster mice (dermal study).
 Tech.  Rpt.  Ser. No.  201.  NIH Pub. No.  82-1757.
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                                                                   £ife Systems, Jnc.
 NTP.   1980.   National  Toxicology  Program.   Bioassay  of  1,2,3., 7,8-  and
 1,2,3,7,8,9-hexachlorodibenzo-p-dipxin  (gavage)  for  possible  carcinogenicity.
 DHHS  Publication No.  (NIH)  80-1754.   Research  Triangle  Park,  NC:   National
 Toxicology Program.

 NRCC.  1981.   National  Research Council  of  Canada.  Polychlorinated
 dibenzo-p-dioxins:  Criteria  for  their  effects on man and  his  environment.
 Pub.  No.  NRCC 18574,  ISSN 0316-0114:  Ottawa,  Canada:   NRCC/CNRC Assoc.  Com.
 Scientific Criteria for  Environ.  Qual.  pp.  251.

 Olson  JR, Bittner WE.   1983.   Comparative  metabolism and elimination of
 2,3,7,8-tetrachlorodibenzo-p-dioxin  (TCDD).  The Toxicologist  3:103.

 Olson  JR, Gasiewicz TA,  Neal  RA.   1980.  Tissue  distribution,  excretion,  and
 metabolism of 2,3,7,8-tetrachlorodibenzo-p-dioxin  (TCDD) in the Golden Syrian
 hamster.  Toxicol. Appl. Pharmacol.  56:78-85.

 Passi  S,  Nazzaro-Porro M, Boniforti L,  Gianotti  F.   1981.  Analysis of lipids
.and dioxin in chloracne  due to tatrachloro-2,3,7,8-p-dibenzodioxin.  Br.  J.
 Dermatol. 105:137-143.

 Perwak J, Eschenroeder A, et  al.   1980.  An  exposure and risk  assessment  for
 2,3,7,8-TCDD.   Interim draft  report.  Washington, DC:   U.S. Environmental
 Protection Agency, pp. 48-57.   EPA Contract  No.  68-01-3857.
 Piper  WN,  Rose  RQ,  Gehring  PJ.   1973.   Excretion  and  tissue  distribution  of
 2,3,7,8-tetrachlorodibenzo-p-dioxin  in  the  rat.   Environ.  Health  Perspect.
 5:241-244.

 Pitot  HC,  Goldsworthy  T,  Poland  H.   1980.   Promotion  by  2,3,7,8-tetrachloro-
 dibenzo-p-dioxin  of hepatocarcinogenesis  from  diethylnitrosamine.   Cancer Res.
 40:3616-3620.

 Pocchiari  F,  Silano V,  Zampieri  A.   1979.   Human  health.effects  from
 accidental release  of  tetrachlorodibenzo-p-dioxin (TCDD) at  Seveso,  Italy.
 Ann. NY  Acad. Sci.  320:311-320.

 Poiger H,  Schlatter C.   1980.  Influence  of solvents  and adsorbents  on  dermal
 and  intestinal  absorption of TCDD.   Food  Cosmet.  Toxicol.  18:477-481.

 Poiger H,  Weber H,  Schlatter C.   1982.  Special aspects  of metabolism and
 kinetics of TCDD  in dogs  and rats.   Assessment of toxicity of
 TCDD-metabolite(s)  in  guinea pigs.   In:   Hutzinger 0,  Frei RW, Merian E,
 Pocchiari  F,  eds.   Chlorinated dioxins  and  related compounds.  Impact on  the
 environment.  New York:   Pergamon Press,  pp. 317-325.

 Poland A,  Knucson JC.   1982.  2,3,7,8-Tetrachiorodibenzo-p-dioxin and related
 halogenated aromatic hyrocarbons:  Examination of the  mechanism  of toxicity.
 Ann. Rev.  Pharmacol. Toxicol. 22:517-554.
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                                                                  £ife Systems, Jnc.
Rose JQ, Ramsey JC, Wentzler TH, Hummel RA, Gehring PJ.  197.6.  The fate of
2,3,7,8-tetrachlorodibenzo-p-dioxin following single and repeated oral doses
to the rat.  Toxicol. Ap'pl.. Pharmacol. 36:209-226.

Sawahata T, Olson JR, Neal RA.  1982.  Identification of metabolities
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) formed an incubation with isolated
rat hepatocytes.  Biochem. Biophys., Res. Commun. 105:341-346.
                         *
Shantz SL, Barsotti DA, Allen JR.  1979.  Toxicological effects produced in
nonhuman primates chronically exposed to fifty parts per trillion
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD).  Toxicol. Appl. Pharmacol.
48:A180.

Schaum J, Falco J.  1982.  Exposure analysis of Vertac facility.  Washington
DC:  U.S. Environmental Protection Agency.  OHEA-E-50, pp. 1-38.  April 5.

Schwetz BA,. Norris JM, Sparschu GL, et al. 1973.  Toxicology of chlorinated
dibenzo-p-dioxins.  Environ. Health Perspect. 5:87-99.

Smith AH, Fisher DO, Pearce N, Teague CA.  1982.  Do agricultural chemicals
cause soft-tissue sarcoma?  Initial findings of a case-control study in New
Zealand.  Community Health Studies 6:114-119.

Smith AH, Fisher DO, Giles HJ, Pearce N.  1983.  The New Zealand soft tissue
sarcoma case-control study:  Interview findings concerning phenoxy-acetic acid
exposure.  Chemosphere 12:565-571.                                	r—^——
Sparschu GL, Dunn FL, Rowe VK.  1971.  Study of the teratogenicity of
2,3,7,8-tetrachlorodibenzo-p-dioxin in the rat.  Food. Cosmet. Toxicol.
9:405-412.

Taylor JA.  1979.  Environmental chloracne:  Update and overview.  Ann. NY
Acad. Sci.  320:295-307.

Thibodeaux LJ.  1983.  Offsite transport of 2,3,7,8-tetrachlorodibenzo-p-
dioxin from a production disposal facility. .In:  Choudhary G, Keith L, Rappe
C, eds.  Chlorinated dioxins and dibenzofurans in the total environment.
Boston, MA:  Butterworth Publishers.

Thomas HS.  1980.  Internal Memorandum to P. Cohn.  Office of Toxic Sub-
stances:  Washington, DC:  U.S. Environmental Protection Agency.

Tognoni G, Bonaccorsi A.   1982.  Epidemiological problems with 2,3,7,8-tetra-
chlorodibenzo-p-dioxin (TCDD).  Drug Metabl. Rev. 13:447-469.

Toth K, Somfai-Relle S, Sugar J,.Bence J.   1979.  Carcinogenicity testing of
herbicide 2,4,5-crichlorophenoxyethanol containing dioxin and of pure dioxin
in Swiss mice.  Nature (Lond).  278:548-549.
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                                                                  £ife Systems, Jnc.
Toth K, Sugar J, Somfai-Relle S, Bence J.  1978.  Carcinogenic bioassay of the
herbicide, 2,4,5-trichlorophenoxyethanol (TCPE) with different 2,3,7,8-tetra-
chlorodibenzo-p-dioxin (dioxin) content in Swiss mice.  Prog. Biochem. Pharmacol.
14:82-93.

USEPA.  1979.  U.S. Environmental Protection Agency.  Report of assessment -.-'I
a field investigation of six-year spontaneous abortion rates in three Oregon
areas in relation to forest 2,4,5-T spray practice.  Washington, DC:  U.S.
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USEPA.  1980.  U.S. Environmental Protection Agency.  Industrial Environmental
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USEPA.  1984.  U.S. Environmental Protection Agency.  Office of Water
Regulations and Standards.  Ambient water quality criteria for 2,3,7,8-tetra-
chloro-dibenzo-p-dioxin.  Washington, DC:  U.S. Environmental Protection
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Van Miller JP, Lalich JJ, Allen JR.  1977.  Increased incidence of neoplasms
in rats exposed to low levels of 2,3,7,8-tetrachlorodibenzo-p-dioxin.
Chemosphere 6:537-544.

Ward C, Matsumura F.  1977.  Fate of 2,4,5,-T contaminant,
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) in aquatic environments.  U.S.
NTIS, PB Rep., PB-264187, pp. 22.-      .
                                  »
Ward CT, Matsumura F.  1978.  Fate of 2,3,7,8-tetrachlorodibenzo-p-dioxin
(TCDD) in a model aquatic environment.  Arch. Environ. Contam. Toxicol.
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Weissburg JB, Zinkl JG.  1973.  Effects of 2,3,7,8-tetrachlorodibenzo-p-dioxin
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Wright B.  1985.  Vertac Chemical Company.  Jacksonville, Arkansas.
Memorandum to G. Lucerp, J. Stanton, B. Elkus and M. Kilpatrick.  Washington,
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Yockim RS, Isensee AR, Jones GE.  1978.  Distribution and toxicity of TCDD and
2,4,5-T in an aquatic model ecosystem.  Chemosphere 7:215-220.

Young AL.  1983.  Long term studies on the persistence and movement of TCDD in
a national ecosystem.  In:  Tucker RE, et al., ed.  Human and environmental
risks of chlorinated dioxins and related compounds.  New York, NY:  Plenum
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Young AL, Kang HK, Shepard BM.  1983.  Chlorinated dioxins as herbicide
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                                      7-9

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                                                                 JCifc Systems, Jnc.
Zack JA, Suskind RR.   1980.   The mortality  experience of workers exposed to
tetrachlorodibenzodioxin in  a trichlorophenol process accident.
J. Occup. Med.  22:11-14.
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                                            £ife Systems, Jnc.
             APPENDIX 3


EPA's PROPOSED ASSESSMENT GUIDELINES


Part 1 - Carcinogen Risk Assessment

Part 2 - Exposure Assessment

Part 3 - Mutagenicity Risk Assessment

Part 4 - Health Assessment of  Suspect
         Developmental Toxicants

Part 5 - Health Risk Assessment
         Chemical Mixtures
                A3-1

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                                          jCife Systems, Jnc.
PART 1 -  CARCINOGEN RISK ASSESSMENT
               A3-2

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Friday
November 23, 1984
Part VII

Environmental
Protection Agency
Proposed Guidelines for Carcinogen Risk
Assessment; Request for Comments

-------
 46294
Federal  Register / Vol. 49. No.  227 / Friday. November 23,  1984 / Notices
 ENVIRONMENTAL PROTECTION
 AGENCY

 1FRL-2706-4]

 Proposed Guidelines for Carcinogen
 Risk Assessment

 AGENCY: Environmental Protection
 Agency (EPA).
 ACTION: Proposed Guidelines for
 Carcinogen Risk Assessment and
 Request for Comments.

 SUMMARY: The U.S. Environmental
 Protection Agency is proposing
 Guidelines for Carcinogen Risk
 Assessment (Guidelines). These
 Guidelines are proposed for use within
 the policy and procedural framework
 provided by the various statutes that
 EPA administers to guide Agency
 analysis of carcinogenicity data. We
 solicit public comment and will take
 public comment into account in revising
 these Guidelines. These Guidelines will
 be reviewed by the Science Advisory
 Board in meetings now tentatively
 scheduled for April 1985.
   These proposed Guidelines were
 developed as  part of a broad guidelines
 development program under the
 auspices of the Office of Health and
 Environmental Assessment (OHEA),
 located in the Agency's Office of
 Research and Development. Consonant
 with the role of OHEA's Carcinogen
"Assessment Group (GAG) as the
 Agency's senior health committee for
 carcinogenicity assessment, the
 Guidelines were developed by an
 Agency-wide  working group chaired by
 the Chairman of GAG.
 DATE: Comments must be postmarked
 by January 22.1985.
 ADDRESS: Comments may be mailed or
 delivered to: Dr. Robert McGaughy.
 Carcinogen Assessment Group (RD-
 689), Office of Health and
 Environmental Assessment, U.S.
 Environmental Protection Agency, 401 M.
 Street SW., Washington. D.C. 20460.
 FOR FURTHER  INFORMATION CONTACT.
 Dr. Robert McGaughy, Telephone: 202-
 382-5952.
 SUPPLEMENTARY INFORMATION: This is
 the first proposed revision of the 1976
 Interim Procedures and Guidelines for
 the Health Risk Assessment of
 Suspected Carcinogens (Federal
 Register 41:21402-21405, 1976). This
 revision incorporates concepts and
 approaches to carcinogen assessment
 that have been developed during the last
 eight years. These proposed revised
 Guidelines describe salient principles
 for evaluating the nature and magnitude
 of the cancer  hazard from suspect
 carcinogens and general framework to
                     be followed in developing analyses of
                     carcinogenic risk.
                       These Guidelines were sent to 38
                     scientists in the field of carcinogenesis
                     from universities, environmental groups,
                     industry, labor, and governmental
                     agencies. We have decided to delay
                     incorporating suggestions from the 26
                     reviewers who submitted comments into
                     the Guidelines published here until
                     comments submitted during this public
                     comment period are received.
                       References and supporting documents
                     used in the preparation of these
                     Guidelines as well as comments
                     received are available for inspection
                     and copying at the  Public Information
                     Reference Unit (202-382-5926). EPA
                     Headquarters Library. 401 M Street SW..
                     Washington, DC, between the hours of
                     8:00 and 4:30 p.m.
                       Dated: November 9,1984.
                     William D. Ruckelshaus,
                     Administrator.

                     Contents
                     I. Introduction
                     II. Hazard Identification (Qualitative Risk
                         Assessment)
                       A. Overview
                       B. Elements of Hazard Identification
                         1. Physical-Chemical Properties and
                         Routes and Patterns of Exposure
                         2. Structure-Activity Relationships
                         3. Metabolic and Pharmacokinetic
                         Properties
                         4. Toxicologic Effects
                         5. Short-Term Tests
                         6. Long-Term Animal Studies
                         7. Human Studies
                       C. Weight of Evidence
                       D. Guidance for Quantitative Assessment
                       E. Summary and Conclusion
                     III. Dose-Responsive  Assessment, Exposure
                         Assessment, and Risk Characterization
                       A. Dose-Responsive Assessment
                         1. Selection of Data
                         2. Choice of Mathematical Extrapolation
                         Model
                         3. Equivalent Exposure Units Among
                         Species
                       B. Exposure Assessment
                       C. Risk Characterization '
                         1. Options for Numerical Risk Estimates
                         2. Concurrent Exposure
                         3. Summary of Risk Characterization
                     IV. Appendix EPA Classification System for
                         Evidence of Carcinogencity From Human
                         Studies and From Animal Studies
                     V. References

                     I. Introduction
                       This is the first revision of the 1976
                     Interim Procedures and Guidelines for
                     Health Risk Assessments of Suspected
                     Carcinogens (U.S. EPA, 1976; Albert et
                     al., 1977). The impetus for this revision is
                     the need to incorporate into these
                     Guidelines the concepts and approaches
                     to carcinogen  risk  assessment that have
                     been deveioped during the iast eight
                     years. The purpose of these Guidelines
is to promote quality and consistency of
carcinogen risk assessments within the
EPA and to inform those outside the
EPA about its approach to carcinogen
risk assessment. These Guidelines
emphasize the broad but essential
aspects of risk assessment that are
needed by the  experts in the various
disciplines required  (e.g., toxicology.
pathology, pharmacology, and statisucsi
for carcinogen assessment. Guidance is
given in general terms since the science
of carcinogenesis is  in a state of rapid
advancement,  and overly specific
approaches may rapidly become
obsolete.
  These Guidelines  describe the general
framework to be followed in developing
an analysis of carcinogenic risk and
some salient principles to be used in
evaluating the quality of data and in
formulating judgments concerning the
nature and magnitude of the cancer
hazard from suspect carcinogens.
  A summary  of the current state of
knowledge in the field of carcinogenesis
and a statement of broad scientific
principles of carcinogen risk
assessment, which was developed by
the Office of Science and Technology
Policy  (OSTP,  1984), forms an important
basis for these Guidelines; the format of
these Guidelines'is similar to that
proposed by the National Research
Council (NRC) of the National Academy
of Sciences in a report entitled "Risk
Assessment in the Federal Government"
(NRC,  1983).
  These Guidelines  are to be used
within the policy framework already
provided by applicable EPA statutes
and do not alter such policies. These
Guidelines provide general directions
for  analyzing and organizing available
data. They do  not imply that one kind of
data or another is a prerequisite for
regulatory action to control, prohibit, or
allow the use of a carcinogen. The •
analysis of carcinogenic risks will be
carried out independently from
considerations of the socioeconomic
consequences of regulatory action.
  Regulatory decisionmaking involves
two components: Risk assessment and
risk management. Risk assessment
defines the adverse  health consequences
of exposure to toxic agents; risk
management combines the risk
assessment with the directives of the
enabling regulatory  legislation, together
with socioeconomic, technical, political,
and other considerations, to reach a
decision as to whether or how  much to
control future  exposure to the suspected
toxic agents.
  Risk assessment includes one or  more
of the  following components: hazard
identification, dose-response

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                    Federal Register /  VoL 49. No. 227 /  Friday.  November 23. 1964 /  Notices
                                                                      46295
  assessment, exposure assessment and
  risk characterization (NRC, 1983).
     «azard identification is a qualitative
     assessment, dealing with the
  process of determining whether
 "exposure to an agent has the potential to
  increase the incidence of cancer. For
  purposes of these Guidelines, malignant
  and benign tumors are used in the
  evaluation of the carcinogenic hazard.
  The hazard identification component
  qualitatively answers the question of
  how likely an agent is to be a human
  carcinogen.
   Traditionally, quantitative  risk
  assessment has been used  as an
  inclusive term to describe all or parts of
  dose-response assessment, exposure
  assessment, and risk characterization.
  Quantitative risk assessment can be a
  useful general term in some
  circumstances, but the more explicit
  terminology is usually preferred. The
  dose-response assessment  defines the
  relationship between the dose of an
  agent and the probability of induction of
  a carcinogenic effect. This  component
  usually entails an extrapolation from the
  generally high doses administered to
  experimental animals or exposures
  noted in  epidemiologic studies to the
  exposure levels expected from human
  contact with the agent in the
^fc/ironment: it also includes
^Pisiderations of the validity of these
  extrapolations.
   The exposure assessment identifies
  populations  exposed to the agent
  describes their composition and size.
  and presents the types, magnitudes,
  frequencies, and durations of exposure
  to the agent.
   In risk characterization, the outputs of
  the exposure assessment and the dose-
  response assessment are combined to
  estimate quantitatively some measure of
  the carcinogenic risk. As part of risk
 characterization, a summary  of the
  strengths and weaknesses  in the hazard
  identification, dose-response
  assessment exposure assessment and
  the public health risk estimates are
  presented. Major assumptions, scientific
  judgments, and, to the extent possible,
  estimates of the uncertainties embodied
  in the assessment are also  presented.
 distinguishing clearly between fact
  assumption, and science policy.
  II. Hazard Identification (Qualitative
  Risk Assessment)
 A. Overview
   The qualitative assessment or hazard
     itification part of risk assessment
     tains a review of the relevant
     logical land chemical information
  bearing on whether or not an ageni may
  pose a carcinogenic hazard. Since
chemical agents seldom occur in a pure
state and are often transformed in the
body, the review should include
information on contaminants,
degradation products, and metabolites.
  Studies are evaluated according to
sound biological and statistical
considerations and procedures. These
have been described in several
publications (Interagency Regulatory
Liaison Group, 1979; OSTP. 1984; Peto et
al., 1980; Mantel I960; Mantel and
Haenszel, 1959; Interdisciplinary Panel
on Carcinogenicity, 1984; National
Center for Toxicological Research, 1981;
National Toxicology Program, 1984; U.S.
EPA. 1983a; 1983b; 1983c). Results and .
conclusions concerning the agent.
derived from different types of
information, whether indicating positive
or negative responses, are melded
together into a weight-of-evidence
determination. The strength of the
evidence supporting a potential human
carcinogenicity judgment is developed
in a weight-of-evidence stratification
scheme.
B. Elements of Hazard Identification
1. Physical-Chemical Properties and
Routes and Patterns of Exposure
  Parameters relevant to carcinogenesis,
including physical state, physical-
chemical properties, and exposure
pathways in the environment should be
described.
2. Structure-Activity Relationships
  This section should summarize
relevant structure-activity correlations
that support the prediction of potential
carcinogenicity.
3. Metabolic and Pharmacokinetic
Properties
  This section should summarize
relevant metabolic information.
Information such as whether the agent is
direct-acting or requires conversion to a*
reactive carcinogenic (e.g., an
electrophilic) species, metabolic
padiways for such conversions,
macromolecular interactions, and
transport in, fate in. and excretion from
the body  as well as species differences
in metabolism should be discussed.
4. Toxicologic Effects
  Toxicologic effects other than
carcinogenicity (e.g., suppression of the
immune system, endocrine disturbances,
organ damage), which are relevant to
the evaluation of carcinogenicity, should
be summarized. Prechronic and chronic
toxicity evaluations, as well as other
test results, may yield information on
target organ eifecis, pathopnyaioiogicai
reactions, and preneoplastic lesions that
bear on the evaluation of
carcinogeniciry. Dose-response and
time-to-response analyses of these
reactions may also be helpful.

5. Short-Term Tests

  Tests for point mutations, numerical
and structural chromosome aberrations.
DNA damage/repair, and in vitro
transformation provide supportive
evidence of carcinogenicity and may
give  information on potential
carcinogenic mechanisms. A range of
tests from each of the above end points
helps to characterize an agent's
response spectrum.
  Short-term in vivo and in vitro tests
that can give indication of initiation and
promotion activity may also provide
supportive evidence for carcinogenicity.

6. Long-Term  Animal Studies

  Criteria for the technical adequacy of
animal carcinogenicity studies have
been published (e.g., U.S. Food and Drug
Administration, 1982; Interagency
Regulatory Liaison Group, 1979;
National Toxicology Program, 1984;
OSTP. 1984; U.S. EPA, 1983a; 1983b;
1983« Feron et al., I960; Mantel, 1980)
and should be used to judge the
acceptability  of individual studies.
  The-strength of the evidence that an
agent is carcinogenic increases~with the
increase in number of tissue sites
affected by the agent; the increase in
number of animal species, strains, and
sexes showing a carcinogenic response;
the occurrence of clear-cut dose-
response relationships as well as  a high
level of statistical significance of the
increased tumor incidence is treated
with respect to control groups; the dose-
related shortening of the time-to-tumor
occurrence or time to death with tumor,
and a dose-related increase in the
proportion of tumors that are malignant.
  Long-term animal studies at or near
the maximum tolerated dose level
(MTD) are used to ensure an adequate
power for the detection of carcinogenic
activity. Negative long-term animal
studies at exposure levels above the
MTD or partial lifetime exposures at the
MTD may not be acceptable because of
toxicity, or if animal survival is so
impaired that the sensitivity of the study .
is significantly reduced below that of a
conventional  chronic animal study at
the MTD. Positive studies ai levels
above the MTD should be carefully
reviewed to ensure that the responses
are not due to factors which do not
operate'at exposure levels below the
MTD. Evidence indicating that high-dose
icsting produces tumor responses by
indirect mechanisms that may be

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Federal Register / Vol.  49. No. 227  /  Friday. November 23. 1984 / Notices
unrelated to effects at lower does should
be dealt with on an individual basis.
  The mechanism of the carcinogenic
responses under conditions of the
experiment should be  reviewed
carefully as it relates to the relevance of
the evidence to human carcinogenic
risks (e.g.. the occurrence of bladder
tumors in the presence of bladder stones
and injection site sarcomas).
Interpretation of animal studies is-aided
by the review of target organ toxicity
and other effects (e.g., changes in the
immune and endocrine systems) that
may be noted in prechronic or other
toxicological studies. Time and dose-
related changes in the incidence of
preneoplastic lesions may also be
helpful in interpreting animal studies.
  Historical control data are often
valuable and could be used along with
concurrent control data in the
evaluation of carcinogenic responses.
For the evaluation of rare tumors, even
small tumor responses may be
significant compared to historical data.
In the case of tumors with relatively
high spontaneous rates, a response that
is significant with respect to the
experimental control group becomes
questionable if the historical control
data indicate that the experimental
control group had an unusually low
background incidence.
  Agents that are positive in long-term
animal experiments and also show
evidence of promoting or cocarcingenic
activity in specialized tests should be
considered as complete carcinogens
unless there is evidence to the contrary.
Agents that show positive results in
special tests for initiation, promotion, or
cocarcingenicity and no indication of
tumor response in well-conducted and
well-designed long-term animal studies
should be dealt with on an individual
basis.
  There  are widely diverging scientific
views (OSTP, 1984;  Ward et al. 1979a;
1979b; Tomatis; 1977; Nutrition
Foundation, 1983) about the validity of
mouse liver tumors  when such tumors
occur in  strains with high spontaneous
background incidence and when they
constitute the only tumor response to an
agent.  These Guidelines take the
position that the mouse-liver-only tumor
response, when other conditions for a
classification of "sufficient" evidence in
animal studies are met, should be
considered as "sufficient" evidence of
carcinogenicity with the understanding
that this classification could be changed
to "limited" if warranted when a
number  of factors such as the following
are observed: The occurrence of tumors
only in the highest dose group and/or
only at the end of the study; no
substantial dose-related increase in the
                     proportion of tumors that are malignant;
                     the occurrence of tumors that are
                     predominately benign, showing no
                     evidence of metastases or invasion; no
                     dose-related shortening of the time to
                     the appearance of tumors: negative or
                     inconclusive results from a spectrum of
                     short-term tests for mutagenic activity;
                     the occurrence of excess tumors only in
                     a single sex.
                       Positive carcinogenic responses in one
                     species/strain/sex are not generally
                     negated by negative results in other
                     species/strain/sex. Replicate negative
                     studies that are essentially identical in
                     all other respects to a positive study
                     may indicate that the positive.results
                     are spurious.
                     .  Evidence for carcinogenic action
                     should be based on the observation of
                     statistically significant tumor responses
                     in specific organs or  tissues.
                     Appropriate statistical analysis should
                     be performed  on data from long-term
                     studies to help determine whether the
                     effects are treatment-related or possibly
                     due to chance. These should at least
                     include a  statistical test for trend,
                     including  appropriate correction for
                     differences in survival. The weight to be
                     given to the level of statistical
                     significance (the p-value) and to other
                     available pieces of information is a
                     matter of overall scientific judgment. A
                     statistically significant excess of tumors
                     of all types in the aggregate, in the
                     absence of a statistically significant
                     increase of any individual tumor type
                     should be regarded as minimal evidence
                     of carcinogenic action unless there are
                     persuasive reasons to the contrary.

                     7. Human Studies
                       Epidemiologic studies provide unique
                     information about the response of
                     humans who have been exposed to
                     suspect carcinogens. Descriptive
                     epidemiologic studies are useful in
                     generating hypotheses and providing
                     supporting data, but can rarely be used.
                     to make a causal inference.  Analytical
                     epidemiologic studies of the case-control
                     or cohort variety, on the other hand, are
                     especially useful in assessing risks to
                     exposed humans. •
                        Criteria for the adequacy  of
                     epidemiologic studies are well
                     recognized and include factors such as
                      the proper selection  and
                     characterization of exposed and control
                     groups, the adequacy of duration and
                      quality of follow-up, the proper
                      identification and characterization of
                      confounding factors and bias, the
                      appropriate consideration of latency
                      effects, andjhe valid ascertainment of
                      the causes of morbidity and death.
                        The strength of the epidemiologies
                      evidence for carcinogenicity depends on
 the magnitude, specificity, and
 statistical significance of the response
 and increases rapidly with the number
 of adequate studies which show the
 same results on populations exposed to
 the same agent under different
 conditions.
   It should be recognized that
 epidemiologic studies are inherently
 capable of detecting only comparatively
 large increases in the relative risk oi
 cancer. Negative results from such
 studies cannot prove the absence of
 carcinogenic action; however, negative
 results from a well-designed and
 conducted epidemiologic study that
 contains usable exposure data can serve
 to define upper limits of risk which are
 useful if animal evidence indicates that
 the agent is potentially carcinogenic.

 C. Weight of Evidence
   Evidence of possible carcinogenicity
 in humans comes primarily from two
 sources: Long-term animal tests and
 epidemiologic investigations. Results
 from these studies are supplemented
 with information from short-term tests.
 pharmacokinetic studies, comparative
 metabolism studies, structure-activity
 relationships, and other relevant
 toxicologic studies. The question of how
 likely an agent is to be a human
 carcinogen should be answered in the
 framework bFa weight-oi-evidence  .
 judgment. Judgments about the weight ot
 evidence involve considerations of the
 quality and adequacy of the data and
 the kinds of responses induced by a
 suspect carcinogen. There are three
 major steps to characterizing the weight
 of evidence for carcinogenicity: (1)
 Characterization of the evidence from
 human studies and from animal studies
 individually, (2) combination of the
 characterizations of these two types of
 data into a final indication of the overall
 weight of evidence for human
 carcinogenicity, and (3) evaluation of all
 supportive information to determine if
 the overall weight of evidence should be
 modified.
   A system for stratifying the weight of
 evidence is recommended, and EPA has
 developed a scheme (see the Appendix).
 The EPA scheme is modeled after the
 classification system developed by the
 International Agency for Research on
 Cancer (IARC. 1982). In the IARC
 classification method, the evidence tha.
• an agent produces cancer in humans is
 divided into three categories: Sufficient.
 limited, and inadequate. A similar
 characterization of evidence is  prdVided
 for animal data.
   The EPA classification system is. in
 general, an adaptation of the IARC
 approach for classifying the weight if

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                                                                                                              46297
   uai


     i
evidence for human data and animal
data. The EPA classification system for
  e characterization of the overall
  tight of evidence for carcinogenicity
 animal, human, and other supportive
•irita) includes: Group A—Carcinogenic
to Humans: Group B—Probably
Cardnogenic to Humans; C—Possibly
Carcinogenic to Humans; Group 0—Not
Classifiable as to Human
Carcinogenicity: and Group E—No
Evidence of Carcinogenicity for
Humans.
  In addition, the following
modifications of the IARC approach
nave been made for classifying human
r short-term evidence). (4) A "no
>»vide>ir.»iv" category is also added. This
•;purational category would include
substances for which there is no
increased incidence of neoplasms in at
It^st two well-designed and well-
conducted animal  studies of adequate
powgr and dose in different species.
i). Guidance For Quantitative
\ssessment
  The qualitative evidence for
       genesis should be discussed for
  irposes of guiding the dose-response
 •:.;essmem. The guidance should be
     in terms of the appropriateness
   i-,d
«:
and limitation of specific studies as well
as phannacokinetic considerations that
should be factored into the dose-
response assessment The appropriate
method of extrapolation should be
factored in when the experimental route
of exposure differs from that occurring
in humans.
  Agents that are  judged to be in the
EPA weight-of-evidence stratification
Groups A and B would be regarded as
suitable for quantitative risk
assessments. The  appropriateness of
quantifying the risks from agents in
Group C, specifically those agents that
are at the boundary of Groups C and D.
would be judged on a case-by-case
basis. Agents that are judged to be in
Groups D and E would generally not
have quantitative  risk  assessments.
E. Summary and Conclusion
  The summary should present all of the
key findings in all of the sections of the
qualitative assessment and the
interpretive rationale that forms the
basis for the conclusion. Uncertainties
in the evidence as well as factors that
may affect the relevance of the chronic
animal study to humans should be
discussed. The conclusion should
present both the weight-of-evidence
rankng and a description that brings out
the more subtle aspects of the evidence
that .may not be evident from the
ranking-alone;	
ITI. Dose-Response Assessment.
Exposure Assessment, and Risk
Characterization
  After data concerning the
carcinogenic properties of a substance
have been collected, evaluated, and
categorized, it is frequently desirable to
estimate the likely range of excess
cancer risk associated with given levels
and conditions of human exposure. The
first step of the analysis needed to make
such estimations is the development of
the likely relationship between dose and
response (cancer incidence) in the
region of human exposure. This
information on dose-response
relationships is coupled with
information on the nature and
magnitude of human exposure to yield
an estimate of human risk. The risk-
characterization step also includes an
interpretation of these estimates in light
of the biological, statistical and
exposure assumptions and
oncertainities that have arisen
throughout the process of assessing risk.
  The elements of dose-response
assessment are described in section
III.A. Guidance on human exposure
assessment is provided in another EPA
document (U.S. EPA. 1S84): however.
section III.B. of these Guidelines
 includes a brief description of the
 specific type of exposure information
 that is necessary for use in carcinogenic
 risk assessment. Finally, in section II1.C.
 there is a description of the type of
 information and its interpretation
 necessary for accurately characterizing
 risk and the dnyree to which it can be
 known.
   It should be emphasized that
 calculation of quantitative estimates of
 cancer risk does not require that an
 agent be a human carcinogen. The
 likelihood that an agent is a human
 carcinogen is a function of the weight of
 evidence, as this  has been described in
 the hazard identification section of these
 Guidelines. It is nevertheless  important
 to present quantitative estimates.
 appropriately qualified and interpreted.
 in those circumstances in  which there is
 likelihood that the agent is a human
 carcinogen. Appropriately qualified
 quantitative estimates of risk, together
 with estimates of their uncertainty, are
-useful in cost-benefit analyses, in setting
 regulatory priorities, and for evaluating
 residual risks associated with the
 application of regulatory controls.
   It should be emphasized in every
 quantitative risk  estimation that the
 results are uncertain. The uncertainties
 due to experimental and epidemiologic
 variability as well as uncertainty in the
• exposure assessment can  be important.
 There are  major uncertainties in
 extrapolating both from animals to
 humans and from high to low doses.
 There are  important species differnces
 in uptake, metabolism, and organ
 distribution of carcinogens, as well as
 species and strain differences in target
 site susceptibilty. Human  populations
 are variable with respect to genetic
 constitution, diet, occupational and
 home environment, activity patterns.
 and other cultural factors. Risk
 estimates should be presented together
 with the associated hazard assessment
 (section III.C.3.) to ensure that there is
 an appreciation of the weight of  •
 evidence for carcinogenicity that
 underlies the  quantitative risk estimates.
                               c\
 A. Dose-Response Assessment

 1. Selection of Data

   As indicated in section II.D. guidance
 needs to be given by the individuals
 doing the qualitative assessment
 (lexicologists, pathoiogists.
 pharmacologists, etc.) to the statisticans
 doing the quantitative assessment as lo
 the appropriate data to be used in the
 dose-response assessment. This is
 determined by the quality of the data, its
 relevance  to human modes of exposure.
 and other  technical details.

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Federal  Register / Vol. 49. No. 227 / Friday. November 23,  1984 / Notices
   If available, estimates based upon
 human epidemiologic data are preferred.
 If adequate exposure data  exist in a well-
 designed and conducted negative
 epidemiologic study, an upper-bound
 estimate of risk should be used in
 preference to higher risks  estimated
 from animal data. In the absence of
 human data, data from a species that
 responds most like humans should be
 used, if information to this effect exists.
 Where, for a given agent, several
 studies are available  which may involve
 different animal species, strains, and
 sexes, at several doses and by different
 routes of exposure, the following
 approach to selecting the  data sets is
 used. The  tumor incidence data are
. separated  according to organ site and
 tumor type. All biologically and
 statistically acceptable  data sets are
 presented. The range of the risk
 estimates  is identified with due regard
 to biological relevance (particularly in
 the  case of animal studies) and
 appropriateness of route of exposure.
 Because it is possible that human
 sensitivity is as high as the most
 sensitive responding animal species, in
 ;he  absence of evidence to the
 contrary, the biologically  acceptable
 data set from long-term animal studies
 showing the greatest sensitivity should
 generally be given the greatest
 emphasis,  again with due  regard_to_
 biological and statistical considerations.
   When the exposure route in the
 species from which the dose-response
 information is obtained differs from the
 route occurring in environmental
 exposures, uncertainties about the dose
 delivered to the target organs from
 different exposure media should be
 explicitly considered, and the
 assumptions should be carefully stated.
   Where two or more significantly
 elevated tumor sites or types^re
 jbserved in the same study,
 extrapolations may be conducted on
 selected sites or types. These selections
 will be made  on biological grounds. To
 obtain a total estimate of carcinogenic
 risk, animals with one or more tumor
 sites or types showing significantly
 elevated tumor incidence should be
 pooled and used for extrapolation; if the
 '.umor sites or types are occurring
  dependently, this procedure is the same
 as summing the risks from the several
 dnds of statistically significant tumors.
 The pooled estimates will generally be
 jsed in preference to risk estimates
 Dased on single sites or types.
   Benign tumors should generally be
 :ombined with malignant tumors for risk
 estimates unless the benign tumors are
 Tot considered to have the potential to
 progress to the associated malignancies
                     of the same morphologic type. However,
                     the contribution of the benign tumors to
                     the total risk should be indicated.

                     2. Choice of Mathematical Extrapolation
                     Model
                        Since risks at low exposure levels
                     cannot be measured directly either by
                     animal experiments or by epidemiologic
                     studies, a number of mathematical
                     models  have been developed to
                     extrapolate from high to low dose.
                     However, different extrapolation models
                     may fit  the observed data reasonably
                     well but may lead to large differences in
                     the projected risk at low doses.
                        No single mathematical procedure is
                     recognized as the most appropriate for
                     low-dose extrapolation in
                     carcinogenesis. When relevant
                     biological evidence on mechanism of
                     action exists, the models or procedures
                     employed should be consistent wj,th the
                     evidence. However, when data and
                     information are limited, as is the usual
                     case given the high degree of
                     uncertainty associated with the
                     selection of a low-dose extrapolation
                     model, specific guidance on model
                     selection is necessary to provide a
                     desirable degree of consistency in risk
                     assessments. The choice of low-dose
                     extrapolation models should be
                     consistent with current understanding of
                     the mechanisms of carcinogenesis and
                    -not solely on goodnesa-of-frt to the
                     observed tumor data. Although
                     mechanisms of the carcinogenesis
                     process are largely unknown, at least
                     some elements of the process have been
                     elucidated, e.g., linearity of tumor
                     initiation. In further support of a linear
                     model, it has been shown that, if a
                     carcinogenic agent acts by accelerating
                     the same stages of the carcinogenic
                     process that lead to the background
                     occurrence of cancer, the added effect of
                     the carcinogen at low dose is virtually
                     linear. Thus, a model that is linear at
                     low dose is plausible.
                        The linearized multistage model
                     procedure for low-dose extrapolation
                     (U.S. EPA, 1980) is therefore
                     recommended in most cases unless there
                     is evidence on carcinogenesis
                     mechanisms or other biological evidence
                     that indicates the greater-suitability of
                     an alternative extrapolation model, or
                     there is statistical or biological evidence
                     that excludes the use of the linearized
                     multistage model.
                        It should be emphasized thai the
                     linearized multistage model leads  to a
                     plausible upper limit to the risk which is
                     consistent with some mechanisms of
                     carcinogenesis. However, such an
                     estimate does not necessarily give a
                     realistic prediction of the risk. In certain
                     cases, the linearized multistage model
cannot be used successfully with the
observed data as, for example, when the
data are nonmonotonic or flatten out at
high doses. In these cases it may be
necessary to make adjustments to the
procedure to achieve low-dose linearity.
  When phannacokinetic or metabolism
data are available, or when other
substantial evidence  on the mechanistic
aspects of the carcinogenesis process
exists, a different low-dose
extrapolation model might be
considered more appropriate on
biological grounds. When a different
model is chosen, the risk assessment
should clearly discuss the nature and
strength of the evidence that lead to the
choice. In most cases, considerable
uncertainty will remain concerning
response at low doses; therefore, an
upper-limit risk estimate using the
linearized multistage model should also
be presented.

3. Equivalent Exposure Units Among
Species

  Low-dose risk estimates derived from
laboratory  animal data extrapolated to
humans are complicated by a  variety of
factors that differ among species and
potentially affect the response to
carcinogens. Included among these
factors are differences between humans
and experimental test animals with
respect to life span, body size, genetic
variability, population homogeneity,
existence of concurrent disease,
pharmacokinetic effects such as
metabolism and  excretion patterns, and
the exposure regimen.
  The usual approach for making
interspecies comparisons has  been to
use standardized scaling factors.
Commonly employed standardized
dosage scales  include mg per kg body
weight per day, ppm  in the diet or water.
mg per mz body  surface area per day,
and mg per kg body weight per lifetime.
In the absence of comparative
lexicological, physiological, metabolic,
and pharmacokinetic data for a given
suspect carcinogen, the extrapolation of
body weight to the 0.67 power is
considered to be appropriate.

B. Exposure Assessment
  In order to obtain a quantitative
estimate of the risk, the results of the
dose-response assessment must be
combined with an estimate of the
exposures  to which the populations of
interest are likely to  be subject. While
the reader is referred to the Proposed
Guidelines for Exposure Assessment
(U.S. EPA,  1984) for specific details, it is
important that the cancer risk assessor
and the decision-maker have an
appreciation of the impact of the

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                   Federal Register  /  Vol. 49.  No. 227 / Friday. November  23, 1984 / Notices            46299
 strengths and weaknesses of exposure
 assessment on the overall cancer risk
 assessment process.
  At present there is no single approach
 to exposure assessment that is
 appropriate for all cases.  On a case-by-
 case basis, appropriate methods are
 selected to match the data on hand and
 the level of sophistication required (e.g.,
 preliminary assessment using crude data
 and worst case assumptions versus a
 final assessment using extensive
 monitoring data). The assumptions.
 approximations, and uncertainties need
 to be clearly stated because, in some
 instances, these will have a major effect
 on the risk assessment.
  In general, the magnitude, duration.
 and frequency of exposure provide
 fundamental information  for estimating
 the concentration of the carcinogen to
 which the organism is exposed. These
 data are generated from monitoring
 information, modeling results, and/or
 reasoned estimates. An appropriate
 treatment of exposure should consider
 the potential for exposure via ingestion,
 inhalation, and dermal penetration from -
 relevant sources of exposures. Where
 feasible, an attempt should be made to
 assess the dose to the target organ,
 either through experimental evidence or
 reasonable assumptions and modeling.
  Special problems arise  when the
 human exposure situation of concern
 suggests exposure regimens, e.g., route
 and dosing schedule, which are
 substantially different from  those used
 in the relevant animal studies. Unless
 there is evidence to the contrary in a
 particular case, the cumulative dose
 received over a lifetime, expressed as
 average daily exposure prorated over a
 lifetime, is recommended  as the
 appropriate measure  of exposure  to a
'carcinogen. That is, the assumption is
 made that a high dose of a carcinogen
 received over a short period of time is
 equivalent to a coresponding low dose
 spread over a lifetime. This  approach
 becomes more problematical as the
'exposures in question become more
 intense but less frequent,  especially
when there is evidence that the agent
has shown dose-rate  effects.
  An attempt should  be made to assess
 the level of uncertainty associated with
 the exposure assessment  which is to be
 used in a cancer risk  assessment.  This
 measure of uncertainty should be
 included in the risk characterization
(section 1II.C.) in order to  provide the
decision-maker with a clear
understanding of the  impact of this
 uncertainty on any final quantitative
 risk estimate.
C. Risk Characterization
1. Options for Numerical Risk Estimates
  Depending on the needs of the
individual program offices, numerical
estimates can be presented in one or
more of the following three ways.
  a. Unit Risk—Under an assumption of
low-dose linearity, the unit cancer risk is
the excess lifetime risk due to a
continuous constant lifetime exposure of
one unit of carcinogen concentration.
Typical exposure units include  ppm or
ppb in food or water, mg/kg/day by
ingestion, or ppm or ug/m 3 in air.
  b. The Dose Corresponding to a Given
Level of Risk—This approach can be
useful, particularly when using
nonlinear extrapolation models where
the unit risk would differ at different
dose levels.
  c. Individual and Population Risks—
Risk may be characterized either in
terms of the excess individual lifetime
risks or the excess number of cancers
produced per year in the exposed -
population or both.
  /respective of the options chosen, the
degree of precision and accuracy in the
numerical risk estimates currently do
not permit more than one significant
figure to be presented.
2. Concurrent Exposure
  In characterizing the risk due to
concurrent exposure to several
carcinogens, the risks are combined on
the basis of additivity unless there is
specific information to the contrary.
Interactions of cocarcinogens,
promoters, and inititators with known
carcinogens should be considered on a
case-by-case basis.
3. Summary of Risk Characterization
  Whichever method of presentation is
chosen, it is  critical that the numerical
estimates not be  allowed to stand alone,
separated from the various assumptions
and uncertainties upon which they -ere
based. The risk characterization should
contain a discussion and interpretation
of the numerical estimates that  affords
the risk manager some insight into the
degree to which the quantitative
estimates are likely to reflect the true
magnitude of human risk, which
generally cannot be known with the
degree of quantitative accuracy
reflected in the numerical estimates. The
final risk estimate will be generally
rounded to one significant figure and
will be coupled with the EPA
classification of the qualitative  weight of
evidence. For example, a lifetime
individual risk of 2X10~* resulting from
exposure to a "possible human
carcinogen" (Group C) should be
designated as:
2X10-«(C]
This bracketed designation of the
qualitative evidence should be included
with all numerical risk estimates (i.e.,
unit risks, which are risks at a specified
concentration, or concentrations
corresponding to a given risk). Agency
statements, such as Federal Register
notices, briefings, and action
memoranda, frequently inclutia
numerical estimates of carcinogenic risk.
It is recommended that  whenever these
numerical estimates are used, the
qualitative weight-of-evidence
classification should also be included.
FV. Appendix—EPA Classification
System for Evidence of Carcinogenicity
From Human Studies and From Animal
Studies (Adapted From IARC)
A. Assessment of Evidence for
Carcinogenicity From Studies in
Humans
  Evidence of Carcinogenicity from
human studies comes from three main
sources:
  1. Case reports of individual cancer
patients who were exposed to the
agent(s).
  2. Descriptive epidemiologic studies  in
which the incidence of cancer in human
populations was found  to vary in space
or time with exposure to the agent(s).
  3. Analytical epidemiologic (case-
control and cohort) studies in which
individual exposure to the agent(s) was
found to be associated with an
increased risk of cancer.
  Three criteria must be met  before a
causal association can be inferred
between exposure and cancer in
humans:
  1. There is no identified bias which
could explain the association.
  2. The possibility of confounding has
been considered and ruled out as
explaining the association.
  3. The association is unlikely to be
due to chance.
  In general, although a single study
may be indicative of a cause-effect
relationship, confidence in inferring a
causal association is increased when
several independent studies are
concordant in showing  the association.
when the association is strong, when
there is a dose-response relationship, or
when a reduction in exposure is
followed by a reduction in  the incidence
of cancer.
  The degrees 01 evidence k>r
Carcinogenicity* from studies in humans
are categorized as:
  1. Sufficient evidence of
  'For purpose of public health protection.
agents associated with life-threatening
benign (umors in humans are included in the
evaluation.

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Federal Register  / VoL 49. No. 227  /  Friday, November 23. 1984 / Notices
:arcinogenicity, which indicates that
here is a causal relationship between
he agent and human cancer.
  2. Limited evidence of carcinogenicity,
•vhich indicates that a causal
nterpretation is credible, but that
ilternative explanations, such as
;hance, bias, or confounding, could not
adequately be excluded.
  3. Inadequate'evidence, which
indicates that one of two conditions
prevailed: (a) There were few pertinent
Jata, or (b) the available studies, while
showing evidence of association, did not
exclude chance, bias,  or confounding.
  4. No evidence, which indicates that
no association was found between
exposure and an increased risk of
cancer in well-designed and well-
conducted independent analytical
epidemiologic studies.
  5. No data, which indicates that data
are not available.

B. Assessment of Evidence for
Carcinogenicity From Studies in
Experimental Animals
  These assessments  are classified into
five groups:
  1. Sufficient evidence* of
carcinogenicity, which indicates that
there is an increased incidence of
malignant tumors or combined
malignant and benign tumors §: (a) In
multiple species or strains; or (b) in
multiple experiments  (preferably with
different routes of administration or
using different dose levels); or (c) to an
unusual degree with regard to incidence.
site or type of tumor,  or age at onset.
Additional evidence may be provided
by data on dose-response effects, as
well as information from short-term
tests or on chemical structure.
  2. Limited evidence of carcinogenicity.
which means that the data suggest  a
carcinogenic effect but are limited
because: (a) The studies involve a single
species, strain, or experiment; or (b) the
experiments are restricted by
inadequate dosage levels, inadequate
duration of exposure  to the agent,
inadequate period of follow-up, poor
   + Under specific circumstances, such as
the production of neoplasms that occur with
high spontaneous background incidence, the
evidence may be decreased to "limited" if
warranted (e.g.. there are widely diverging
scientific views regarding the validity of the
mouse liver tumor as an indicator of potential
human carcinogenicity when this is the only
response ooserved. even in replicated
experiments in the absence of short-term or
other evidence).
   5 Benign and malignant tumors will be
combined unless the benign tumors are not
considered to have the potential to progress
;o ;he associated malignancies of the same
morphologic type.
                      survival, too few animals, or inadequate
                      reporting; or (c] an increase in the
                      incidence of benign turmors only.
                        3. Inadequate evidence, which
                      indicates that because of major
                      qualitative or quantitative limitations,
                      the studies cannot be interpreted as
                      showing either the presence or absence
                      of a carcinogenic effect.
                        4. No evidence, which indicates that
                      there is no increased incidence of
                      neoplasms in at  least two well-designed
                      and well-conducted animal studies in
                      different species.
                        5. No data, which indicates that data
                      are not available.
                        The  categories "sufficient evidence"
                      and "limited evidence" refer only to the
                      strength of the experimental evidence
                      that these agents(s) are carcinogenic
                      and not to the power of their
                      carcinogenic action.

                      C. Categorization of Overall Evidence
                      Group A—Human Carcinogen
                        This category is used only when there
                      is sufficient evidence from
                      epidemiologic studies to support a
                      causal association between exposure to
                      the agent(s) and cancer.
                      Group B—Probable Human Carcinogen
                        This category includes agents for
                      which the evidence of human
                      carcinogenicity from epidemiologic
                      studies ranges from almost "sufficient"
                      to "inadequate." To reflect this range,
                      the category is divided into higher
                      (Group Bl) and lower (Group BZ)
                      degrees of evidence. Usually, category
                      Bl is reserved for agents for which there
                      is at least limited evidence of
                      carcinogenicity  to humans from
                      epidemiologic studies. In  the absence of
                      adequate data in humans, it is
                      reasonable, for practical purposes, to
                      regard agents for which there is
                      sufficient evidence of carcinogenicity in
                      animals as if they presented a
                      carcinogenic risk to humans. Therefore,
                      agents for which there is inadequate
                      evidence from human studies and
                      sufficient evidence form animal studies
                      would usually result in a  classification
                      ofBZ.
                         In some cases, the known chemical  or
                      physical properties of an agent and the
                      results from short-term tests allow its
                      transfer from Group B2 to Bl.
                      Group C—Possible Human Carcinogen
                         This category is used for agents with
                      limited evidence of carcinogenicity in
                      animals in the absence of human data. It
                      includes a wide variety of evidence: (a)
                      Definitive malignant tumor response in a
                      single well-conducted experiment, fb)
                      marginal tumor response in studies
 having inadequate design or reporting,
 (c) benign but not malignant tumors with
 an agent showing no response in a
 variety of short-term tests for
 mutagenicity, and (d) marginal
 responses in a tissue known to have a
 high and variable background rate.
   In some cases, the known physical or
 cehmical properties of an agent and
 results from short-term tests allow a
 transfer from Group C to B2 or from
 Group D to C.

 Group D—Not Classified

   This category is used for-agent(s) with
 inadequate animal evidence of
 carcinogenicity.

 Group E—No Evidence of
 Carcinogenicity for Humans

   This category is used for agent(s) that
' show no evidence for carcinogenicity in
 at least  two adequate animal tests in
 different species or in both
 epidemiologic and animal studies.

 V. References
 Albert, R.EM Train, R.E.. and Anderson. E.
   1977. Rationale developed by the
   Environmental Protection Agency for the
   assessment of carcinogenic risks. ]. Nad.
   Cancer Inst. 58:1537-1541.
 Feron, V.J., Grice, H.C., Griesemer, R.. Peto
   R.. Agthe, C, Althoff, J.. Arnold. D.L..  ^
   BlumenthaL H., Cabral, J.RJ>.. Delia Porta.
   G., Ito. N., Kimmejle, G., Kroes, R., Mohr.
   U., Napalkov, N.P., Odashima. S., Page.
   N.P., Schramm, T.. Steinhoff, D., Sugar, J..
   Tomatis, L., Uehleke. H., and Vouk, V. 1980.
   Basic requirements for long-term assays for
   carcinogenicity. In: Long-term and short-
   term screening assays for carcinogens: a
   critical appraisal. 1ARC Monographs.
   Supplement 2. Lyon. France: International
   Agency for Research on-Cancer, pp 21-83.
 Interagency Regulatory Liaison Group (IRLG).
   1979. Scientific basis for identification of
   potential carcinogens and estimation of
   risks. J. Nad. Cancer Inst. 63:245-267.
 Interdisciplinary Panel on Carcinogenicity.
   1984. Criteria for evidence of chemical
   carcinogenicity. Science 225:682-687.
 International Agency for Research on Cancer
   (1ARC). 1982. IARC Monographs on the
   Evaluation of the Carcinogenic Risk of
   Chemicals to Humans. Supplement 4. Lyon.
   France: International Agency for ReseHrch
   on Cancer.
 Mantel.  N. 1980. Assessing laboratory
   evidence for neoplastic activity. Biometrics
   36:381-399.
 Mantel,  N.. and Haenszel, W. 1959. Statistical
   aspects of the analysis of data  from
   retrospective studies of disease. J. Natl.
   Cancer Inst. 22:719-748.
 National Center for loxicoiogicai Research
    (NCTR). 1981. Guidelines for statistical
    tests for carcinogenicity in chronic
   bioassays. NCTR Biometry Technical
    Report 81-001. Available from: National
    Center for Toxicological Research.
 National Research Council (NRC',. 1983. Risk
    assessment in the Federal government:

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                    Federal Register /  Vol. 49,  No.  227  / Friday. November 23. 1984  / Notices
                                                                              46301
  managing the process. Washington, D.C.:
  National Academy Press.
National Toxicology Program. 1984. Report of
  the Ad Hoc Panel on Chemical'
  Carcinogenesis Testing and Evaluation of
  the National Toxicology Program. Board of
  Scientific Counselors. Available from: U.S.
  Government Printing Office, Washington,
  D.C. 1984-421-132:4726.
Nutrition Foundation. 1983. The relevance of
  mouse liver hepatoma to Human
  carcinogenic risk: a report of the
  International Expert Advisory Committee
  to the Nutrition Foundation. Available
  from: Nutrition Foundation. ISBN 0-935368-
  37-x.
Office of Science and Technology Policy
  (OSTP). 1984. Chemical carcinogens:
  review of the science and its associated
  principles. Federal Register 49:21595-21661.
Peto, R.. Pike, M., Day, N.. Gray, R., Lee, P..
  Parish, S., Peto,}.. Richard. S., and
  Wahrendorf. ]. 1980. Guidelines for simple.
  sensitive, significant tests for carcinogenic
  effects in long-term animal experiments. In:
  Monographs on the long-term and short-
  term screening assays for carcinogens: a
  critical appraisal. IARC Monographs.
  Supplement 2. Lyon. France: International
  Agency for Research on Cancer, pp. 311-
  428.
Tomatis, L. 1977. The value of long-term
  testing for the implementation of primary
  prevention. In: Origins of human cancer.
  Hiatt H.H., Watson. J.D., and Winstein.
  J.A., eds. Cold Spring Harbor Laboratory.
  pp. 1339-1357.
U.S. Environmental Protection Agency (U.S.
  EPA). 1976. Interim procedures and
  guidelines for health risk economic impact
  assessments of suspected carcinogens.
  Federal Register 41:21402-21405.
U.S. Environmental Protection Agency [U.S.
  EPA). 1980. Water quality criterial
  documents; availability. Federal Register
  45:79318-79379.
U.S. Environmental Protection Agency (U.S.
  EPA). 1983a. Good laboratory practices
  standards—toxicology testing. Federal
  Register 48:53922.
U.S. Environmental Projection Agency (U.S.
  EPA). 1983b. Hazard evaluations: humans
  and domestic animals. Subdivision F.
  Available from: NTIS, Springfield. VA. PB
  83-153916.
U.S. Environmental Protection Agency (U.S.
  EPA). 1983c. Health effects test guidelines.
  Available from: NTIS Springfield. VA. PB
  83-232984.
U.S. Environmental Protection Agency (U.S.
  EPA). 1984. Proposed guidelines for
  exposure assessment.
U.S. Food and Drug Administration (U.S.
  FDA). 1982. Toxicological prir.-iplc^ for the
  safety assessment of direct food additives
 •and color additives used in food. Available
  from: Bureau of Foods. U.S. Food and Drug
  Administration.
Ward. J.M., Griesemer, R.A., and Weisburger,
  E.K. 1979a. The mouse  liver tumor as an
  endpoint in carcinogenesis tests. Toxicol.
  Appl. Pharmacol. 51:389-397.
Ward, J.M. Goodman. D.G., Squire. R.A.-Chu,
  K.C., and Linhart. M.S. 1979b. Neoplastic
  and nonneoplastic lesions in aging (C57BL/
  6N x C3H/HeN)F, (B6C3F,) mice. J. Nail.
  Cancer Inst. 63:849-854.
IFR Doc. 84-30724 Filed 11-21-84: 8:45 am]
BILLING CODE 65SO-50-M

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                                         £ife Systems, Jnc.
PART  2 - EXPOSURE ASSESSMENT
              A3-3

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Friday
November 23, 1d84
Part VIII
Environmental
Protection Agency
Proposed Guidelines for Exposure
Assessment; Request for Comments

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46304
Federal  Register / Vol. 49.  No. 227  /  Friday. November 23. 1984 / Notices
ENVIRONMENTAL PROTECTION
AGENCY

IFRL-2706-5]

Proposed Guidelines for Exposure
Assessment

AGENCY: Environmental Protection
Agency (EPA).
ACTION: Proposed Guidelines for
Exposure Assessment and Request for
Comments.

SUMMARY: The U.S. Environmental
Protection Agency is proposing
Guidelines for Exposure Assessment
(Guidelines). These Guidelines are
proposed for use within the policy and
procedural framework provided by the
various statutes which EPA administers
to guide Agency analysis of exposure
data. We solicit public comment and
will take public comment into account in
revising these Guidelines. These
Guidelines will be reviewed by the
Science Advisory Board in meetings
now tentatively scheduled for April
1985.
  These proposed Guidelines were
developed as part of a broad guidelines
development program under the
auspices of the Office of Health and
Environmental Assessment (OHEA),
located in the Agency's Office of
Research and Development. Consonant
with the role of OHEA's Exposure
Assessment Group (EAG) as the
Agency's senior health committee for
exposure assessment, the Guidelines
were developed by an Agency-wide
working group chaired by the Director of
EAG.
DATE: Comments must be postmarked
by January 22.1985.
ADDRESSES: Comments may be mailed
or delivered to: Dr. James W. Falco,
Exposure Assessment Group (RD-689),
Office of Health and Environmental
Assessment, U.S. Environmental
Protection Agency, 401 M Street  S.W..
Washington, DC 20460.
FOR FURTHER INFORMATION CONTACT:
Dr. James W. Falco, Telephone: 202-475-
8909.
SUPPLEMENTARY INFORMATION:
Preliminary drafts of these Guidelines
were sent out for review to 15 scientists
and engineers in the field of exposure
assessment within government,
universities in the United States and
abroad, and the private sector.
Comments received from these reviews,
generally favorable, were taken  into
account in developing the Guidelines
proposed here.
  In addition, as a result of the reviews.
four areas requiring further research
were identified as follows:
                       (1) Development of Mathematical
                     Model Selection Criteria.
                       A large number of mathematical
                     models are used to estimate a wide
                     variety of parameters needed for
                     estimating exposures. Guidance in the
                     form of selection criteria are needed to
                     ensure that the most appropriate
                     mathematical model is used for each
                     exposure parameter estimate.
                       (2) Development of Guidance for
                     Analysis of Metabolism Data.
                       Guidance is needed to provide
                     appropriate consideration of metabolism
                     data in the calculation  of whole body
                     dose and in the extrapolation of whole
                     organism dose from one species to
                     another.
                       (3) Definition of the Relationship
                     Between Exposure Assessment and
                     Epidemiology.
                       Guidance is needed to ensure that
                     pertinent parameters of exposure are
                     measured in prospective epidemiologic
                     studies. Methods providing the best
                     estimates of exposure for retrospective
                     and historical epidemiologic studies
                     must be defined.
                       (4) Development of Methods to Relate
                     Exposures Measured by Personal
                     Monitoring to Source Contributions.
                       Guidance is needed to establish
                     methods to relate exposures as
                     measured by personal monitoring to
                     controllable  sources and to discriminate
                     among possible sources and between
                     background and anthropogenic sources.
                     It is the Agency's intent to revise the
                     Guidelines periodically to incorporate
                     the results obtained in the four research
                     areas defined above as they become
                     available.
                       In addition to the publication of the
                     Guidelines, the Agency also will provide
                     technical support documents that
                     contain detailed technical information
                     needed to implement the Guidelines.
                     Two of these technical reports entitled
                     "Development of Statistical Distribution
                     or Ranges of Standard Factors Used in
                     Exposure Assessments" and
                     "Methodology for Characterization of
                     Uncertainty  in Exposure Assessments"
                     are currently available. Technical
                     reports for the four new guideline areas
                     described above will be available at the
                     time of publication of the corresponding
                     guideline section. These technical
                     support documents will be revised
                     periodically to reflect improvements in
                     exposure assessment methods and new
                     information  or experience.
                       Support documents used in the
                     preparation  of these Guidelines as well
                     as comments received are available for
                     inspection and copying at the Public
                     Information  Reference Unit (202-382-
                     5926), EPA Headquarters Library, 401 M
Street S.W., Washington, DC, between
the hours of 8:00 a.m. and 4:30 p.m.
  Dated: November 9.1984.
William D. Ruckelshaus.
Administrator.
Contents
I. Introduction
II. General Guidelines and Principles
  A. Exposure and Dose
  B. Decision Path to Determine Scope of the
   Assessment
  C. Uncertainty
III. Organization and Contents of an
   Exposure Assessment
  A. Overview
  B. Detailed Explanation of Outline
   1. Executive Summary
   2. Introduction
   3. General Information
   4. Sources
   5. Exposure Pathways and Environmental
   Fate
   6. Monitored or Estimated Concentration
   Levels
   7. Exposed Populations
   8. integrated Exposure Analysis
   9. References
  10. Appendexes

I. Introduction

  These Guidelines provide the Agency
with a general approach and framework
for carrying out human or nonhuman
exposure assessments for specified
pollutants. The Guidelines have-been—
developed to assist future assessment
activities and encourage improvement in
those EPA programs that require, or
could benefit from the use of exposure
assessments. The Guidelines are
procedural. They should be followed to
the extent possible in instances where
exposure assessment is a required
element in the regulatory process or
where exposure assessments are carried
out on a discretionary basis by EPA
management to support regulatory or
programmatic decisions.
  This document, by laying out a set of
questions to be considered in carrying
out an exposure assessment, should help
avoid inadvertent mistakes of omission.
EPA recognizes that gaps in data will be
common, but the Guidelines will
nevertheless serve to assist in
organizing the data that are available,
including any new data developed as
part of the exposure assessment. It is
understood that exposure assessments
may be performed at many different
levels of detail depending on the scope
of the assessment.
  These. Guidelines should also promote
consistency among various exposure
assessment activities that are carried
out by the Agency. Consistency with
respect to common physical, chemical,
and'biological parameters, with  rsspect
to assumptions about  typical exposure

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                  Federal  Register / VoL 49, No. 227  / Friday, November 23, 1984 / Notices
                                                                     46305
situations, and with respect to the
characterization of uncertainty of
estimates, will enhance the
comparability of results and enable the
Agency to improve the state-of-the-art of
exposure assessment over time through
the sharing of common data and
experiences.
  It is recognized that the main
objective of an exposure  assessment is
to provide reliable data and/or
estimates for a risk assessment Since a
risk assessment requires  the coupling of
exposure information and toxicity or
effects information, the exposure
assessment process should be
coordinated with the toxicity/effects
assessment. This document provides a
common approach to format, which
should simplify the process of reading
and evaluating exposure  assessments
and thereby increase their utility in
assessing risk.
  . As the Agency performs more
exposure assessments, the Guidelines
will be revised to reflect  the benefit of
experience.
II. General Guidelines and Principles
A. Exposure and Dose  •
  Exposure has been denned by
Committee E-47, Biological Effects and
Environmental Fate, of the American
Society for Testing and Materials.Tas the
contact with a chemical or physical
agent The magnitude of the exposure is
determined by measuring or estimating
the amount of an agent available at the
exchange boundaries, i.e., lungs, gut
skin, during some specified time.
Exposure assessment is the
determination or estimation (qualitative
or quantitative] of the magnitude,
frequency, duration, and  route of
exposure. Exposure assessments may
consider past present and future .
exposures with varying techniques for
each phase, i.e., modeling of future
exposures, measurements of existing
exposure, and biological  accumulation
for past exposures. Exposure
assessments are generally combined
with environmental and health effects
data in performing risk assessments.
  In considering the exposure of a
subject to a hazardous agent there are
several related processes. The contact
between the subject of concern and the
ai^ent may lead to the intake of some  of
the agent. If absorption occurs, this
constitutes an uptake (or an absorbed
dose) which then may  lead to health
effects. When biological  tissue or fluid
measurements indicate the presence of a
chemical,  exposures can  be estimated
from these data. Presence of a chemical
in such biological samples is  the most
direct indication  that an  exposure has
occurred The route of exposure
generally impacts the overall exposure
and should be considered in performing
risk assessments.
B. Decision Path to Determine Scope of
the Assessment
  The first step in preparing an
exposure assessment should be the
circumscription of the problem at hand
to minimize effort by use of a narrowing
process. A decision logic path that
describes  this process is shown in
Figure 1. As illustrated in Figure 1, the
preliminary assessment and the in-depth
assessment are two major phases in this
logic path.
  The preliminary assessment phase
should commence by considering what
risk is under study and what law might
regulate the exposure to the agent
Within this framework, a preliminary
data base should be compiled from
readily available scientific data and
exposure information based on
manufacturer, processor, and user
practices.  Next the most likely areas of
exposure (manufacuring, processing,
consumer, distribution, disposal,
ambient water and food, etc.) should be
identified. Since a complete data search
has not been conducted, well-identified.
assumptions and order of magnitude
estimates  are used to further narrow the
exposure areas of concern.
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  Data from this preliminary exposure
assessment can then be coupled with
toxicity information to perform a
preliminary risk analysis. As a result of
this analysis, a decision will be made
that either an in-depth exposure
assessment is necessary or that there is
no need for further exposure
information. The organization and
contents of an in-depth exposure
assessment are given in the following
section.
  •In assembling the information base for
either a preliminary assessment or a
more detailed assessment, its adequacy
should be ascertained by addressing the
following considerations:
—Availability of information in every
  area needed for an adequate
  assessment;
—Quantitative and qualitative nature of
  the data;
—Reliability of information;
—Limitations on the ability to assess
  exposure.
C. Uncertainty
  Exposure assessments are based on
monitoring data, simulation model
estimates, and assumptions about
parameters used in approximating
actual exposure conditions. Both data
and assumptions contain varying
degrees of uncertainty which influence
the accuracy of exposure assessments.
An evaluation of these uncertainties is
important when the assessment is the
basis for regulatory action.
  The uncertainty analyses performed
will vary depending on the scope of the
assessment the quantity and quality of
monitoring data collected, and the type
and complexity of mathematical models
used. A discussion of the types of
analysis used for quantifying
uncertainties in exposures  is presented
in the next section.
III. Organization and Contents of an
Exposure Assessment
A. Overview
  A suggested outline for an exposure
assessment document is given in Exhibit
1. The five major topics to be addressed
within most exposure assessments are
as follows: Source(s); Exposure
Pathways; Monitored or Estimated
Concentration Levels and Duration;
Exposed Population(s); and Integrated
Exposure Analysis. These five topics are
appropriate for exposure assessments in
general, whether the assessments are  of
global, national, regional, local, site-
specific, workplacerrelated. or other
scope. The topics are appropriate for
exposure assessments on new or
existing chemicals and radionuclides.

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Federal Register / Vol.  49.  No. 227  /  Friday. November 23. 1984 / Notices
They are also applicable to both single
media and multimedia assessments.
Since exposure assessments are
performed at different levels of detail,
the extent to which any assessment
contains items listed in Exhibit 1
depends upon its scope. The outline is a
guide to organize the data whenever
they are available.

B. Detailed Explanation of Outline

1. Executive Summary

  The "Executive Summary" should be
written so that it can stand on its own
as a miniature report. Its main focus
should be on a succinct description of
the procedures used, assumptions
employed, and summary tables or charts
of the results. A brief discussion of the
uncertainties associated with the results
should be included.

2. Introduction (Purpose and Scope)
  This section should state the intended
purpose of the exposure assessment and
identify the agent being investigated, the
types of sources and exposure routes
included, and the populations of
concern.
Exhibit 1.—Suggested Outline for an
Exposure Assessment
1. EXECUTIVE SUMMARY
2.. INTRODUCTION
  a. Purpose
  b. Scope             —,-
3. GENERAL INFORMATION
  a. Identity
    (1) Molecular formula and structure. CAS
    number. TSL number
    (2) Description of technical grades,
    contaminants, additives
    (3) Other identifying characteristics
  b. Chemical and Physical Properties
4. SOURCES
  a. Characterization of Production and
    Distribution
    (1) Production and processing
    (2) Distribution in commerce
  b. Uses
  c. Disposal
  d. Summary of Environmental Releases
5. EXPOSURE PATHWAYS AND
    ENVIRONMENTAL FATE
  a. Transport and Transformation
  b. Identification of Principal Pathways of
    Exposure
  c. Predicting Environmental Distribution
6. MONITORED OR ESTIMATED
    CONCENTRATION LEVELS
  a. Summary of Monitoring Data
  b. Estimation of Environmental
    Concentrations
  c. Comparison of Concentration Estimates
    with Monitoring Data
7. EXPOSED POPULATIONS
  a. Human Populations (Size. Location, and
    Habits)
    (1) Population size and characteristics
    (2) Population location
    (3) Population habits
  b. Nonhuman Populations (where
    appropriate)
                         (1) Population size and Characteristics
                         (2) Population location
                         (3) Population habits
                     8. INTEGRATED EXPOSURE ANALYSIS
                       a. Calculation of Exposure
                         (1) Identification and characterization of
                         the exposed populations and critical
                         elements of the ecosystem
                         (2) Pathways of exposure
                       b. Human Dosimetry and Monitoring
                       c. Development of Exposure Scenarios and
                         Profiles
                       d. Evaluation of Uncertainty
                     9. REFERENCES
                     10. APPENDICES
                     3. General Information
                      ' a. Identity. (1) Molecular formula and
                     structure, synonyms, Chemical Abstract
                     Service number, Toxic Substance List
                     number.
                       (2) Description of technical grades,
                     contaminants, additives.
                       (3) Other identifying characteristics.
                       b. Chemical and Physical Properties.
                     This subsection should provide a
                     summary description of the chemical
                     and physical properties of the agent.
                     Particular attention should be paid to
                     the features that would affect its
                     behavior in the environment. Examples
                     of factors to be included are molecular
                     weight, density, boiling point, melting
                     point vapor pressure, solubility, pK..
                     partition coefficients, and half-lives.
                     4. Sources
                       The points at which a hazardous
                     substance is believed to enter the
                     environment should be described, along
                     with any known rates of entry. Points of
                     entry may be indoors as well as
                     outdoors, and environments include
                     indoor settings such as offices as well as
                     outdoor environments. A detailed
                     exposure assessment should include a
                     study of sources, production, uses,
                     destruction/disposal, and environmental
                     release of a substance. The studies
                     should include a description of human
                     activities with respect to the substance
                     and the environmental releases resulting
                     from those activities. It should account
                     for the controlled mass flow of the
                     substance from creation to destruction
                     and provide estimates of environmental
                     releases at each step in this flow.
                     Seasonal variations in environmental
                     releases should also be examined. All
                     sources of the substances should be
                     accounted for with the sum of the uses,
                     destruction, and the environmental
                     releases. The environmental releases
                     can be described in terms  of geographic
                     and temporal distribution and the
                     receiving environmental media, with-the
                     form identified at the various release
                     points.
                       a. Characterization of Production and
                     Distribution. All sources of the
substance's release to the environment.
consistent with the scope of the       '
assessment, should be included, such as
production, extraction, processing,
imports, stockpiles, transportation.
accidental/incidental production as a
side reaction, and natural sources. The
sources should be located, and activities
involving exposure to the substance
should be identified.
  b. Uses. The substance should be
traced from its sources through various
uses (with further follow-up on the
products made to determine the
presence of the original material as an
impurtiy], exports, stockpile increases,
etc.
  c. Disposal. This subsection should
contain an evaluation of disposal sites
and destruction processes, such as
incineration of industrial chemical
wastes, incineration of the substance as
part of an end-use item in municipal
waste, landfilling of wastes, biological
destruction in a secondary wastewater
treatment plant, or destruction in the
process of using the end product.
Hazardous contaminants of the
substance may be included, and
products containing the substance as a
contaminant may be followed from
production through destruction/
disposal.
  d. Summary of Environmental
Releases. Estimates should be made of
the quantities of the substances released
to the various environmental media.
Sources of release to the environment
include production, use, distribution/
transport, natural sources, disposal, and
contamination of other products.
Environmental releases should be
presented at a reasonable level of detail.
Extremely detailed exposure estimates
would attempt to specify the following
information for each significant
emission source: Location, amount of the
substances being released as a function
of time to each environmental medium,
physical characteristics of the emission
source, and the physical and chemical
form of the substance being released.
Evaluation of the uncertainties
associated,with the emission estimates
should be given. A detailed discussion
of procedures for estimating uncertainty
is presented in section S.d.

5. Exposure Pathways and
Environmental Fate
  The exposure pathways section
should address how a hazardous agent
moves from the source to the exposed
population or subject. For a less detailed
assessment broad generalizations on'
environmental pathways and fate may
be made. In the absence of data,  e.g., for
new substances, fate estimates may

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                                                                      46307
 have to be predicted by analogy with
 data from other substances. Fate
 estimates may alscrbe made by using
 models and/or monitoring data and
 laboratory-derived process rate
 coefficients. At any level of detail,
 certain pathways may be judged
 insignficiant and not pursued further.
   For more detailed assessments
 involving environmental fate, the
 sources analysis described previously
 should provide the amount and rate of
 emissions to the environment, and
 possibly the locations and form of the
 emissions. The environmental pathways
 and fate analysis follows the substance
 from its point of initial environmental
 release, through the environment, to its
 ultimate fate.  It may result in an
 estimation of  the geographic and
 temporal distribution of concentrations
 of the substance in the various
 contaminated environmental media.
   a. Transport and transformation. The
 substance, once released to the
 environment,  may be transported (e.g.,
 convected downstream in water or on
 suspended sediment, through the
 atmosphere, etc.) or physically
 transformed (e.g., volatilized, melted,
 absorbed/ desorbed, etc.]; may undergo
 chemical transformation such as
 photoysis, hydrolysis, oxidation.
 reduction; may undergo
 biotransformation such as
 biodegradation; or may accumulate in
 one or more media. Thus, the
 environmental behavior of a substance
 should be evaluated before exposures
 are assessed.  Factors that should be
 addressed include:
   • How does the agent behave in air,
 water, soil, and biological media? Does
 it bioaccumulate or biodegrade? Is  it
 absorbed or taken up by plants?
   * What are -the principal mechanisms
• for change or  removal in each of the
 environmental media.
   • Does the  agent react with other
 compounds in the environment?
   • Is there intermedia transfer? What
 are the mechanisms for intermedia
 transfer? What are the rates of the
 intermedia transfer or reaction
 mechanisms?
   • How long might the agent remain in
 each environmental medium? How does
 its concentration change with time in
 each medium?
   • What are the products into which
 the agent might degrade or change  in the
 environment? Are any of these
 degradation products ecologically or
 biologically harmful? What is the
 environmental-behavior of the harmful
 products?
   • Is a steady-state concentration
 distribution in the environment or in
specific segments of the environment,
achieved? If not can the nonsteady-
state distribution be described?
  • What is the resultant distribution in
the environment—for different media.
different types or forms of the agent,  for
different geographical areas, at different
times or seasons?
  b. Identification of Principal
Pathways of Exposure. The principal
pathway analysis should evaluate the
sources, locations, and types of
environmental releases, together with
environmental behavioral factors, to
determine the significant routes of
human and environmental exposure to
the substance. Thus, by listing the
important characteristics of the
environmental release .(entering media,
emission rates, etc.) and the agent's
behavior (intermedia transfer,
persistence, etc.) after release to each of
the entering media, it should be possible
to follow the movement of the agent
from its initial release to its  subsequent
fate in the environment. At any point in
the environment, human or
environmental exposure may occur.
Pathways  that result in major
concentrations of the agent and high
potential for human or environmental
contact are the principal exposure
pathways.
  c. Predicting Environmental
Distribution. Models may be used to
predict environmental distributions of
chemicals. Many modeling estimates of
environmental distribution of chemicals
are based in part on monitoring data. In
predicting environmental distributions
of chemicals, available monitgring data
should be  considered.
  In this section an estimation is made,
using appropriate models, of
representative concentrations of the
agent in different environmental media,
and its time-dependence in specific
geographical locations (e.g., river basins,
streams, etc.).
6. Monitored or Estimated Concentration
Levels
  a. Summary of Monitoring Data.
Monitoring data are used to identify
releases (source terms) and, in the
exposure pathways and fate
assessments, to quantitatively estimate
both release rates and environmental
concentrations. Some examples of uses
of monitoring data are: Sampling of
stacks of discharge pipes for emissions
to the environment; testing of products
for chemical or radionuclide content:
testing of products for chemical or
radioactive releases; sampling of
appropriate points within a
manufacturing plant to determine
releases from industrial processes or
practices;  and sampling of solid waste
for chemical or radionuclide content.
These data should be characterized as
to accuracy, precision, and
representativeness. If actual
environmental monitoring data are
unavailable, concentrations can be
estimated by various means, including
the use of fate models (see previous
section) or. in the case of new
chemicals, by analogy with p-.isting
chemicals.
  The analysis of monitoring data       '
should be considered a complement to
environmental pathway and fats
analysis for the following reasons: For
most pollutants, particularly organic and
new chemicals, monitoring data are
limited;  analysis of monitoring data does
not often yield relationships between
environmental releases and
environmental concentration
distribution in media or geographic
locations that have not been monitored;
analysis of monitoring data does not
provide information on how and where
biota influence the environmental
distribution of a pollutant: and
monitored concentrations may not be
traceable to individual sources that EPA
can regulate. Monitoring data are,
however, a direct source of information
for exposure analysis and, furthermore,
they can be used to calibrate or -
extrapolatejnodels or calculations to
assess environmental distribution.
   b. Estimation of Environmental
Concentrations. Concentrations of
agents should be estimated for all
environmental media that might
contribute to significant exposures.
Generally, the environmental
concentrations are'estimated from
monitoring data, mathematical models.
or a combination of the two.
   The concentrations must be estimated
and presented in a format consistent
with available dose-response
information. In some cases an estimate
of annual average concentration will be
sufficient, while in other cases the
temporal distribution of concentrations
may be  required. Future environmental
concentrations resulting from current or
past releases may also be projected. In
some cases, both the temporal and
geographic distributions of the
concentration may be assessed.
Moreover, if the agent has natural
sources, the contribution of these to
environmental concentrations may be
relevant. These "background"
concentrations may be particularly
important when the results of tests of
toxic effects show a threshold or
distinctly nonlinear dose-response.
   The uncertainties associated with the
estimated concentrations should be
evaluated by an analysis of the

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uncertainties of the model parameters
and input variables. When the estimates
of the environmental concentrations are
based on mathematical models..the
model results should be compared to
available monitoring data, and any
significant discrepancies should be
discussed. Reliable, analytically-
determined values should be given
precedence over estimated values
whenever significant discrepancies are
found.

7. Exposed Populations

  Populations selected for study may be
done a priori, but frequently the
populations will be identified as a result
of the sources and fate studies. From an
analysis of the distribution of the agent,
populations convected and
subpopulations (i.e., collections of
subjects) at potentially high explosure
can be identified, which will then form
the basis for the populations studied.
Subpopulations of high sensitivity, such
as pregnant women, infants, chronically
ill, etc., may be studied separately.
  In many cases, exposed populations
can be described only generally. In some
cases, however, more specific
information may be available on matters
• such as the following:
  a. Human Populations. (1) Population
size and characteristics (e.g..  trends,
sex/age distribution)
  (2) Population location
  (3) Population habits—transportation
habits, eating habits, recreational habits,
workplace habits, product use habits,
etc.
  b. Nonhuman Populations (where
appropriate). (I) Population size and
characteristics (e.g., species, trends)
   (2) Population location
   (3) Population habits
  Census and other survey data may be
used to identify and describe the
population exposed to  various
contaminated environmental media.
Depending on the characteristics of
available toxicological data, it may be
appropriate to describe the exposed
population by other characteristics such
as species, race-age-sex distribution,
and health status.

8. Integrated Exposure Analysis
   The integrated exposure analysis
combines the estimation of
environmental concentrations (sources
and fate information] with the
description of the exposed population to
yield exposure profiles. Data should be
provided on the size of the exposed
populations; duration,  frequency, and
 intensity of exposure: and routes of
 exposure. Exposures should be related
 to sourc es.
                       For more detailed assessments, the
                     estimated environmental concentrations
                     should be considered in conjunction
                     with the geographic distribution of the -
                     human and environmental populations.
                     The behavioral and biological
                     characteristics of the exposed
                     populations should be considered and
                     the exposures of populations to various
                     concentration profiles should be
                     estimated.The results can be presented
                     in tabular or graphic form, and an
                     estimate of the uncertainty associated
                     with them should be provided.
                       a. Calculations of Exposure. The
                     calculation of exposure involves two
                     major aspects:
                       (1) Identification of the Exposed
                     Population and Critical Elements of the*
                     Ecosystem.
                       The estimate of environmental      <
                     concentrations also should give the
                     geograhical areas and environmental
                     media contaminated. The stated purpose
                     of the assessment should have
                     prescribed the human and
                     environmental subjects for which
                     exposures are to be calculated. If the
                     subjects are not listed, the contaminated
                     geographical areas and environmental
                     media can be evaluated to determine
                     subject populations. The degree of detail
                     to be used in defining  the exposed
                     population distribution depends on the
                     concentration gradient over geographic
                     areas.
                       (2) Identification of pathways of
                     exposure.
                       (a) Identification and description of
                     the routes by which the substances
                     travel from production site, through
                     uses, through environmental releases/
                     sources, through transport and fate
                     processes, to the target population.
                       (b) Quantitative estimates of the
                     amounts of the chemical following each
                     exposure pathway. Such estimates allow
                     the various pathways to be put in the
                     perspective of relative importance.
                       From the geogrpahic and tempral
                     distribution of environmental
                     concentrations, the exposed population,
                     the behavioral characteristics, and the
                     critical elements of the ecosystem,
                     exposure distributions can be estimated.
                     The results of exposure calculation
                     should be presented in a format that is
                     consistent with the requirements of the
                     dose-response functions which may
                     later be used in a risk assessment. For
                     example, when health risks caused by
                     exposure over extended durations are
                     considered, average daily exposure over
                     the duration of exposure usually is
                     calculated. When lifetime risks are
                     considered, average daily exposure .over
                     a lifetime usually is calculated. In
                     contrast when health risks caused by
                     exposures over short durations are
considered, exposure rates are
calculated over short time intervals to
ensure that peak risks are defined.
Many exposure assessments are based
on the average exposure occurring over
the exposure period. The range of
possible exposures is usually divided
into intervals, and the exposures within
each interval are counted. The reuslts
can be presented in a tabular form or as
a histogram.
  The population residing in a specific
geographic area may be exposed to a
substance from several exposure routes.
For each exposure route, exposure of
individuals in these populations may be
determined by summing the contribution
of all sources to the exposure route.
When exposures involve more than one
exposure route, the relative amounts of
a substance absorbed is usually route
dependent. Consequently, total
absorbed dose estimates must account
for these differences. Because EPA
regulates sources of releases, the
contribution to exposures from each
type of source being considered should
be displayed. Exposure estimates should
be presented for each significant
exposure route (i.e., those routes
consistent with the regulatory purpose),
and the results should be^ tabulated in
such a way that total externally applied
and-absorbed dose can be determined.
  b. Human Dosimetry and Monitoring.
Biological monitoring of human body
fluids and tissues for substances or their
metabolites can be used to estimate
current or past exposure to chemicals.
When analytical methods are available,
chemicals that have been absorbed into
the body can be measured in body
tissue and fluid. Such measurements can
be used to estimate exposure. However.
the substances to which humans are
exposed are highly variable in the
degree to which they leave in the body
reliable indicators of exposure.
Furthermore, although a compound may
be relatively easy to detect in body
tissue, for some compounds, attributing
body burdens to specific environmental
releases may be difficult because of
limited ability to obtain environmental
monitoring data.
   c. Development of Exposure Scenarios
and Profiles. Depending on the scope of
the exposure assessment, the total
exposure may be fractionated into one
or more "exposure scenarios" to
facilitate quantification. As an example.
Table 1 lists seven very broad scenarios:
Occupational, Consumer.
Transportation. Disposal, Food, Drinking
Water, and Ambient. For each of the
scenarios, the major topics necessary to
quantify exposure  include sources,
pathways, monitoring, and population

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                   Federal Register / Vol. 49. No.  227  /  Friday, November  23.  1984 /Notices
                                                                                           46309
characteristics. Investigation of only one
scenario may be necessary for the scope
of some assessments. For example, a
pesticide application exposure
assessment may consider the
                 occupational scenario which would
                 address the exposure to applicators and
                 populations in the vicinity of the site. An
                 exposure assessment around a
                 hazardous waste site may focus on the
                                  disposal scenario. The exposure
                                 • assessment also may consider other
                                  scenarios. The more extensive and
                                  comprehensive the scope, the more
                                  scenarios are usually involved.
                             TABLE 1. EXPOSURE ASSESSMENT NEEDS FOR VARIOUS EXPOSURE SCENARIOS
      Exposure scenario
                                Source needs
                                                         Fata needs
                                                                            Population characteristics needs
                                                                                                         Monitoring needs
Occupations! (chemical production)..
Consumer (direct use ol chemical or
 inaovenam use).
Transportation/storage/spills	

Disposal (include incineration, land-
 fill).
Site/plant locations irvplant/on-site
 materials balance.

Consumption rates, iflsti (button pat-
 t3cn amounts in products.
Patterns ol distribution and transpor-
 tation? models for spills.
Materials balance around disposal
 mottled, officNMny, rtthimii-i to en*
                                                 Ptty steal  and
                                                   models.
                                                           chemical properties
                         Workers, families, peculation around
                          sites/plants.
Physical and chemical  properties,
  snetl life release rates, models.
Physical and chemical  properties,
  enwonmentaj fate models.
Fate within disposal process; envi-
  ronmental  fata  ol   releases;
                                                                          Consumers....
Drinking water....
Ambient..
Food chain, rrarfr aging, inriflvea   .-]

Groundwater. surface water, dbtrfeu-
 don system.

Releases to environment air, land.
Food  cnajii models,  late during
 preparation or processing of food.
Leach lataa from pipes, ctdonnation
 processes, fate in water models.

Environmental fate models	
Storage,  transportation  workers.
 general population in area.
Workers at site of disposal, general
 population around site.

General population, nonhuman pop-
 ulation.
General population	
                                                                          General population, nonhuman pop-
                                                                            ulation.               A,
In-ptam/on-site  releases, ambient
 levels  surrounding  site/plants.
 human monitoring.
Levels in products releases.

Releases, ambient levels.

Releases, levels at various points
 wrtrun process, ambient levels.

Levels in food, feedstuff; food chain
 sampling. •  .
Levels in drinking water, groundwat-
 er.  surface  water,  treatment
 plants.
Ambient Air. water, soil, etc.; human
 monitoring.
  It will usually be advantageous in
performing an exposure assessment to
identify exposure scenarios, quantify the
exposure in each scenario, and then
integrate the scenarios to estimate total
exposure. In this "integrated exposure
analysis," summation of independent
exposures from different scenarios
(keeping exposure routes separate) often
will result in a breakout of exposure by
subpopulations. since the individual
scenarios usually treat exposure by
subpopulation. Therefore, the
integration of the scenarios, or
integrated exposure analysis,  will often
result in an  exposure profile.
  For each exposed subpopulation,
exposure profiles should include the size
of the group, the make-up of the group
(age, sex, etc.), the source of the agent,
the exposure pathways, the frequency
and the intensity of exposure  by each
route (dermal, inhalation, etc.), duration
of exposure, and the form of the agent
when exposure occurs. Assumptions
and uncertainties associated with each
scenario and profile should be clearly
discussed.
  d. Evaluation of Uncertainty. (1)
Introduction. Often an exposure
assessment progresses through several
stages of refinement. The purpose of
these Guidelines is to present methods
appropriate for characterization of
uncertainty for assessments at various
stages of refinement, from assessments
based upon limited initial data to those
based upon extensive data.
  The appropriate method for
characterizing uncertainty for an
exposure assessment depends upon the
underlying parameters being estimated.
the type and-extent of data available,
and the estimation procedures utilized.
                 The uncertainty of interest is always
                 with regard to the population
                 characteristic being estimated. For
                 example, when the population
                 distribution of exposures is being
                 estimated, characterization of
                 uncertainty addresses the possible
                 differences between the estimated
                 distribution of exposure and the true
                 population distribution of exposure.
                   An exposure assessment quantifies
                 contact of a substance with affected
                 population members (human or
                 nonhuman subjects). The measure of
                 contact (e.g., environmental level of
                 absorbed dose) depends upon what is
                 needed to predict risk. An  integrated
                 exposure assessment quantifies this
                 contact via all routes of exposure
                 (inhalation, ingestion, and  dermal) and
                 all exposure pathways (e.g.,
                 occupational exposure, exposure from
                 consumption of manufactured goods,
                 etc.). The exposed population generally
                 is partitioned into subpopulations such
                 that the likely exposure of all members
                 of a subpopulation is attributable to the
                 same sources. The exposure for each
                 member  of a subpopulation is then the
                 sum of exposures over a fixed set of
                 sources and pathways. The measured or
                 estimated exposures for members of a
                 sub'population are ideally used to
                 estimate the subpopulation distribution
                 of exposure or characteristics thereof.
                 However, a lack of sufficient
                 information sometimes precludes
                 estimation of the subpopulation
                 distributions of exposure and only
                 summary measures of this  distribution,
                 such as the mean, minimum, maximum,
                 etc.. are  estimated. In each case
                 characterization of uncertainty for the
                 exposure assessment primarily
                                  addresses limitations of the data and the
                                  estimation procedures. The proportions
                                  of the population members in the
                                  individual  subpopulations are usually
                                  estimated and can be used (by
                                  combining estimated distributions for
                                  the subpopulations) to estimate the
                                  distribution of exposure for the total
                                  population. Uncertainty concerning the
                                  sizes of the subpopulations should be
                                "~arfdres"sed~b5rdiscussing limitations of
                                  the data and estimation methods as well
                                  as by tabulating confidence interval
                                  estimates for the population  sizes
                                  whenever possible.
                                    (2) Assessments Based Upon Limited
                                  Initial Data.  The initial exposure
                                  assessment for a substance may be
                                  based upon limited data for exposure
                                  and/or input variables for an exposure
                                  prediction  model (i.e.,  an  equation that
                                  expresses exposure as a function of one
                                  or more input variables). These data
                                  might be either extant data'or data
                                  produced by an initial small-scale study.
                                  The initial limited data frequently are
                                  insufficient to permit estimation of the
                                  entire distribution of exposure. Instead.
                                  summary measures of this distribution,
                                  such as the mean, minimum, and
                                  maximum, are usually estimated.
                                    If the assessment is  based upon
                                 ' measured exposures, the  methods used
                                  to characterize uncertainty depend
                                  mainly upon whether or not  the data
                                  result from a probability sample for
                                  which the probability  of inclusion is
                                  known for each sample member.
                                  Characterization of uncertainty for an
                                  assessment based upon a probability
                                  sample  of exposures is discussed later
                                  in section 8.  d.  (5). If the measured
                                  exposures are not based upon a
                                  probability sample, acknowledgement

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46310            Federal Register / Vol 4a No.  227 / Friday. November  23. 1384 / Notices
that no strictly valid statistical
inferences can be made beyond the
units actually in the sample is one
aspect of the characterization of
uncertainty. If'inference procedures are
implemented, the assumptions upon
which these inferences are based (e.g.,
treatment of the sample as if it was a
simple random sample, or assumption of
an underlying model) should be
explicitly stated and justified. The  data
collection methods and inherent
limitations of the data should also  be
discussed.
  An initial exposure assessment also
may be based upon limited data, such as
estimated ranges, for input variables for
an exposure prediction model.- The
exposure prediction mode! would be •
derived from a postulated exposure
scenario that describes the pathways
from sources to contact with population
members. If the data were only
sufficient to support estimates of the
ranges of the input variables, the
exposure assessment might be limited to
a sensitivity analysis. The purpose of
the sensitivity analysis would be to
identify influential model input
variables and develop bounds on the
distribution of exposure. A sensitivity
analysis would estimate the range-of
exposures that would result as
individual model input variables were
varied from their minimum to their
maximum possible values with the other
input variables held at fixed values, &£.,
their midranges. The overall minimum
and maximum possible exposures
usually would be estimated also. For an
exposure assessment of this type, the
uncertainty would be characterized by
describing the limitations of the data
used to estimate plausible ranges of
model input variables and by discussing
justification for the model. Justification
of the model should include a
description of the exposure scenario,
choice of model input variables, and the
functional form of the model Sensitivity
to the model formulation also can be
investigated by replicating the
sensitivity analysis for plausible
alternative models.
  If the maximum possible exposure
estimated by the sensitivity analysis
presented no significant health risk,
there might be no need to refine the
assessment. If both the minimum and
maximum exposures presented a
potentially significant health risk,  it
would be known that the exposure
scenario represented a significant  health
problem without refining the
assessment When the minimum
exposure estimate does not present a
potentially significant health risk and
maximum dose, then greater importance
is placed 
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                    Federal Register /  Vol. 49. No. 227 / Friday. November  23.  1984  /  Notices
                                                                                       ^6311
distribution. Alternatively, the sample
survey data can be used to compute
joint confidence interval estimates for
percehtiles of the input variable
distribution, which can then be used to
generate confidence interval estimates
for percentiles of the exposure
distribution. In either case, the interval
estimates for percentiles of the exposure
distribution are a useful quantitative
characterization  of uncertainty.
  Characterization of uncertainty for the
exposure assessment would contain a
thorough discussion of limitations of the
data and justification for the model.used
to compute expected exposures. The
design of the sample survey used to
produce the data  base should  also be
discussed. If a probability sample were
not used, the lack of a probability
sample would  be an additional source of
uncertainty. Any  assumptions used in
computing the  confidence interval
estimates, such as independence of
model input variables, should  be
explicitly stated and justified.
Sensitivity to model formulation can be
investigated by estimating the
distribution of exposure for plausible
alternative models and comparing the
estimated percentiles, if sample survey
data have been collected for the input
           variables of the alternative models.
           Appropriate available data for exposure
           should be used to validate the predicted
           distribution of exposure. If specific
           probability distributions have been
           presumed for any model input variables,
           the data for these variables should be
           used to test for goodness of fit for these
           distributions.
             (5) Assessment Based Upon Data for
           Exposure. A major reduction in the
           uncertainty associated with an exposure
           assessment can be achieved by directly
           measuring the exposure for a sufficiently
           large sample of members of the affected
           population. This reduction in
           uncertainty is achieved by eliminating
           the use of a model to predict exposure.
           The measured exposure levels can be
           used to directly estimate the population
           distribution of exposure and confidence
           interval estimates for percentiles of the
           exposure distribution. Direct confidence
           interval estimates also can be computed
           for other characteristics of the exposure •
           distribution, such as the mean exposure.
             These confidence interval estimates
           are then the primary characterization of
           uncertainty for the exposure
           assessment. Limitations of the data and
           design of the sample survey used to
           collect the data also should be
                      discussed. If the sample was not a
                      probability sample, this would again be
                      an additional source of uncertainty.
                        (6) Summary. A summary of the
                      primary methods recommended for
                      characterizing  uncertainty in exposure
                      assessments is presented in Table 2.
                      Virtually all exposure assessments.
                      except those based upon measured
                      exposure levels for a probability sample
                      of population members, rely upon a
                      model to predict exposure. The model
                      may be any mathematical function,
                      simple ox complex, that expresses an
                      individual's exposure as a function of
                      one or more input variables. Whenever
                      a model that has not been validated  is
                      used as the basis for an exposure
                      assessment, the uncertainty associated
                      with the exposure assessment may be
                      substantial. The primary
                      characterization of uncertainty is at
                      least partly qualitative in this case, i.e..
                      it includes a  description of  the
                      assumptions inherent in the model and
                      their justification. Plausible alternative
                      models should be discussed. Sensitivity
                      of the exposure assessment to model
                      formulation can be investigated by
                      replicating the assessment for plausible
                      alternative models.
               TABLE Z—SUMMARY OF PRIMARY METHODS-FOR CHARACTERIZING UNCERTAINTY FOR EXPOSURE ASSESSMENTS
       Type and extern of date
                                 Population characteristic being estimated
                                                                               Primary methods lor characterizing uncertainty
                                                                        Qualitative method*
                                                                                                       Quantitative methods
Measured exposures lor a large sample at
 population uieinboia.
Measured exposures lor a small sample of
 population members.
Measured model input variables lor a large
 sample of population members.
Estimated distnputions of model input varia-
Umitad data for model input variables..
Distribution or exposure....
Summary parameters) of the exposure distri-
 bution, e.g., mean or a percentae.
Disbibulion of exposure....
1. Limitations of the survey design and meas-
 urement techniques.
1. Limitations of the survey design and meas-
 urement tecnrnquea.            /
                                1. Limitations of the survey design and
                                 urement techniques.
                                2. Validity of the exposure model
                                Distribution of exposure...
                                                               1. Validity of the exposure model	

                                                               2. Limitations of the data or other basis lor
                                                                 the input variable distributions.
                                              &nd
                                 sure distribution.
                                1. Limitations of the data	
                                2. Validity of the exposure model..
1. Confidence interval estimates lor percent-
 des of the exposure distribution.
2. Goodness of fit lor exposure models, if any
 have been postulated.
1. Confidence interval estimates lor the sum-
 mary parameter(s).
2. Goodness of fit for exposure models, if any
 have been postulated.
1. Confidence interval estimates for percent-
 lies of the exposure distribution.
2. Goodness of fit for input variable distribu-
 tion functions, it any have been postulated.
3. Estimated distribution of exposure based
 upon alternative models.
1. Confidence interval estimates for percent-
 iles of the exposure distribution.
2. Goodness of fit for input variable distribu-
 tions,  if  input variable data are available.
3. Estimated distribution of exposure based
 upon alternative models.
If input  variable data are  very limited, e.g.,
 some  extant data collected lor  other  pur-
 poses, quantitative characterization of un-
 certainty may not be possible.
  When an exposure assessment is
based upon directly measured exposure
'.evels for a probability sample of
population members, uncertainly can be
greatly  reduced and described
quantitatively. In this case, the primary
sources of uncertainty are measurement
errors and sampling errors. The effects
of these sources of error are measured
quantitatively by confidence interval
estimates of psrcentiles of the exposure
           distribution. Moreover, the sampling
           errors can be limited by taking a large
           sample.
             Whenever the latter is not feasible, it
           is sometimes possible to obtain at least
           some data for exposure and model input
           variables. These data should be used to
           assess goodness of fit of the model and/
           or presumed distributions of input
           variables. This substantially reduces the
           amount of quantitative uncertainty for
                      estimation of the distribution of
                      exposure and is strongly recommended.
                      It is recognized, however,  that it may not
                      be feasible to collect such data.
                        9. References
                        The references should contain a
                      listing of all reports, documents, articles.
                      memoranda, contacts, etc. that have
                      been  cited in the report.
                        10.  Appendices

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46312	Federal Register / Vol. 49, No. 227  /  Friday.  November 23. 1964 / Notices
  The appendices may contain such
items as memoranda and letters that are
not readily accessible, other tables of
monitoring data, detailed lists of
emission sources, detailed tables of
exposures, process flow diagrams,
mathematical model formulations, or
any other item that may be needed to
describe  or document the exposure
assessment.
(FR Doc. 84-30723 Filed 11-21-84:8:45 am)
BILLING CODE «S60-«0-M

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                                          £ifc Systems, Jnc.
PART 3 - MUTAGENICITY RISK ASSESSMENT
              A3-4

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Friday
November 23, 1984
Part IX

Environmental
Protection Agency
Proposed Guidelines for Mutagenicity
Risk Assessment; Request for Comments

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46314
Federal  Register / Vol. 49. No. 227 / Friday. November 23, 1984  / Notices
ENVIRONMENTAL PROTECTION
AGENCY

[FRL-2706-6]

Proposed Guidelines for Mutagenicity
Risk Assessment

AGENCY: Environmental Protection
Agency (EPA).
ACTION: Proposed Guidelines for
Mutagenicity Risk Assessment and
Request for Comments.
SUMMARY: The U.S. Environmental
Protection Agency is proposing
Guidelines for Mutagenicity Risk
Assessment (Guidelines). These
Guidelines are proposed for use within
the policy and procedural framework
provided by the various statutes that
EPA administers to guide Agency
analysis of mutagenicity data. We solicit
public comment and will take public
comment into account in revising these
Guidelines. These Guidelines will be
reviewed by the Science Advisory Board
in meetings now tentatively scheduled
for April 1985.
  These proposed Guidelines  were
developed as part of a broad guidelines
development program under the
auspices of the Office of Health and
Environmental Assessment (OHEA),
located in the Agency's Office of
Research and Development. Consonant
with the role-of OHEA's Reproductive
Effects Assessment Group (REAG) as
the Agency's senior health committee
for mutagenicity assessment, the
Guidelines were developed by an
Agency-wide working group chaired by
the REAG.
DATES: Comments must be postmarked
by January 22,1985.
ADDRESSES: Comments may be mailed
or delivered to: Dr. David Jacobson-
Kram, Reproductive Effects Assessment
Group (RD-689). Office of Health and
Environmental Assessment U.S.
Environmental Protection Agency, 401 M
Street SW., Washington, DC 20460.
FOR FURTHER INFORMATION CONTACT
Dr. David Jacobson-Kram, Telephone:
202-382-7338.
SUPPLEMENTARY INFORMATION: Public
comments received as a result of the
proposed guidelines for Mutagenicity
Risk Assessment, which was published
in the Federal Register [45(221):74984-
74988) on November 13. 1980. have been
addressed. The guidelines published
here reflect the suggestions that were
provided during that initial comment
period. A new draft of these Guidelines,
taking into account the earlier public
comments, was recently sent for review
to approximately 14 scientists in the
field of chemical mutagenesis within
                     government, universities in the United
                     States, and the private sector.
                     Comments received from these reviews,
                     generally favorable, were also taken
                     into account in developing the
                     Guidelines proposed here.
                       References and supporting documents
                     used in the preparation of these
                     Guidelines as well as comments
                     received are available for inspection
                     and copying at the Public Information
                     Reference Unit (202-382-5926), EPA
                     Headquarters Library, 401 M Street, SW,
                     Washington, DC, between the hours of
                     8:00 a.m. and 4:30 p.m.
                       Dated- November 9,1984.
                     William D. Ruckelshaus,
                     Administrator.
                     Contents
                     I. Introduction
                     II Comments Received From the Federal
                        Register Publication of the Proposed 1980
                        Guidelines and Agency Responses to
                        These Comments
                       A. Comments on the Introduction
                       B. Concepts Relating to Heritable Genetic
                        Risk
                       C. Testing Systems
                       D. Weights-Evidence Approach
                       E. Quantitative Assessement of Results
                     III. Proposed Guidelines
                       A. Introduction
                        1. Concepts Relating to Heritable
                        Mutagenic Risk
                        2. Test Systems
                       B. Qualitative Assessment (Hazard
                        Identification)
                        1. Mutagenic Activity
                        2. Chemical Interactions in the
                        Mammalian Gonad
                        3. Weight-of-Evidence Determination
                       C. Quantitative Assessment
                        1. Dose-Response
                        2. Exposure Assessment
                        3. Risk Characterization
                     IV. References

                     I. Introduction
                       On November 13,1980, the U.S.
                     Environmental Protection Agency (EPA)
                     published purposed guidelines for
                     Mutagenicity Risk Assessment (1} and
                     solicited comments on those guidelines.
                     The proposed guidelines of 1980
                     described the procedures that the
                     Agency would follow to evaluate the
                     genetic risks associated with the
                     exposure of humans to chemical
                     mutagens. These procedures
                     incorporated a weight-of-evidence
                     approach that considered the quality
                     and adequacy of all the available data «•
                     on a chemical substance in order to
                     make qualitative, and. where possible,
                     quantitative evaluations of mutagenic
                     potential. The Agency stated that  '
                     mutagenicity risk assessments prepared
                     pursuant to the proposed guidelines
                     would be utilized within the
                     requirements and constraints of the
applicable statutes that the Agency
administers to arrive at regulatory
decisions concerning mutagenicity.
  The current proposed Guidelines
address the comments received in
response to the Agency's proposed
mutagenicity risk assessment guidelines
and provide the basis for the Agency's
risk assessments for mutagenicity.
These Guidelines, which adopt the
general approach set forth in the 1980
proposal, reflect additional changes
made in response to the comments and
to new scientific information generated
since the time of the proposal.
  The current proposed Guidelines
reflect  changes made in response to the
public  comments to the proposed
guidelines of 1980. These changes dealt
primarily with the section addressing
the weight-of-evidence approach. This
section has been expanded to  define
"sufficient," "suggestive," and "limited"
evidence for potential  human germ-cell
mutagenicity and to include two
categories of evidence, "sufficient" and
"suggestive" for chemical interaction
with the gonads. Also, in the
quantitative assessment section, the
dominant skeletal and dominant
cataract tests have been added to the
list of systems for possible use in
estimating the magnitude of genetic '
risks. Other minor changes have been
made in the text for clarification.
  A draft of the current proposed
Guidelines was submitted for review to
individuals from industry, educational
institutions, enivornmental groups, and
other government agencies. These
reviews were useful in revising the
Guidelines.
  The  Agency has not attempted to
provide in the current  proposed
Guidelines a detailed discussion of the
mechanisms of mutagenicity or of the
various test systems that are currently
in use  to detect mutagenic potential.
Background information on mutagenicity
•end mutagenic test systems is available
in "Identifying and Estimating the
Genetic Impact of Chemical
Environmental Mutagens," National
Academy of Sciences (NAS) Committee
on Chemical Environmental Mutagens
(2), as  well as in other recent
publications^, 4).
  For the information  of the reviewer,
Chapter II discusses the comments that
were received in response to tne
proposed guidelines of 1980 and the
Agency's responses to those comments.
The current proposed  Guidelines for
Mutagenicity Risk Assessment, for
which  comments are currently invited.
are described in Chapter III. The Agencj
anticipates that as methods for
mutagenicity risk assessment  are

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Federal  Register / Vol. 49. No. 227 / Friday. November 23. 1984 / Notices
                               46315
  refined, and more information becomes
  available in the area of mutagenicity.
    •visions to these Guidelines may be
    sirable or necessary.

- II. Comments Received From the Federal
  Register Publication of the Proposed
  isau Guidelines and Agency Responses
  to These Comments
    As stated in the Introduction, the
  current Guidelines are being proposed to
  encourage further public comment. For
  the information of the reviewer, a
  summary of the public comments
  received in response to the proposed
  guidelines of 1980 and  the Agency
  responds to those comments are
  presented here.
    A totul of 34 comments were received.
  17 from  manufacturers of regulated
  products, eight from associations, four
  from individuals, three from educational
  institutions, and one each from a private
  consulting laboratory and a government
  agency.  Many responses noted that the
  proposed guidelines of 1080 were timely
  and appropriate and praised the Agency
  fur  initiating procedures for scientific
  evaluation of mutagenicity data. Other
  commenters felt that the proposed
  guidelines were "premature." Various
  reasons  were given for this position: (1)
  The mechanisms by which mutations
  occur are not  understood: (2) the data
  lases for many  mutagenicity tests are
  Timited, and hence the tests have not
  been validated:  (3) the  Agency should
  wait until the EPA Gene-Tox Program is
  completed: and  (4) epidemiologic studies
  have failed to document chemically-
  induced mutations in humans.
    It is the opinion of the Agency that
  there is a need for mutagenicity
  guidelines because various statutes
  administered  by the Agency provide the
  authority to regulate chemicals on the
  basis of mutagenicity. The purpose of
  the  current proposed Guidelines is  to
  promote Agency-wide consistency  in the
  evaluation of  mutagenicity data. In
  response to the  specific concerns
  enumerated above relating to the issue
  of prematurity, the Agency has
  concluded that the comments do not
  provide  an adequate basis for delaying
  the  development of mutagenicity
  guidelines. Specifically, with regard to
  the first  comment that the mechanisms
  by which mutations occur are not
  understood, the  Agency does not believe
  that a full understanding of all aspects
  of these  mechanisms is necessary to
  evaluate the mutagenic potential of
  chemicals in the environment.
  Additionally,  the comment ignores  the
«tensive body of data on specific
    emical DNA adducts. repair
  processes, and mutational expression
  that enable description of the mutational
                     process in specific physiochemical terms
                     (2).
                       With regard to the second comment,
                     the Agency agrees that the data bases
                     for many mutagenicity tests are limited:
                     however, the Agency does not agree that
                     the validity of a test is a function of the
                     •ize of the data base. Validity is the
                     extent to which a test measures the
                     particular biological end point of
                     interest and should not be confused with
                     sensitivity, the proportion of known
                     mutagens that are positive in a system.
                     or specificity, the proportion of
                     nonmutagens that are negative. Hence, a
                     mutagenesis assay ia validated when Its
                     ability to detect a heritable genetic
                     change is demonstrated.
                       In response to  the third comment, the
                     Agency does not believe it is  necessary
                     to wait for completion of the Gene-Tox
                     Program before issuing guidelines for
                     evaluating mutagenicity data. The
                     Agency acknowledges that future
                     scientific developments can be expected
                     to affect the methods for the evaluation
                     of mutagenicity data. Such
                     developments may stem from phase II of
                     the Gene-Tox Program (which focuses
                     on test applications) as well as from
                     other collaborative activities  in basic
                     and applied research. However, the
                     Agency believes  that the current
                     Guidelines, as written, can
                     accommodate new information.
                       With respect to the fourth comment
                     the Agency does  not agree that the
                     failure to identify a chemical  as a
                     known human mutagen is justification
                     for not proposing guideline* to evaluate
                     mutagenicity data. Despite the difficulty
                     in translating changes in mutation rate
                     to alterations in disease frequency, the
                     NAS Committee on Chemical
                     Environmental Mutagens has concluded
                     that the aet effect of an increase in
                     mutation rate is harmful because almost
                     all mutants with any detectable effect
                     are deleterious (2).
                     A. Comments on  the Introduction
                       Many commenters on the proposed
                     guidelines of 1980 were critical of the
                     statement, "Since the prospect of curing
                     most heritable diseases caused by
                     mutagens in the near future is unlikely.
                     minimizing exposure to mutagens is
                     among the best available means to
                     protect against further deterioration of
                     the human gene pool." At the present
                     time there is no direct evidence in
                     humans that heritable diseases are
                     being caused by chemical mutagens, and
                     there is no evidence of deterioration of
                     the gene pool. This sentence has been
                     deleted.
                       Several commenters objected to the
                     statement, "Mutations are largely
                     recognized as being deleterious." and
pointed out-that many mutations are
silent or have no effect. In the current
proposed Guidelines, this sentence has
been changed to read. "It is generally
recognized that most mutations that are
phenotypically expressed are in some
ways deleterious to the organism
carrying them."
  Gne commenter requested  an
explanation of how mulageninity
guidelines would be administered and
requested a statement indicating
requirements for genetic toxicology
testing in premarket manufacturing
notices. The Agency believes that the
language in the current proposed
Guidelines clearly states that they will
be used to assess risks associated with
human exposure to chemical  mutugens.
Requirements for genetic toxicology
testing are the responsibility  of the
appropriate Agency office.

B. Concepts Relating to Heritable
Genetic Risk

  One commenter objected to the
definition of a mutagen because it was
not limited to stable and heritable
alternations in the ONA. The Agency
agrees that the ultimate end point of
concern for the purpose of the current
proposed Guidelines is heritable and
stable-mutation.  For gene mutations,
heritability is an obvious and necessary
component, since all tests used to detect
gene mutations actually detect mutant
cells or organisms that are  descendants
of the treated cells. The same is not
always true for certain cytogenetic end
points, such as chromatid breaks, etc..
which may be 'detected in the same cell
generation in which they occur. Since
these latter end points provide
information relevant to heritable
mutation, they will be considered in any
mutagenicity assessment. As a result.
the  Agency feels that the general
definition of a mutagen as used in these
Guidelines is appropriate.

C. Testing Systems

  One commenter felt that  most
cytogenetic end points that are routinely
evaluated (e.g.. chromosome  breaks,
micronuclei) are  not transmitted, and
therefore, are not germane  to the issue
of heritable mutation. The Agency
disagrees. Although it is clear that cells
that carry such aberrations generally do
not reproduce, other related aberrations
(i.e., balanced translocations.
inversions, small duplications, and
deficiencies) are compatible with cell
survival in germ  cells and can be
transmitted. Additionally, there is no
evidence indicating that the non-
transmissible aberrations occur by

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46316
Federal  Register / Vol. 49. No.  227 / Friday. November 23,  1984 / Notices
mechanisms different from transmissible
aberrations.
 - Several commenters requested that
the Agency establish minimal criteria by
which assays are to be judged for use in
risk assessment determinations. The
Agency believes that to list a specific set
of criteria that must be met for each
assay before the Agency evaluates data
would be overly restrictive and
inappropriate. Data generated in any
system that measures or correlates with
a true genetic end point may provide -
some useful information. The Agency
believes that the general protocols and
criteria for  data evaluation established
by the expert committees of the  Phase-I
Gene-Tox Program as well as other
sources provide sufficient guidance for
those planning to conduct mutagenicity
tests.

D. Weight-of-Evidence Approach
   Several commentes suggested that the
weight-of-evidence section required
clarification of the phrase, "positive
response in any two different point
mutation test systems," because this
phrase may be subject to various
interpretations. The Agency agrees that
the section as proposed may have been
subject to misinterpretation. Therefore,
the current proposed Guidelines define
sufficient evidence of potential human
mutagenicity to include positive
responses in any two different gene
mutation test systems (one of which
utilized mammalian cells) or positive
responses in two different somatic
cytogenetic tests (one of which utilizes
mammalian cells), coupled with
sufficient evidence of germ-cell
interaction in both caes. Alternatively,
the combination of a positive finding in
one mammalian gene mutation assay
and  one mammalian cytogenetics test
and  sufficient evidence of germ-cell
interaction also provides sufficient
evidence of potential human
mutagenicity. The demostration of
heritable effects induced in mammalian
germ cells is by itself sufficient evidence
for mutagenicity.
   Many commenters objected to the
criterion that considers a chemical
mutagen a  potential human germ-cell
mutagen if there is "evidence for the
presence of the test substance and/or its
matabolites in mammalian gonadal
organs." First, they pointed out  that the
presence of a chemical in the testis or
ovary does not necessarily mean it has
reacted with germ-cell DNA. Such
studies are generally performed with
 radiolabeled chemicals, and it is
 possible that metabolism of the
 compound could result in incorporation
 of the radiolabel into normal cellular
 macromolecules. The Agency recognizes-
                     the shortcomings in the various criteria
                     used to determine whether a mutagen
                     interacts with germ-cell DNA. As a
                     result, in the current Guidelines, two
                     categories of such evidence have been
                     adopted. Sufficient evidence that a
                     mutagen interacts in the mammalian
                     gonad will be the demonstration that an
                     agent interacts with germ-cell DNA or
                     other chromatin constituents, or that it
                     induces such end points as unscheduled
                     DNA synthesis, sister chromatid
                     exchange (SCE), or chromosomal
                     aberrations in germinal cells. Suggestive
                     evidence will include advese gonadal
                     effects following acute, subchronic, or
                     chronic  toxicity testing or adverse
                     reproductive effects, such as decreased
                     fertilization index, reduced sperm count.
                     or abnormal sperm morphology.
                       One commenter suggested that the
                     Agency develop a scale of weighting
                     tests which would place more emphasis
                     on test systems more relevant to human
                     beings. The Agency .has explored the
                     possibility of developing such a scale
                     and has concluded that the assignment
                     of fixed values for each test system
                     could be overly simplistic and might not
                     allow for the consideration of such
                     variables as dose range, route of
                     exposure, and magnitude of respone.
                     The Agency believes that the scheme in
                     the current proposed Guidelines, which_
                     generally gives greater weight to
                     mammalian rather than submammalian
                     assays and to germ cell rather than
                     somatic cell data, is currently the most
                     appropriate  way to evaluate the
                     information from a variety of systems.
                     E. Quantitative Assessment of Results
                       Several commenters expressed the
                     opinion that it is'not possible to
                     quantitatively express the risk of genetic
                     disease from exposure to a chemical,
                     and therefore no attempt should be
                     made to do so. The Agency does not
                     suggest that it is necessarily possible to
                     generate a numerical estimate of the
                     genetic  risk  that will result from
                     exposure to any particular chemical. It
                     is well-recognized and documented that
                     the mutational component of certain
                     categories of human genetic disease is
                     not known. However, mutagenicity data
                     have been used to generate semi-
                     quantitative estimates of the impact of
                     ionizing radiation on genetic disease(5,
                     6). The current proposed Guidelines
                     state the Agency's commitment to utilize
                     existing relevant mutagenicity data to
                     give some estimate of potential human
                     mutagenicity. All such estimates will
                     include a careful  delineation of the
                     assumptions and uncertainties
                     associated with the assessment.
                        Many commenters objected to the use
                     of "linear or nonthreshold models" for
 low-dose extrapolation on point
 mutation rates. The Agency
 acknowledges that linearity and the
 presence or absence of a threshold are
 separate issues. The Agency will strive
 to use the most appropriate
 extrapolation model for risk analysis
 and will be guided by the available data
 in this selection. However, it is
 anticipated that for whole-animal germ-
 cell assays, few dose points will be
 available to define a dose-response
 function. In these situations there is a
 theoretical basis for a linear,
 nonthreshold extrapolation provided
 that no major germ-cell killing (and thus
 possible cell selection) has occurred(2,
 7).
   One commenter suggested (hat for
 quantitative risk it is more appropriate
 to rely on tests for structural
 chromosomal aberrations than on gene
 mutations, particularly since many
 diseases can be more readily associated
 with an identifiable chromosome
 abnormality. The Agency agrees that
 associations between diseases and
 specific chromosomal changes can be
 estimated. This concept is well
 documented and has been discussed at
 length in the NAS report(2). However,
 similar estimates can be made for gene
 mutations, and such techniques have
 been used for some time for effects of
 ionizing radiation(5, 5). Because the
 spectrum of mutational effects induced
 by different  chemicals is known to be
 variable, the Agency believes that it is
 necessary to perform estimates on all
 end points.
  /One commenter objected to the
. omission of the dominant skeletal and
 cataract mutation systems for
 quantitative risk assessment. The
 Agency recognizes that these dominant
 mutation systems do have relevance in
 the preparation of quantitative risk
 assessment along with specific-locus
 test systems. The  current proposed
 Guidelines have been  modified to
 include both types of tests.

 III. Proposed Guidelines

 A. Introduction

   This section describes the procedures
 that the U.S. Environmental Protection
 Agency will follow in  evaluating the
 potential genetic risk associated with
 human exposure to existing industrial
 chemicals and to pesticides*. The central
 purpose of the health risk assessment is
 to provide a judgment concerning the
 weight of evidence that an agent is a
 potential human mutagen with respect
 to transmitted genetic changes, and, if
 so, how great an impact it is likely to
 have on public health. Regulatory

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                  Federal -Register / Vol. 49. No. 227  / Friday, November 23, 1984  /  Notices
                                                                      46317
decision making involves two
components: Risk assessment and risk
  anagement Risk assessment estimates
  c potential adverse health
consequences of exposure to toxic
chemicals; risk management combines
the risk assessment with the directives
of the enabling regulatory legislation—
together with socioeconomic, technical,
political, and other considerations—to
reach a decision as to whether or how
much to control future exposure to the
chemnicals. The issue of risk
management will not be dealt with in
these Guidelines.
  Risk assessment is comprised of the
following components: Hazard
identification, dose-response
assessment, exposure assessment, and
risk characterize tion(5). Hazard
identification is the qualitative risk
assessment, dealing with the inherent
toxicity of a chemical substance. The
qualitative mutagem'city assessment
answers the question of how likely an
agent is to be a human mutagen. The
three remaining components comprise
quantitative risk assessment, which
provides a numerical estimate of the
public health consequences of exposure
to an agent. The quantiative
mutagenicity risk assessment deals with
the question of how much mutational
damage is likely to be produced by
exposure to a given agent under
particular exposure scenarios.
  In  a dose-response assessment, the
relationship between the dose of a
chemical and the probability of
induction of an adverse effect is defined.
The component generally entails an
extrapolation from the high goses
administered to experimental animals or
noted in some epidemiologic studies to
the low exposure levels expected from
human contact with the chemical in the
environment.
  The exposure assessment identifies
popu'atioris exposed to toxic chemicals,
describes their composition and size,
and presents thu types, magnitudes,
frequencies,  and durations of exposure
to the r.hemcials. This component is
developed independently of the other
components of the mutagenicity
assessment and is addressed in separate
Agency guidelines(S).
  In  risk characterization, the outputs of
the exposure assessment and the dose-
response assessment are combined to
estimate quantitatively the mutation
risk,  which is expressed as either
es'mated increase of generic disease per
generation or per lifetime,  or the
fractional increase in the assumed
background mutation rate  of humans. In
each step of the assessment, the
strengths and weaknesses of the major
H.ssumptions need to be  presented, and
the nature and magnitude of
uncertainties need to be characterized.
  The procedures set forth in these
Guidelines will ensure consistency in
the Agency's scientific risk assessments
for mutagenci effects. The necessity for.
a consistent approach to the evaulation
of mutagenic risk from chemical
substances arises from the authority
conferred upon the Agency by a number
of statutes to regulate potential
mutagens. As appropriate, these
Guidelines will apply to statutes
administered by  the Agency, including
the Federal Insecticide. Fungicide, and
Rodenticide Act; the Toxic Substances
Control Act; the Clean Air Act; the
Federal Water Pollution Control Act; the
Safe Drinking Water Act; the Resource
Conservation and Recovery Act; and the
Comprehensive Environmental
"Response, Compensation, and Liability
Act. Because each statute is
administered by  separate offices, a
consistent Agency-wide approach for
performing risk assessments is
desirable:
  The mutagenciry risk assessments
prepared pursuant to these Guidelines
will be utilized within the requirements
and constraints of the applicable
statutes to arrive at regulatory decisions
concerning mutagenicity. The standards
of the applicable statutes and
regulations may dictate that additional
considerations (e.g., the economic and
social benefits associated with use of
the chemical substance) will come into
play in reaching appropriate regulatory
decisions.
  The Agency is concerned with the risk
associated with both germ-cell
mutations and somatic cell mutations.
Mutations carried in germ cells are
inherited by future  generations and may
contribute to genetic disease, whereas
mutations occurring in somatic cells
may be implicated in the etiology of
several disease states, including cancer.
These Guidelines, however, are only
concerned with genetic damage as it
relates to germ-cell mutations. The use
of mutagenicity test results in the
assessment of carcinogenic risk is
described in the .proposed Guidelines for
Carcinogen Risk Assessment (JO).
   As a result of the progress in the
control of infectious diseases, increases
in average human life span, and better
procedures for identifying genetic
disorders, a considerable heritable
genetic disease burden has been
recognized in the human population. It is
estimated that at least 10% of all human
disease is related to specific genetic
states, such as abnormal composition,
arrangement, or dosage of genes and
chromosomes(2  8,11). Such genetic
diseases can lead to structural or
functional health impairments. These
conditions may be expressed in utero: at
the time of birth; or during infancy,
childhood, adolescence, or adult life:
they may be chronic or acute in nature.
As a result, they often have a severe
impact upon the affected individuals
and their families in terms of physical
and mental suffering and economic
losses, and upon society in general,
which often becomes responsible for
institutional care of severely affected  •
individuals. Some examples of genetic
conditions are Down's and Klinefelter's
syndromes, cystic fibrosis, hemophilia.
sickle cell anemia, and achondroplastic
dwarfism. Other commonly recognized
conditions that are  likely to have a
genetic component  include
hypercholesterolemia. hypertension,
pyloric stenosis, glaucoma, allergies.
several types of cancer, and mental
retardation. These disorders are only a
few of the thousands that are at least
partially genetically determined^).
  Estimation of the fraction of human
genetic disease that results from new
mutation is difficult, although in certain
specific cases insights are available(i3).
It is clear that recurring mutation is
important in determining the incidence
of certain genetic conditions, such as
some chromosomal aberration
syndromes (e.g.,-Down's) and rare
dominant and X-linked recessive
diseases (e.g., achondroplasia and
hemophilia A). For other single-factor
conditions (e.g., sickle-cell anemia and
color blindness) and certain
multifactorial conditions (e.g., pyloric
stenosis), the contribution of new
mutations to disease frequency is
probably very small. However, it is
generally recognized that most
mutations that are phenotypically
expressed are in some ways deleterious
to the organism receiving them. Adverse
effects may be manifested at the .
biochemical, cellular, or physiological
levels of organization. Although
mutations are the building blocks for
further evolutionary change of species, it
is believed that increases in the
mutation rate above the spontaneous
level could lead to  an accumulation of
deleterious mutations in  the human
population and. to a varying extent, an
increased frequency of expressed
genetic disease.
  Life  in our technological society
results in exposure to many natural and
synthetic chemicals. Some have been
shown to have mutagenic activity in
mammalian and submammalian test
systems, and thus may have the
potential to increase genetic damage in
the human population. Chemicals
exhibiting mutagenic activity in various

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46318	Federal Register  /  Vol. 49.  No. 227 / Friday, November 23.  1984 / Notices
 test systems have been found
 distributed among foods, tobacco, drugs,
 food additives, cosmetics, industrial
 compounds, pesticides, and consumer
 products. As our knowledge of genetics
 and disease etiology increases, and
 techniques for detecting mutations in
.human beings improve, we may become
 aware of chemically-induced human
 genetic effects. The extent to which
 exposure to natural and synthetic
 environmental agents may have
 increased the amount of genetic damage
 in the present human population and
 contributed to the mutational "load"
 that will be transmitted to future
 generations is unknown at this time.
 However, for the reasons cited above, it
 seems prudent to limit exposures to
 potential human mutagens.

 1. Concepts Relating to Heritable
 Mutagenic Risk
   For the purposes of these Guidelines,
 a muta'gen is considered a chemical
 substance or mixture of substances that
 can induce alterations in the DNA of
 either somatic or germinal cells. The
 mutagenicity of physical agents (e.g.,
 radiations] is not addressed here. There
 are several mutagenic end points of
 concern to the Agency. These include
 point mutations (i.e., submicroscopic
 changes in the base sequence of DNA)
 and structural or numerical chromosome
 aberrations. Structural aberrations
 include deficiencies, duplications,
 inversions, and translocations, whereas
 numerical aberrations are gains or
 losses of whole chromosomes (e.g.,
 trisomy, monosomy) or sets of
 chromosomes (haploidy, polyploidy).
   It is conceivable that only one or a
 few molecules of an active compound
 may be sufficient to cause certain types
 of heritable changes in DNA. Mutagenic
 effects may also come about through
 mechanisms other than chemical
 alterations of DNA. Among these are
 interference with normal DNA
 synthesis, or induction of DNA
 misrepair, DNA methylation, abnormal
 nuclear division processes, or lesions in
 non-DNA targets (e.g., protamine,
 tubulin).
   The best evidence that an agent
 induces heritable mutations in human
 beings would be epidemiologic data
 indicating a strong association between
 chemical exposure and a heritable
 response. Such data do not exist  at this
 time because any specific mutation is a
 rare event, and only a small fraction of
 the estimated thousands of human genes
 and conditions are currently useful as
 markers in estimating mutation rates.
 Human genetic variability, small
 numbers of offspring per individual, and
 long generation times further
complicates such studies. In addition,
only dominant mutations, some sex-
linked recessive mutations, and certain
chromosome aberrations can be
detected in the first generation after
their occurrence. Conditions caused by
autosomal recessive mutations (which
appear to occur more frequently than
dominants) or by interaction of multiple
factors may go unrecognized for many
generations. Therefore, in the absence of
human germ-cell data, it is appropriate
to rely on data from experimental
animal systems.
  Despite species differences in
metabolism, DNA repair, and other
physiological processes affecting
chemical mutagenesis, the virtual
universality of DNA as the genetic
material and of the genetic code
provides a rationale for using various
nonhuman test systems to predict the
intrinsic mutagenicity of test chemicals.
Additional  support for the use of
nonhuman systems is provided by the
observation that chemicals causing
genetic effects in one species or test
system frequently cause similar effects
in other species or systems. There also
exists evidence thai chemicals can
induce genetic damage in somatic cells
of exposed humans. For example, high
doses of mutagenic chemotherapeutic
agents have been shown to cause
chromosomal abnormalities^), sister
chromatid exchange'^), and, quite
probably, point mutations in human
lymphocytes exposed in vivo(15). While
these results are not in germ cells, they
do indicate that it is possible to induce
mutagenic events in human cells in vivo.
Furthermore,  a wide variety of different
types of mutations have been observed
in humans including numerical
chromosome aberrations, translocations.
base-pair substitutions, and frameshift
mutations. Although the cause of these
mutations is uncertain, it is clear from
these observations that the human germ-
cell DNA is subject to the same types of
mutational events that are observed in
other species and test systems.
  Certain test systems offer notable
advantages: Cost; anatomical,
histological, and/or metabolic
similarities to humans; suitability for
handling large numbers of test
organisms; a large data base; and a
basis for characterizing genetic
events(iO).
2. Test Systems
  Many test systems are currently
available that can contribute
information about the mutagenic
potential of a test compound  with
respect to various genetic end points.
These tests have recently been
evaluated through the EPA Gene-Tox
Programs and the results of Phase I have
been published(4). The Agency's Office
of Pesticides and Toxic Substances has
published various  testing guidelines for,
the detection of mutagenic effects(m
17].
  Test systems for detecting point
mutations include  those in bacteria. •
eukaryotic microorganisms, higher
plants, insects, mammalian somatic cells
in culture, and germinal cells of intact
mammals (e.g., the mouse specific-locus
test). Positive results in a mouse
germinal gene-mutation test argue
strongly that a chemical is a potential
human mutagen because such tests
demonstrate that the mutations occur in
mammalian germinal cells and are
transmitted to the  next genera ton.
However, because large numbers of
offspring must usually  be generated, it is
not expected that  many chemicals will
be tested using these systems. To obtain
data on  a large number of
environmental chemicals, it will be
necessary to rely on other tests to
identify and characterize hazards from
gene mutations.
  Test systems for detecting structural
chromosome aberrations have been
developed in a variety of organisms
including higher plants, insects, fish.
birds, and several mammalian species. •
Many of these assays can be performed
in vitro  or in vivo, and in either germ or
somatic cells. Procedures available for
detecting structural chromosome
aberrations in mammalian germ cells
include  measurement of heritable
translocations or dominant lethality, as
well as  direct cytogenetic analyses of
germ cells and early embryos in rodents.
  Some chemicals may cause numerical
chromosome changes (i.e., aneuploidy)
as their sole mutagenic effect. These
agents may not be detected as mutagens
if evaluated only in tests for DNA
damage, gene mutations, or chromosome
breakage and rearrangement. Therefore.
it is important to consider tests for
changes in chromosome number in the
total assessment of mutagenic hazards.
Although tests for the  detection of
variation in the chromosome number are
still at an early stage of development,
systems exist in such diverse organisms
as fungi, Drosophila, mammalian cells in
culture, and intact mammals (e.g.. mouse
X-chromosome loss assay).
Mondisjunction and chromosome  lagging
are recognized sources of numerical
aberrations. Aneuploidy can also arise
from chromosome breakage and reunion
followed by segregation's). The
mechanmisms by  which nondisjunction
occurs are  not well understood.
However, proteins (e.g., spindle •
apparatus), rather than DNA. may be

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                   Federal  Register / Vol. 49. No.  227 / Friday. November 23.  1984 /  Notices            46319
 the target molecules for at least some
 mechanisms of induced nondisiunction.
   Other end points that provide
 information bearing on the mutagenicity
 of a chemical can be detected by a
 variety of test systems. Such tests
 measure DNA damage in eukaryotic or
 prokaryotic cells, unscheduled DNA
 synthesis in mammalian somatic and
 germ cells, mitotic recombination and
 gene conversion in yeast, and .sister-
 chroma tid exchange in mammalian
 somatic and germ cells. Results in these
 assays are useful because the induction
 of these end points often correlates
 positively with the potential of a
 chemical to induce mutations.
   In general, for all three end points (i.e..
 point mutations and numerical and
 structural aberrations) the Agency will
 place greater weight on tests conducted
 in germ cells than in somatic cells, on   .
 tests performed in vivo rather than in
 vitro, in eukaryotes rather than
 prokaryotes. and in mammalian species
 rather than in submammalian species.
 Formal  numerical weighting systems
 have been developed(7S); however, the
 Agency has concluded that these do not
 readily  accommodate  such variables as
 dose range, route of exposure, and
 magnitude of response.
   The Agency anticipates that  from time
 to time data from chemically-exposed
 human beings will be available (e.g..
 cytogenetic markers in peripheral
'lymphocytes). When posssible, the
 Agency will use such data in
 conjunction with other studies  for the
 purpose of performing risk assessments.
   The test systems mentioned
 previously are not the  only ones that
 will provide evidence  of mutagenicity or
 related DNA effects. These systems are
 enumerated merely to  demonstrate the
 breadth of the available techniques for
 characterizing mutagenic hazards, and
 to indicate the types of data that the
 Agency will consider in its evaluation of
 mutagenic potential of a chemical agent.
 Most systems possess  certain
 limitations that must be taken into
 account. The selection and performance
 of appropriate tests for evaluating the
 risks associated with human exposure  to
 any suspected mutagen will depend on
 sound scientific judgment and
 experience, and may necessitate
 consultation with geneticists familiar
 with the sensitivity and experimental
 design of the test system in question. In
 view oi  the rapid advances in test  '
 methodology, the Agency expects that
 both the number and quality of the tools
 for assessing genetic risk  to human
 beings will increase with  time.  The
 Agency will closely monitor
 developments in mutagenicity
 evaluation and will refine its risk
 assessment scheme as better test
 systems become available.
 B. Qualitative Assessment (Hazard
 Iden tification)
   The assessment of potential human
 germ-cell mutagenic risk is a multistep
 process. The first step is an analysis of
 the evidence bearing on a chemical's
 ability to induce mutagenic events,
 while the second step involves an
 analysis of its ability to produce these
 events in the mammalian gonad. All
 relevant information is  then integrated
 into a weight-of-evidence scheme which
 presents the strength of the information
 bearing on the chemical's potential
 ability to produce mutations in human
 germ cells. For chemicals demonstrating
 this potential, one may decide to
 proceed with  an evaluation of the
 quantitative consequences of mutation
' following expected human exposure.
   For hazard  identification,  it is clearly
 desirable to have data from  mammalian
 germ-cell tests, such as  the mouse
 specific-locus test for point mutations
 and the heritable translocation or germ-
 cell cytogenetic  tests for structural
 chromosome aberrations. It is
 recognized, however, that in most
 instances such data will not be
 available, and alternative means  of .
 evaluation will be required. In such
• cases the Agency will evaluate the
 evidence bearing on the agent's
 mutagenic activity and the agent's
 ability to reach and interact with  or
 affect the mammalian gonadal target.
 When evidence  exists that an agent
 possesses both these attributes, it is
 reasonable to deduce that the agent is a
 potential human germ-cell mutagen.
 1. Mutagenic Activity
   In evaluating chemicals for mutagenic
 activity, a number of factors will be
 considered: (1) Genetic end points (e.g.,
 gene mutations,  structural or numerical
 chromosomal aberrations) detected by
 the test systems, (2) sensitivity and
 predictive value of the test systems for
 various classes of chemical compounds,
 (3) number of different test systems used
 for detecting each genetic end point, (4)
 consistency of the results obtained in
 different test systems and different
 species, (5) aspects of the dose-response
 relationship, and (6) whether the tests
 are conducted in accordance with
 appropriate test protocols agreed upon
 by experts in the field.
   The array of mutagenicity tests
 available will be reviewed within the
 following qualitative perspective:
 greater weight will be attributed to tests
 conducted in germ cells than in somatic
 ceils, to studies in mammalian ceils than
 in submammalian cells, and to studies in
 eukaryotic cells than in prokaryotic
 cells.

 2. Chemical Interactions in the
 Mammalian Gonad

   Evidence for chemical interaction in
 the mammalian gonad spans a range of
 different types of findings. Each
 chemical under consideration needs to
 be extensively reviewed since tiiis type
 of evidence may be part of testing
 exclusive of mutagenicity per se (e;g..
 reproduction, metabolism, and
 mechanistic investigations). Although i!
 is not possible to classify  clearly each
 type of information that may be
 available on a chemical, two possible
 groups are illustrated.
   Sufficient evidence of chemical
 interaction is given by the
 demonstration that an agent interacts
 with germ-cell DNA or other chroma tin
 constituents, or that it induces such end
 points as unscheduled DNA synthesis.
 sister-chromatid exchange, or
 chromosomal aberrations in germinal
 cells. Positive results in a  mammalian
 germ-cell mutation study also
 demonstrate the action of the chemical
 in the gonadal target cells.
   b. Suggestive evidence will include
 the finding of adverse  gonadal effects
 following acute, subchronic, or chronic
 toxicity testing, or findings of adverse
• reproductive effects, which are
 consistent with interaction with  germ
 cells.

 3. Weight-of-Evidence Determination

   The evidence for a chemical's  ability
 to produce mutations and to interact
 with the germinal target are integrated
 into a Weight-of-evidence  judgment thai
 the agent may pose a hazard as a
 potential human germ-cell mutagen. All
 information bearing on the subject.
 whether indicative of potential concern
 or not, must be evaluated. Whatever
 evidence may exist from humans must
 also be factored into the assessment.
   Information available will vary
 greatly from  chemical  to chemical
 because there are many mutageniciiy
 test systems, and there has been no
 systematic attempt to develop
 information on all chemicals of concern.
 The responses noted for different tests
 may also vary from chemical to
 chemical since often one does  not find
 consistent positive or negative results
 across all tests. Chemicals may show
 positive effects  for some end points in
 some test systems, but negative
 responses in others. Each review must
 take into account the limitations in the
 testing and in the types of response;;
 that mav exist.

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46320
Federal Register /  Vol. 49.  No. 227 / Friday. November 23, 1984  /  Notices
  To provide guidance as to the
categorization of the weight of evidence,
a classification scheme is presented to
illustrate, in a simplified sense, the
strength of the information bearing on
the potential for human germ-cell
mutagenicity (Table 1). It is not possible
to illustrate all potential combinations of
evidence, and considerable judgment
must be exercised in reaching
conclusions. The factors illustrated in
Table 1 and discussed previously in
sections 1,  2, and 3 must all be
considered in making an assessment of
mutagenicity. In addition, certain
responses in tests that do not measure
well-defined mutagenic end points (e.g..
SCE induction in mammalian germ cells)
or germ-cell tests in higher eukaryotes
(e.g., Drosophila tests) may provide a
basis for raising the weight of evidence  .
from one category to another:
  Sufficient evidence for potential
human germ-cell mutagenicity would
include cases in which positive
responses are demonstrated in a
mammalian germ-cell test. Also,  in
general, sufficient evidence exists when
there is confirmed mutagenic activity in
 nher test systems (positive responses in
it least two different test systems, at
•oast one of which is in mammalian
•,eiis), and  there is sufficient evidence
tor germ-cell interaction as defined
nbove.
  Suggestive evidence encompasses a
weight-of-evidence category between
sufficient and limited that includes
cases in which there is some evidence
for mutagenic activity and for
interaction with germ cells.
  Limited evidence for potential human
germ-cell mutagenicity exists when
evidence is available only for
mutagenicity tests (other than
mammalian germ cells) or only for
chemical interactions rathe gonad.

Table 1.—Classification of Weight of
Evidence for Potential Human Germ-Call
Mutagenicity •

  1. Sufficient evidence exists when positive .
responses are demonstrated in:
  a. at least one in vivo mammalian  germ-cell
mutation test, or
  b. al least two point mutation tests (at least
one in mammalian cells) plus sufficient
evidence that the chemical interacts with
mammalian germ cells, or
  c. least two structural chromosome
  • Takes into consideration the extent
quality, and consistency of responses bearing
on an agent's ability to product mutagenic
events and to interact with the mammalian
gonadal target Nonmutagenic test responses
(e.g.. SCE in germ ceila) may help to etevate
evidence of mutagenicity from one category
to Another.
                       2. Suggestive evidence exists in those cases
                      in which there are positive data for both
                      mutagenic activity and evidence for chemical
                      interactions in the gonad, but the evidence is
                      less than sufficient. This category is
                      potentially large and heterogeneous in nature
                      and ranges from almost sufficient to
                      essentially limited.
                       3. Limited evidence denotes a situation in
                      which the evidence is limited to information
                      on mutagenic activity or to evidence of
                      chemical reactivity in the target
                      aberration tests (at least one in mammalian
                      cells) plus sufficient evidence that the
                      chemical interacts with mammalian germ
                      cells, or
                       d. one gene mutation assay in mammalian
                      ceils and one structural chromosome
                      aberration test in mammalian cells and
                      sufficient evidence for chemical interaction
                      with mammalian germ cells.

                      Designation of evidence as limited does
                      not preclude the use of such information
                      to set priorities for further testing or to
                      support a case for potential
                      carcinogenicity.
                       Although definitive proof of
                      nonmutagenicity is not possible, it
                      seems appropriate that a chemical could
                      be  classified operationally as not a
                      human germ-cell mutagen, if it gives
                      negative responses in those test systems
                      that together fulfill  the criteria (i.e., all
                      relevant end points) for sufficient
                      evidence1 of a potential human germ-cell
                      mutagen, providing that all assays have
                      been properly performed. Test systems
                      used to define a negative should be
                      capable of detecting weak responses
                      (adequate statistical power) and should
                      be  appropriate for the chemical or class
                      of chemicals under investigation.
                       Negative evidence  of chemical
                      interaction in the gonad hi the presence
                      of evidence of mutagenic activity may
                      still signal some concern in regard to
                      somatic effects(JO). Other combinations
                      of relevant information will most likely
                      require case-by-case evaluation. It may
                      also be possible to  operationally define
                      a chemical as not being a human germ-
                      cell mutagen based on negative results
                      from other assays which provide
                      information about mutagenicrty and/or
                      interaction with germ-cell chromatm.
                      C.  Quantitative Assessment
                        The preceding section addressed
                      primarily the processes of hazard
                      identification, i.e., the determination of
                      whether a substance is a potential germ-
                      cell mutaaen. Often, no further data will
                      be available, and judgments will need to
                      be based on mainly qualitative criteria.
                      For quantitative risk assessment further
                      information is required, namely,
                      determination of the  heritable effect per
                      unit of exposure (dose-response) and the
                      relationship between mutation rate and
                      disease incidence.  Dose-response
information is combined with
anticipated levels and patterns of
human exposure in order to derive a
quantitative assessment (risk
characterization).

I. Dose-Response

  Two approaches to obtaining dose-
response data are available. One
approach requires experimental uai« on
germinal mutations induced in intact
mammals. Several test systems may
provide such information, e.g., the
mouse heritable translocation, dominant
skeletal, dominant cataract, and
specific-locus tests. Although the
dominant skeletal and cataract assays
have the advantage of measuring
dominant mutations,  the heritability of
observed effects has  not been clearly
demonstrated. The experimental data on
induced mutation frequency are usually
obtained at exposure levels much higher
than those that will be experienced by
human beings. An assessment of human
risk is obtained by extrapolating the
induced mutation frequency or the
observed phenotypic effect downward
to the approximate level of anticipated
human exposure.
  The Agency will strive to use the most
appropriate extrapolation models for
risk analysis and will be  guided by the
available data and mechanistic
considerations in this selection.
However, it is anticipated that for tests
involving germ cells  of whole mammals.
few dose points will  be available to
define dose-response functions. In these
situations certain theoretical
considerations will apply(20). For point
mutations,  linear extrapolations with no
threshold may be used as a conservative
approximation, provided the results
allow one to rule out major germ-cell
selection. For structural chromosome
rearrangements such as heritable
translocations, linear extrapolation  of
the experimental data is  thought to
overestimate the risks at low levels  of
exposure and use of  a multiple-hit model
is more appropriate.
   The second experimental approach for
quantitative assessment of genetic risk
uses molecular dosimetry data from
intact mammals in conjunction with
mutagenicity and dosimetry data from
other validated test systems(^). The
intact mammal is used primarily for
relating the exposure level  for a giver.
route 01 administration of a chemical to
germ-ceil dose, i.e.. the level of mutagen-
DNA interactions. This information is
then used in conjunction with results
obtained from mutagenicity test systems
in which the relationship between the
induction of mutations and chemical
interactions with DNA can be derived.

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                     Federal  Register  /  Vol. 49. No. 227 / Friday,  November 23. 1984 / Notices             46321
 Using mutagen-DNA interactions as the
 common denominator, a relationship
  San be constructed between mammalian
  xposure and the induced mutation
 frequency. The amount of DNA binding
 induced by a particular chemical agent
 may often  be determined at levels of
 anticipated human exposure. This
 approach is still experimental and its
 application involves many unknowns,
 such as possible differences between
 mammalian'germ cells and cells of the
 reference system with regard to types of
 genetic damage induced and magnitude
 of repair.
   For some mutagenic events, DNA may
 not necessarily be the critical target.
 interaction of chemicals with other
 macromolecules, such as tubulin, which
 is involved in the separation of
 chromosomes during nuclear division.
 can lead to chromosomal'
 nondisjunction. At present, general
 approaches are not available for dose-
 response assessments for these types of
 mutations. Ongoing research should
 provide the means to make future
 assessments on chemicals causing
 aneuploidy.

 1. Exposure Assessment
   Tlie exposure assessment identifies
 populations exposed to toxic chemicals,
Describes their composition and size,
'and presents the types, magnitudes,
 frequencies, and durations of exposure
 to the chemicals. This component is
 developed  independently of the other
 components of the mutagenicity
 assessment(d).

 3. Risk Characterization
   In performing mutagenicity risk
 assessments, it is important to consider
 each genetic end point individually. For
 example, although certain chemical
 substances that interact with DNA may
 cause both point and chromosomal
 mutations, it is expected that the ratio of
 these events may differ for individual
 chemicals and between doses for a
 given chemical. Furthermore,
 transmissible  chromosomal aberrations
 appear to be inducible with higher
 frequencies in meiotic and postmeiotic
 germ-cell stages, which have a brief life
 span, than  in spermatogonial stem ceils,
 which can  accumulate genetic damage
 throughout the reproductive life of an
 individual. For these reasons, when data
are available; the Agency, to the best
extent possible, will assess risks
associated with all genetic end points.
  Any risk assessment should clearly
delineate the strengths and weaknesses
of the data, the assumptions.made, the
uncertainties in the methodology, and
the rationale used in reaching the
conclusions, e.g., similar or different
routes of exposure  and metabolic
differences between humans and test
animals. When possible, quantitative
risk assessments should be expressed in
terms of the estimated increase of
genetic disease per generation or per
lifetime, or the fractional increase in the
assumed background spontaneous
mutation rate of humans(5). Examples of
quantitative risk estimates have been
published (6, 22); these examples  may be
of use  in performing quantitative risk
assessments for mutagens.
IV. References
  (1) U.S. Environmental Protection Agency.
1980. Mutagenicity risk assessment: proposed
guidelines. Federal Register 45 (221): 74984-
74988.
  (2) Committee on Chemical Environmental
Mutagens. 1982. Identifying and estimating
the genetic impact of chemical environmental
mutagens. Washington. DC: National
Academy Press.
  (3) Committee 1 Final Report. 1983.
Screening strategy for chemicals that are
potential germ-cell mutagens in mammals.
Mutat. Res. 114:117-177.
  [4] A complete reference of ail Gene-Tox
publications is available-from the TSCA
Industry Assistance Office (TS-794), Office of
Toxic Substances, U.S. Environmental
Protection Agency, Washington, DC 20460.
  (5) Committee on the Biological Effects of
Ionizing Radiation. 1980. The effects on
populations of exposure to low levels of
ionizing radiation. National Academy of
Sciences. Washington, DC: National
Academy Press.
  (6) United Nations Scientific Committee on
the Effects of Atomic Radiation. 1977.
Sources and effects of ionizing radiation.
Report of the General Assembly, 32nd
Session. Supplement No. 40(A/32/40), United
Nations, New York.
  (71 Ehling. U.H., D. Averback, P.A. Cerutti,
J. Friedman, H. Greim. A.C. Kolbye, and M.L.
Mendelsohn. 1983. Review of the evidence for
the presence or absence of thresholds in the
induction of genetic  effects by genotoxic
chemicals. Mutat. Res. 123:281-341.
  (8) Committee on the Institutional Means
for the Assessment of Risks to Public  Health.
1983. Risk assessment in the Federal
government: managing the process.
Commission on Life  Sciences, National
Research Council. Washington. DC: Nalionu.l
Academy. Press.
  (9} U.S. Environmental Protection Agency.
1984. Proposed guidelines for exposure
assessment. Office of Health and
Environmental Assessment.
  (10] U.S. Environmental Protection Agency.
1984. Proposed guidelines for carcinogen risk
assessment. Office of Health and
Environmental Assessment.
  (11} Flamm, W.G. 1977. DHEW Report on
approaches to determining the mutagenic
properties of chemicals: risk to future
generations. ]. Environ. Pathol. Toxicol.
1:301-352.
  (12) McKusick, V.A. 1973. Mendelian
inheritance in man: catalogs of autosomal
dominant, autosomal recessive and x-linked
phenotypes. Baltimore, MD: Johns Hopkins
University Press.
  (73) Crow, J.F., and C. Denniston. 1981. The
mutation component of genetic damage.
Science 212:888-893.
  (14) Musilova, ]., K. Michalova, and J.
Urban. 1979. Sister chromatic! exchanges and
chromosomal breakage in patient treated
with cytostatics. Mutat. Res. 67:289-294.
  (15) Strauss, G.H.. and R.J. Albertini. 1970.
Enumeration of 8-thioguanine-resistant
peripheral blood lymphocytes in man as it
potential test for somatic cell mutations
arising in vivo. Mutat. Res. 61:353-379.
  (16] U.S. Environmental Protection Agency.
1983. Health effects test guidelines. Office of
Toxic Substances. EPA 560/6/82-001.
Available from: NTIS. Springfield, VA.
          Enuirnnmpntal Protection Agency.
November 24; 1982. Pesticides registration;
'proposed data requirements. Federal Register
47: 53192-53203.
   (18) Parker, D.R., and J.H. Williamson. 1974.
Some radiation effects on segregation in
Drosophila. Genetics 78:163-171.
   (19] Russell, L.B., C.S. Aaron, F. de Serres.
W.M. Generoso, K.L. Kannan, M. Shelby, J.
Springer, and P. Voytek. Evaluation of
existing mutagenicity bioassays for purposes
of genetic risk assessment. Mutat. Res. in
press.
   (20) Ehrenberg L, E. Moustacchi, and S.
Osterman-Golkar. 1983. Dosimetry of
genotoxic agents and dose-response
relationships of their effects. Mutat. Res.
123:121-179.
   (21) Lee. W.R. 1979. Dosimetry cf chemical
mutagens in eukaryote germcells. In: A.
Hollaender and F.J. de Serres, eds. Chemical
mutagens: principles and methods for their
detection. Vol. 5. New York: Plenum Press.
pp. 177-202.
   (22} Ehling. U.H., and A. Neuhauser. 1979.
Procarbazine-induced specific-locus
mutations in male mice. Mutat. Res. 59:245-
256.
(FR Doc. 84-30722 Filed 11-21-84: 8:45 am|
3ILUNG CODE 6560- SO-M

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                                          £ife Systems, Jnc.
PART 4 -  HEALTH ASSESSMENT OF SUSPECT
         DEVELOPMENTAL TOXICANTS
               A3-5

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Friday
November 23, 1984
Part X

               •

Environmental

Protection  Agency
        /                  ~
Proposed Guidelines for the Health
Assessment of Suspect Developmental
Toxicants and Request for Comments

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46324
Federal  Register / Vol. 49. No. 227 / Friday. November 23. 1984  / Notices
ENVIRONMENTAL PROTECTION
AGENCY

IFRU-2706-7]

Proposed Guidelines for the Healfi
Assessment of Suspect
Developmental Toxicants

AGENCY: Environmental Protection
Agency (EPA).
ACTION: Proposed Guidelines for the
Health Assessment of Suspect
Developmental Toxicants and Request
for Comments.

SUMMARY: The U.S. Environmental
Protection Agency is proposing
Guidelines for the Health Assessment of
Suspect Developmental Toxicants
(Guidelines). These Guidelines are
proposed for use within the policy and
procedural framework provided by the
various statutes that EPA administers to
guide Agency analysis of developmental
toxicity data. We solicit public comment
and will take public comment into
account in revising these Guidelines.
The Guidelines will  be reviewed by the
Science Advisory Board in meetings
now tentatively scheduled for April
1985.
  These proposed Guidelines we're
developed as part of a broad guidelines
development program under the
auspices of the Office of Health and
Environmental Assessment (OHEA),
located inthe Agency's Office of
Research and Development. Consonant
with the role of OHEA's Reproductive
Effects Assessment  Group (REAG) as
the Agency's senior health committee
for developmental toxicity assessment,
the Guidelines were developed by an
Agency-wide working group chaired  by
the.REAG.
DATE: Comments must be postmarked
by January 22,1985.
ADDRESSES: Comments may be mailed
or delivered to: Dr. Carole A. Kimmel,
Reproductive Effects Assessment Group
(RD-689), Office of Health and
Environmental Assessment, U.S.
Environmental Protection Agency, 401 M
Street, SW.. Washington. DC 20460.
FOR FURTHER INFORMATION CONTACT:
Dr. Carole A. Kimmel, telephone: 202-
382-7331.
SUPPLEMENTARY INFORMATION: A
preliminary draft of the Guidelines was
sent for review to approximately 20
scientists in the field of developmental
toxicology within government,
universities in the United States, and the
private sector. Comments received from
these reviewers, generally favorable,
were taken into account in developing
the Guidelines proposed here.
                       References and supporting documents
                     used in the preparation of these
                     Guidelines as well as comments
                     received are available for inspection
                     and copying at the Public Information
                     Reference Unit (202-382-5926), EPA
                     Headquarters Library, 401 M Street,
                     SW., Washington, DC. between the
                     hours of 8:00 a.m. and 4:30 p.m.
                       Dated: November 9.1984.
                     William D. Ruckelshaus,
                     Administrator.
                     Contents
                     L Introduction
                     II.. Definitions and Terminology
                     III. Qualitative Assessment (Hazard
                        Identification of Developmental
                        Toxicants)
                       A. Conventional Developmental
                        Toxicology Protocols: End Points and
                        Their Interpretation
                        1. End Points of Maternal Toxicity
                        2. End Points of Developmental Toxicity
                        3. Overall Evaluation of Maternal and
                        Developmental Toxicity
                       B. Functional Teratology
                       C. Short-Term Testing in Developmental
                        Toxicity
                        1. In Vivo Mammalian Teratology Screen
                        2. In Vitro- Teratology Screens
                        3. Application
                       D. Pharmacokinetica
                       E. Human Studies
                       F. Comparisons of Molecular Structure
                       G. Weight-of-Evidence Determination
                     IV. Quantitative Assessment
                       A. Dose-Response Assessment
                       B. Exposure Assessment
                       C. Risk Characterization
                     V. References

                     I. Introduction
                       These. Guidelines describe the
                     procedures that the U.S. Environmental
                     Protection Agency will follow in
                     evaluating potential developmental
                     toxicity associated with human
                     exposure to environmental toxicants. In
                     the past, the Agency has sponsored
                     conferences and issued publications
                     which addressed issues related to such
                     evaluations^, 2, 3). These publications
                     provided some of the scientific basis for
                     these risk assessment Guidelines, and
                     testing guidelines have provided
                     protocols designed to determine the
                     potential of a test substance to induce
                     structural and/or other abnormalities in
                     the developing conceptus. The Agency's
                     authority to regulate substances that
                     have the potential to interfere adversely
                     with human development is derived
                     from a number of statutes which are
                     implemented through multiple offices
                     within the Agency. Because many'
                     different offices evaluate developmental
                     toxicity, there is a need for intra-agency
                     consistency in the approach to assess
                     these types of effects.  The procedures
                     described here will promote consistency
in the Agency's assessment of
developmental toxic effects.
  Approximately 50% of human
conceptuses fail to reach term(3, 4);
approximately 3% of newborn children
are found to have one or more
significant congenital malformations at
birth, and, by the end of the first
postnatal year, about 3% more are found
to have serious developmental defects
(5, 8). It is estimated that 20% of human
congenital malformations are caused by
mutations, 10% are attributable to
known environmental factors, and the
remainder result from unknown causes
(7).
  Numerous agents have been shown  to
be developmental toxicants in animal
test systems(fl). Several of them have
also been shown to be the cause of
adverse developmental effects in
humans, including alcohol, aminopterin.
busulfan, chlorobiphenyls,
diethylstilbestrol, isotretinoin, organic
mercury, thalidomide, and valproic acid
(9,10,11,12). Exposure to agents
affecting development generally results
in multiple manifestations
(malformation, functional impairment,
altered growth, and/or lethality).
Therefore, assessment efforts should
encompass a wide array of adverse
developmental end points such as
spontaneous abortions, stillbirths,
malformations, and other adverse
functional physical changes that occur
postnatally.
  The developmental toxicity
assessments prepared pursuant to these
Guidelines will be utilized within  the
requirements and constraints of the
applicable statutes to arrive at
regulatory decisions concerning
developmental toxicity. These
Guidelines provide a general format for
analyzing and organizing the available
data for conducting risk assessments.
The Guidelines do not change any
statutory or regulatory prescribed
standards for the type of data necessary
for regulatory action. Moreover, risk
assessment is just one component of the
regulatory process and defines the
adverse health consequences of
exposure to a .toxic agent. The other
component,  risk management, combines
risk assessment with the directives  of
the enabling regulatory legislation
together with socio-economic, technical,
political, and other considerations to
reach a decision as to whether or how
much to control future exposure to the
suspected toxic agent. The issue of risk
management will not be addressed  in
these Guidelines.
  The National Research Council(.73)
has defined risk assessment as being
comprised of some or all of the following

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                   Federal Register  /  Vol 49, No. 227 /  Friday.  November 23.  1984 / Notices
                                                                      46325
 components: hazard identification, dose-
 uuonse assessment, exposure
 ^•ssment and risk characterization. In
 general, the process of assessing the risk
'of human developmental toxicity may
 be adapted to this format However, due
 to. special considerations in assessing
 developmental toxicity, which will be
-discussed later in these Guidelines, it is
 not always appropriate to follow the
 exact standards  as defined for each
 component.
   Hazard identification is the
 qualitative risk assessment in which all
 available experimental animal and
 human data are used to determine if an
 agent is likely to cause developmental
 toxicity. In considering developmental
 toxicity, these Guidelines will address
 not only malformations, but also fetal
 wastage, growth alteration, and
 functional abnormalities that may result
 from developmental exposure to
 environmental agents.
   The dose-response assessment
 defines the relationship of the dose of an
 agent and the occurrence of
 developmental toxic effects. According
 to the National Research Council(J3),
 this component would usually include
 the results  of an  extrapolation from high
 doses administered to experimental
  jimals or noted in epidemiologic
       _to_thfi-law_fixposute. levels
  tpected for human contact with.the
 agent in the environment However,
 since at present there is no
 mathematical extrapolation model that
 is generally accepted for developmental
 toxicity, the Agency, for the most part,
 continues to use safety factors and
 margins of safety, which will be
 discussed in these Guidelines.
   The exposure assessment identifies
 populations exposed to the agents,
 describes their composition and size,
 and presents the types, magnitudes,  .
 frequencies, and durations of exposure
 to the agent
   In risk characterization, the exposure
 assessment and the dose-response
 assessment are combined to estimate
 some measure of the risk of
 developmental toxicity. As part of risk
 characterization, a summary of the
 strengths and weaknesses in each
 component of the assessment are
 presented along with major
 assumptions, scientific judgments, and.
 to the extent possible, estimates of the
 uncertainties.

 II. Definitions and Terminology
   The Agency recognizes that there are
 ^fferences in the use of terms in the
 feld of developmental toxicology. For
 the purposes of these Guidelines the
 following definitions and terminology
 will be iisnd.
  Developmental Toxicology—The field
dealing with the induction of adverse
effects on the developing organism
occurring up to the time of puberty. The
manifestations of developmental
toxicity include: (1) Death of the
developing organism, (2) structural
abnormality (teratogenicity), (3) altered
growth, and (4) functional deficiency.
  Embryotoxicity and Fetotoxicity— _
Any toxic effect on the conceptus as a
result of prenatal exposure; the
distinguishing feature between the terms
is the period during which the insult
occurred. The terms, as used here,
include malformation, altered  growth,
and in utero death.
  Altered Growth—A significant
alteration in fetal or neonatal  organ or
body weight Body weight may or may
not be accompanied by a change in
crown-rump length and/or hi skeletal
ossification. Altered growth can be
induced at any stage of development
may be reversible,  or may result in a
permanent change.
  Functional Teratology—The field
dealing with the causes, mechanisms,
and manifestations of alterations  or
delays in functional competence of the
organism or organ system following
exposure to an agent during critical
periods of development either pre- or
.postnatally.
  Malformations and Variations—A
malfunction is usually defined as  a
permanent structural deviation which
generally is incompatible  with or
severely  detrimental to normal postnatal
survival or development A variation is
usually defined as  a divergence beyond
the usual range of structural constitution
but which may not have as severe an
effect on survival or health as a
malformation. Distinguishing between
variations and malformations is difficult
since there exists a continuum of
responses from the normal to  the
extreme deviant. There is no generally
accepted classification of malformations
and variations. Other terminology that is
often used but no better defined.
includes  anomalies, deformations, and
aberrations.
III. Qualitative Assessment (Hazard
Identification of Developmental
Toxicants)
  Developmental toxicity studies
provide a number of end points that are
useful for evaluating the potential of an
agent to produce adverse outcomes of
pregnancy. The four types of effects on
the conceptus that may be produced by
in utero exposure to toxicants include
death, structural abnormality, altered
growth, and functional deficits. Of these,
the first three effects are measured in
the conventional developmental toxicity
(teratogenicity) protocol (discussed
below), while functional deficits are
seldom evaluated in routine
assessments of environmental agents.
This section will discuss the format and
analysis of conventional studies as well
as the use of data from other types of
studies, including functional studies.
short-term tests, and pharmacokinetic.i.

A. Conventional Developmental
Toxicology Protocols: End Points and
Their Interpretation

  The most commonly used protocol  for
assessing developmental toxicity
involves  the administration of a test
substance to pregnant animals (usually
mice, rats, or rabbits) during the period
of major  organogenesis, evaluation of
maternal responses throughout
pregnancy, and examination of the dam
and the uterine contents just prior to
term(£ 3,14,15). Other protocols may
use exposure periods of one to a few
days to investigate periods of particular
sensitivity for induction of anomalies in
specific organs or organ systems(76).
Fetuses alive at maternal  sacrifice are
thoroughly evaluated for alterations in
morphological development Because
the relationship of maternal and fetal
toxicity is important in assessing the
developmental toxicity of an agent,
dose-response data are important.
Ideally, study designs should include a
high dose, which produces some
maternal toxicity (i.e., a level that
produces marginal but significantly
reduced body weight or weight gain
during pregnancy up to a level that
produces no more than 10% maternal
mortality), a low dose, which
demonstrates a no observed effect level
(NOEL) for maternal and/or fetal
effects, and  at least one intermediate
dose level. Test animals should be
selected  based on considerations of
species, strain, age, weight and health
status, and should be randomized to
dose groups in order to reduce bias and
provide a basis for performing valid
statistical tests. Replication of the study
is desirable  and strengthens the
confidence of data interpretation.
   The next two sections discuss
individual end points of maternal and
developmental toxicity, respectively, as
measured in the conventional
developmental toxicity study. The third
section deals with  the integrated
evaluation of all data including the
relative effects of exposure on maternal
animals  and their offspring.

1. End Points of Maternal Toxicity

   A number of end points that may be
observed as indicators of maternal
toxicity are  listed in Table 1. Maternal

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46326
Federal Register / Vol. 49, No. 227  /Friday. -November 23. 1984 / Notices
mortality is an obvious end point of
maternal toxicity; however, a number of
other end points can be observed which
may give an indication of the subtle
effects of the agent For example, in
well-conducted studies the end point,
percent pregnant, indicates the general
fertility rate- of the animal stock used
and is an important indicator of toxic
effects if treatment begins prior to
implantation.

Table 1.—-End Points of Maternal Toxicity
Mortality
Percent Pregnant (includes all litters with
  implants)
Body Weight
  Treatment days (at least first, middle, and
    last'treatment days) Sacrifice day
Body Weight Change
  Throughout Gestation
  During treatment (including increments of
    time within treatment period)
  Post-treatment to sacrifice
  Corrected maternal (body weight change
    throughout gestation minus gravid
    uterine weight or litter weight at
    sacrifice)
Organ Weights (in cases of suspected specific
  organ toxicity)
  Absolute
  Relative to body weight
Food and Water Consumption (where
  relevant)
Clinical Signs (on days of treatment and at
  sacrifice)                  _
  Daily welglit changes during treatment
  Types and incidence of clinical signs

  Body weight and the change in body
weight are viewed collectively as
indicators of maternal toxicity for most
species, although these end points may
not be as useful in rabbits, because
body weight changes in rabbits are not
goocMndicators of pregnancy status.
Body weight changes may provide  more
information than a daily body weight
measured during treatment or during
gestation. Changes in weight during
treatment could occur that would not be
reflected in the overall weight change
throughout gestation, because of
compensatory weight gain that may
occur following treatment but before
sacrifice. For this reason, changes in
weight during treatment can be
examined as another indicator of
maternal toxicity.
  Changes  in maternal body weight
corrected for gravid uterine weight at
sacrifice may indicate whether the effect
is primarily maternal or fetai. For
example, there may be a signficant
reduction in weight gain throughout
gestation and in gravid uterine weight,
but no change in corrected maternal
weight  gain which would indicate
primarily an intrauterine effect.
Conversely, a change in corrected
                      weight gain and no change in gravid
                      uterine weight suggests primarily
                      maternal toxicity and little or no
                      intrauterine effect. An alternate estimate
                      of maternal weight change during
                      gestation can be obtained by subtracting
                      the sum of the weights of the fetuses.
                      However, this weight does not include
                      the uterine tissue, placental tissue, or
                      the amniotic fluid.
                        Changes in other end points should
                      also be determined. For example,
                      changes in relative and absolute organ
                      weights may be signs of maternal effect
                      when an agent is suspected of causing
                      specific organ toxicity. Food and water
                      consumption data are useful, especially
                      if the agent is administered in the diet or
                      drinking water. The amount ingested
                      (total and relative to body weight) and
                      the dose of the agent (relative to body
                      weight) can then  be calculated, and
                      changes in food and water consumption
                      with treatment can be evaluated along
                      with changes in body weight and body
                      weight gain. Consumatory data are also
                      useful when an agent is suspected of
                      affecting appetite, water intake, or
                      excretory function. Clinical signs of
                      toxicity may also be used as indicators
                      of maternal toxicity. Daily body weight
                      changes during treatment along with
                      clinical observations may be useful in
                      describing the profile of maternal
                      toxicity.

                      2. End Points of Developmental Toxicity
                        Because the maternal animal and not
                      the conceptus is the individual  treated
                      during gestation,  statistical analysis of
                      the data should consider both the
                      individual fetus and the litter. Table 2
                      indicates the way in which fetal and
                      litter end points can be expressed.

                      Table 2.—End Points of Developmental
                      Toxicity

                      All litters
                      No. implantation sites/dam
                      No. corpora lutea (CL)/dam*
                      Percent Preimplantation. loss  •
                      No. and percent live fetuses/litter
                      No. and percent resbrptions/litter
                      No. and percent litters with resorptions
                      No. and percent late fetal deaths/litter
                      No. and percent nonlive (late fetal deaths +
                        resorptions) implants/litter
                      No. and percent litters with nonlife implants
                      No. and percent affected (nonlive +
                        malformedl implants/litter
                      No. and percent with affected implants
                      No. and percent litters with total resorptions
                      Litters with live fetuses
                      No. and percent litters with live fetuses
                      No. and percent  live fetuses/litter
                      No. males/litter
                      No. females/litter
No. ratio/litter
Mean (x) fetal body weight/litter
Mean (x) male body weight/litter
Mean (x) female body weight/litter
No. and percent externally malformed
  fetuses/litter
No. and percent viscerally malformed
  fetuses/litter
No. and percent skeletally malformed
  fqtuse.s/litter
No. and percent malformed fetuses/litter
No. and percent litters with malformed
  fetuses
No. and percent malformed males/litter
No. and percent malformed females/litter
No. and percent fetuses with variations/litter
No. and percent litters having fetuses with
  variations
Types and incidence of individual
  malformations
Types and incidence of individual variations
Individual fetuses and their malformations
  and variations (grouped according to litter
  and dose)
  • Only when treatment begins prior to
implantation. May be difficult in mice.
  When  treatment begins prior to
implantation, an increase in
preimplatation loss could indicate an  •
adverse effect either on the developing
blastocyst or on the process of
implantation itself. Further studies
would be necessary to determine the
cause and extent of this type of effect.
  The number of live  fetuses per litter,
based on all litters, includes any litters
that have no live implants. On the other
hand, total nonlive implants
(postimplantation loss), is a combination
of the end points, resorptions, and late
fetal deaths. An increased incidence per
litter for any of the end points indicating
postimplantation loss would be
considered a significant toxic effect to
the conceptus. The number of litters
showing an increased incidence for
these end points is less useful than
incidence per litter, because a litter is
counted  whether it has one or all
resorbed, dead, or nonlive implants.
  A statistically significant increase in
postimplantation loss following
exposure to an agent  is a severe form of
developmental toxicity, but there is
considerable interlitter variability in the
incidence of postimplantation loss(17). If
a statistically significant increase is
found after exposure  to an agent, the
data may be compared not only with
concurrent controls, but also with recent
historical control data. If a given study
control group exhibits an unusually high •
or low incidence of postimplantation
loss compared to historical  controls,
then scientific judgment would have to
be used  to determine the adequacy of
the studies for risk assessment purposes.
   The end point for affected implants
(i.e., the combination of nonlive and

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                   Federal  Register / Vol. 49, No. 227 / Friday. November 23. 1984 / Notices
                                                                      46327
 malformed conceptuses) given an
   'ication of the total intrauterine
   ponse to an agent and sometimes
 reflects a better dose-response
 relationship than each taken
 individually. This is especially true at
 ihe high end of the dose-response curve
 in cases where most implants die in
 uiero. In such cases, the malformation
 rate may appear to decrease because
 only unaffected fetuses have-survived to
 term. If the incidence of prenatal death
 or malformation is unchanged, then the
 incidence of affected implants will not
 provide any additional information.
  The number of live fetuses per litter.
 based on those litters that have one or
 more live fetuses, may be unchanged
 even though  the incidence of nonlive in
 all litters is increased. This could occur
 either by an increase in the number of
 litters with no live fetuses or by an
 increase in the number of implants per
 litter. A decrease in the number of live
 fetuses per litter should be accompanied
 by an increase in the incidence of
 nonlive implants per litter, unless the
 implant numbers differ among dose
 groups.
  The sex ratio per litter, as well as the
 body weights of males and females, can
 be examined to determine whether or
  |0t one sex is preferentially affected by
  e agent. However, this is an unusual
 occurrence.
- A change in fetal body weight is  a
 .sensitive indicator of developmental
 toxicity. in part because it is a
 continuous variable. In some cases, fetal
 weight reduction may be the only
 indicator of developmental toxicity: if
 so. there is always a question remaining
 as to whether weight reduction is a
 permanent or transitory effect. When
 fetal weight reduction is the only
 indicator of developmental toxicity, data
 from the two-generation reproduction
 studyfJ) may be useful for evaluating
 these parameters. Ideally, follow-up '
 studies to evaluate postnatal viability,
 an.'wth. and survi%ral through weaning
 should be conducted. There are other
 factors tlint should be considered in the
 uvalu.-ition of fetal weight  changes. For
 axainple. in polytocous animals, fetal
 weighl is usually  inversely correlated
 with litter size, and the upper end of the
 dose-response curve may be confounded
 by smaller litters and increased fetal
 '.-.eight. Additionally, ihe average body
 weight of male fetuses is greater than
 rhat of female fetuses in the more
 commonly used laboratory animals.
  Live fetuses should be examined for
 ••xternal, visceral, and skelatal
'malformations. If only a portion of the
 litter is examined, then it is preferable
 ih;it (hose to be examined be selected
 »n * random basis from each litter. The
incidence of individual types of
malformations and variations gives an
indication of the types of developmental
deviations produced by a particular
agent. A listing of individual
malformations and variations by fetus
gives an indication of the pattern of
developmental deviations. The
incidence of external, visceral, and
skeletal malformations gives an
indication of which systems may be
specifically affected A significant
increase in the incidence of particular
malformations or of the total number of
fetuses malformed per treated litter as
compared with controls indicates a
teratogenic effect. If variations are
significantly increased in a dose-related
manner, these should also be evaluated
as a possible indication of
developmental toxicity. The Interagency
Regulatory Liaison Group noted that
dose-related increases in spontaneously
occurring defects are as relevant as
dose-related increases in any other
developmental toxicity end points(W).
The number  and percentage of litters
with malformed fetuses are  more
reliable indicators of developmental.
toxicity than the number of litters with
resorptions, since malformations do not
occur frequently in controls. The data on
the incidence of individual types of
malformations and variations should be
examined for significant changes which
may be masked if the data on all
malformations and variations are
pooled. This information can also be
used for comparison with historical
control data. Appropriate historical
control data are helpful in interpretation
of major malformations,  especially those
that normally occur at a  low incidence
when seen in an individual study
apparently unrelated to dose.

3. Overall Evaluation of Maternal and
Developmental Toxicity
  As discussed previously, individual
end points are evaluated hi
developmental toxicity studies, but an  '
integrated evaluation must be done
considering all maternal and
developmental end points in order to
interpret the data fully. The overall
interpretation usually consists of the
evaluation of maternal toxicity and the
dose levels at which it occurs, then the
evaluation of developmental toxicity
and the levels ai which these end points
occur. In general, an agent that produces
changes in any of the four major classes
of developmental toxicity at a dose that
is  minimally toxic or not toxic to the
maternal animal is considered to have
selective developmental effects.
However, when effects are produced  at
maternally toxic doses by agents to
which adult  human exposure may occur
at toxic levels (e.g., smoking, alcohol,
solvents], these developmental effects
should no be ignored.
  Approaches for ranking agents for
their selective developmental toxicity
are being developed; Schardein(S) has
reviewed several of these. Of current
interest are approaches that develop
ratios relating an adult toxic dose tu a
developmental toxic dose(19, 20, 21).
Ratios near unity indicate that
developmental toxicity occurs only at
doses producing maternal toxicity; as
the ratio increases, there is a greater
likelihood of developmental effects
occurring without maternal
manifestations. Although further
exploration and validation are
necessary, such approaches may
ultimately help  in identifying those
agents that pose the greatest threat and
should be given priority for further
testing^).

B. Functional teratology

  Developmental effects, which are
inducible by exogenous agents, are not
limited to death, structural
abnormalities, and altered growth.
Rather, it has been demonstrated in a
number of instances that subtle
alterations  in the functional competence
of an organ or a variety of organ
systems may result from exposure
during critical developmental periods
that may occur between conception and
puberty. Often, these functional defects
are observed at dose levels  below those
at which gross malformations are
evident(23). Much of the early work in
this field was related to behavioral
evaluations, and the term "behavioral
teratology" became prominent in the
mid 1970s. Less work has been done on
other functional systems, but sufficient
data have accumulated to indicate that
the cardiopulmonary, immune,
endocrine, digestive, urinary, and
reproductive systems are subject to
alterations  hi functional competence.
Hence the term "functional  teratology"
has been applied to this general area.-
  The variety of systems and end points
that may be evaluated is too extensive
to discuss here(24).  (25). At  present no
standard testing procedures are
routinely used, and this has led  to
apparent discrepancies in the outcome
of certain studies. Some attempts to
standardize and evaluate procedures
are being made(26). The determination
of functional competence often involves
highly specialized training and
equipment  and is not generally practical
for routine  test procedures.  Therefore.
these approaches may have their
greatest application in determining the
nature of a suspected alteration in term

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Federal  Register / Vol. 49. No.  227 / Friday. November 23,  1984 / Notices
of its biological significance and dose-
response relationship.
  The means for appropriate
interpretation of data from functional
teratology studies is not always clear
due to the lack of knowledge about the
toxicological significance of specific
functional alterations. However, several
general concepts have arisen from the
research to date which may be useful in
designing studies and evaluating data.
 • 1. Several aspects of study design are
similar to those used in standard
developmental toxicity studies (e.g., a
dose-response approach with the
highest dose producing minimal overt
maternal or fetal toxicity, number of
litters large  enough for adequate
statistical power, randomization of
animals to dose groups, litter generally
considered the statistical unit, etc.).
  2. Replication of a study strengthens
the confidence of data interpretation.
  3. Use of a pharmacological challenge
may aid in evaluating function and
"unmasking" effects not otherwise
detectable, particularly in the case  of
organ systems that are endowed with a
reasonable degree of functional reserve
capacity.
  4.  Choice  oHunctional tests with a
moderate degree of background
variability may be more useful in
detecting effects of agent exposure than
tests based  on functional systems with
low variability that may be impossible
to disrupt without  being life-threatening.
Butcher et al.(27) have discussed this
with relation to behavioral end points.
/ 5. A battery of functional tests is often
necessary to evaluate fully the
functional competence of any given
system; these tests may need to be
conducted at several ages to account for •
maturational changes.
  6. Critical periods for.the disruption of
functional competence may include both
the prenatal period to the time of
puberty, and the effect is likely to vary
depending on the time of exposure.
  Although interpretation of functional
data may be difficult at present, there
are at least two days in which the data
from these studies may be useful for risk
assessment purposes. First, these
studies can be used to indicate whether
 or not an agent has the potential'to
cause functional alterations, and
whether these effects occur at doses
lower than  those that produce other
forms of toxicity. Second, if the agent in
question is  already in the environment,
 the functional data may be used for
 focusing on organ systems to evaluate in
 exposed human populations.
                     C. Short-Term Testing in Development'
                     Toxicity •       :     •
                       The need for developmental toxicity
                     screens has arisen from the large
                     number of agents in or entering the
                     environment and the increased interest
                     in reducing the number of animals used
                     in and the expense of testing. Currently,
                     two approaches are being considered for
                     their applicability in the overall testing
                     process: an in vivo mammalian screen
                     and a variety of in vitro systems.
                     Neither approach is seen at this time as
                     replacing current in vivo developmental
                     toxicity testing. Rather, they are being
                     considered for their usefulness in
                     assigning priorities for further, more
                     extensive testing..

                     1. In Vivo Mammalian Teratology
                     Screen
                       An in vivo approach developed by
                     Chemoff and Kavlock(2fl) uses the
                     pregnant mouse and it designed to
                     reduce the resources required for
                     precliminary indication of
                     developmental toxicity. This approach is
                     based on the hypothesis that a prenatal
                     insult, which results in altered
                     development, will be manifested
                     postnatally as reduced viability and/or
                     impaired growth. In general, the test
                     substance is administered over the
                     period of major organogenesis at a
                     single dose level that will elicit some
                     degree of maternal toxicity. After birth,
                     the pups are counted and weighed on
                     days 1 and 3. End points that are
                     considered in the evaluation include:
                     general maternal toxicity (including
                     survival and weight gain), litter size,
                     viability and  weight of the offspring, and
                     gross malformations. Basic priority
                     categories for further testing have also
                     been suggested:  (1) Agents that induce
                     perinatal death should receive highest
                     priority, (2) agents inducing perinatal
                     weight changes should be ranked lower -
                     in priority, and (3) agents inducing no
                     effect should receive the lowest
                     priority(2a). The major goal of this test is
                     to predict the potential for
                     developmental toxicity of an agent in
                     the species utilized. It does not increase
                     the ability to extrapolate risk to other
                     species, including humans. Additional
                     studies to evaluate the validity of this
                     approach as a screen for developmental
                     toxicity are currently being carried out.
                     and a system for giving a numerical
                     ranking to the results has been-
                     suggested to prioritize agents for further
                     testing(29, 30).

                     2. In Vitro Teratology Screens
                        Test systems that fall under the
                     general heading of "in vitro" include any
                      system that employs a test subject other
than the intact pregnant mammal. These
systems have long been used to assess
events associated with normal and
abnormal development, but only
recently have they been considered for
their potential as screens in testing (31.
32, 33). Many of these systems are now
being evaluated for their ability to
predict the developmental toxicity of
various agents. This validation process
requires certain considerations in study
design, including defined end points for
toxicity and an understanding of the
system's ability to handle various test
agents(32, 34). A list of agents for use in
these validation studies has been
developed(35).
3. Application
  When the validity of a screening
system is established, it may be used to
set priorities for further, more
comprehensive in vivo testing. In many
cases, a battery of two or more
screening systems may be needed,
employing tests with end points that
collectively represent several
embryologic processes. In addition,
many of these systems can be applied in
an attempt to answer specific questions
of a  dose-response, target-organ, or
mechanistic nature. In vitro approaches
may aid in establishing the effective
dose that reaches the target tissue.
Either the in vivo or in vitro short-term
approaches may be useful in addressing
structure-activity relationships and the
synergistic-antagonistic potential of
chemical interactions. Thus, pertinent
information can be derived from these
approaches and may be useful in the
assessment of potential risk.

D. Pharmacokinetics

  Extrapolation of data between species
can be aided considerably by the
availability of data on the
pharmacokinetics of a particular agent
in the species tested and, if possible, in
humans. Information on half-lives,
placental metabolism and transfer, and
concentrations of the parent compound
and metabolites in the maternal animal
and conceptus may be useful in
predicting risk for developmental
toxicity. Such data may also be helpful
in defining the dose-response curve,
developing a more accurate comparison
of species sensitivity including that of
humans (36. 37], determining dosimetry
at target sites, and comparing
pharmacokinetic profiles for various
dosing regimens or routes of exposure.
   Pharmacokinetic studies in
developmental toxicology are most
useful once a developmental toxic effect
has been produced in a give species
with a particular agent. Pharmacokinetic

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                   Federal  Register / Vol. 49. No. 227 / Friday. November  23, 1984 / Notices             46329
 data for risk assessment in
 developmental toxicology ideally should
 be derived from pregnant females at the
 stage when developmental insults occur.
 Often the only data available are from
 males, nonpregnant females, or from
 pregnant females at a time unrelated to
 the event of interest (e.g.,
 pharmacokinetic analyses done during
 the fetal period when malformations
 were induced early in organogenesis).
 The correlation of pharmacokinetic and
 developmental toxicity data may be
 useful in determining the contribution of
 specific pharmacokinetic parameters to
 the effects observed (38).

 E. Human Studies

   Because of the ethical considerations
 involved, little human testing has been
 or is likely to be done. Therefore, dose-
 effect developmental toxicity data from
 humans are generally not available.
 Human epidemiologic'studies may
 provide the best information for
 assessing human risk and would reduce
 the problems in species-to-species
 :':Xtrapolation.  However, interpretation
 of epidemiologic data must account for
 -omounding factors, such as maternal
 •.ae, parity, multiple exposures to
 -nvironmental agents, difficulty in .
 -staining accurate estimates of
 exposure levels in the environment,
 insufficient data on background
 incidence of certain developmental end
 points, etc. When human data are
 available, they can be used with other
 supporting animal data to assess human
 risk.

 F. Comparisons of Molecular Structure ~
   Comparisons of the chemical or
 physical properties of an agent with
 those of known developmental toxicants
 may provide some indication of a
 potential for developmental toxicity.
 Such information may be useful in
 priority-setting of Agents for testing or  -
 for further evaluation when only
 minimal data are available.

 C. Weight-of-Evidence Determination

  Information available from studies
 discussed previously, whether indicative
 of potential concern or not, must be
 evaluated and  factored into the
 assessment. The types of data may vary
 from chemical  to chemical, and certain
 types of data may be more relevant  than
 other  types of data in performing
 developmental toxicity assessments.
Therefore, all data pertinent to
 developmental toxicity-should be
 examined in the determination of a
chemical's.potential to cause
 developmental toxicity in humans.
 Whatever evidence may exist from
humans must also be factored into the
assessment.
IV. Quantitative Assessment
  Risk assessment involves the
description of the nature and often the
magnitude of potential human risk.
including a description of any attendant
uncertainty. In the final phase of the risk
assessment, the outputs of the
qualitative evaluation, the dose-
response, and the exposure data are
combined to give qualitative and/or
quantitative estimates of the
developmental toxicity risk. As part of
the risk assessment a summary of the
strengths and weaknesses of the hazard
identification, dose-response
assessment, exposure assessment, and
the risk characterization are presented.
Major assumptions, scientific judgments,
and, to the extent possible, estimates  of
the uncertainties in the assessment are
also presented.
A. Dose-Response Assessment
  Because human dose-effect data
usually are not available, other methods
have been used in developmental
toxicology for estimating exposure
levels that are unlikely to produce
adverse effects in humans. The dose-
response assessment-js-usually based^.
upon the evaluation of tests performed
in laboratory animals. Two approaches
frequently employed involve the use of
safety factors and margins of safety,
which in some respects are conceptually
similar. However, they are computed
differently and are often used in
different regulatory situations. The
choice  of approach is dependent upon
many factors, including the statute
involved, the situation being addressed,
the data base used, and the needs of the
decision-maker.
  The safety factor approach is intended
to derive a calculated exposure level
that is unlikely to cause any
developmental toxic responses in
humans. The size of the safety factor
will vary from agent to agent and will
require the exercise of scientific
judgment(d, 39), taking into account
interspecies  differences, the nature and
extent of human exposure, the slope of
the dose-response curve, and the  .
severity of the developmental effects
observed at exposure levels below
maternal toxicity in the  test species. The
safety factor selected is then divided
into the NOEL obtained from the most
appropriate and/or sensitive
mammalian species examined to obtain
an acceptable exposure level. Currently,
there is no one laboratory animal
species that can be considered most
appropriate for predicting risk to
 humans(S). Each agent should be
 considered on a case-by-case basis.
  The margin of safety approach derives
 a ratio of the NOEL from the most
.sensitive species to the estimated
 human exposure'level from all potential
 sources(40). The adequacy of the margin
 of safety is then considered, based upon
 the weight of evidence, including quality
 of data, number of species affected,
 dose-response relationships, and. other
 factors such as benefits of the agent.
  As discussed earlier, the preferred
 study design for a developmental
 toxicity study includes a minimum of
 three doses: a high dose that produces
 minimal maternal toxicity, at least one
 intermediate dose, and a low dose that
 demonstrates a NOEL. Nevertheless,
 there may be circumstances in that there
 is a need to perform a risk assessment
 based on the results of a study in which
 a NOEL could not be identified,  but.
 rather, in which the lowest dose
 administered caused some marginally
 significant effect(s). This lowest dose
 could be identified as the lowest
 observed effect level (LOEL). In
 circumstances where a LOEL can be
 identified, it may be appropriate to
 apply an additional safety factor. The
 magnitude of this additional factor is
 dependent upon scientific-judgment. In  .
 some instances, additional studies may
 be needed to strengthen the confidence
 in this additional safety factor.

 B. Exposure Assessment
  The results of the dose-response
 assessment are combined with an
 estimate of human exposure in order  to
 obtain a quantitative estimate of risk.
 The proposed Guidelines for Exposure
 assessment are being developed
 separately and will not be discussed in
 any detail here. In general, the exposure
 assessment describes the magnitude,
 duration, schedule, and route of
 exposure. This information is developed
 from monitoring data and from
 estimates based on modeling of
 environmental exposures. Unique
 considerations relevant to
 developmental toxicity are duration and
 period of exposure as related to  stage of
 gestation (i.e., critical periods), and the
 fact that a single exposure may be
 sufficient to produce adverse
 developmental effects (i.e., chronic
 exposure is not necessary for
 developmental toxicity to be
 manifested).
 C. Risk Characterization
  There  are numerous uncertainties
 associated with the toxicological and
 exposure components of risk assessment
 that in the past have often not been

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Federal Register / Vol 49. No. 227./ Friday, November 23. 1984 / Notices
readily apparent or consistently
presented. The presentation of any
qualitative or quantitative risk
assessment for developmental toxicity
should be accompanied by statements
concerning the quality of the data.
resolving power of the studies, number
of end points examined,  selection of
doses, replication of the  data, the
number of species examined,
pharmacokinetic considerations, and
any other factors that affect the quality
and precision of the assessment The
presentation of any numerical estimate
should be sufficiently qualified as to the .
assumptions used and the accuracy of
the estimates.
  In the assessment of developmental
toxicity,-statistical considerations
require special attention. For example,
the power of a  study  (i.e., the ability to
demonstrate an effect), is limited by the
sample size used in the study, the
background incidence of the end point
observed, and the variability in the
incidence of the end point As an
example, Nelson and Holson(47) have
shown that the number of litters needed
to detect a 5 or 10 percent change was
dramatically lower for fetal weight (a
continuous variable with low
variability) than for resorptions (a
binomial response with high variability).
With the current recommendation in
testing protocol being 20 rodents per
dose group(7. 3], it is  possible to detect
an increased incidence of malformations  •
in the range of 5 to 12 times above
control levels, an increase of 3 to 6 times
the in utero death rate, and a decrease
of 0.15 to 0.25 times the fetal weight
Thus, even within the same study, the
ability to detect a change in fetal weight
is much greater than  for the other end
points measured. Consequently, for
statistical reasons only,  changes in fetal
weight are often observable at doses
below those producing other signs of
developmental toxicity.
   At present, there is no mathematical
model that is generally used for
estimating developmental toxicity
responses below the  applied dose range.
This is due primarily to  the lack of
understanding of the biological
mechanisms underlying  developmental
toxicity, intra/interspecies differences in
the types of developmental events, the
influence of maternal effects on the
dose-responss curve, and whether or not
a threshold exists below which no effect
will be produced by  an agent. The
assumption of a threshold is based
largely on the biological rationale that
the embryo is known to  have some
capacity for reoair of the damage or
insult(42), and that most developmental
deviations are probably multifactorial in
                      narure(43). However, the existence of a
                      no effect level cannot be proven
                      statistically.
                        Discussions of risk extrapolation
                      procedures have noted that further work
                      is needed to improve mathematical tools
                      for developing estimates of potential
                      human developmental risk( J9, 44).
                      Gaylor(45) has suggested an approach
                      for controlling risk that combines the
                      use of mathematical models for low-
                      dose estimation of risk with the
                      application of a  safety factor based on a
                      preselected level of allowable risk. This
                      approach is similar to approaches
                      proposed for carcinogenesis, but does
                      not preclude  the possibility of a
                      threshold, and may provide a more
                      quantitative approach to controlling
                      risk. For the present the Agency will
                      continue to use safety factors and
                      margins of safety as described above,
                      where applicable. However, more
                      appropriate models will be sought and
                      applied if considered  acceptable.
                        These Guidelines summarize the
                      procedures that the U.S. Environmental
                      Protection Agency will follow in
                      evaluating the potential for agents to
                      cause developmental  toxicity. These
                      Guidelines will be reviewed and
                      updated as advances  are made in the
                      field, since it is evident that our ability
                      tO PvaliiafajapH  prpriirt
                      developmental toxicity is imprecise.
                      Further studies that delineate the
                      mechanisms of developmental toxicity  -
                      and pathogenesis, provide comparative
                      pharmacokinetic data, and elucidate the
                      . functional modalities that may be
                      altered by exposure to toxic agents will
                      aid in the interpretation of data and
                      interspecies extrapolation. These types
                      of studies, along with further evaluation
                      of the relationship between maternal
                      and fetal toxicity and the concept of a
                      threshold in developmental toxicity, will
                      provide for  the development of
                      improved mathematical models to more
                      precisely assess risk.
                      V. References
                        (1) U.S. Environmental Protection Agency.
                      1982. Health  effects test guidelines. Chapter
                      II. Specific organ/tissue toxicity-
                      teratogenicity. Office of Toxic Substances.
                      Available from: NT1S. Springfield VA. PB82-
                      232984.
                        [2] U.S. Environmental Protection Agency.
                      1980. Assessment of risks to human
                      reproduction and to development of the
                      human concepms from exposure to
                      environmental substances, pp. 99-116.
                      Available from: NTIS, Springfield. VA. DE82-
                      007897.
                        (3) U.S. Environmental Protection Agency.
                      1982. Pesticides registration: proposed data
                      requirements. Federal Register 47:53192-
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                        (4) Hertig,  A.T. 1967. The overall problem
                      in man. hr K. Benirschke, ed. Comparative
aspects of reproductive failure. New York,
NY: Springer-Verlag, pp. 11-41.
  (3) McKeown, T.. and R.C. Record. 1903.
Malformations in a population observed fur
five years after birth. In: G.E.W.
Wolstenholme and C.M. O'Conner, eds.. Ciba
Foundation symposium on congenital
malformations. Boston, MA: Little Brown, pp
2-18.
  (6) Mellin. G.W.. and M. Katzenstein. 1964.
Increased incidence of malformations-
change. J. Am. Med. Asaoc. 187:570-573.
  (7) Wilson, J.G. 1977. Erabryotoxicity of
drugs in man.  In: J.G. Wilson and F.C. Fraser.
eds. Handbook of teratology. New York. NY:
Plenum Press, pp. 309-355.
  (8) Shepard. T.H. 1980. Catalog of
teratogenic agents. Third Edition. Baltimore.
MD: Johns Hopkins University Press.
  (9) Schardein. J.L. 1983. Teratogenic risk
assessment In: H. Kalter, ed. Issues and
reviews in teratology.  Vol. 1. New York. NY:
Plenum Press, pp. 181-214.
  (10] Shepard. T.R 1984. Teratogens: an
update. Hosp. Pract, Jan., pp. 191-200.
  (11} Brown,  N.A., and S. Fabro. 1983. The
value of animal teratogenicity testing for
predicting human risk. Clin. Obstet. Gynecol.
26:487-477.
  (12) Kimmel, C.A., J.F. Holson. C.J. Hogue.
and GX. Carlo. 1984. Reliability of
experimental  studies for predicting  hazards
to human development. NCTR Technical
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Jefferson, Arkansas.
 • (13) Committee on the  Institutional Means
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1983. Risk assessment in the Federal
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Commission on Life Sciences, National
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  (14) Food and Drug  Administration. 1966.
Guidelines for reproduction and teratology of
drugs. Bureau of Drugs.
  (IS) Food and Drug  Administration. 1970.
Advisory Committee on Protocols for Safety
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on Reproduction Studies in the Safety
Evaluation of Food Additives and Pesticide
Residues. Toxicol. Appl. Pharmacol. 16:264-
296.
  (18) Symposium on  effects of radiation and
other deleterious agents  on embryonic
development 1954. J. Cell. Comp. Physiol. 43
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   (77) Woo. D.C., and  R.M. Hoar. 1979.
 Reproductive performance and spontaneous
 malformations in control Charles River rats.
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   (;a)1nteragency Regulatory Liaison Group
 1981. Report of the Developmental Toxicity
'End Points Workgroup. Workshop on
 Reproductive Toxicity Risk Assessment.
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   (19) Johnson, E.M. 1901. Screening for
 teratogenic hazards: nature of the problem.
 Annu. Rev. Pharmacol. Toxicol. 21:417-429.
   (20) Johnson. E.M., and B.E.G. Gabel. 1983.
 An artificial embryo for detection of
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 Toxicol. 3:243-249.
   (21) Fabro.  S.. G. Schull. and N.A. Brown.
 1982. The relative teratogenic index and
 teratogenic potency: proposed components of

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                      Federal Register /  Vol. 49.  No. 227 / Friday.  November 23. 1984  /  Notices
                                                                                46331
 developmental toxicity risk assessment.
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 teratology. In: J.G. Wilson and F.C. Fraser,
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 Development and standardization of
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   (25) Kavlock. R.J., and C.T. Grabowski, eds.
 1983. Abnormal functional development of
 the heart lungs, and kidneys: approaches to
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   (26) Kimmel. C.A.. J. Buelke-Sam. J. Adams.
 L.W. Reiter, T.J. Sobotka. and H.A. Tilson.
 1982. Design considerations in the evaluation
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 teratology study. Teratology  25:S4A.
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 Vorhees. 1980. Standards in behavorial
 teratology testing: test variability and
 sensitivity. Teratogenesis Carcinog. Mutagen.
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 An in vivo teratology screen utilizing
- pregnant mice.}. Toxicol. Environ. Health
 10:541-550.
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 vivo screen  for the determination of embryo/
 fetal toxicity in mice. SRI International. EPA
 contract no. 68-01-5079.
   (30) Schuler R.. B. Hardin. R. Niemeyer. G.
 Booth, K. Hazelden. V. Piccirillo, and K.
Smith. 1984. Results of testing fifteen glycol
ethers in a short-term, in vivo reproductive
toxicity assay. Environ. Health. Perspect. in
press.                       «
  (31) Wilson. J.G. 1978. Survey of in vitro
systems: their potential use in teratogenicity
screening. In: J.G. Wilson and F.C. Fraser,
eds. Handbook of teratology.  Vol. 4. New
York, NY: Plenum Press, pp. 135-153.
  (32) Kimmel. G.L., K. Smith. D.M. Kochhar.
and RM. Pratt. 1982. Overview of in vitro
teratogenicity testing: aspects of validation
and application to screening.  Teratogenesis
Carcinog. Mutagen. 2:221-229.
  (33) Brown. N.A., and S.E. Fabro. 1982. The
in vitro approach to teratogenicity testing. In:
K. Snell, ed. Developmental toxicology.
London. EnglanduCroom-Helm, pp. 31-57.
  (34) Kimmel, G.L. 1984. In vitro tests in
screening teratogens: considerations to aid
the validation process. In: M. Morris, ed.
Prevention of physical and mental congenital
defects. Part A. New York. NY: Alan R. Liss.
Inc., in press.
  (35) Smith, M.R., G.L. Kimmel. D.M.
Kochhar, T.H. Shepard. S.P. Spielberg, and
J.G. Wilson. 1983. A selection of candidate
compounds for in vitro teratogenesis test
validation. Teratogenesia Carcinog. Mutagen.
3:461-480.
  (36) Wilson. J.G., W.J. Scott E.J. Ritter, and
R. Fradkin. 1975. Comparative distribution
and embryotoxicity of hydroxyurea in
pregnant rats and rhesus monkeys.
Teratology 11:169-178.
  (37) Wilson. J.G., E.J. Ritter. W.J. Scott and
R. Fradkin. 1977. Comparative distribution
and embryotoxicity of acerylsalicylic acid in '
pregnant rats and rhesus monkeys. Toxicol.
Appl. Pharmacol. 41:67-78.
  (38) Kimmel. C.A.. and J.F. Young. 1983.
Correlating pharmacokinetics and teratogenic
end points. Fund. Appl. Toxicol. 3:250-255.
  (39) Hogan. M.D., and D.G. Hoel. 1982.
Extrapolation to man. In: A.W. Hayes, ed.
Principles and methods of toxicology. New
York. NY: Raven Press, pp. 711-731.
  (40) Chitlik, L.D.. Q.Q. Bui, G.J. Burin, and
S.C. Dapson. 1984. Standard evaluation
procedures for teratology studies (Draft).
Toxicology Branch. Hazard Evaluation
Division. Office  of Pesticide Programs. U.S.
Enironmental Protection Agency.
  (41) Nelson, C.J., and J.F. Holson. 1978.
Statistical analysis of teratogenic data:
problems and advancements.}. Environ.
Pathol. Toxicol.  2:187-199.
  (42) Wilson, J.G. 1973. Environment and
birth defects. New York, NY: Academic Press,
pp. 30-32.
  (43) Fraser. F.C. 1977. Relation of animal
studies to the problem in man. In: J.G. Wilson
and F.C. Fraser. eds. Handbook of teratology.
Vol. 1. New York, NY: Plenum Press, pp. 75-
96.
  (44) Environmental Health Criteria 30.1984.
Principles for evaluating health risks to
progeny associated with exposure to
chemicals during pregnancy, pp. 111-114.
World Health Organization, Geneva.
Switzerland.
   (45) Gaylor. D.W. 1983. The use of safety
factors for controlling risk.}. Toxicol.
Environ. Health 11:329-336.
[FR Doc. M-30721 Filed 11-21-34: 8:4! °m|  ^
BIUJNQ CODE M8O-SO-*

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                                         £tfe Systems, Jnc.
PART 5 - HEALTH RISK ASSESSMENT
        CHEMICAL MIXTURES
              A3-6

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Wednesday
January 9, 1985
Part III



Environmental

Protection  Agency

Proposed Guidelines for the Health Risk
Assessment of Chemical Mixtures and
Request for Comments; Notice

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1170
Federal Register / Vol. 50, No.  8 / Wednesday,  January 9, 1985  / Notices
ENVIRONMENTAL PROTECTION
AGENCY

[FRL-2742-8]

Proposed Guidelines for the Health
Risk Assessment of Chemical Mixtures

AGENCY: Environmental Protection
Agency (EPA.
ACTION: Proposed guidelines for the
Health Risk Assessment of Chemical
Mixtures and request for comments.

SUMMARY: The U.S. Environmental
Protection Agency is proposing
Guideline? for  the Health Risk
Assessment of Chemical Mixtures
(Guidelines). These Guidelines are
proposed for use within the policy and
procedural framework provided by the
various statutes that EPA administers to
guide Agency analysis of health effects
data. We solicit public comment and
will take public comment into account in
revising these Guidelines. These
Guidelines will be reviewed by the
Science Advisory Board in meetings
now tentatively scheduled for April
1985.
  These proposed Guidelines were
developed as part of a board guidelines
development program under the
auspices of the Office of Health and
Environmental Assessment (OHEA),
located in the Agency's Office of
Research and Development. Consonant
with the role of OHEA's Environmental
Criteria and Assessment Office in
Cincinnati (ECAO-Cin) as the Agency's
senior health committee for health risk
assessment of chemical mixtures, the
Guidelines were developed by an
Agency-wide working group chaired by
the Director of ECAO-Cin.
DATE: Comments must be postmarked
by March 11.1985.
ADDRESS: Comments may be mailed or
delivered to: Dr. Jerry Stara,
Environmental Criteria and Assessment
Office. U.S. Environmental Protection
Agency. 26 West St. Clair. Cincinnati,
OH 45268.
FOR FURTHER INFORMATION CONTACT:
Dr. Richard Hertzber. Telephone: 513-
684-7531.
SUPPLEMENTARY INFORMATION:
Preliminary drafts of these Guidelines
were sent for review to approximately
20 scientists in the fields of toxicology.
pharmacokinetics and statistics within
the Agency and a later draft was sent
for external review to 12 scientists
within government, academia and the
private sector. Comments received from
these reviewers, generally favorable.
were considered in developing the
Guidelines proposed here.
                       References and supporting documents
                     used in the preparation of these
                     guidelines as well as comments received
                     are available for inspection and copying
                     at the Public Information Reference Unit
                     (202-382-5926), EPA Headquarters
                     Library, 401 M Street, SW., Washington,
                     DC, between the hours of 8:00 a.m. and
                     4:30 p.m.
                       Dated January 2.1985.
                     William 0. Ruckelshaus,
                     Administrator.
                     Contents
                     I. Introduction
                     II. Proposed approach
                       A. Data Available on similar mixtures
                       B. Data Available only on Mixture
                        Components
                        1. Systemic Toxicants
                        2. Carcinogens
                        3. Interactions
                        4. Uncertainties
                          a. Health Effects
                          b. Exposure Uncertainties
                          c. Uncertainties Regarding
                        Composition of the Mixture

                     III. Assumptions and Limitations
                     IV. Mathematical Models and the
                        Measurement of Joint Action
                       A. Dose Addition
                       B. Response Addition
                     •  C Interactions
                     V. References

                     I. Introduction
                       The primary purpose of this document
                     is to generate a consistent Agency
                     approach for evaluating data on the
                     chronic  and  subchronic effects of
                     chemical mixtures. It is a procedural
                     guide which emphasizes broad
                     underlying principles of the various
                     science  disciplines (toxicology,
                     pharmacology, statistics) necessary for
                     assessing health risk from chemical
                     mixture exposure. Approaches to be
                     used with respect to the analysis and
                     evaluation of the various data are also
                     discussed.
                       It is not the intent of these Guidelines
                     to regulate any social or economic
                     aspects concerning risk of injury to
                     human health or the environment
                     caused by exposure to a chemical
                     agents(s).  All such action is addressed
                     in specific statutes and federal
                     legislation and is independent of these
                     Guidelines.
                       While some potential environmental
                     hazards involve significant exposure to
                     only a single compound, most instances
                     of environmental contamination involve
                     concurrent or sequential exposures to a
                     variety  of compounds that my induce
                     similar or dissimilar effects over
                     exposure periods ranging from short-
                     term to lifetime. In some instances, the
                     mixtures are highly complex consisting
                     of scores of compounds that are
 generated simultaneously as by-
 products from a single source or process
 (e.g., coke oven emissions and diesel
 exhaust). In other cases, complex
 mixtures of related compounds are
 produced as commercial products (e.g..
 PCBs, gasoline and pesticide
 formulations) and eventually released to
 the environment. Another class of
 mixtures consists of compounds, oftn-
 unrelated chemically or commercially,
 which are placed in the same area for
 disposal or storage, eventually come
 into contact with each other, and are
 released as a mixture to the
 environment. The quality and quantity
 of pertinent information available for
 risk assessment varies considerably for
 different mixtures. Occasionally, the
 chemical compositions of a mixture  is
 well characterized, levels of exposure to
 the population are known, and detailed
 toxicologic data on the mixture are
 available. Most frequently, not all
 components of the mixture are known,
 exposure data are uncertain, and
 toxicologic data on the known
> components of the mixture are limited.
 Nonetheless, the Agency may be
 required to take action because of the
 number of individual at potential risk or
 because of the known toxicologic effects
 of these compounds that have been
 identified in the mixture.
   Guidelines for single compound risk	
 assessments have been developed for
 subchronic and chronic exposures to
 both systemic toxicants and
 carcinogens. In the current document,
 these approaches are extended to
 provide compatible guidelines for
 assessing the  effects of multiple toxicant
 or multiple carcinogen exposures.
   The ability to predict how specific
 mixtures of toxicants will interact must
 be based on an understanding of the
 mechanisms of such interactions. Most
 reviews and texts  that discuss toxicant
 interactions make some attempt to
 discuss the biological or chemical bases
 of the interactions (e.g., Klaassen and
 Doull, 1980; Levine, 1973: Goldstein  et
 aL, 1974; NRC. 1980a; Veldstra. 1956;
 Withey, 1981). Although different
 authors use somewhat different
 classification  schemes for discussing the
 ways in which toxicants interact, it
 generally is recognized that  toxicant
 interactions may occur during any of the
 toxicologic processes that take place
 with a single compounds-absorption.
 distribution, metabolism, excretion, and
 activity at the receptor site(s). In
 addition, compounds may interact
 chemically, causing a change in the
 biological effect or they may interact by
 causing different effects  at different
 receptor sites.

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                   Federal Register  / VoL 50. No. 6 / Wednesday. January 9. 1985  /  Notices
                                                                         1171
  Because of the uncertainties inherent
in any approach to predicting the
magnitude and nature of toxicant
interactions, any assessment of health
risk from chemical mixture must  include
a thorough discussion of all
assumptions. No single approach is
recommended in these Guidelines.
Instead, guidance.is given for modifying
a few simple approaches involving risk
addition or dose addition.  The
mathematical details are presented in
Section IV.

III.  Proposed Approach

  No single approach can  be
recommended to risk assessments for
multiple chemical exposures.
Nonetheless, general guidelines can be
recommended depending on the type of
mixture, the known toxic effects of the
components in the mixture, the
availability of toxicity data on the
mixture or similar mixtures,  the known
or anticipated interactions among
components in the mixture, and the
quality of the exposure data. Given the
complexity of this issue  and the relative
paucity of empirical data from which
sound generalizations can be
constructed, emphasis must be placed
on flexibility, judgment, and a clear
articulation of the •assumption and
limitations in any risk assessment that is
developed. The proposed approach is
summarized in Table I and detailed
below.

A. Data Available on Similar Mixtures

  For predicting the effects of
subchronic or chronic exposure to •
mixtures,  the preferred approach. is to
use subchronic or chronic  health effects
data on the mixture of concern and '
adopt the  same procedures as those
used for single compounds, either
systemic toxicants or carcinogens. Such
data are most likely to be  available on
highly complex mixtures, such as coke
oven emission or diesel  exhaust, which
are generated in large quantities  and
associated with or suspected of having
adverse health effects. Even if such data
are available, attention should be given
to the persistence of the mixture  in the
environment as well as the variability of
composition of the mixture over time or
from different sources of emissions. If
the components in the mixture are
known to  partition into different
environmental compartments or to
degrade or transform at 'different rates
in the environment, then those factors
must also be taken into account,  or the
confidence in and applicability of the
risk assessment is diminished.
TABLE 1.— OUTLINE or THE RISK ASSESSMENT
    APPROACH FOR CHEMICAL MIXTURES
1. MeaMi eftecti MumiegUf> it
                           on *» cMmical
   a, * yes. proceed O Step 5.
   6. n no. uiULUUd 03 Stop 2
2. Aasec* Om (Moty of tie masum on wMtfi bee«i
 effects data ant svatebie to the nurture of concern. «*ti
 emphasis on any difference* in components, proportions
 d components, and environmental partitioning.
   I. » euMcientt* samtm. proceed Ml Step S.
   ta. II  not sufficiently writer or  If no  tucfi dsta exist,
    picceed e Stop 3.
a Oeme acpraprieM none* of *Li.eyfel
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1172
Federal  Register / Vol. 50. No. 6 / Wednesday, January 9.  1985 / Notices
assessments, the exposure levels may be
expressed in a variety of ways such as
Acceptable Daily Intakes (ADIs), levels
associated with various Margins Of
Safety (MOS), or Ambient Air
Standards. For the purpose of this
discussion, the term "Acceptable Level"
(AL) will be used to indicate any of the
criteria, standards, or advisories derived
by the Agency. For such estimates, the
"hazard index" (HI) of a mixture based
on the assumption of dose additivity
may be defined as:
HI = Ei/AL,+E2/AL,+...-f Ei/Al,    (II-l)
where:
£,= exposure level to the i"1 toxicant, and
AL,= maximum acceptable level for the itt
    toxicant
Since the inverse of the acceptable level
can be used as an estimate of toxic
potency, Equation U-I can be interpreted
as a normalized weighted-average dose,
with each component dose scaled by its
potency. As this index  approaches unity,
concern for  the potential hazard of the
mixture increases. If HI>1, the concern
for the potential hazard is the same as if
an acceptable level were exceeded for
an individual compound, i.e., if EjAL,
exceeded 1. If the variabilities of the
acceptable levels are known, or if the
acceptable levels are given as ranges
{e.g., associated with different margins
of safety^ then HI should be presented
with estimates of variation or as a
range.
  The hazard index is not a
mathematical prediction of incidence of
effects or severity. Statistical properties
of this index and its dependence on the
shape of the dose-response curves for
the components are not yet known.
Much additional research is required to
determine the accuracy of the hazard
index as a numerical prediction of toxic
severity. The hazard index is only a
numerical indicator of  the transition
between acceptable and unacceptable
exposure levels and should not be
overinterpreted.
  As discussed in Section IV, the
assumption of additivity is most
properly applied to compounds that
induce the same effect by the same
mechanism. Consequently, the
application of Equation II-l  to a mixture
of compounds that does not interact and
is not expected to induce the same types
of effects could overestimate hazard.
Thus, if the application of Equation II-l
results in an index near to or greater
than unity, it may be desirable to
segregate the compounds in the mixture
by critical effect and derive separate
indices for each effect. Conversely, if the
dissimilar effects  influence one another
(e.g., liver failure diminishing the
function of  another organ), then simple
                     dose addition could underestimate the..
                     total hazard; this is discussed more fully
                     in Section HI.
                       The Agency has developed methods
                     for estimating dose-response curves for
                     single chemicals, e.g. carcinogens (U.S.
                     EPA, 1984). In attempting to assess the
                     response to mixtures using dose-
                     response curves for the components of
                     the mixture, dose-additive or response-
                     additive assumptions can be used, with
                     preference given to the most biologically
                     plausible assumption.

                     2. Carcinogens
                      . For carcinogens, whenever linearity of
                     the dose-response curve can be assumed
                     (usually restricted to low doses], the
                     increase in incremental risk P, caused
                     by exposure d, is related to carcinogenic
                     potency B, as:
                     P = d B.    (II-2)
                     For multiple compounds, this equation
                     may be generalized to:
                     P = 2 d, B,.   (H-3)
                     This equation assumes independence of
                     action by  the several carcinogens and is
                     equivalent to the assumption of dose
                     addition- as well as to response addition
                     with completely negative correlation of
                     tolerance  (see Section FV). Analogous to
                     the procedure used in Equation II-l for
                     systemic toxicants, an index could be
                     developed by dividing exposure levels
                     (E) by doses (DR) associated with
                     varying levels of risk:
                     HI = E./DR, + E,/DR, + ... = E,/DR,
                     (II-l)
                     It should be emphasized that because of
                     the uncertainties in estimating dose
                     response relationships for single
                     compounds and the additional
                     uncertainties in combining the
                     individual estimate to assess response
                     from exposure to mixtures, response
                     rates and hazard indices may have merit
                     in comparing risks but should not be
                     regarded as measures of absolute risk.
                     3. Interactions
                       None of the above equations
                     incorporates any form of synergistic or
                     antagonistic interaction. Some types of
                     information, however, may be available
                     that suggest that two or more
                     components in  the mixture may interact.
                     Such information must be assessed in
                     terms of both its relevance to subchronic
                     or chronic hazard and its suitability for
                     quantitatively altering the risk
                     assessment.
                       For example, if chronic or subchronic
                     toxicity or carcinogenicity studies have
                     been conducted that permit a
                     quantitative estimation  of interaction for
                     two chemicals, then it may be desirable
                     to consider using equations detailed in
Section IV, or modifications of these
equations, to treat the two compounds
as a single toxicant with greater or
lesser potency than would be predicted
from additivity. Other compounds in the
mixture, on which no such interaction
data are available, could then be treated
in an additive manner. Before such a
procedure is adopted, however, a
discussion should be presented of the
likelihood that other compounds in the
mixture may interfere with the
interaction of the two toxicants on
which quantitative interaction data are
available. If the weight of evidence
suggests that interference is likely, then
an attempt to quantitatively alter the
risk assessment may not be justified. In
such cases, the discussion of the risk
assessment may only indicate the likely
nature of interactions, either synergistic
or antagonistic, but not attempt to
quantify the magnitude of this
interaction.
   Other types of available information.
such as those relating to mechanisms of
toxicant interaction, or quantitative
estimates of interaction between two
chemicals derived from acute studies,
are even less likely to be of quantitative
use in the assessment of long-term
health risks. Usually it will be
appropriate only  to discuss these types
of information. Indicate the relevance of
the information to subchronic or chronic
exposure, and, as above, indicate, if
possible, the nature of any pgtential
interaction, without attempting to
quantify the magnitude of the
interaction.

4. Uncertainties
   In addition to uncertainties on the
nature and magnitude of toxicant
interactions in the mixture, data may be
inadequate to assess exposure to human
populations or the potential health
effects of one or more components of the
mixture. In such a case, the less studied
chemicals must not be assumed to be
harmless. Instead the uncertainty is
increased. Confidence in the risk
assessment is reduced because the
contribution of these components to the
toxicity of the mixture and.
consequently, the toxicity of the mixture
itself are not known.
   a. Health Effects. In some cases, when
health effects data are incomplete, it
may be possible to argue by analogy or
quantitative structure-activity
relationships that the compounds on
which no health effects data are
available are not likely to significantly
affect the toxicity of the mixture. If a
risk assessment is conducted based on
such an argument, the limitations of the
• approach must be clearly articulated.

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                    Federal Register  /  Vol. 50,  No. 8  /  Wednesday, January. 9, 1985 / Notices
                                                                       1173
 Since a methodology has not been
 adopted for estimating an acceptable
 level (e.g., ADI) or carcinogenic potency
 for single compounds based either on
 quantitative structure-activity
 relationships or on the results of short-
 term screening tests, such methods are
 not presently recommended as the sole
 basis of a risk assessment on chemical
 mixtures.
   b. Exposure Uncertainties. If levels of
 exposure to certain compounds known
 to be in the mixture are not available.
 but information on health effects and -
 environmental persistence and transport
 suggest that these compounds are not
 likely to be significant in affecting the
 toxicity of the mixture, then a risk
 assessment can be conducted based on
 the remaining compounds in the
 mixture, with appropriate caveats. If.
 such an argument cannot be supported,
 no final risk assessment can be
 performed until adequate monitoring
 data are available. As an interim
 procedure, a risk assessment may be
 conducted for those components in the
 mixture for which adequate exposure
 and health effects data are available. If
 the results of the interim risk
 assessment suggest that a hazard
 already exists, resources might be better
 expended on remedial action as part of
 the a risk management decision rather
 than on further assessment. Concern is
 not reduced if the interim risk
 assessment does not suggest a hazard
 because not all components in the
 mixture have been considered.
   c. Uncertainties Regarding
 Composition of the Mixture. As a worst
 case scenario, information may be
 lacking not only on health effects  and
 levels of exposure, but also on the
 identity of some components in the
 mixture. Analogous to the procedure
 described in the previous paragraph, an
 interim risk assessment can be
' conducted on the components of the
 mixture for which adequate health
 effects and exposure information are
 available. If a hazard is indicated, then
 the resulting partial assessment should
 be carefully'qualified to avoid over
 interpretation of the accuracy of the
 assessment. If no hazard is indicated,
 the risk assessment should not be
 quantified until better health effects and
 monitoring data are  available.
 III. Assumptions and Limitations
   Most of the data available on toxicant
 interactions are derived from acute
 toxicity studies using experimental
 animals in which mixtures of two
 compounds were tested, often in only a
 single combination. Major areas of
 uncertainty with such data involve the
 appropriateness of interaction data from
an acute toxicity study to quantitatively
alter a risk assessment for subchronic or
chronic exposure, the appropriateness of
interaction data on two component
mixtures to quantitatively alter a risk
assessment on a mixture of several
compounds, and the predictability of
interaction data on experimental
animals to quantitatively  assess
interactions in humans.
  The use of interaction data from acute
toxicity studies to assess  the potential
interactions on chronic exposure would
be highly questionable unless the
mechanism(s) of the interaction on acute
exposure were known to apply to low
dose chronic exposure. However, most
known biological mechanisms for
toxicant interactions involve some form
of competition between the chemicals or
phenomena involving saturation of a
receptor site or metabolic pathway. As
the doses of the toxicants are decreased,
it is likely that these mechanisms either
no longer will exert a significant effect
or will be decreased to an extent which
cannot be measured or approximated.
  The use of information from two
component mixtures to assess the
interactions in a mixture containing
more  than two compounds also is
questionable from a mechanistic
perspectives-For example.'if two	
compounds are known to  interact, either
synergistically or antagonistically,
because of the effects of one compound
on the metabolism or excretion of the
other, the addition of a third compound
which either chemically alters or affects
the  absorption of one of the  first two
compounds could substantially alter the
degree of the toxicologic interaction.
Usually, detailed studies quantifying
toxicant interactions are not available
on multicomponent mixtures,'and the
few studies that are available on such
mixtures (e.g., Gullino et al., 1956) do not
provide sufficient information to assess
the  effects of interactive interference.
  Concerns with the use of interaction
data on experimental mammals to
assess interactions in humans is based
on the increasing appreciation for
systematic differences among species in
their response to individual  chemicals. If
systematic differences in interspecies
sensitivity exist among species, then it
seems reasonable to suggest that the
magnitude  of toxicant interactions
among species also may vary in a
systematic manner. Consequently, even
if excellent chronic data are available
on the magnitude of toxicant
interactions in a species of experimental
mammal, there is uncertainty that the
magnitude of the interaction will be the
same  in humans. Again, data are not
 available to properly assess the
 significance of this uncertainty.
   Last, it should be emphasized that
 none of the models for toxicant
 interaction can predict the magnitude of
 toxicant interactions in the absence of
 extensive data. If sufficient data are
 available to estimate interactive
 coefficients as described in S^c-tinn IV.
 then the magnitude of the toxicant
 interactions for various proportions of
 the same components can be predicted.
 The availability of an interaction ratio
 (observed response divided by predicted
 response) is useful only in assessing the
 magnitude of the toxicant interaction for
 the specific proportions of the mixture
 which were used to generate the
 interaction ratio.
   The basic assumption in the
 recommended approach is the risk
 assessments on chemical mixtures are
 best conducted using toxicologic data on
 the mixture of concern or a reasonably
 similar mixture. While such risk
 assessments do not formally consider
 toxicologic interactions as part of a
 mathematic model, it is assumed that
 responses in experimental mammals or
 human populations noted after exposure
 to the chemical mixture can be used to
 conduct risk assessments on human
 populations. In bioassays of chemical
""mixtures using'experimental mammals,
 the same limitations inherent in species-
 to-species extrapolation for single
 compounds apply  to mixtures. When
 using health effects data on chemical
 mixtures from studies on exposed
 human populations,  the limitations of
 epidemiologic studies in the risk
 assessment of single compounds also
 apply to mixtures. Additional limitations
 may be involved when using health
 effects data on chemical mixtures if the
 components in the mixture are not
 constant or if the components partition
 in the environment.
   If sufficient data are not available on
 the effects of the chemical mixture of
 concern or a reasonably similar mixture,
 the proposed approach is to assume
 additivity. Dose additivity is based on
 the assumption that  the components in
 the mixture have the same mode of
 action and elicit the same effects. This
 assumption will not  hold true in most
 cases, at least for mixtures of systemic
 toxicants. For systemic toxicants,
 however, most single compound risk
 assessments will result in the derivation
 of acceptable levels, which, as currently
 defined, cannot be adapted to the
 different forms of response additivity as
 described in Section IV.
   Additivity models can be modified to
 incorporate quantitative data on
 toxicant interactions from subchronic or

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 174
Federal  Register / Vol. 50, No. 6 / Wednesday. January  9. ISfoS / Notices
 hronic studies using the models given
 i Section IV or modifications of these
 lodels. If this approach is taken,
 owever, it will be under the assumption
 .iat other components in the mixture do
 .ot interfere with the measured
 nteraction. In practice, such subchronic
 •r chronic interactions data seldom will
 >e available, and most risk assessments,
 n the absence of health effects data on
 he mixture of concern, will be based on
 in assumption additivity.
  Dose-additive and response-additive
 '.ssumptions can lead to substantial
 •rrors in risk estimates if synergistic or
 mtagonistic interactions occur.
 \lthough dose additivity has been
 ;hown to predict the acute toxicities of
 nany mixtures of similar and dissimilar
 :ompounds (e.g., Pozzani et al., 1959;
 Smyth et al.. 1969,1970; Murphy, 1980).
 )ome marked exceptions have been
 loted. For example, Smyth et al. (1970)
 ested the interaction  of 53 pairs of
 ndustrial chemicals based on acute
 ethality in rats. For most pairs of
 :ompounds, the ratio of the predicted
LDso to observed LD5o did  not vary by
more than a factor of 2. The greatest
variation was seen with an equivolume
mixture of morpholine and toluene, in
which the observed LDso was about five
times less than the LDso predicted by
dose addition. In a study by Hammond  .
et al. (1979), the relative risk of lung
cancer attributable to smoking was 11,
while the relative risk associated, with
asbestos exposure was 5.  The relative
risk of lung cancer from both smoking
and asbestos exposure was 53,
indicating a substantial synergistic
 effect. Consequently,  in some cases,
additivity assumptions may
 substantially underestimate risk. In
 other cases, risk may be overestimated.
 While this is certainly an  unsatisfactory
 limitation, it is a limitation associated
 more with the nature and  quality of the
 available data on toxicant interaction
 than with the proposed approach itself.

 IV. Mathematical Models and the
 Measurement of Joint Action
  The simplest mathematical models for
 joint action assume no interaction in
 any mathematical sense. They describe
 either dose addition or response
 addition and are motivated by data on
 acute lethal effects of mixtures of two
 compounds.
 A. Dose Addition
  Dose addition assumes that the
 toxicants in a mixture behave as if they
 were dilutions or concentrations  of each
 other, thus the slopes of the dose-
 response curves for the individual
 compounds are identical, and the
 response elicited by the mixture can be
                     predicted by summing the individual
                     doses after adjusting for differences in
                     potency; this is defined as the ratio of
                     equitoxic doses. Probit transformation
                     typically makes this ratio constant at all
                     doses when parallel straight lines are
                     obtained. Although this assumption can
                     be applied to any model (e.g., the one-hit
                     model in NRG, 1980b), it has been most
                     often used in toxicology with the log-
                     dose probit-response model, which will
                     be used to illustrate the assumption of
                     dose additivity. Suppose that two
                     toxicants show the following log-dose
                     probit-response equations:
                     Y, =03+3 log Z,    (IV-l)
                     where Y, is the probit response associated
                         with a dose of Z, (i =1,2).
                     The potency, p, of toxicant-2 with
                     respect to toxicant-1 is defined by the
                     quantity Zi/Z-j when Yi=Y2 (that is
                     what is meant by equitoxic doses). In
                     this example, the potency, p, is
                     approximately 2. Dose addition assumes
                     that the response, Y, to any mixture of
                     these two toxicants can be predicted by:
                     Y=0.3 + 3log(Zi+pZj)    (IV-3)
                     Thus, since p is defined as Zi/Zj,
                     Equation IV-3 essentially converts Za
                     into an equivalent dose of Zi by
                     adjusting for the difference in potency.
                     A more generalized tonn of this
                     equation for any member of toxicants is:
                     Y=a,+blog(f, + 2f,p,)+blogZ    (IV-4)
                     where ai is the y-intercept of the dose-
                     response equation for toxicant-1, b is the
                     slope of the dose-response lines for the
                     toxicants, f, is the proportion of the i"1
                     toxicant in the mixture, pt is the potency
                     of the i'Moxicant with respect to
                     toxicant-1 (Zi/Z,), and Z is the sum of
                     the individual doses in the mixture. A
                     more detailed discussion of the
                     derivation of the equations for dose
                     addition is presented  by Finney (1971).
                     B. Response Addition
                        The other form of additivity is
                     referred to as response addition. As
                     detailed by Bliss (1939), this type of joint
                     action assumes that the two toxicants
                     act on different receptor systems and
                     that the correlation of individual
                     tolerances may range from completely
                     negative (r= —1) to completely positive
                     (r= +1) correlation. Response addition
                      assumes that the response to a raven
                     concentration of a mixture of toxicants
                      is completely determined by the
                     responses to the components and the
                      correlation coefficient. Taking P as the
                      proportion of organisms responding to a
                      mixture of two toxicants which evoke
                      individual responses  of Pi and Pt. then
                      p=p, if r=l and P,>P,    (IV-S)
P=Piifr=landP,
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                    Federal  Register  / Vol. 50,  No.  6 / Wednesday. January  9. 1985  /  Notices
                                                                              1175
also been proposed, along with
appropriate statistical tests for the
assumption of additivity (Korn and Liu,
1983; Wahrendorf et al. 1981).
  In the epidemiologic literature,
measurements of the extent of toxicant
interactions (S) can be expressed as the
ratio of observed relative risk to relative
risk predicted by some form of
additivity assumption. Analogous to the
ratio of interaction in classical
toxicology studies, S=l indicates no
interaction, S<1 indicates synergism,
S<1 indicates antagonism. Several
models for both additive and
multiplicative risks have been proposed
(e.g., Hogan et al., 1978; NRG, 1980b;
Walter. 1976). For instance, Rothman
(1976) has discussed the use of the
following measurement of toxicant
interaction based on the assumption of
risk additivity:
where R10 is the relative risk from
compound-1 in the absence of
compound-2, Roi  is the relative risk from
compound-2 in the absence of
compound-1. and Rn is the relative risk
from. exposure to both compounds. A
multiplicative risk model adapted from
Walter and Holford (1978, Eq. 4) can be
stated as:
S=Rl,/(R,0Roi)    (IV-12)   _
As discussed by  both Walter and
Holford (1978) and Rothman (1976), the
risk-additive model is generally applied
So agents causing diseases while  the
multiplicative model is more appropriate
to agents that prevent disease'. The
relative merits of these and other  „
indices have been the subject of   /
considerable discussion in the
epidemiologic literature (Hogan et al.,
1978; Kupper and Hogan, 1978; Rothman;
1978; Rothman et al., 1980; Walter and
Holford, 1978) which has not yet been
resolved.
  Both the additive and multiplicative
models assume statistical independence
in that the risk associated with exposure
to both compounds in combination can
be predicted by the risks associated
with separate exposure to the individual
compounds. As illustrated by
Siemiatycki and  Thomas (1981) for
multistage carcinogenesis, the better
fitting  statistical  model will depend not
only upon actual biological interactions
but clso upon the stages of the disease
process which the compounds affect.
Consequently, there is no a priori basis
for selecting either type of model in a
risk assessment.  As discussed by Stara
et al. (1983), the concepts of multistage
carcinogenesis and the effects of
promoters and cocarcinogens on  risk are
extremely complex issues. Although risk
models for promoters have been
proposed (e.g., Burns et al., 1983) no
single approach can be recommended at
this time.

V. References
  ACGIH (American Conference of
Governmental Industrial Hygienists). 1983.
TLVs: threshold limit values for chemical
substances and physical agents in the work
environment with intended changes for 1983-
1984. Cincinnati. OH. p. SB.
  Alstott, R.L., M.E. Tarrant, and R.B. Forney.
1973. The acute toxicities of 1-
methylxanthine, ethanol. and 1-
methylxanthine/ethanol combinations in the
mouse. ToxicoL Appl. Pharmacol. 24:393-404.
  Bliss, C.L 1939. The toxicity of poisons
applied jointly. Ann. Appl. Biol. 28:585-615;
  Burns, P.. R. Albert, E. Altschuler. and E.
Morris. 1983. Approach to risk assessment for
genotoxic carcinogens based on data from
the mouse skin initiation-promotion model.
Environ. Health Perspect 50:309-320.
  Durkin, P.R. 1979. Spent chlorination liquor
and chlorophenolics: a study in detoxication
and joint action using Daphnia magna. Ph. D.
Thesis. Syracuse, NY: State University of
New York College of Environmental Science
and Forestry, p. 145.
  Durkin, P.R. 1981. An approach to the
analysis of toxicant interactions in the
aquatic environment. Proc. 4th Ann. Symp.
Aquatic Toxicology. American Society for
Testing and Materials, p. 388-401.
  Finney, D.J. 1942. The analysis of toxicity
tests on mixtures of poisons. Ann. Appl. Biol.
29:82-94
  Finney, D.J. 1971. Probit analysis.  3rd ed
Cambridge, Great Britain: Cambridge
University Press. 333 p..
  Goldstein, A., L. Aronow, and S.M.
Kalman. 1974. Principles of drug action: the
basis of pharmacology, 2nd ed. New York,
NY: John Wiley and Sons. Inc., 854 p.
  Gullino. P.. M. Winitz, S.M Birnbaum. J.
Cornfield. M.C Otey, and J.P. Greenstein.
1956. Studies on  the metabolism of amino
acids and related compounds in vivo. I.
Toxicity of essential amino acids,
individually and in mixtures, and the
protective effect of L-arginine. Arch. Biochem.
Biophys. 64:319-332.
  Hammond. E.G.. I.V. Selikoff. and H.
Seidman. 1979. Asbestos exposure, cigarette
smoking and death rates. Ann. NY Acad. Sci.
330:473-490.
  Hewlett P.S. 1969. Measurement of the
potencies of drug mixtures. Biometrics.
25:477-487.
  Hogan M.D., L Kupper, B. Most, and J.
Haseman. 1978. Alternative approaches to
Rothman's approach for assessing synergism
(or antagonism) in cohort studies. Am. J.
Epidemiol. 108(l):80-fl7.
  Klaassen. CD., and I. Doull. 1980.
Evaluation of safety: Toxicologic evaluation.
In: ]. Doull. C.D. Klaassen. and M.O. Amdur.
eds. Toxicology: The basic science of
poisons. New York. NY: Macmillan
Publishing Co.. Inc., P. 11-27
  Korn. E.L. and P-Y. Liu. 1983. interactive
effects of mixtures of stimuli in life table
analysis. Biometrika 70:103-110
  Kupper. L. and MJ). Hogan. 1978.
Interaction in epidemiologic studies; Am. ].
Epidemiol. 108(6):447-453.
  Levine, R.E. 1973. Pharmacology: drug
actions and reactions. Boston, MA: Little.
Brown and Company, 412 p.
  Murphy, S.D. 1980. Assessment of the
potential for toxic interactions among
environmental pollutants. In: C.L Galli. S.D.
Murphy, and R. Paoletti. eds. The nrinriples
and methods in modern toxicology,
Amsterdam. The Netherlands: Elsevier/North
Holland Biomedical Press.
  NRG (National  Research Council). 1980a.
Drinking water and health. Vol. 3.
Washington, DC:  National Academy Press, p.
27-28.
  NRC (National  Rescrach Council).  1980b.
Principles of toxicological interactions
associated with multiple chemical exposures.
Washington. DC:  National Academy Press, p.
204.
  OSHA (Occupational Safety and Health
Administration). 1983. General Industry
Standards. Subpart 2. Toxic and Hazardous
Substances. Code of Federal Regulations.
40:1910.1000(d)(2)(i). Chapter XVII—
Occupational Safety and Health
Administration, p. 667.
  Plackett. R.L and P.S.  Hewlett.. 1948.
Statistical aspects of the independent joint
action of poisions. Ann. Appl. Biol. 35:347-
358.
  Pozzani, U.C.. C.S. Weil, and C.P.
Carpenter. 1959. The toxicological basis of
threshold values: 5. The  experimental
inhalation of vapor mixtures by rats.' with
notes upon the relationship between single
dose inhalation and single dose oral data.
Am. Ind. Hyg. Assoc. J. 20:364J69.
  Rothman. K. 1978. The estimation of
synergy or antagonism. Am.). Epidemiol.
103(5):506-511.
  Rothman. K. 1978. Estimation versus •
detection in the assessment of synergy. Am. J.
Epidemiol. 108(1):9-11.
  Rothman. K., S. Greenland, and A Walter.
1980. Concepts of interaction. Am. ].
Epidemiol. 112(4):467-470.
  Siemiatycki. J..  and D.C. Thomas. 1981.
Biological models and statistical interactions:
An example from multistage carinogenesis.
Int. J. Epidemiol. 10(4):383-387,
  Smyth. H.F.. C.S. Weil. J.S. West, and C.P.
Carpenter. 1969. An exploration of joint toxic
action: I. Twenty-seven industrial chemicals
intubated in rats in all possible pairs.
Toxicol. Appl. Pharmacol. 14:340-347.
  Smyth. H.F., C.S. Weil. J.S. West, and C.P.
Carpenter. 1970. An exploration of joint toxic •
action: II. Equitoxic versus equivolume
mixtures. Toxicol. Appl.  Pharmacol. 17:498-
503.
  Stara, J.F., D. Mukerjee. R. McGaughy, P.
Durkin. and M.L. Dourson. 1983. The current
use of studies on promoters and
cocarcinogens in quantitative risk
assessment. Environ. Health Perspect. 50:359-
368.
  U.S. EPA. 1984. Proposed guidelines for
carcinogen risk assessment. Office of Health
and Environmental Assessment. Carcinogen
Assessment Group. Draft.
  Veldstra. H. 1956. Synergism and
potentiation with special reference to the

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1176	   Federal Register /  Vol. 50.  No.  6 / Wednesday, January 9.  1985  / Notices
combination of structural analogues.
Pharmacol. Rev. 8339-387.
  Wahrendorf.}.. R. Zentgrof. and C.C.
Brown. 1981. Optimal designs for the analysis
of interactive effects of two carcinogens or
other toxicants. Biometrics. 37:45-54.
  Walter, S.D. 1978. The estimation and
interpretation of attributable risk in health
research. Biometrics.  32:829-849.
  Walter, S.D.. land T.R. Holford. 1978.
Additive, multipicative, and other models for
disease risks. Am. J. Epidemiol. 108:341-346.
  Withey, J.R. 1981. Toxicodynamics and
biotransformation. In: International
Workshop on the Assessment of
Multichemical Contamination. Milan. Italy.
(Draft copy courtesy of J.R. Withey)
  WHO (World Health Organization). 1981.
Health effects of combined exposures in the
work environment. WHO Tech. Rept. Series
No. 662.
[FR Doc. 85-589 Filed 1-6-85; 8:45 am]
BtLum cooe asto so n

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                                                                  £ifc Systems, fac.
                                   APPENDIX 4
                    TEST PROTOCOL CRITERIA FOR ANIMAL ASSAYS
Several test systems have been devised to determine the potential for
development of various toxicologic endpoints following exposure to various
chemical substances.  These assays share in common certain fundamental
features with respect to design and conduct.  These are discussed below:

1.   Dose

In acute studies, a single administration of the test substance at four or
five varying dose levels should be sufficient for determining ranges of
mortality and toxic effects.  Doses are selected to provide data sufficient to
estimate the LD   (the dose at which 50% of the test organisms die) and to
produce a dose-response curve.

For subchronic and chronic studies, at least three dose levels should be used
in addition to a concurrent control group.  The highest dose level should
elicit some signs of toxicity without causing excessive lethality.  The lowest
dose level should not produce toxicity.  To obtain maximum information on the
dose-response characteristics of the test chemical, at least one intermediate
dose is generally used.

2.   Route of Exposure and Duration of Treatment

The most common routes of compound administration for chronic and subchronic
testing are inhalation, oral and dermal.  Corresponding routes, in addition to
ocular exposure, are employed in acute toxicity studies.
                                      /'
In subchronic testing, oral and inhalation studies are accomplished in three
months.  In most inhalation studies, comparable results will be obtained from
either the 5- or 7-day/week exposure.  The inhalation exposure schedule is
usually .5 days/week, 6 hours/day.  For repeated dermal route studies, a
maximum of 21 applications to rabbits on a 5-day/week basis is considered to
be practical and of sufficient duration.

In chronic toxicity testing, the oral route of administration is usually pre-
ferred if the test substance is known to be absorbed from the gastrointestinal
tract.  If the test substance is administered in the drinking water or mixed
in the diet, exposure is continuous.  If the test substance is administered by
gavage or capsule, the animals are dosed seven days per week.  For cutaneous
exposure, dosing schedules should be selected to simulate human exposure.  For
inhalation exposures, the choice of intermittent or continuous dosing depends
on che objectives of the ocudy and on the expected human exposure conditions.
Long-term inhalation studies are patterned on expected occupational exposures
of 6 to 8 hours/day for 5 days/week or possible environmental exposures of 22
to 24 hours/day for 7 days/week.
                                     A4-1

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                                                                  tifc Systems, JHC.
3.   Selection of Species

The selection of species should take into account, whenever possible, whether
the test species' metabolism of the chemical, or its analogues, is similar to
that of humans.

Historically, it has generally been recommended that chronic and subchronic
testing be performed with two mammalian species, one a rodent and the other a
nonrodent.  The rat has normally been the rodent of choice.  Dogs are the
species of choice for the nonrodents.  The strains of test species used should
be well characterized, commonly used, disease resistant, and free from
interfering congenital defects.  In special circumstances with a small number
of chemicals, other species have been shown to be more sensitive than either
the rat or the dog.  However, the use of additional species would often not
appreciably affect the determination of a safe exposure level for man.

4.   Number of Animals

The number of animals to be employed in chronic tests varies depending on the
goals and needs of the investigation.  A sufficient number of animals should
be used so that reliable statistical analysis can be performed to evaluate the
test results.  At the end of the study, enough animals should be alive in each
group for a thorough clinical and morphological examination.  With respect to
species tested, a minimum of 50 rodents/sex/dose level and 8 dogs/sex/dose
level should be utilized in chronic toxicity tests.  At least 20 rats/sex/dose
level and 4 dogs/sex/dose, level are considered to be sufficient for subchronic
testing.  For repeated skin application studies, 20 r-abbits/sex/dose are
usually required.

5 .   Age of Animals

The age at which animals are/started on a test is an important consideration
in toxicity testing.  In routine subchronic testing it is generally
recommended that rodents be started on treatment as young as practically
possible.  The earliest practical age to start rodents on test is 5 to 8
weeks.  For nonrodents, especially the dog, starting the exposure at 4 to 10
months is preferable to using older animals.

In chronic testing, exposure of rodents and dogs should be no later than six
weeks and four months of age, respectively.
                                     A4-2

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                                                                 £ife Systems, Jnc.
                                   APPENDIX 5

                       DEFINITION OF TOXICOLOGIC ENDPOINTS

A wide range of chemicals have been reported to produce adverse health effects,
The effects manifested have been characterized as toxicologic endpoints which
include primarily neurotoxicity, behavioral toxicity,  hepatotoxicity,  renal
toxicity, blood toxicity, teratogenicity,  reproductive toxicity, mutagenicity,
or carcinogenicity.   These endpoints can be characterized as follows:

       •  Neurotoxicity refers to effects  of toxic substances on various
         .structures comprising the nervous system.   The effects exerted may
          involve direct damage to structures including axons of peripheral
          neurons, myelin, synaptic junctions, etc.   Manifestations of neuro-
          toxicity include acute toxic effects such  as muscular twitching,
          weakness,  convulsions, and respiratory paralysis.   Delayed neuro-
          toxicity may result from direct  action of  the toxic substance
          through axon degeneration followed by demyelination of tracts in  the
          spinal cord or peripheral nerves with resultant paralysis.

       •  Behavioral toxicity refers to changes in adaptive  behavioral
          capacity that result from the effect of toxic substances on the
          neural system.  Changes may occur in behavioral functions such as
          acquisition of skills, learning, short- and long-term memory,
          decision-making, and psychomotor functioning.

       •  Hepatotoxicity is the elicitation of adverse effects in the -.
          morphology and/or function of the liver.  Some common endpoints of
          chemical injury include the following:

            •  Accumulation of abnormal.amounts of hepatic lipid, especially
               triglycerides
               Inhibition of protein synthesis
               Lipid peroxidation of hepatic microsomes
               Necrosis
               Cholestasis
               Cirrhosis
               Carcinogenesis

          Renal toxicity is the elicitation of adverse effects in the
          morphology and/or functions of the kidney.   Some manifestations of
          renal toxicity include depression of creatinine clearance and phos-
          phate reabsorption.to severe tubular degeneration.

          Blood toxicity refers to chemical-induced  alteration in components
          of the blood by influencing their production, rate of peripheral
          destruction or distribution.

          Teratology may be defined as the study of  permanent structural or
          functional abnormalities arising during embryogenesis and that are
          generally  incompatible with, or  severely detrimental to, normal
          post-natal survival or development.
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                                                       £ife Systems, Jnc.
Reproductive toxlcity refers to detrimental effects on reproduction
and on the offspring following parental exposure.   Manifestations of
reproductive toxicity include impaired fertility,  fetal death and
birth or developmental defects.

Mutagenicity is the capacity to cause heritable changes in the
genetic make-up of a cell.  Manifestation of mutagenic effects
include point mutations, numerical aberrations, and structural aberr
rations.

Carcinogenicity refers to the ability of a chemical to significantly
increase the incidence of malignant lesions in animals or humans, to
induce rarely occurring tumors, or significantly decrease the
latency period for tumor development relative to an appropriate
background or control group.
                           A5-2

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