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              Environmental Protection
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DIRECTIVE NUMBER: 9295.4-01

TITLE:    MOD Between ORlTand OERR



APPROVAL DATE: "Iff? °

EFFECTIVE DATE: // f£f
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                       H I'lrective initiation Request  I  9295.
                             4/01
        of Contact Panon
       David Bennett
                       attpnona oat
                       475-9486
     3. Tiu«
       MOU Between ORD and OERR
     4. Summary of O'tctivf (includt enti statamant of purpose)                                      '
            Transmits MOU between OSWER and ORD for implementation of a cornnunicatons
         and technical support network between Regions, Laboratoreis and HQ managemerit
         units
     9. Ktywora*
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9. Syvatuf* el lead Otfiea Oiracuvta Coordinaior
Betti C. VanEpps, OERR Directives Coordinator
10. Na/na and Titli of Approving 0"ioal
Henry L. "Longest II / Di rector,, QERR
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     ,
     3        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
     *                   WASHINGTON, D.C. 20460
                         NOV   5 1990

                                             SOLID WASTE AND £ve»G£\C> RESPONSE

                                  OSWER Directive 9295.4-01
 MEMORANDUM

 SUBJECT:    Memorandum of Understarid/^g Between ORD and OERR

 FROM:        Henry L. Longest II
             Director, OERR

_TP_:_        .Addressees

      PURPOSE:   The purpose of this memorandum is to transmit for
 your records a copy of the Memorandum of Understanding (MOU)
 between the Office of Solid Waste and Emergency Response (OSWER)
 and the Office of Research and Development (ORD) which was signed
 on M_arch 10,  1990.

      BACKGROUND:  In 1987, the Office of Solid Waste and
 Emergency Response, the Regional Superfund Offices, and the
 Office of Research and Development established the Superfund
 Technical Support (TSP) project to organize and implement a
 network for communications and technical support among the
 Regions and Laboratories.  Currently the project consists of five
 Technical Support Centers (TSCs), each with its own specialty.
 The attached document creates a sixth TSC to be located in the
 Office of Health and Environmental Assesment (OHEA), with
 Environmental Criteria and Assessment Office (ECAO), Cincinnati
 identified as the focal point to coordinate the assessment of
 human health and risk issues.  The Toxics Integration Branch of
 OERR is the designated contact to work with the TSP project
 manager to establish and monitor the conduct and performance of
 this Center.

      OBJECTIVE AND IMPLEMENTATION:  The addition of this
 specialized Center will begin to meet the objective of
 establishing-a- consistent approach to the coordination of
 assessment of human health and risk issues.  Toward this end, all
 Superfund managers are directed to become familiar with this
 Memorandum of Understanding and to begin immediately to utilize
 the program outlined herein.  Questions with respect to this
 program should be directed to David Bennett, Director, Toxics
 Integration Branch, OERR at 475-9486.

 ADDRESSEES:
    Waste Management Division Directors
    Superfund Regional Branch Chiefs
    OERR Division Directors and Branch Chiefs

                                                          Pruutd an Ricycltd Paptr .

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                                                  OSKER  Directive  9255.4-G1
                           MEMORANDUM OF UNDERSTANDING
                                     BETWEEN
                     THE OFFICE OF RESEARCH AND DEVELOPMENT
                                       AND
                THE OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE


        I.    Purpose

                  The Office of Emergency and Remedial Response has
             proposed the establishment of the Technology Support Center
             (TSC) in the Office of Health and Environmental Assessment
             (OHEA), Environmental Criteria Assessment Office,
             Cincinnati, OH (ECAO-Cin) to address the human health risk
             assessment issues pertinent to Superfund-related activities.
            . This memorandum of understanding (MOU)  establishes functions
             and responsibilities for the TSC.

        II.   Authority

                  The Office of Solid Waste and Emergency Response
             (OSWER), Regional Superfund Offices, and Office of Research
             and Development (ORD) established the Superfund Technical
(             Support Project (TSP) in 1987.  The broad objectives of the
•             TSP are to provide technical support and assistance to
             regional staff; improve communications among regions and ORD
             laboratories; ensure consistency in applications of
             technologies; and furnish state-of-the-art science
             information for remedial project managers (RPMs) and
             on-scene coordinators (OSCs).  The project consists of a
             network of Regional Forums, four specialized technology
             support centers (TSCs) located in ORD laboratories, and one
             TSC at the Emergency Response Team (ERT).  The specialties
             and locations of the five TSCs are as
             follows: groundwater fate and transport (RSKEL, Ada, OK);
             engineering and treatment  (RREL, Cincinnati, OH);  monitoring
             and site characterization  (EMSL, Las Vegas, NV); exposure
             and ecorisk assessment (ERL, Athens, GA); and hazardous
             substances releases and response (ERT, Edison, NJ).

                  Regional technical personnel have established forums in
             engineering- and treatment, and groundvater fate and
             transport.  Acting as technical resources, forum members
             work to improve communications and assist in technical
             transfer between the Regions and the Centers.  Monthly
             teleconferences and periodic TSP meetings are held by the
             project manager in OSWER'S Office of Program Management and
             Technology;                     - • --

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          In setting up the TSCs, ORD designated the above
     laboratories to respond to technical questions with respect
     to the laboratory's specialties and expertise.  Resources of
     such assistance usually come from technical assistance and
     enforcement support projects funded by the Agency's
     Superfund Research Subcommittee.  Even on an ad hoc basis,
     however, such projects have limited abilities to be flexible
     or to fashion more extensive site-specific support.  TSP is
     intended to address this inadequacy by encouraging the
     regions to utilize their in-house expertise (through the
     formation of regional technical support forums), and by
     providing the TSC access to a pool of OSWER funds to
     "procure" specific support from TSCs, or through the TSCs to
     obtain certain expertise inside or outside the Agency.

          This MOU proposes the establishment of the 6th TSC in
     the Office of Health and Environmental Assessment with ECAO-
     Cin identified as the focal point to coordinate OHEA- and
     Agency-wide assessment of the human health and risk issues.
     The Toxics Integration Branch (TIB) in the Office of
     Emergency and Remedial Response (OERR) will work with the
     TSP project manager to establish and monitor the conduct and
     performance of the Center.

III.  Scope of Responsibility

          This MOU covers the specific tasks and functions to be
     conducted by ECAO-Cin as a TSC for the Superfund program.

          Risk assessments are used to determine baseline risk
     and remedial alternatives and contribute to development of
     cleanup levels at Superfund sites.  They are performed by
     many different contractors, and are reviewed in the regional
     offices for adherence to program guidance and consistency of
     approach.  Those reviewers, with various levels of program
     experience, are required to evaluate the contractor's
     performance on calculating and characterizing risks from
     chemicals and chemical mixtures.  There may be data gaps
     associated with these chemicals regarding their toxicities,
     chemical interactions, exposure uncertainties, extrapolation
     methods, and the use of default values in various parts of
     the rioX assessment process.  There are stages during the
     procM^ where expert judgment is necessary, and there are
     roany-*rea» where inconsistency can occur.
          It is important to'the Superfund program that the
     regions, contractors and potentially responsible parties
     (PRPs) use a consistent process to characterize risk; and
    --that- selection of remedies to meet a health-based cleanup
     level for a specific chemical is reasonably comparable
     across regions.  Toward that end, the program has updated
     the guidance on Superfund human health evaluation, has added
     checklist and reporting format to the guidance, and has been

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    working with ORD and other offices to develop policy and
    guidance on exposure scenarios or risk assessment procedures
    for certain chemical classes.  Despite these efforts, the
    Superfund program does not always have the most current
    information concerning the state-of-the-science on risk
    assessment methodologies, chemical-specific toxicity values
    or characteristics, or the status of review or assessment
    for Superfund priority chemicals.

         The Superfund program is proposing that ORD designate
    ECAO-Cin as a TSC on health risk assessment to respond to
    the needs of Superfund regional and headquarters staff.
    ECAO-Cin has a long history of providing support to
    different regulatory programs, has experience on chemical
    review and toxicity validation, and has an excellent working
    relationships with other ORD labs and program offices; all
    of these are critical elements for the success of the TSC.

         In addition to the proposal for establishment of a TSC
    in ECAO-Cin, TIB/OERR will work with the regions to
    formalize a regional risk assessment forum as an integral
    part of coordinating technical support and assistance
    through all TSCs.  All requests for technical assistance
    should be funneled through appropriate regional forum
    representatives.  Forum representatives from every region
    will also participate in regularly scheduled teleconferences
    with TIB staff and representatives to TSCs to ensure that
    consistent approaches are applied across all the NPL sites
    and to identify any issues for which policies or
    recommendations need to be developed.

A.  Functions of the TSC

         Generic categories of functions of the TSC for health
    risk assessment are as follows:

    1.   To provide direct client services on a rapid turnaround
         basis by use of available in-house expertise to
         minimize additional referrals.  At a minimum, the TSC
         should be able to access most data bases and quickly
         assemble a panel of risk assessment experts to meet a
         particular need.

    2.   Where such expertise is not available [e.g., air
         toxics, radiation, structure activity relationship
         (SAR) review], the TSC oust be able to work with the
         project manager, regional forum representatives, ORD
         Office of Technology Transfer and Regional Support
         (OTTRS), and other program offices (for example,
      .  - AirRisc at OAQPS and Chemical Assessment Desk at OTS)
         to have the service delivered when needed.

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     3.   To coordinate with other TSCs to provide a "total
          response" to the extent feasible, using direct referral
          when appropriate.  This includes assuming lead
          responsibility for integrating responses to
          multi-facted questions, as well as referrals to other
          TSCs when appropriate.

     4.   To work with the TIB staff and TSP project managers in
          conducting regularly scheduled forum teleconferences,
          in holding periodic meetings (to review activities,
          issues, major requests, etc.,) and in distributing
          minutes of such events.

     5.   To document inquiries  (and responses to those
          inquiries) to enable the TIB to identify long-term
          research needs.

     6.   To coordinate with CERI, OTTRS, or other offices in the
          preparation, publication and distribution of technical
          updates, summaries, and other information used in risk
          assessment.

     7.   To articulate Superfund priorities in ORD so that
          chemical-specific information needed for risk
          assessment (e.g., inhalation reference doses or slope
          factors) will be developed for interim and final
          usages.

B.    Specific Tasks

          The following list is  not at all inclusive, but does
     provide a good overview of  the functions and
     responsibilities of the TSC for health risk assessment:

     1.   Provide rapid response by telephone and written follow-
          up when appropriate to regional toxics integration
          coordinators, RPMs, OSCs, and regional Superfund staff
          relating to chemical-specific health information
          [worker protection and protective clothing questions
          are to be addressed jointly with ERT.]  Obtain
          background information about the site, provide answers
          rather than making referrals, as appropriate, and
          inform the regional Superfund staff regarding the
          response provided to the requestor.

     2.   Work with TIB in providing interpretations and
          clarifications regarding questions on the Risk
          Assessment Guidance for Superfund (RAGS): Human Health
          Evaluation Manual.  Also to develop interim or default
          recommendations or rationale on issues applicable to
          risk assessment for Superfund sites (for example,
          route-to-route extrapolation, interim RfDs and dermal
          risk parameters).

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     3.    Develop,  working with TIB and other OERR staff as
          appropriate,  site-specific,  medium-specific and health-
          based trigger or cleanup levels for a contaminant,  or
          help the Regions to justify the use of a surrogate
          cleanup level based on risk to human health (for all
          phases of Superfund Programs, such as removal and
          remedial programs).

     4.    Help TIB/OERR to compile periodic updates and notices
          of refinements for risk assessment methodology for  the
          Superfund Program,  to be distributed to users of RAGS.
          Also assist TIB/OERR in providing training tools for
          Regional Superfund staff in order to ensure consistency
          and to improve the quality of all Superfund risk
          assessment.

     5.    Provide periodic status reports regarding TSC activities
          to TIB/OERR.   Help identify and plan future research to
          address issues related to the Superfund Program.
          Assist TIB/OERR in coordination with other TSCs to
          better utilize the existing expertise and resources.

     6.    Work with other TSCs on analysis of issues, such as the
          characterization of risidual risks or risks posed by
          cleanup technology.

     7.    Provide review and comment on site-specific Superfund
          risk assessments or risk assessment methods.

IV.   Period of Agreement

         This MOU will continue in effect until modified or
     amended by the concurrence of both parties or terminated by
     either party upon a 30-day advance written notice of the
     other party.  Nothing in the memorandum is intended to
     diminish or otherwise alter authority of the offices
     involved.

 V.   Amendments

         The memorandummay be amended at any time by the
     agreement of both parties.  Each amendment must be in
     writing and signed by the appropriate ORD and OSWER
     officials.

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             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C. 20460
                               '•IB 23 .:.-
                                                 3C:.'D
                                                         i\0 iV?
INTERPRETATION OF TEXT IN MEMORANDUM OF UNDERSTANDING ESTABLISHING
     TECHNICAL SUPPORT CENTER FOR HUMAN HEALTH RISK ASSESSMENT

     Although the last paragraph under II.  Authority of the
Memorandum of Understanding identifies ECAO-Cin as the focal
point  to coordinate OHEA- and Agency-vide assessment of human
health risk issues,  there is need for more explicit understanding
of the role of other Office of Health and Environmental
Assessment (OHEA)  entities.

     Our expectation is that ECAO-Cin will continue to work with
and  refer appropriate inquiries to the Exposure Assessment Group
(EAG)  and Human Health Assessment Group of OHEA and ECAO-RTP.
Typically ECAO-Cin would coordinate as needed with HHAG and ECAO-
RTP  on toxicity issues and consult with or delegate questions on
exposure assessment to EAG.  EAG would serve as primary resource
on topics addressed in Chapters 4, 5,  and 6, "Data Collection",
"Data  Evaluation"  and Exposure Assessment" of Risk Assessment
Guidance for Suoerfund;   Human Health Evaluation Manual.
William H.  Farland,  Ph.D.
Director
Office of Health and
  Environmental  Assessment
Larry G. Reed
Acting Director
Hazardous Site Evaluation Div.

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f
        VI.  Effective  Date

                  This  memorandum  will  become effective  at  noon  on  the
             date of the  last  signature below.
        Erich w. Bretthauer              />~Don R- Clay
        Acting Assistant Administrator   /"(Assistant Administrator  for
            for Research and Development  ^   Solid Waste and Emergency
                  *. I,  f*n                   Response
        Date:     ^/O  I rO                Date:

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