Hazard Ranking System Issue Analysis:
     Toxicity as a Ranking Factor
                MITRE

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Hazard Ranking System  Issue  Analysis:
       Toxicity as  a Ranking  Factor
                    John M. DeSesso
                      August 1987
                      MTR-86W128
                        SPONSOR:
                 U.S. Environmental Protection Agency
                      CONTRACT NO.:
                       EPA-68-01-7054
                   The MITRE Corporation
                     Civil Systems Division
                      7525 Colshire Drive
                   McLean, Virginia 22102-3481

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   Department Approval
:  ^^L  l£).
MITRE Project Approval:	
                     Ll

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                              ABSTRACT
     This report, prepared for the Office of Emergency and Remedial
Response (OERR) of the Environmental Protection Agency, recommends
modifications to the toxicity factor of the EPA Hazard Ranking
System (HRS) that incorporate:  (1) an the assessment of the
capacity of a substance to cause short- or long-term adverse
effects, cancer, birth defects, or changes in genetic material;
(2) a more accurate assessment of the potential hazard of substances
by considering the toxicity of each substance for each expected mode
of exposure to humans; and (3) more discrimination in the ranking of
toxic substances and waste sites.  This report critiques the current
HRS toxicity factor and eight other ranking systems selected as
representative of the methodologies used to discern the relative
dangers of substances.  This report then presents the rationale and
derivation of the suggested modifications to the HRS toxicity factor
and presents the evaluation of 30 substances found at National
Priorities List (NPL) sites as examples of the proposed scoring
methodology.

Suggested Keywords:  Acute Toxicity, Chronic Toxicity,
Carcinogenicity, Mutagenicity, Developmental Toxicity, and
Carcinogenic Potency.
                                 iii

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                            ACKNOWLEDGMENTS
     The author is indebted to MITRE1s toxicology staff for assistance
in the preparation of early versions of this document.  Drs. Maryce
Jacobs, Michael Cunningham, Roman Pienta, Byong-Han Chin, and
J. Michael Kelley contributed to preliminary asessments of other
toxicity ranking methodologies and to discussions of the methodology
proposed herein.  Extraction of toxicity data and preliminary scoring
of substances were performed by various members of the MITRE staff
including Drs. Daniel Casagrande, Maryce Jacobs, Michael Cunningham,
Roman Pienta, Byong-Han Chin, Miss Suzanne Locher, and Messrs. Gerald
Goldgraben and Mack Skaggs.  Dr. Barbara Fuller was instrumental in
performing quality assurance of the toxicity data extracted for
example, scoring of chemicals.
                                 iv

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                           TABLE OF CONTENTS


                                                                  Page

LIST OF TABLES                                                    ix

1.0  INTRODUCTION                                                  1

1.1  Background                                                    1
1.2  Toxicity as a Ranking Factor                                  3
1.3  Review of Other Ranking Systems                               4
1.4  Objectives                                                    5
1.5  Scope and Approach                                            5

2.0  CHARACTERISTICS EVALUATED                                     9

2.1  Type of Toxic Effect                                          9

     2.1.1  Acute Toxicity                                         9
     2.1.2  Chronic Toxicity                                       9
     2.1.3  Carcinogenicity, Mutagenicity, and/or
            Teratogenicity (CMT) Potential                        10

2.2  Determinants of Exposure                                     10

     2.2.1  Persistence                                           10
     2.2.2  Routes of Release                                     11
     2.2.3  Presence of Incompatible or Reactive Mixtures         11

2.3  Use of Data                                                  11

     2.3.1  Number of Hazardous Substances Evaluated              11
     2.3.2  Quantity of Data Required on Each Hazardous
            Substance                                             12
     2.3.3  Clarity and Ease of Use                               12

3.0  EVALUATION OF THE EPA HAZARD RANKING SYSTEM AND
     COMPARATIVE OVERVIEW OF SELECTED OTHER SYSTEMS               13

3.1  Environmental Protection Agency Hazard Ranking
     System (EPA HRS)                                             13

     3.1.1  Type of Toxic Effect                                  13
     3.1.2  Determinants of Exposure                              17
     3.1.3  Use of Data                                           19

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                     TABLE OF CONTENTS (Continued)


                                                                 Page

3.2  Comparative Review of Selected Ranking Systems               22

     3.2.1  Types of Toxic Effect                                 25
     3.2.2  Determinants of Exposure                              28
     3.2.3  Use of Data                                           30

4.0  RECOMMENDATIONS FOR IMPROVEMENT TO THE HRS TOXICITY
     FACTOR                                                       33

4.1  Framework for Considering Toxicity                           34

4.2  Type of Toxic Effect                                         35

     4.2.1  Acute Toxicity                                        35
     4.2.2  Chronic Toxicity                                      40
     4.2.3  Carcinogenicity, Mutagenicity, and
            Teratogenicity (CMT) Potential                        50
     4.2.4  Toxicity of Metals                                    54

4.3  Determinants of Exposure                                     58

     4.3.1  Persistence                                           58
     4.3.2  Routes of Release                                     59
     4.3.3  Presence of Incompatible or Reactive Mixtures         60

4.4  Use of Data                                                  62

     4.4.1  Number of Substances Evaluated                        62
     4.4.2  Quantity of Data on Each Substance                    64
     4.4.3  Clarity                                               66

5.0  GLOSSARY                                                     67

6.0  BIBLIOGRAPHY                                                 73

APPENDIX A  ENVIRONMENTAL PROTECTION AGENCY NOTIFICATION
            REQUIREMENTS:  CERCLA REPORTABLE QUANTITIES (RQ)      77

APPENDIX B  SUPERFUND PUBLIC HEALTH EVALUATION SYSTEM (SPHE)      85

APPENDIX C  PRELIMINARY POLLUTANT LIMIT VALUE (PPLV) METHOD       93

APPENDIX D  SITE ASSESSMENT SYSTEM (SAS), STATE OF MICHIGAN       99
                                  VI

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                     TABLE OF CONTENTS (Concluded)


                                                                 Page

APPENDIX E  HAZARD ASSESSMENT RATING METHODOLOGY II (HARM II)    105

APPENDIX F  RCRA HAZARDOUS WASTE SCHEDULING METHODOLOGY          111

APPENDIX G  EUROPEAN ECONOMIC COMMUNITY (EEC) PLAN               117

APPENDIX H  SYSTEM FOR PREVENTION, ASSESSMENT, AND CONTROL
            OF EXPOSURES AND HEALTH EFFECTS FROM HAZARDOUS
            SITES (SPACE)                                        123

APPENDIX I  EXAMPLE OF PROPOSED SCORING METHODOLOGY              127

APPENDIX J  SUPPORTING DATA FOR ASSIGNING TOXICITY VALUES TO
            HAZARDOUS SUBSTANCES                                 133
                                 vii

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                            LIST OF TABLES
Table Number                                                     Page

     1       DISTRIBUTION OF MRS TOXICITY/PERSISTENCE FACTOR
             VALUES AT NPL FACILITIES                             16

     2       SUBSTANCES MOST FREQUENTLY USED TO ASSIGN
             TOXICITY/PERSISTENCE FACTOR VALUES AT NPL
             FACILITIES                                           21

     3       COMPARATIVE EVALUATION OF TOXICITY FACTORS
             AMONG SELECTED HAZARDOUS WASTE RANKING SYSTEMS       24

     4       PROPOSED ACUTE TOXICITY VALUES FOR ORAL, DERMAL
             AND INHALATIONAL EXPOSURES                           38

     5       PROPOSED CHRONIC TOXICITY VALUES BASED ON
             REFERENCE DOSES OR ACCEPTABLE DAILY INTAKES FOR
             ORAL, DERMAL AND INHALATIONAL EXPOSURES              49

     6       PROPOSED CM WEIGHT-OF-EVIDENCE CATEGORIES            53

     7       PROPOSED RELATIVE CARCINOGENIC POTENCY GROUPS
             BASED ON THE CARCINGOGENIC ED10                      55

     8       PROPOSED CM VALUES BASED ON WEIGHT-OF-EVIDENCE
             AND RELATIVE POTENCY                                 56

     9       EXAMPLE CALCULATION OF TOXICITYORAL VALUE
             (CHLOROFORM)                                         61

    10       COMPARISON OF TOXICITY VALUES USING THE CURRENT      65
             EPA HRS WITH THE PROPOSED PATHWAY-SPECIFIC
             TOXICITY FACTOR METHODOLOGY
                                  ix

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1.0  INTRODUCTION




1.1  Background




     The Comprehensive Environmental Response, Compensation and




Liability Act of 1980 (CERCIA) (PL 96-510) requires the President to




identify national priorities for remedial action among releases or




threatened releases of hazardous substances.  These releases are to




be identified based on criteria promulgated in the National




Contingency Plan (NCP).  On July 16, 1982, EPA promulgated the




Hazard Ranking System (HRS) as Appendix A to, the NCP (40 CFR 300;




47 FR 31180).  The HRS comprises the criteria required under CERCLA




and is used by EPA to estimate the relative potential hazard posed




by releases or threatened releases of hazardous substances.




     The HRS is a means for applying uniform technical judgment




regarding the potential hazards presented by a release relative to




other releases.  The HRS is used in identifying releases as national




priorities for further investigation and possible remedial action by




assigning numerical values (according to prescribed guidelines) to




factors that characterize the potential of any given release to




cause harm.  The values are manipulated mathematically to yield a




single score that is designed to indicate the potential hazard posed




by each release relative to other releases.  This score is one of




the criteria used by EPA in determining whether the release should




be placed on the National Priorities List  (NPL).

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     During the original NCP rulemaking process and the subsequent

application of the HRS to specific releases, a number of technical

issues have been raised regarding the  HRS.  These  issues concern  the

desire for modifications to the HRS, to improve its capability, to

estimate the relative potential hazard of  releases.   The issues

include:

     •  Review of other existing ranking systems suitable  for
        ranking hazardous waste sites  for  the NPL.

     •  Feasibility of considering ground  water flow direction and
        distance, as well as defining  "aquifer of concern," in
        determining potentially affected targets.

     •  Development of a human food chain exposure evaluation
        methodology.

     •  Development of a potential for air release factor category
        in the HRS air pathway.

     •  Review of the adequacy of the  target distance  specified in
        the air pathway.

     •  Feasibility of considering the accumulation of hazardous
        substances in indoor environments.

     •  Feasibility of developing factors to account for
        environmental attenuation of hazardous substances in ground
        and surface water.

     •  Feasibility of developing a more discriminating toxicity
        factor.

     •  Refinement of the definition of "significance" as it relates
        to observed releases.

     •  Suitability of the current HRS default value for an unknown
        waste quantity.

     •  Feasibility of determining and using hazardous substance
        concentration data.

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     •  Feasibility of evaluating waste quantity on a hazardous
        constituent basis.

     •  Review of the adequacy of the target distance specified in
        the surface water pathway.

     •  Development of a sensitive environment evaluation
        methodology.

     •  Feasibility of revising the containment factors to increase
        discrimination among facilities.

     •  Review of the potential for future changes in laboratory
        detection limits to affect the types of sites considered for
        the NPL.

     Each technical issue is the subject  of one or more separate but

related reports.  These reports, although providing background,

analysis, conclusions and recommendations regarding the technical

issue, will not directly affect the HRS.   Rather,  these reports will

be used by an EPA working group that will assess and integrate the

results and prepare recommendations to EPA management regarding

future changes to the HRS.  Any changes will then be proposed in

Federal notice and comment rulemaking as  formal changes to the NCP.

The following section describes the specific issue that is the

subject of this report.

1.2  Toxicity as a Ranking Factor

     As a result of both the NCP and NPL  rulemaking and the

subsequent application of the HRS to uncontrolled hazardous wastes

sites, public comments have been received by EPA on the method used

in the HRS to rank the toxicity of hazardous substances.  Hie

current HRS method is based on a rating scheme developed by

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N. Irving Sax  (1975, 1979 and  1984) and rates the toxicity of




hazardous substances on  a scale  of  0  to 3 (see  Section  3  for further




discussion  of  the  HRS  toxicity factor).




     Several  technical issues  were  raised by commenters that suggest




the possible  need  for  modification  of the HRS in order  to improve




its ability to discriminate among sites whose wastes have different




toxicological  characteristics.  In  particular,  commenters raised  the




following issues:   (1) better  guidance or instructions  for




determination  of HRS toxicity  values  should  be  given; (2) chronic




toxicity and  carcinogenic effects are not addressed adequately in




the HRS; (3) mutagenic and  teratogenie effects  are not considered;




and  (4)  the current HRS  toxicity factor provides insufficient




stratification in  toxicity  values for many toxic substances and




consequently has little  influence on  the  final  ranking of sites.




EPA also desires to evaluate modifications of the HRS that could




improve  its ability to estimate  the relative dangers due to the




toxicity of substances at uncontrolled hazardous wastes disposal




sites.




1.3   Review of Other Ranking Systems




      Many other systems  for ranking the relative toxicities of




hazardous substances or  the relative  dangers of hazardous wastes




disposal sites have been developed.   More than  55 systems were




reviewed at the initiation  of  this project (Haus and Wolfinger,




1986).   Eight  of these systems were selected for further review and

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analysis as representative of the spectrum of approaches to hazard




ranking.  Ihese systems include the CERCLA Reportable Quantities




(RQ) Methodology; the Superfund Public Health Evaluation (SPHE)




Method; the Preliminary Pollutant Level Value (PPLV) Method; the




State of Michigan Site Assessment System (SAS);  the U.S. Air Force




Hazard Assessment Rating Methodology II (HARM II);  the RCRA




Hazardous Waste Scheduling Methodology; the European Economic




Community (EEC) Plan; and the Centers for Disease Control (CDC)




System for Prevention, Assessment, and Control of Exposures




(SPACE).  Since each system was developed with a different set of




objectives and has its own approach for addressing toxicity, it is




possible that one or more of these systems could provide guidance




for designing an approach to improve the ability of the HRS to




estimate the relative dangers posed by hazardous substances present




at wastes disposal sites.  Descriptions and evaluations of these




systems are found in Section 3 and Appendices A through H.




1.4  Objectives




     The objective of this study is to determine if improvements can




be made in the means of evaluating hazardous substances at hazardous




wastes sites to better reflect the relative toxic hazard posed by




these substances.




1.5  Scope and Approach




     The scope of this project consisted of an evaluation of the




method used by the current HRS for estimating the relative toxicity

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of substances at hazardous wastes disposal sites as  well  as  the




methods employed by other ranking systems and (2) the presentation




of suggested improvements to the HRS toxicity factor.




     Three sets of characteristics were selected to  evaluate the




various systems.  These characteristics address the  range of toxic




effects considered, the ability to account for variables  that affect




exposure, and the manner for using the available data, as discussed




below.




     Since human exposure to substances that are released from




uncontrolled hazardous wastes sites may be of either an acute (short




duration) or a chronic (long duration) nature, an appropriately




designed ranking system should address the toxic effects  resulting




from both acute and chronic exposure.  Therefore, one set of




characteristics that must be evaluated, concerns the comprehensive-




ness of the toxic effects (i.e., acute toxicity, carcinogenicity,




mu ta genie it y-. teratogenicity and other chronic effects) that provide




the basis for the hazard assessment.




     Since the toxicity of a substance can be influenced  by the




duration of exposure to it, an appropriately designed ranking system




should take into account factors that determine human exposure to  a




substance.  Therefore, the second set of characteristics  that




require evaluation relates to the ability of the ranking  system to




account for variables that affect exposure,  including modes  of

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exposure, persistence, and presence of incompatible or reactive

mixtures.*

     In order to ensure consistency and the appropriate application

of a ranking methodology to a given hazardous wastes site,  the

methodology should be readily understood,  simply designed,  easy to

use, and scientifically sound.   Therefore,  the third set of

characteristics that require evaluation is  the manner with  which

each ranking system uses the available data.   This  includes the

number of hazardous substances  considered  in  the toxicity ranking,

the quantity of data required for scoring  each hazardous substance,

and the clarity of instructions and ease of use of  the ranking

system.

     These three sets of characteristics are  described in detail in

Section 2.  In order to ensure  a consistent evaluation, each ranking

system was evaluated according  to these characteristics.  In

addition, each ranking system was assessed  to determine the purpose

for which it was designed, the  toxicologic  endpoints that were

considered, and how the final toxicity score  was calculated.   This

additional information is presented in Section 3 to provide a

complete understanding of the various systems evaluated.
Incompatible or reactive mixtures were considered  within this
 category due to their potential to accelerate the  release of
 substances via fires and/or explosions as well as  their ability to
 create new toxic substances.

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     Based on the evaluation of the EPA HRS, its limitations in




assessing toxicity were identified.  Evaluation of the other eight




ranking systems provided insight to the design of approaches to




address the limitations in the HRS.  Where possible, modifications




are recommended to improve the capability of the HRS to assess




toxicity, and a proposed scoring methodology is described.   This




information is presented in Section 4.  The details of the




evaluation of the other eight systems are presented in Appendices A




through H.




     Thirty substances have been ranked as examples using the




methodology described in Section 4.  Appendix I presents a summary




of the ranking assigned to each substance.




     Section 5 provides a glossary of terms and Section 6 is a




bibliography of references used in this report.

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2.0  CHARACTERISTICS EVALUATED




     The EPA MRS and eight other ranking systems were evaluated using




the characteristics described below.   These characteristics include




the type of toxic effect (e.g., acute and chronic),  the determinants




of exposure (e.g., persistence and mode of exposure), and the use of




available data (e.g., number of substances considered).




2.1  Type of Toxic Effect




     2.1.1  Acute Toxicity




     The evaluation of acute toxicity includes a description of the




types of toxic effects (lethality, sensitization, irritation,




corrosion, etc.) which may result after short  term exposure to




hazardous substances.  Assessment of  acute toxicity potential is




important to protect persons who may be exposed to hazardous




substances accidentally, for a short  period of time.   In addition,




acute toxicity data are generally available for most toxic




materials, allowing a common ground for estimating the relative




acute danger posed by the hazardous substances.




     2.1.2  Chronic Toxicity




     All types of chronic toxic effects may be important because




substances escaping from hazardous wastes sites are likely to result




in long term exposures at low doses.   Therefore, a ranking system




should be able to discriminate between hazardous substances which




cause toxic effects after short exposure (acute toxicity) versus




hazardous substances which cause toxic effects only after prolonged

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exposure (chronic toxicity).  In the latter case,  it  is  implicit

that the acute (short term) toxicity is relatively low,  or else the

chronic toxicity may not be seen because of the acute effects.

     2.1.3  Carcinogenicity, Mutagenicity,  and/or  Teratogenicity
            (GMT) Potential

     The potential for hazardous substances to cause  CMT effects  is

important in ranking hazardous wastes sites because (1)  carcinogenic

effects are usually not observed in numans  until 20 to 30 years

after exposure, in which time large numbers of people may be

exposed; (2) mutagenic effects may go undetected in humans for

periods up to many years, and such effects  may cause  either

heritable genetic damage that can be passed on from generation  to

generation or lethal effects that result in abortion  or miscarriage;

and (3) teratogenic effects may be undetected in pregnant women but

may cause major structural malformations or mental retardation  in

offspring.

2.2  Determinants of Exposure

     2.2.1  Persistence

     Persistence describes the longevity of the hazardous substance

in the environment.  This characteristic of a hazardous substance is

included because the more resistant a substance is to environmental

degradation, the greater the potential period of exposure.
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     2.2.2  Routes of Release




     The routes by which hazardous substances can be released from




wastes sites are important because the route of release from a site




dictates the mode of exposure to humans and the environment.  Routes




of release generally include ground water, surface water,  and air,




but may also include direct exposure to the waste without  a release




to the environment.  The modes of exposure, therefore,  are ingestion




(oral), breathing (inhalational), and direct contact (dermal).




     2.2.3  Presence of Incompatible or Reactive Mixtures




     An assessment of the ability of multiple substances in a wastes




site to react to produce either additional (new) hazardous




substances or fires and/or explosions is important.  These reactions




may result in the danger of injury to persons in the immediate




vicinity, the release of new hazardous substances, or a change  in




the rate of migration of hazardous substances from the  site.




2.3  Use of Data




     2.3.1  Number of Hazardous Substances Evaluated




     The number of individual hazardous substances or chemical




species that are used in ranking sites is important in  order to




understand how each system assesses the overall hazard  of  the site.




Many wastes sites contain more than one hazardous substance or




chemical species and the total hazard to health or the  environment




is dependent upon all hazardous substances to which exposure occurs.
                                 11

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     2.3.2  Quantity of Data Required on Each Hazardous Substance




     The amount and availability of data required for each hazardous




substance assessed at a release site can greatly affect the ability




of an individual to use the system.  How problems, such as lack of




sufficient data, are handled by the ranking system is very important




because the toxicity data base is a central feature for assessing




the hazards inherent in each substance.  Easily available information




is required; extensive data requirements can lead to an impractical




system due to increased expenditures of time or money without




commensurate benefits (i.e., ability to discriminate among sites).




     2.3.3  Clarity and Ease of Use




     Not  only is the simplicity with which the toxicity factor(s) of




each system is derived important, but also how clearly the directions




and the  rationale for their use are presented.  Effective use of any




ranking  system requires consistency that must be based on an




understanding of how the system functions.  Misunderstanding or




misinterpretation due to ambiguity in descriptions or directions may




lead to  inconsistent scores and improper ranking of sites or wastes.
                                 12

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3.0  EVALUATION OF THE EPA HAZARD RANKING SYSTEM AND COMPARATIVE
     OVERVIEW OF SELECTED OTHER SYSTEMS

3.1  Environmental Protectlog Agency Hazard Ranking System (EPA HRS)

     The EPA HRS was designed to identify releases or threatened

releases of hazardous substances as national priorities for further

investigation and possible remedial action.  The system was

described and promulgated in the July 16, 1982 Federal Register

(47 FR 31219).

     3.1.1  Type of Toxic Effect

     3.1.1.1  Acute Toxicity.  In the EPA HRS, toxicity is evaluated

using either the rating scheme developed by Sax (1975, 1979 and

1984) or the rating scheme developed by the National Fire Protection

Association (1977).  These toxicity rating schemes are, in general,

based on the acute lethal dose (LD,_0)* of a substance.  The Sax

reference provides toxic hazard review (THR) values for the

substances contained in the compendium.  Each substance is assigned

a THR value from 0 (no data or an ID   above 40,000 mg/kg) to 3

(an LDrn less than 400 mg/kg).  These criteria have changed over

time with each new edition of the Sax reference (1975, 1979 and

1984).   The toxicity value is combined with a persistence value

(c.f. 3.2.1.5) in a matrix to provide a toxicity/persistence factor

value.
      is the dose of a substance that causes 50 percent of the exposed
 experimental animals to die.
                                 L3

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     There are several shortcomings in the use of the Sax rating




system for HRS purposes.  The THR values in Sax are apparently based




on the L^cf, although other (chronic) criteria for assigning THR




values are discussed in the introductory material.  Often, the only




THR values given in Sax are based on the most sensitive mode (route)




of administration, including injections into the abdomen (intra-




peritoneal), directly into veins (intravenous), or beneath the skin




(subcutaneous).  These routes of administration are shortcomings for




the assessment of the toxicity of substances from hazardous wastes




sites because the expected human exposure routes at these sites are




oral, inhalational, or dermal routes.   In addition, it is not




possible to verify the appropriateness and accuracy of the THR




values presented in the Sax data base because the specific data used




to evaluate the toxicity of a given substance are not indicated.




(See Section 3.1.1.2 for a further discussion of the Sax evaluation




system.)




     In the EPA HRS, toxicity is evaluated for each environmental




route of migration (ground water, surface water, and air) according




to the toxicity and persistence of the most toxic substance




identified at the site which is available to migrate via that




migration route.  (See Section 3.1.2.1 for a discussion of toxicity/




persistence values.)  Although data are not available to determine




the actual distribution of toxicity/persistence values that have




been assigned to all wastes sites ranked using the HRS,  it is
                                 14

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apparent from data for NPL sites that there is  little  variation in




the toxicity values assigned among NPL sites.   Table 1 presents the




distribution of toxicity/persistence values (for  the ground  and




surface water migration routes) and toxicity values (for  the air




migration route) that have been assigned to 888 NPL sites.   Nearly




90 percent of the NPL sites have had the maximum  toxicity value




assigned.  (Toxicity/persistence values of 18 can result  only from




maximum toxicity values of 3.  Toxicity/persistence values of 15,  12




or 9 may or may not result from a maximum toxicity value.  For




example, a toxicity/persistence value of 15 can result from  a




toxicity value of 3 and persistence value of 2  or vice versa.)




Table 1 illustrates that the toxicity factor of the present  EPA HRS




provides little discrimination among NPL sites  based on the  toxicity




of the substances present.  These data do not,  however, indicate the




effect of toxicity values on the ability of the current HRS  to




discriminate between NPL and non-NPL sites.  It is possible  that low




toxicity values do, in fact, assist in discriminating  non-NPL from




NPL sites.  Data to prove or disprove this have not been  compiled.




     3.1.1.2  Chronic Toxicity.  In effect, the EPA HRS does not




consider chronic toxicity in the ranking of hazardous  wastes sites.




According to the scheme presented in Sax (1975, 1979 and  1984),




chronic toxicity appears to be a consideration  in the  evaluation (by




Sax) of the toxicity potential of a compound.   In point of fact, the
                                 15

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                                 TABLE 1

             DISTRIBUTION OF HRS TOXICITY/PERSISTENCE FACTOR
                        VALUES AT NPL FACILITIES*
Toxicity / Pers is tence
Values for
Water Routes
18
15
12
9
6
3
0
Total:
Toxicity
Value for
Air Route
3
2
1
0
Total:
Number of NPL Facilities
Ground Water Surface
No. % No.
776 84 641
80 9 40
65 7 50
10 2
00 0
00 0
922 100 733

Water
%
87
5
7
0
0
0
100
Number of NPL Facilities
Air
No.
130
3
0
133
Air
%
98
2
0
100
*Represents data on 951 NPL facilities  through Final  Update  3/4.
                                 16

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values assigned to substances in the Sax compendium are derived




primarily on the basis of LDcn values as stated in the Preface to




that compendium and not on the basis of chronic toxicity




considerations (Sax, 1984).




     Thus, the values in Sax (and, therefore,  the EPA HRS toxicity




factor wherein the Sax THR values are used) are not generally based




on information about chronic toxicity.  This is a limitation for




adequate assessment of the potential danger associated with




substances released by any route of migration.




     3.1.1.3  Carcinogenicity, Mutagenicity, and Teratogenicity




(GMT) Potential.  The EPA HRS does not consider the potential of a




hazardous substance to produce GMT effects in  the ranking of




hazardous wastes sites.  This is a shortcoming for adequate




assessment of the potential danger associated  with hazardous




substances released by any route of migration.




     3.1.2  Determinants of Exposure




     3.1.2.1  Persistence.  The EPA HRS assigns persistence values




from 0 to 3 for hazardous substances based upon their resistance to




biodegradation.  Loss of substances from the site due to volatility




or environmental degradation such as hydrolysis or photolysis, are




not considered.  Substances that are easily biodegraded receive a




value of 0; those substances that are very persistent receive a




value of 3.  The EPA HRS provides a table of substances listed by




resistance to biodegradation.  If the substance in question is not
                                 17

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presented in the table, a set of persistence criteria are provided

to help the individual evaluating a site to assign a persistence

value based on chemical structure.  The persistence value is used in

a matrix with the toxicity value to provide a single toxicity/

persistence value, which ranges from 0 to 18, for use in the surface

water and ground water migration routes of the EPA HRS, but not in

the air route.*  Although consideration of the persistence of a

substance is an important feature of the EPA HRS, the persistence

factor has limitations because only biodegradation is considered in

the evaluation.

     3.1.2.2  Routes of Release.  The EPA HRS describes the possible

migration routes by which substances can be released from hazardous

wastes sites including releases to ground water, surface water, and

the atmosphere.  A hazard score for each migration route is

calculated and the three migration route scores are combined to

provide an index of the hazard to people or the environment due to

migration of substances away from the site.  Consideration of

multiple routes of release of a chemical is a strong point of the

EPA HRS.

     3.1.2.3  Presence of Incompatible or Reactive Mixtures.   This

factor applies only to the HRS air route and is used to assess the

potential of substances present in wastes sites to react,  thereby
 *Since  persistence in  the EPA HRS is based solely upon resistance to
  biodegradation  (i.e., via microbial metabolism), it is not combined
  with the  toxicity value in the air patuway.

-------
producing either new toxic substances or explosions which further




the release of toxicants.   Incompatibility is assigned values




from 0 to 3, where zero indicates that no incompatible substances




are present and three indicates that incompatible substances are




both present and pose an immediate hazard.  Examples of both




incompatible substances (designated Groups A and B) and their




consequences include:  (1) a mixture of metals such as sodium




(Group A) with acids (Group B) which could generate flammable




hydrogen gas, (2) a mixture of spent cyanide (Group A) with acids




(Group B) which could generate toxic hydrogen cyanide, and (3)  a




mixture of chlorates or chlorites (Group A) with corrosive acids




(Group B) which could generate chlorine gas.




     The National Fire Protection Association (NFPA, 1977) rating




for reactivity is used to evaluate the reactivity of materials  at




wastes sites.  For example, reactivity values range from 0 for




materials that are normally stable even when exposed to fire and




that are not reactive with water, to a value of 3 for materials that




are readily capable of detonation, explosive decomposition, or




explosive reaction at normal temperatuccs.  The larger of the




assigned incompatibility value or the reactivity value is used  for




this factor in the HRS air migration route.




     3.1.3  Use of Data




     3.1.3.1  Number of Substances Evaluated.  The EPA HRS selects




the substance with the highest toxicity/persistence value (discussed
                                 19

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above) for the ground and surface water routes or the substance  with




the highest toxicity value for the air route in scoring a migration




route.  This approach provides a conservative estimate of the




potential hazard presented by wastes sites that contain more than




one substance.  It is apparent that this approach has resulted in a




NPL where many sites receive a maximum toxicity/persistence value




and, therefore, where discrimination based on toxicity among sites




ranking high enough to be placed on the NPL is low.




     The combined toxicity/persistence values for 16 substances  most




frequently used to score the migration routes at 951 NPL facilities




are presented in Table 2.  A total of 13 of the 16 substances have




an assigned toxicity/persistence value of 18; the remaining three




substances have toxicity/persistence values of 15 or 12.  The data




distribution is similar for the air migration route.  The result of




this skewed distribution is that nearly 90 percent of NPL sites




received the highest possible toxicity/persistence value (Table  1).




Consequently, there is virtually no discrimination among NPL sites




based on the toxicity/persistence values.  However, tnis does not




imply that the toxicity/persistence values do not discriminate




between NPL and non-NPL sites.  Data to prove or disprove this are




not currently available.




     3.1.3.2  Quantity of Data on Each Substance.  The EPA MRS




depends primarily upon the rating system and toxicity data base




developed by Sax.  The current edition (Sax, 1984)  contains
                                 20

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                                  TABLE  2

      SUBSTANCES MOST  FREQUENTLY*  USED TO ASSIGN TOXICITY/PERSISTENCE
                      FACTOR  VALUES AT NPL FACILITIES
Frequency of Use
Substance
Lead and Compounds, NOS
Polychlorinated Biphenyls, NOS
Chloroform
Chromium and Compounds, NOS
Arsenic and Compounds, NOS
Cadmium and Compounds, NOS
Pentachlorophenol
Carbon Tetrachloride
Mercury and Compounds, NOS
Benzene
1,1, 2-Trichloroethylene
1 ,1-Dichloroethene
Zinc and Compounds, NOS
Copper and Compounds, NOS
Chromium, Hexavalent
DDT
Vinyl Chloride
Ground
Water
180
126
119
93
86
55
37
46
34
13
27
32
22
21
17
12
16
Surface
Water
153
117
79
75
67
47
34
23
31
13
20
6
19
17
14
14
6
Air
8
15
8
0
6
5
2
2
3
23
1
3
0
0
0
2
6
Tox/Per
for Water
Routes**
18
18
18
18
18
18
18
18
18
12
12
15
18
18
18
18
15
Toxicity
for Air
Route***
3
3
3
3
3
3
3
3
3
3
2
3
3
3
3
3
3
  *Most frequently is determined by the sum of  the  total  number  of
   migration routes of the 951 NPL facilities  (through Final  Update  3/4)
   for which each substance was used to assign  an HRS  rating  factor  value
   for toxicity.  Only those substances used at least  25  times are shown.
 **Toxicity/persistence rating factor value for ground and  surface water
   migration routes.
***Toxicity rating factor value for air migration route.  This is combined
   with a multiplier  (3).
                                 21

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information on approximately 18,000 substances.   In the event no




data are available for a substance, that substance is assigned a




value of 0.  This allows substances with known toxicity to receive




higher rating values than those for which it is unknown.  Hie




consequence is that sites are rated based on known hazards rather




than on unknowns.




     3.1.3.3  Clarity.  The EPA HRS clearly describes  how wastes




sites are evaluated for their potential to cause adverse human health




or ecological effects for the purpose of priority ranking.   Detailed




instructions are provided, as are definitions and descriptions of




the components contained in the EPA HRS.  References,  graphics, and




examples are included, which guide the reader through  the use of the




system.  Worksheets for the routes of exposure are provided.




3.2  Comparative Review of Selected Ranking Systems




     A  detailed description and analysis of eight other ranking




systems is provided in Appendices A through H.  The following




paragraphs summarize that information.  Although each  of the eight




other ranking systems that were evaluated is designed  to protect




people  from the dangers associated with hazardous substances, there




are important differences in the kinds of substances to be evaluated




and the immediate objective of the hazard ranking.  b'or instance,




the plan developed by the European Economic Community  (EEC)




(Schmidt-Bleek et al., 1982) is designed to predict the dangers to

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public health from new chemicals that might be produced by chemical




companies prior to their being manufactured on a large scale.   The




Preliminary Pollutant Limit Value (PPLV) Method (Rosenblatt et al.,




1980, 1982) is designed to determine the acceptable level of cleanup




at a contaminated site.  The EPA HRS and Michigan's Site Assessment




System (SAS) (Michigan, 1983) are designed to assign priorities for




further investigation and possible cleanup of hazardous wastes




sites.  The RCRA Hazardous Waste Scheduling Methodology (RCRA)




(Environ, 1985) is designed to schedule substances for further study




as to whether they should be banned from land disposal.  The CERCLA




Reportable Quantities (RQ) Methodology (Environmental Monitoring and




Services, 1985) is designed to identify those quantities of released




substances that require mandatory notification so that the need for




Federal removal or remedial action can be assessed.   Due to the




differences in purpose of each of the systems,  there are differences




in the ways in which the relative danger to people is assessed.




These differences include consideration of different aspects of




toxicity of substances, differences in toxicity data requirements,




and differences in both the required expertise of the individuals




doing the evaluation and the extent of professional judgment




permitted.  Table 3 presents a comparative summary of each of the




ranking systems reviewed in this document.  The following paragraphs




present an overview of the findings.  Details are discussed in




Appendices A through H.
                                 23

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                                            TABLE 3
                         COMPARATIVE EVALUATION OF TOXICITY FACTORS
                       AMONG SELECTED HAZARDOUS WASTE  RANKING SYSTEMS
Parameter
Evaluated
Acute Toxicity
Chronic Toxicity
CMT
Persistence
Routes of Release
Incompatible Mixtures
Number of Chemicals
Used in Ranking
Quantity of Data
Clarity/Ease of Use
RanlHne Svst.em* 	 	
HRS
+
-
-
+c
+
+

1
Mod
High
SAS
+
+
CMT
+
+
-d

all
Mod
High
HARM II
+
_
_
+c
-e
-

all
High
Low
RCRA
+
+
C
-
-
-

1
Low
Mod
EEC

b
M
+
+
_

1?
N/A
Low
SPACE
+a
-
-
+a,c
+
+?

5
Mod
High
RO
+
+
CT
+
-
-d

individual
Low
High
PPLV
_
+
-
+?
+
-

individual
High
Low
SPHE
_
+
C
+
+
-

10-15
High
Low
7 =
a
b
c
d
e =
      present in ranking system
      absent from ranking system
      discussed but no guidance for use is provided
      uses HRS methods
      based on subchronic (28 day) NOEL
      considers only biodegradability
      addresses reactivity and ignitability of individual chemicals
      includes ground and surface water routes only
N/A = not applicable
CMT = Carcinogenicity, Mutagenicity,  Teratogenicity

   *HRS = Hazard Ranking System (EPA,  1982)
    SAS = Site Assessment System (Michigan, 1983)
HARM II = Hazard Assessment  Rating Methodology (Barnthouse, 1986)
   RCRA = Resource  Conservation and Recovery Act Hazardous Waste Scheduling Methodology
          (Environ,  1985)
    EEC = European  Economic  Community  (Schmidt-Bleck et al., 1982)
  SPACE = System for Prevention,  Assessment and Control of Exposure (CDC, 1984)
     RQ = Reportable Quantities (Environmental Monitoring and Services, 1985)
   PPLV = Preliminary Pollutant Limit  Values (Rosenblatt et al., 1980, 1982)
   SPHE = Superfund  Public Health Evaluation Method (ICF, 1985)

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     3.2.1  Types of Toxic Effect




     3.2.1.1  Acute Toxicity.  Six of the systems evaluated (HRS,




SAS, HARM II, RCRA, SPACE and RQ) include consideration of acute




toxicity.  All of these systems use U>50 or LC5Q data from




experimental animals as a basis for scoring.   Although the EEC plan




does not assess acute toxicity per se, it is  the only system that




evaluates substances based upon dermal sensitization.




     3.2.1.2  Chronic Toxicity.  Six of the systems  evaluated (SAS,




RCRA, EEC, RQ, PPLV and SPHE) assess the chronic toxicity of




substances by one of two methods.  The SAS, RQ,  SPHE and EEC systems




use either the magnitude of the lowest dose that caused an




irreversible toxic effect or the magnitude of the highest dose that




caused no toxic effect in groups of experimental animals during




chronic (SAS, RQ and SPHE) or subchronic (EEC) tests to obtain a




score.  In the case of the RQ method, the toxicity score is the




product of a value based on the dosages and a severity index score




which describes the seriousness of the observed  effect.  Reproductive




and teratogenic effects are considered as chronic effects.  In




contrast to the four systems mentioned above, the RCRA and PPLV




systems assess chronic toxicity based upon modifications of a




technique used to calculate the acceptable daily intake (ADI) of




toxic substances.  (This technique is described  in Section 4.1.2.)




     Of these two methods of assessing chronic toxicity, the ADI




method is more rigorous because it systematically uses the most
                                 25

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appropriate toxicity data that are available.  If human data are




available, they are used to determine the ADI.  If human data are




not available, chronic animal data are used.  If chronic animal data




are not available, subchronic data may be used.   If subchronic data




are unavailable, acute data may be used.  With each type of data, a




different safety factor (discussed in Section 4.3.2) is applied




according to a predetermined set of rules.  The other method (used




by SAS, RQ, SPHE and EEC) has no such hierarchy of data use.




     3.2.1.3  Carcinogenicity, Mutagenicity, and Teratogenicity




 (GMT)  Potential.  Among the nine systems evaluated, only SAS




 considers all three CMT effects.  SAS scores chemicals for GMT




 effects based upon the weight-of-evidence.  If a substance is a




 proven human carcinogen, mutagen, or teratogen,  it receives the




 highest score.  Decreasing scores are assigned based on decreasing




 strength of evidence (e.g., proven animal carcinogen; suspected




 animal carcinogen; mutagenic in short term test).  Although the




 weight-of-evidence method does not discriminate between strong and




 weak carcinogens, it has the advantage of a predetermined, objective




 set of criteria by which substances are scored.   Tiis makes the




 weight-of-evidence approach easy to apply.




     Ihe EEC plan considers the mutagenicity of substances.  Scores




 are assigned based on the weight-of-evidence from short term




 mutagenicity tests.  Circinogenicity and teratogenicity are not




 addressed.
                                 26

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     Both the SPUE and RCRA methods score substances for carcinogenic




potential based upon animal test data.  The SPHE method requires




calculation of the ED,.,, (the dose which causes a 10 percent




increase in cancer incidence among treated animals).  The RCKA




method entails calculation of carcinogenic potencies and unit cancer




risks (see Appendix F for details).  The RCRA approach depends upon




good animal data and the choice of the appropriate mathematical




model to obtain low-dose extrapolations from high-dose test data.




There are several models available for such extrapolations including




linear extrapolation to the origin (zero dose),  probit (Mantel and




Bryan, 1961), single hit (Turner, 1975), multi-hit (Turner, 1975),




multi-hit multistage (Armitage and Doll, 1%1),  and multistage with




dependent dose patterns (Crump and Howe, 1984) models.  All have




different assumptions and give different results at low doses.




     The RQ system considers both teratogenic and carcinogenic




effects.  Teratogenic effects are defined as chronic toxicity




effects and, therefore, are included under consideration of chronic




toxicity scoring.  For carcinogenic effects, the RQ system combines




the qualitative weight-of-evidence scores in a matrix with relative




carcinogenic potencies derived from animal data to arrive at a




relative hazard score for potential carcinogens (Cogliano, 1986).




Mutagenic effects are not considered.

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     Of the approaches outlined above, the combined weight-of-




evidence with ED-, Q approach (RQ methodology) appears most




appropriate for hazard ranking of potential carcinogens.   This




methodology is objective, easy to apply, and it provides a measure




of carcinogenic potency while avoiding much of the scientific




controversy currently surrounding topics like the choice of




appropriate low-dose extrapolation models for calculating




carcinogenic potency.




     3.2.2  Determinants of Exposure




     3.2.2.1  Persistence.  All of the systems evaluated except the




RCRA method consider the environmental persistence of chemicals.




However, three of the systems (HRS, HARM II, and SPACE) consider




only biodegradation; the EEC plan gives only vague guidelines for




assessing persistence; and the PPLV method states that persistence




is an important consideration, but gives no guidance at all.   The RQ




method restricts persistence to loss from the environment by biode-




gradation, hydrolysis, or photochemical decomposition.  The SPHE and




SAS methods score persistence based on the half-life of the substance




in various environmental media regardless of the mechanism of loss.




(The SPHE document contains a table of half-lives of many substances




in an appendix.)




     Among the systems, the most appealing method is that used by




SAS and SPHE because several types of degradation (e.g.,  hydrolysis




in water and photolysis in air) are considered.  However,  SAS does
                                 28

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not identify data sources for this information.  SPHE provides a




look-up table for scores for selected chemicals, but it does not




consider volatility.  Thus, there is no system which has




satisfactorily outlined criteria or data sources for scoring




persistence for a wide range of substances from all types of




environmental degradation.




     3.2.2.2  Routes of Release.  Seven systems consider routes of




release of hazardous substances from the sites.  The two systems




which do not consider routes of release (RCRA and RQ) were designed




to consider the danger associated with a particular substance,




independent of the route of release.




     3.2.2.3  Presence of Incompatible or Reactive Mixtures.  The




EPA HRS is the only system that gives guidance concerning the




reactivity and incompatibility of mixtures of substances since it




provides guidance in terms of classes of substances (e.g., alcohols




mixed with metal hydrides).  SPACE instructs individuals using the




system to determine whether or not there are incompatible substances,




and if so, whether they are safe distances apart; however, SPACE




provides no guidelines for performing this type of assessment.




     Both the SAS and RQ methods present criteria to help assess the




reactivity and ignitability of individual substances, but not of




mixtures of substances.
                                 29

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     3.2.3  Use of Data




     3.2.3.1  Number of Substances Evaluated.   Five of the systems




evaluate either "the most toxic" substance (MRS,  RCRA) or are




designed to evaluate one substance at a time (EEC, RQ and PPLV).




Two systems (SAS and HARM II) evaluate all substances identified.




Of the other two systems, SPACE evaluates the  five most toxic




substances; and SPHE evaluates 10 to 15 substances.   Thus, seven  of




the nine systems consider one extreme or the other in numbers of




substances per site (i.e., one or all).




     In order to get a more characteristic toxicity profile of a




site, it would be more appropriate to evaluate more than one




substance per site.  Although evaluation of all suostances at a site




would provide the most complete toxicity profile,  the methodology




becomes unwieldy due to the potentially large  number of calculations




necessary.  Ihe formula prescribed by SPACE, which evaluates the




five most toxic substances, appears to be a reasonable compromise




while still providing a toxicity profile.




     3.2.3.2  Quantity of Data on Each Substance.   Only three of  the




methodologies (HARM II, PPLV and SPHE) require extensive amounts  of




data to score the substances in question.  These systems require




additional information and calculations, such  as tue tabulation of




multiple physical and chemical characteristics (e.g.,  vapor




pressure, solubilities in various solvents and partition




coefficients), or tabulation of the results of multiple toxicity

-------
tests in multiple species of laboratory animals,  or the selection of




"structural analogues" of the substance under consideration and the




tabulation of data for those analogues.




     3.2.3.3  Clarity.  Among the nine systems evaluated,  five (MRS,




SAS, RCRA, SPACE and RQ) are straightforward, logical,  and easy to



use.  Die EEC plan provides too little guidance to evaluate many




factors.  Both the PPLV and HARM II systems require many data



manipulations and calculations that make the systems difficult to




use.  Both the SPHE and PPLV systems leave many aspects of the




assessment to the "professional judgment" of the individual doing




the assessment.  This allows results derived using those methods to




be subjective and less consistent than the other systems.
                                 31

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4.0  RECOMMENDATIONS FOR IMPROVEMENT TO THE MRS TOXICITY FACTOR

     Both public comments on the EPA HRS and the present evaluation

of how the EPA HRS toxicity factor is scored have called attention

to the limitations of the system in assessing toxicity.   The EPA HRS

toxicity factor is based primarily on information contained in Sax

(1975, 1979 and 1984), which generally uses acute toxicity data (the

lowest mammalian I*Dirn)«  The toxicity factor is combined with

environmental persistence by means of a matrix to provide a toxicity/

persistence value which is used in the calculation of surface water

and ground water migration route scores.  The toxicity value is not

combined with persistence in the air route.

     As discussed in the preceding sections of this report, the

major limitations of the EPA HRS with respect to the toxicity factor

include the following:

     •  The evaluation of toxic effects relies heavily on Sax to
        assign toxic hazard ratings.  Since Sax does not specify the
        rationale for each assigned value, it is not possible to
        verify his values.

     •  Chronic toxicity is not usually considered.

     •  CMT effects are not considered.

     •  There is little discrimination among the most toxic
        subs tances.

     Although the overall objective of modifying the HRS toxicity

factor is to design a system that would address these limitations

and would thereby better reflect the relative hazards posed by the

toxic substances at waste sites, soiae important constraints were
                                 33

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identified.  In particular, the methodology must be easy to apply




(i.e., a low level of toxicological expertise should be required);




the system should use methodologies that have been approved by the




scientific community; and where possible, the system should use




readily available toxicity data.




     In order to address the limitations and conform to the




constraints, the following sections present several recommended




modifications to the EPA HRS and the rationale underlying them.




4.1  Framework for Considering Toxicity




     Prior to discussing the methodologies which are available for




the assessment of the various aspects of toxicity, a framework is




presented within which the toxicity of a substance may be considered.




Since systemic toxicity is, to a large extent, dependent upon both




rate and amount of a substance which enters the body, the tozicity




of a substance can be affected by its mode of entry into the body.




The major routes by which substances enter the body are via the




lungs, the gastrointestinal tract, and the skin.  Each of these




routes differs in the efficiency with which it will absorb a




substance and the tide that it takes for absorption to occur.  For




instance, many substances that are absorbed well via the




gastrointestinal route are not absorbed (or are absorbed extremely




slowly and to a small extent) via the skin.  Such substances could




exert toxic effects if ingested, but toxicity would not be observed
                                 34

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if the exposure were only via the percutaneous route.   Therefore,  it

seems appropriate to assess toxicity factors based upon the expected

mode of entry into the body.  If substances are expected to be

ingested, a toxicity factor based upon the oral toxicity is

appropriate, whereas if substances are expected to be  inhaled, a

toxicity factor based upon inhalational toxicity is appropriate.

     The capacity of a substance to cause damage can be either acute

in nature, that is, occurring shortly after the agent  has been

applied to the organism, or the effects may be chronic in nature.

For the purposes of the present analysis, chronic effects are

considered as those that are generally manifested after long-term,

low-level exposure to a chemical.  Chronic effects can be divided

into two broad categories:  non-neoplastic chronic effects* and

carcinogenic and mutagenic (CM) effects.  This framework is

displayed schematically below.

     Toxicity      = f [acute toxicity + chronic toxicity + CM]

4.2  Type of Toxic Effect

     4.2.1  Acute Toxicity

     Toxic effects subsequent to acute exposure are of special

relevance to people who may be exposed accidentally to high

concentrations of substances for a brief period at or  near  hazardous

wastes sites.  For the purposes of this analysis, an acute  exposure
*For reasons to be discussed below,  developmentally toxic effects
 (including teratogenic effects) will be considered as non-neoplastic
 chronic effects.
                                 35

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is defined as exposure to a single dose over a short period




(24 hours or less).  Ihe acute toxicity of hazardous substances is




generally assessed through the use of I^CQ or LC   tests in




laboratory rodents.  Indeed, the most frequently determined index of




toxicity is the LD5n»  An LD5Q may be calculated for oral,




dermal, subcutaneous, intravenous, intraperitoneal, or other routes




of exposure (LC50 for inhalational route).  The EPA HRS toxicity




factor is based on the LD5Q appropriate for the route of exposure




(e.g., LD-Q [oral] for drinking water) when it is available.  If




the pathway-specific LDc0 is unavailable, the factor is based on




the lowest LI>cn value available, regardless of mode of exposure.




     Since exposure to substances present at wastes sites generally




occurs only via oral, dermal, and inhalational modes, it is




inappropriate to assign acute toxicity scores based on data from




other than these modes of exposure (e.g., intraperitoneal,




intravenous or subcutaneous injection data are not appropriate) .  It




is recommended, therefore, that three acute toxicity values be




assigned  to a substance, one for each relevant mode of exposure




(oral, dermal and  inhalational).  For oral or dermal exposures,




LD5Q data should be used; for substances which will be inhaled




(including vapors, gases, dusts or mists) LC . data should be used.
      The  lowest  reported mammalian LDcg or ^50




 appropriate mode of exposure should be used.  This assumes that




 humans will respond to the hazardous substances in the same way as
                                 36

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the most sensitive test mammal.  Such an assumption is conservative




in that it may overstate risk.  If a mammalian LDcQ (LC5Q^ is



not available, use of an LD,  (LC, ) is recommended.  In the
                           lo    lo


case of substances for which oral, dermal or inhalational LD^Q



(LC5Q) data are not available, guidelines for establishing toxicity



values based upon either dermal or ocular irritation are presented



in Table 4.  The assigned acute toxicity values range from 0 to 3



and are based upon EPA toxicology guidelines, including break points,



as summarized by Ashton (1982).  In the event that no acute toxicity



data are available, use of the toxicity value obtained for chronic



toxicity (discussed in Section 4.2.2) for the same route of adminis-
tration is recommended.  In the above scheme, the LDi-n (-^cn) of



the most sensitive mammal listed in the NIOSH Registry of the Toxic



Effects of Chemical Substances is used to assign a toxicity value.



     In the event that inhalational or dermal data are not available,



the toxicity value for the dermal or inhalational route defaults to



the toxicity value obtained via the oral route.  Defaulting to that



value does not imply a physiologic or mechanistic rationale for



assigning an equivalent LC^.) or dermal LDcn from orally derived



data.  Rather, the default to the oral toxicity value is used



instead of defaulting to 0.



     In the absence of toxicity data, a default to a score of 0 is



the procedure that is followed in the current HRS.  The rationale



for this default value is that sites would then be scored on the
                                 37

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                                                    TABLE 4
                  PROPOSED ACUTE TOXICITY VALUES FOR ORAL,  DERMAL AND INHALATIONAL EXPOSURES*
03
•Acute Toxic Effects
Inhalatlonal LC$Q**
Oral LD5o
(me/ke)
>5,000
Dermal LDgg
(me/kK)
>20,000
Dust
or Mist
(mi/liter)
>200
Gas or
Vapor
>20,000
Dermal
Irritation
No irritation
Ocular
Irritation
No irritation
Acute
Toxicity
Value***
0
                                                            within 72 hours  within 72 hours
          >500
         5,000
           >50
           500
           <50
>2,000-
20,000
  >200-
 2,000
  £200
>20
200
 20
>2,000-  Mild or slight
20,000   Irritation
         within 72 hours
  >200   Moderate
 2,000   irritation
         within 72 hours
           £200   Severe
                   irritation  or
                   damage within
                   72  hours
No corneal opacity;
irritation
reversible within
72 hours

Corneal opacity
reversible within
7 days, or irritation
persisting for 7 days

Corneal opacity
irreversible within
7 days
        *Adapted from U.S.  EPA Toxicology Guidelines, summarized by Ashton, 1982.
       **The exposure period  for acute  inhalational studies is normalized to 4 hours using Haber's law
         which states that  the product  of exposure concentration and period of exposure is a constant
         (Ct»K).
      ***If LDso or  LCso  data are unavailable, dermal or ocular irritation data can be used as
         indicated above.   If no acute  data are available, the chronic toxicity value for same mode of
         exposure is used.  If no toxicity data are available, assign a value of 0.

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basis of known toxic effects.  Hie issue of the appropriate default




value is one that could be revisited.  It is possible that a default




to the highest value (3) could be assigned.  Such a value would tend




to overstate most dangers.  If the MRS were to be used in a




regulatory decision to establish allowable levels of a substance in




the environment, the appropriate default seems to be one of a higher




toxicity value in order to be conservative and to protect the public




from unknown, potential danger.  However, since the HRS is used as a




screening tool to decide where additional resources should be




allocated for further study (remedial investigation), a default to a




score of 0 appears more appropriate because the sites would be scored




on the basis of known dangers.




     In addition to considering how acute toxicity may be assessed,




it is appropriate to consider to what extent the acute toxicity




value should affect the total, value for assessment of toxicity for a




particular substance.  For instance, it is not expected that members




of the general public would be exposed to large single doses of




substances from abandoned hazardous waste sites; however, this is




the exposure regime for acute toxicity studies in animals.  This




could be the basis for an argument to remove acute toxicity from




consideration in determining the HRS toxicity value that is assigned




to a hazardous substance.  On the other hand, acute toxicity data




are the most commonly available data and may provide the best common




ground on which to compare chemicals.  It is recommended that acute

-------
toxicity be included in the determination of the toxicity  factor




value; however, acute toxicity should not carry as much weight  as



chronic toxicity in that determination.




     4.2.2  Chronic Toxicity




     It is recommended that chronic toxicity parameters for each




mode of exposure (oral, dermal and inhalational) be added to the EPA




HRS.  The chronic toxicity parameters should be based upon the




maximum daily dose of a substance that is anticipated to not pose a




risk to adult (70 kg) humans after lifetime (70 years) exposure.




The ADI method has been used to recommend regulatory limits and




safety standards for maximum daily exposure to toxic substances in




human food supplies and drinking water by various national and




international scientific advisory and regulatory agencies including




the U.S. EPA, the U.S. Food and Drug Administration, the Food and




Agriculture Organization, and the World Health Organization (Kilgore




and Li, 1980).  The method is usually restricted to noncarcinogenic




substances because it assumes there is a threshold dose for each




substance below which there is no adverse effect.  The assumption of




a threshold is not widely accepted for carcinogens.




     The ADI is based on a No Observed Effect Level (NOEL) and a




Margin of Safety (MOS).  The NOEL is obtained from chronic or




subchronic experiments in laboratory animals.   The NOEL is the



highest dose of a substance, in a series of dose levels tested, at



which no adverse effect is detected in treated animals compared to
                                 40

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untreated control animals.  The ADI is calculated from the NOEL by

dividing by the MOS; i.e.,

                           ADI = NOEL/MOS

     The MOS is a factor that converts an apparently safe daily dose

in laboratory animals to a presumed safe daily dose for humans.  The

MOS is the product of several safety factors and ranges from 10

to 10 .  The safety factors (e.g., f.,, f-, . . . f ) are

commonly, but not always, each equal to 10.  A summary of the

justification for using safety factors of 10 is presented in Kushner

et al. (1983), although other authors have suggested the use of

safety factors of alternative (usually smaller) magnitudes (Zielhuis

and van der Kreek, 1979).  In calculating the MOS, safety factors

are multiplicative (f.. x f» . . . x f ), and can account for

such uncertainties as (Klaassen, 1986):

     •  Variation in susceptibility among humans.

     •  Difference between the sensitivity of the test species and
        humans.

     •  Lack of confidence in the experimental data or less than
        ideal conditions (e.g., conversion of LOEL* to NOEL or using
        subchronic rather than chronic lifetime tests).

     Recently, the Office of Research and Development (ORD) of EPA

has assessed the chronic toxicity of substances through the

establishment of reference dose (RfD) values.  RfDs are established

for noncarcinogenic effects.  The RfD methodology is similar in
*LOEL = The lowest observed effect level.


                                 41

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concept to the ADI methodology.  The primary difference between ADI




and RfD methodologies is that RfDs are never calculated based on acute



data.  About  200 RfDs have been subjected to Agency-wide verification




(DeRosa, 1987), most of which have been based on oral exposures.




     Although MITRE concurs with the  scientific underpinnings  of  the




RfD methodology, the relatively small number of currently  available




RfDs and the  paucity of chronic data  for  substances listed at  hazardous




waste sites require that a more flexible method be  used to evaluate




the relative  chronic toxicity  of substances.   In cases where the  only




toxicity data available for a  substance are acute toxicity data,  it is




a mistake for a screening tool (such  as the HRS) to postpone assessing




the hazard until appropriate data become available  or to use an




arbitrary default value.  Therefore,  it is  recommended that in cases




where RfDs are available they  be used as described  in Section  4.2.2.4,




and that when they are not available, an ADI be calculated to  assess




the relation  chronic toxicity.




     The recommended methods for calculating ADIs for substances  based




upon exposure via ingestion, direct contact, or inhalation are




presented below.




     The ^reat strength of the ADI is that  it uses  the best toxicity




data that are available.  Thus, if human data are available, they may




be used in the calculation of an ADI.  In the event  that human data are




not available, animal data are used.  Chronic and subchronic data are




preferred but, if necessary, acute toxicity data can be  used.   Note



that calculation of an ADI by this  method  is not presumed  to be



                                 42

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anything more than a means to derive a relative toxicity value for

use in the MRS.  It is not intended to actually set Acceptable Daily

Intakes.

     4.2.2.1  Calculation of an ADI;  Ingestion.  Calculation of an

ADI for ingestion uses toxicity data derived from studies of

laboratory animals exposed via the oral route when data for human

exposure are not available.  Studies which can be used to identify a

NOEL or LOEL (i.e., chronic or subchronic studies) are preferred for

this calculation because of the long term nature of the studies used

to calculate the NOEL or LOEL as opposed to the acute nature of the

studies used to determine other toxicity indices (e.g., ID-,,).

     The following guidelines (adapted from U.S. EPA, 1980) are

recommended as a Means of calculating an ADI for oral exposure from

data derived from a variety of experimental designs.

A.  NOEL Available

    If a NOELorai is available:

       ADIoral = NOELoral/MOS

    The MOS is calculated as follows:

    •  If human data are available, MOS = 10 (human variability)

    •  If only data for laboratory animals are available, MOS
       [10 (species extrapolation) x 10 (human variability)]

B.  LOEL Available

    If a NOELorai is not available but a LOELQra^ is available:

       ADIoral = LOELoral/MOS
                                 43

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    The MOS  is  calculated as follows:

    •  If human data  are available,  MOS » [10 (human variability)  *•
      10 (conversion of LOEL to NOEL)] - 102

    •  If only  data for laboratory animals are available,  MOS • [10
      (species extrapolation) x 10 (human variability) x 10
      (conversion of LOEL to NOEL)] - 103

    TDlo* Available

    If only  TD^0 oral data are available:

      ADIoral  - TDlo/MOS

    The  MOS  is  calculated as follows:

    •  If human data  are available,  MOS - [10 (human variability)  x
      100  (conversion of TDlo to NOEL)] » 103

    •  If only  data for laboratory animals are available,  MOS •
       [10  (species extrapolation) x 10 (human variability) x
       100  (conversion of TDlo to NOEL)] = 104

    LDlo**  or LD5Q Available

    If only LD^0 or LD^Q data are available:

       ADIoral  = LDlo/MOS or LD50/MOS

    The  MOS is  calculated as follows:

    •  If human data  are available,  MOS » [10 (human variability)  x
       1000 (conversion of LDlo or LD5Q to NOEL)]*** - 10^

    •  If only  data for laboratory animals are available,  MOS "
       [10  (species extrapolation) x 10 (human variability) x
       1000 (conversion of LDlo or LD5Q to NOEL)]  - 105
        = The lowest dose which causes a toxic effect in any animal in
          the test group.
 **LD^0 = The lowest dose which causes the death of any animal in the
          test group.
***The LD^0 of a substance is generally 1/10 the LD5Q value.
   However, since the LD^0 is a single observed mortality,  confidence
   in its value is weaker than in the LD^Q (which is calculated from
   statistical analysis).  Thus, an additional factor of 10 in the MOS
   (for conversion of LD^0 to LD5g) is effectively cancelled out by
   the difference in magnitude between the two values.

                                 44

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     4.2.2.2  Calculation of an ADI;  Dermal.  Calculation of an ADI for

exposure to substances by direct contact (dermal exposure) uses toxicity

data derived from studies of humans or laboratory animals exposed via the

dermal route over their lifetime.  Studies which can be used to identify

a NOEL or LOEL (i.e., chronic or subchronic studies) are preferred for

this calculation because of the long term nature of the studies conducted

to calculate the NOEL or LOEL as opposed to the acute nature of the

studies which provide other toxicity indices (e.g., LD^Q).

     The following guidelines (adapted from EPA, 1980) may be used to

calculate an ADI for dermal exposure from data derived from a variety of

experimental designs.

A.  NOEL Available

    If a NOEL
-------
C.  TDlo Available

    If only TDlo dermal data are available:

       ADIdermal = TDlo/MOS

    The MOS is calculated as follows:

    •  If human data are available, MOS  =  [10  (human  variability) x
       100 (conversion of TDlo to NOEL)] = 103

    •  If only data from laboratory animals are  available, MOS  -  [10
       (species extrapolation) x 10 (human variability) x 100
       (conversion of TDlo to NOEL)] " 10^

D.  LD^0 or LD5Q Available

    If only LD-L0 dermal or LDtjg dermal data are  available:

       ADIdermal " LDlo/MOS °r LD50/MOS

    The MOS is calculated as follows:

    •  If human data are available, MOS  =  [10  (human  variability) x
       1000 (conversion of LDlo or LD50  to NOEL)] = 104

    •  If only data from laboratory animals are  available, MOS  =  [10
       (species extrapolation) x 10 (human variability) x 1000
       (conversion of LDio or 11)50 to NOEL)] = 10^

     4.2.2.3  Calculation of an ADI;  Inhalation.  Calculation  of an

ADI inhalation uses toxicity data derived  from studies of laboratory

animals exposed via inhalation.  The Threshold Limit  Value-Time

Weighted Average (TLV-TWA)*, as defined  by the American Conference

of Governmental Industrial Hygienists (ACGIH,  1985),  is usually used

as the basis for the inhalational ADI calculation.  TLV-CL values
 *Threshold  Limit  Value-Time Weighted Average  (TLV-TWA) is defined as
  the maximum average concentration for a normal 8-hour workday and a
  40-hour workweek,  to which nearly all workers may be repeatedly
  exposed, day after day, without adverse effect.
                                 46

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are not to be used because they are not designed to protect people

from long term exposure, but rather to set a upper bound on exposure

levels which should not be exceeded.  If a TLV-TWA is not available,

the OSHA standard air TWA may be used.  TLV-TWA or OSHA standard air

TWA values are preferred for the calculation over data from nonhuman

laboratory studies using I£50, NOEL, or LOEL data because TLV-TWAs

and OSHA standard air TWAs are human estimates.

     The following guidelines (adapted from U.S. EPA, 1980) may be

used to calculate an ADI for inhalational exposure from data derived

from a variety of sources.

A.  TLV-TWA Available

    If a TLV-TWA is available:

       ADIinhalation = TLV-TWA(mg/m3) x 10 (m3/day) x 8/24 x
                       5/7 x (0.5)/MOS = 1.19 x TLV-TWA/MOS

where:

      10 m-Vday = Estimated amount of air breathed per workday

      8/24      = Conversion of an 8 hour workday to a 24 hour day

      5/7       = Conversion of a 5 day/week exposure to a 7 day/week
                  exposure

      0.5/1.0   = Efficiency of absorption of airborne chemicals from
                  air exposure (0.5) and from oral exposure (1.0)*

      MOS       = 10 to account for human variability
*Although many scientists believe that the efficiency of pulmonary
 absorption may be equal to that of gastrointestinal absorption, the
 assumption of 50 percent absorption decreases the magnitude of the
 calculated ADI and is, therefore, conservative in that it may
 overestimate risk.
                                 47

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B.  Animal Data Available

    If only animal toxicity data are available, the following

    formula may be used to calculate an ADIinhalation:

    ADIinhalation = CA x DE x d x  (0.5) x BRA x 70 kg/(BWA x MOS)

where:

    CA       =  Lowest reported concentration of  chemical in  the air
                (in mg/m^) that caused an effect

    DE       =  Duration of exposure  (hours/day)

    d        =  Number of days exposed/number of  days  observed

    0.5/1.0  =  Efficiency of absorption  of  airborne chemicals from
                air exposure  (0.5)  and from  oral  exposure (1.0)

    BRA      =  Volume of air breathed by the animal in one day
                (m3)

    70 kg    =  Assumed human body  weight

    BWA.      =  Body  weight of experimental  animals  (kg)

    MOS      =  [10  (species extrapolation)  x 10  (human
                variability)] = 102

     4.2.2.4  Use of  RfDs or APIs to  Evaluate Chronic  loxicity.  It

 is  recommended  that the magnitude of  the  RfD or calculated ADI be

 used as  the basis for evaluating the  relative chronic  toxicity

 potential  of a  substance.  The chronic toxicity value  may be

 assigned based  on the RfD or ADI, as  presented in Table 5.  The

 assigned values range from 0 to 3 and are the same as  to the  range

 of  values  of the proposed acute toxicity  factor.

     The break  points for chronic toxicity values were selected to

 provide  a  reasonable  distribution of  values  among the  substances to
                                  48

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                                 TABLE 5

        PROPOSED CHRONIC TOXICITY VAIUES BASED ON REFERENCE DOSES
               OR ACCEPTABLE DAILY INTAKES FOR ORAL, DEEIMAL
                       AND INHAIATIONAL EXPOSURES
  RfD or       RfD or                                             Assigned
 ADI Oral     ADI Dermal    RfD or ADI Inhalational (mg/kg/day)    Toxicity
(mg/kg/day)    (mg/kg/day)    Dust or Mist	Gas or Vapor	Value
  >5.0

 >0.5-5.0

 >0.05-0.5

  <0.05
 >20

>2.0-20

>0.2-2.0

 <0.2
  >0.2

>0.02-0.2

>0.002-0.02

  <0.002
  >20

>2.0-20

>0.2-2.0

  <0.2
0

1

2

3
                                49

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be assessed.  In the event chronic toxicity data are not available

for dermal or inhalational routes, the pathway-specific acute

toxicity value may be used (except when based on irritation).  In

the event no toxicity data are available for either the inhalational

or dermal modes of exposure, the assigned oral chronic  toxicity

value is to be used as the default value for the inhalational or

dermal chronic toxicity value.  If no toxicity data are available at

all, a value of 0 is assigned.  Hie discussion of the issues

surrounding default values is the same as that presented previously

for the acute toxicity assessment (see Section 4.2.1).

     4.2.3  Carcinogenicity, Mutagenicity, and Teratogenicity (CMI)
            Potential

     The EPA HRS does not consider the possible carcinogenic,

mutagenic, or teratogenie actions of substances.  It is recommended

that the toxicity factor be modified to account for the possible

carcinogenicity, mutagenicity and teratogenicity of substances.

Although GMT effects are frequently considered together in

regulatory toxicology, the grouping of the effects is for

convenience.  There is no clear mechanistic linkage among the three

types  of effects.   Indeed, many investigators believe that

environmental agent-induced teratogenesis demonstrates a threshold

 (Wilson, 1977; Beckman and Brent, 1986), whereas the concept of a

threshold is not believed to apply to carcinogenesis or

mutagenesis.  Since agents that induce teratogenesis exhibit a

threshold, it is recommended that they be assessed under the


                                 50

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methodology described for chronic toxicity (Section 4.2.2).  Since




carcinogenesis and rautagenesis are considered to be stochastic




events (i.e., they do not exhibit thresholds), it is suggested that




they be assessed together as described below.




     A combined weight-of-evidence and relative potency approach is




suggested for determination of the CM factor.  This type of approach




combines qualitative assessment of the reliability of carcinogenicity




data for a given substance with a quantitative assessment of the




relative potency of that substance to induce cancer.




     A weight-of-evidence approach is a method for assigning values




based upon a set of predetermined guidelines.  For the proposed CM




factor, the first step is to determine the weight-of-evidence.



Those substances for which epidemiological studies indicate the




substances produce carcinogenic effects in humans or for which




laboratory tests demonstrate carcinogenic effects in multiple



species of test mammals are assigned to Category III.  Substances




which produce carcinogenic effects in one species of test mammal or




mutagenic effects in one or more whole animal tests, but for which




there are no relevant human data, are assigned to Category II.




Substances which are mutagenic in cellular systems, but have not yet




been proven to produce carcinogenic effects in humans or animals,




are assigned to Category I.  Substances which have been tested in




any of the above systems but were found to be inactive are assigned




to Category 0.  Guidelines for assigning the CM weight-of-evidence
                                 51

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categories, based on the weight-of-evidence approach (adapted from




Squire, 1981 and U.S. EPA, 1986), are presented in Table 6.




     The sources of data acceptable for evaluation of the CM




weight-of-evidence categories are the Registry of Toxic Effects of




Chemical Substances (RTECS)  (Tatken and Lewis, 1982; Lewis and




Sweet, 1985), the International Agency for Research on Cancer




(IARC), the National Toxicology Program (NTP), and the National




Cancer Institute (NCI).  If  no data exist from any of the above




sources, the substance is assigned to Category 0.  The discussion




surrounding default values is the same as discussed under acute




toxicity  (Section 4.2.2).



      The  second step in determining the CM factor is to estimate the




relative  carcinogenic potency (i.e., the efficacy) of the




substance.  The carcinogenic potency of a substance is usually




determined through low dose  extrapolations using sophisticated




mathematical models that have theoretical bases in the presumed




mechanism of carcinogenic action.  The most commonly used of these




models is  Crump's Global 82. Use of such mathematical models




requires  access to high quality laboratory animal data.  In




addition,  a high level of expertise is required in deciding the




appropriate model to use since for some carcinogens (e.g., amitrole)




multistage models such as Global 82 are not appropriate in




determining carcinogenic potency.
                                  52

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                               TABLE 6

              PROPOSED CM* WEIGHT-OF-EVIDENCE CATEGORIES
                                                       CM Weight-of-
	Evidence	Evidence Category

Available information demonstrates the substance            III
is carcinogenic to humans or to multiple mammalian
test species.

Available information demonstrates the substance             II
is carcinogenic in a single mammalian test species
and/or mutagenic in one or more whole animal tests
(human evidence is not available).

Available information demonstrates the substance              I
is mutagenic in cellular systems but information
for whole animals is not available.

Available data demonstrate the substance to be                0
neither carcinogenic nor mutagenic in humans,
animals, or cellular systems.

No data are available.                                        0
*CM = carcinogenicity and mutagenicity.
                                 53

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     An alternative method to the low dose extrapolation approach




uses the ED10«  The ED1Q methodology estimates the lifetime daily




dose of a substance which causes 10 percent of the animals to have a




particular lesion, in this case, cancer.  Most studies published in




peer reviewed journals and/or studies conducted by the National




Toxicology Program or National  Cancer Institute have a sufficient




number of treated and control groups to allow the incidence of tumors




to be plotted as a function of  dose.  Generally, the H>10 level is




in the linear range of the dose response curve and consequently,




sophisticated modeling procedures such as are used in the Global 82




method are not necessary.  The  magnitude of the estimated ED-in (in




mg/kg/day) can be used as an indicator of the carcinogenic potency of




a substance.  The proposed relative carcinogenic potency groups,




based  on the  magnitude of the ED-,,, are presented in Table 7.




Substances for which an  ED10 is not available or for which




inadequate data  exist to calculate an ED.._ are assigned a relative




carcinogenic  potency of low.




      The final step in determining the proposed CM value for a




substance is  accomplished by combining the weight-of-evidence




category with the relative carcinogenic potency group according to




the  matrix in Table 8.   The proposed CM values range from 0 to 3.




      4.2.4  Toxicity of Metals




      One class of hazardous substances which is particularly




difficult to  assess toxicologically is the metals.  Metals exist in
                                  54

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                      TABLE 7

PROPOSED REIATIVE CARCINOGENIC POTENCY GROUPS BASED
             ON THE CARCINOGENIC
 (mg/kg/day)
Carcinogenic Potency Group
     0.01                           High

  1.0-0.01                         Medium

     1.0                             Low
                        55

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                               TABLE 8

           PROPOSED CM* VALUES  BASED ON WEIGHT-OF-EVIDENCE
                        AND RELATIVE POTENCY
Weight-of-Evidence               	Relative Potency Group	
    Category	Low	Medium	High

       0                             000

       I                             112

      II                             123

     III                             233


*CM = Carcinogenicity and Mutagenicity.
                                 56

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various forms in the environment, including inorganic metal salts




(e.g., nickel chloride and zinc sulfate), organometallic compounds




(e.g., methylmercury), and other covalently bound metals (e.g., zinc




sulfide and iron oxide).  When metals have been identified at NPL




sites, analytical data are reported as total metal without




specifying the type of metal compound.  For example, lead chloride,




lead sulfate, lead oxide, lead sulfide, and tetraethyl lead each




have their own toxicity characteristics, CAS numbers, and can be




assigned toxicity factor values using the EPA HRS.  However,




analytical results would report the sum of these substances as




simply lead.  Unless an inventory or other means of identifying the




individual lead compounds is available, they would be listed under a




common heading of "lead, NOS" (Not Otherwise Specified).




     A scientifically defensible, reasonable approach would evaluate




such substances on the basis of the most toxic chemical that




contains the metal in question.  Due to the large number of entries




in RTECS for any given metal (e.g., lead),  a method Must be found to




reduce the number of substances to be assessed.   It would be




appropriate to confine the toxicity factor evaluation to substances




that have been defined as "hazardous substances" by the EPA.  A list




of 717 hazardous substances has been compiled under CER.CLA.




Hierefore, it is recommended that the assignment of toxicity values




to metals, NOS or unspecified metal compounds be accomplished in the




following manner.  First, obtain the identities of all species of
                                 57

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that metal which are found in the CERCLA list of hazardous




substances.  Then, identify the most toxic species for which there




are toxicity data and which contain a single moiety that is expected




to be active in causing toxicity.  The most toxic species in that




list is denoted by the species with the smallest reportable




quantity  (RQ).  The current list of RQs is presented in the March 16,




1987 Federal Register (52 FR 8140).




     As an example, the selection of the appropriate compound for




assigning a toxicity value to "lead and compounds, NOS" follows.




According to the CERCLA RQ list, there are 12 lead-containing




compounds.  The lead compound with the smallest RQ (1) is lead




arsenate.  Since that substance is comprised of two metals, it is




not used  to assign a toxicity value.  Two lead-containing substances




have RQs  of 10:  lead acetate and tetraethyl lead.  Since tetraethyl




lead has  both more and better toxicity data (including an oral RfD




and a TLV-TWA), it would be selected as the lead compound to use for




assigning a toxicity factor value to all unspecified lead compounds.




4.3  Determinants of Exposure




     4.3.1  Persistence




     Exposure to a substance depends, in part, on its persistence in




the environment.  Since the chance of long-term exposure to a toxic




substance in the environment is directly related to the stability of




the substance in the environment, substances which are easily




degraded  present less chance of chronic exposure than those which
                                 58

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are resistant to degradation.  The current EPA HRS presents




guidelines for evaluating persistence based upon biodegradation.




Although the criteria for assigning a persistence value were not




analyzed in depth by the present study, it is apparent that other




types of physical and chemical processes can cause a substance to be




lost from the environment (e.g., photolysis by sunlight; hydrolysis




in aqueous environment; volatilization from soil or water).  Other




HRS-related studies have indicated that biodegradation is not an




important loss mechanism within the context of the HRS.  Efforts are




underway to modify or replace the current, biodegradation-based




persistence factor.  It is recommended that EPA continue its effort




to review the current persistence factor but to separate this




consideration from the toxicity factor.




     4.3.2  Routes of Release




     It is recommended that the EPA HRS continue to evaluate the




hazard from hazardous substances which have been or may be released




from hazardous wastes sites by any of the migration pathways.




Pathway-specific toxicity values should be used in the calculation




of the different pathway scores.  For each pathway, a pathway-




specific toxicity value should be calculated that incorporates




measures of acute toxicity, as well as chronic toxicity and CM




effects.  As described below, it is recommended that the toxicity




factor value be calculated from an equation that adds terms for




acute toxicity, chronic toxicity and CM effects.  The additive
                                 59

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nature of this scheme allows the chronic toxicity and CM effects to
be weighted more heavily than the acute effects and it prevents a
very low value (e.g., zero) for any one toxic effect from negating
the effects in others.  A multiplicative scheme would be undesirable
for this reason.
     The toxicity   , value should be used as the toxicity factor
                yoral
value in the surface water and ground water pathways.  The
toxicity   » value is calculated as follows:
        oral
         toxicity   , = acute toxicity   - value + chronic
                       toxicity   -  value + CM
     As an example, the toxicity   , value for chloroform is
calculated in Table 9.  The toxicityinhalational (for the air
pathway) and toxicity,    , (for direct contact) values are
calculated in a similar manner.
      The pathway-specific toxicity values range from 0 to 9 (in unit
increments) in this recommended change to the HRS compared to a
range of 0 to 3 for the toxicity rating factor of the current HRS.
Note  that the current HRS also uses a multiplier of 3 for the
toxicity factor, yielding an effective range of values from 0 to 9
in increments of 3.
      4.3.3  Presence of Incompatible or Reactive Mixtures
      The current HRS does an adequate job of assessing incompati-
bility/reactivity for the purposes of toxicological assessment;
therefore, no changes are recommended in this part of the system.
                                  60

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                               TABLE 9

       EXAMPLE CALCULATION OF TOXICITYORAL VALUE (CHLOROFORM)
Type of Toxicity
Acute
Chronic
CM

LD50 =
RfD =
a. We
Basis
36 mg/kg (mouse)
0.01 mg/kg /day
ight-of-Evidence Catei
Value
3
3
jory III
                                (+ rat; + mouse)

                     b.  Potency Group Medium
                             (ED10 = °-508 mg/kg/day)

                     c.  Ill x Medium from Matrix*

Toxicityoral Value   Acute + Chronic + CM


*See Table 8.
                                 61

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4.4  Use of Data




     4.4.1  Number of Substances Evaluated




     The current EPA MRS assigns a toziclty value for a pathway




based upon "the substance with the highest score (toxicity/




persistence)."  As has been shown in Tables 1 and 2, this practice




results in little discrimination among NPL sites based on torlcity.




This occurs because the majority of NPL site migration pathways are




assigned toxicity values on a very limited number of substances




receiving high factor values, at least one of which can be found




among the multiple substances identified at most sites.  The




proposed revision to the EPA HRS toxicity factor will provide




increased discrimination among substances.  However, if only the




single "most toxic" substance is used for the site evaluation, it is




likely that many sites (most of which contain multiple substances)




will be evaluated on the same "most toxic" substance as is currently




done.  This, once again, is expected to provide little discrimination




among NPL sites.  To provide a better profile of the combined




estimated toxicity of the substances at a site, and to provide




additional discrimination among sites, it is recommended that each




site be rated for toxicity for each relevant pathway by combining




toxicity values of the five "most toxic" substances (defined below)




found at the site and available for migration.  The toxicity values




of multiple substances will provide a better toxicity assessment of




the hazard posed by a site than will the toxicity value of a single
                                 62

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substance.  Although the assessment of the potential hazard from all




substances present at a site would give the best toxicity assessment




for a site, such an assessment would be time-consuming and could




possibly understate the danger associated with very toxic substances




if a large number of weakly toxic substances were also present.  The




assessment of the potential hazard associated with a site based on




the five highest ranking substances is a reasonable compromise.  The




toxicity values can be combined in a variety of ways.  For example,




the average of the toxicity values assigned could be used as a con-




venient method to normalize the value.  Alternatively, the geometric




mean of the toxicity values for the five most toxic substances could




be used.  Whichever method is used must account for the possibility




of a site with fewer than five substances.  This is to ensure that




the combined toxicity value is not less at a site with few sub-




stances than that at a site with the same plus additional substances.




     It is recommended that "most toxic" be defined by the numerical




designations of the toxicity values assigned to of substances




available for migration in a given pathway.  For each pathway, at




each site, the five substances (potentially) available for migration




by that pathway, with the highest appropriate toxicity




values, would be used.  Thus, the selection of the most toxic




substances would be migration pathway-specific.  For example, to




evaluate the pathway water route, substances present in the ground




water (or available to migrate to ground water) would be evaluated
                                 63

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to determine their toxicity     values.  The five substances with



the highest values would be used to assign a value to the toxicity



factor in the ground water pathway.



     The increased discrimination among the values assigned to 30



selected substances is demonstrated in Table 10.  The data



supporting these values are presented in Appendix J.  Under the



current HRS toxicity factor evaluation method, possible values range



from 0 to 3.  Ten of the substances are assigned toxicity values of



2, the remaining 20 substances are assigned a 3.  Under the proposed



pathway-specific methodology, the substances have possible values



that range from 0 to 9 for each of the 3 pathways.  The substances



were assigned values that ranged from 3 to 9 for the oral and dermal



pathways; and from 1 to 9 for the inhalational pathway.  The



toxicity values of a particular substance differ according to the



underlying data, as is exemplified by chloroform which has a



toxicity   n value of 9, toxicity,     - value of 7, and a
       Joral           '        Jdermal


toxicitylnhalat:lonal value of  5.



     4.4.2  Quantity of Data on Each Substance



     The preferred source of toxicity data for use in the proposed



methodology is RTECS because it contains all of the toxicity data



required to assess a substance.  RTECS is intended to be a single



data source.  It presents toxicity data concerning the lowest



reported dose of a substance to cause toxic effects by several



routes of exposure in various species.   The RTECS data base  is
                                 64

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                            TABLE 10

COMPARISON OF TOXICITY VALUES USING THE CURRENT  EPA HRS  WITH THE
      PROPOSED PATHWAY-SPECIFIC TOXICITY FACTOR METHODOLOGY
Current HRS
Toxicity
Value
Acetone
Arsenic and Compounds, NOS
Benzene
Benzo(a)pyrene
Cadmium and Compounds, NOS
Carbon Tetrachloride
Chlorobenzene
Chloroform
Chromium and Compounds, NOS
Chromium, Hexavalent
Chromium, Trivalent
Copper and Compounds, NOS
Creosote
DDT
1,1-Dichloroethylene
Lead and Compounds, NOS
Lindane
Mercury and Compounds, NOS
Methyl Ethyl Ketone
Naphthalene
PCBs (Arochlor), NOS
Penta chloro phen ol
Phenanthrene
Phenol
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
1, 1, 2-Trichloroethylene
Vinyl Chloride
Zinc and Compounds, NOS
2
3
3
3
3
3
2
3
3
3
2
3
2
3
3
3
3
3
2
2
3
3
3
3
2
2
2
2
3
3
Proposed Pathway-Specific
Toxicity Values
Oral
4
9
4
7
8
7
4
9
8
8
3
7
5
8
8
7
7
6
3
5
7
5
5
5
4
4
3
6
7
6
Dermal
4
9
5
6
8
7
4
7
8
8
3
7
5
8
8
6
8
6
4
5
7
7
5
6
7
5
6
8
7
6
Inhalational
2
9
4
7
9
5
2
5
9
9
5
5
7
9
6
7
8
6
1
3
9
7
5
5
4
2
3
4
6
6
                              65

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updated annually; the last hard copy editions (Tatken and Lewis,




1982; Lewis and Sweet, 1985) contain entries for a total of 57,599




substances.  Updates are available on-line.  TLVs are listed in




RTECS; alternatively, they may be obtained from the American Council




of Governmental and Industrial Hygienists.  RfDs and ED1Q are




available on-line on EPA's IRIS system.  Alternatively, they are




listed in the appendices of the Superfund Public Health Evaluation




Manual (IGF, 1986).




      4.4.3  Clarity




      Details of the recommended method for assessing acute and




chronic  toxicity and CM effects have been described in Sections 4.2.1




to  4.2.3.   The recommended methodology provides a logical evaluation




method and  allows the toxicity potential of substances to be




assessed independently for each potential mode of exposure.  In




addition, pathway-specific toxicity values can be calculated for




substances  in advance and be provided as guidance (a look-up table)




for  the  substances commonly identified at NPL.  Ihe supporting data




from which  the values were derived and further description of the




methodology (including an example) are presented in Appendix I.
                                 66

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5.0  GLOSSARY

Acute ToxLcity
ADI
Bioaccumulation
CM


CMT


Carcinogens

Carcinogen!city


Chronic Toxicity
Acute toxLcity is the capacity of a substance
to cause adverse effects occurring within a
short time (usually 4 days or less, but up to
14 days) following administration of a single
exposure or multiple exposures of that
substance within a 24-hour period.

The acceptable daily intake is the maximum
daily dose of a substance that is anticipated
to be without risk to adult (70 kg) humans
after a lifetime (70 years) of exposure.
Calculated by dividing the NOEL by a MOS.
Substitutions for the NOEL, such as an
LC50, LOEL or TLV-TWA, can be made with
appropriate adjustments in the MOS.

Bioaccumulation is the uptake of a substance
from the environment, via a biological process,
to be incorporated into and stored within
tissue.

CM is an abbreviation for carcinogencity and
mutagenicity.

CMT is an abbreviation for carcinogenic!ty,
mutagenicity, and teratogenicity.

Carcinogens are agents that induce cancer.

Carcinogen!city is the ability of an agent to
cause cancer.

Chronic toxicity is the capacity of a substance
either to cause adverse effects resulting from
repeated exposures to that substance throughout
a long period of time, for instance, greater
than 50 percent of the lifespan of a laboratory
rodent (e.g., 12 to 15 months in rat strains),
or to cause adverse effects that appear much
later in time than the initial exposure.
                                 67

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EC50
EDE
Incompatible
Substances
Intraperitoneal
LC
  '50
LC50
LD50
The effective concentration, 50 percent, is the
concentration in air or water (any fluid) of a
chemical that elicits a measurable effect
within a specified period of time in 50 percent
of a group of treated animals above the
background incidence (in control animals) of
that effect.

The effective dose, 10 percent, is the dose
that elicits any measurable effect in 10
percent of a group of treated animals above the
background incidence (in control animals) of
that effect.

The equivalent dose estimate is that dose at
which the estimated risk associated with a
compound is comparable among all compounds
being evaluated.

Substances which, when commingled under
uncontrolled conditions, produce heat or
pressure; fires or explosions; violent
reactions; toxic dusts, mists or gases; or
flammable fumes or gases.

Intraperitoneal means within the abdominal
cavity.

The lethal concentration, 50 percent, ±s the
concentration in air or water of a substance
that kills 50 percent of a group of treated
animals within a specified period of time.

The lethal, concentration, low, is the
concentration in air or water of a substance
that kills at least one of a group of treated
animals within a specified period of time.

The lethal dose, 50 percent, is the dose of a
substance that kills 50 percent of a group of
treated animals within a specified period of
time.

The lethal dose, low, is the lowest dose of a
substance that kills at least one of a group of
treated animals within a specified period of
time.

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LOEL  (or LEL)
Log P
MCL
MED
MOS
Multistage
Model
Mutagens
The lowest observed effect level (LOEL) is the
lowest dose, in a series of doses tested in
long term (chronic or subchronic) studies, at
which an adverse effect is observed in the
species tested.

The logarithm of P is the logarithm of the
ratio of the concentration of a substance in
octanol to the concentration of the substance
in water.  It is considered to be a measure of
lipophilicity and to be directly proportional
to the ease with which a substance can cross
biological membranes and thereby enters the
body.  It is used to estimate bioaccumulation
potential.

The maximum concentration limit is the maximum
permissible level of a contaminant in water
that may be delivered to a user of a public
water system serving a minimum of 25 people.
The maximum concentration limits are
promulgated pursuant to Section 1412 of the
Safe Drinking Water Act.

The minimum effective dose is the minimum dose
of a substance that elicits a statistically
significant incidence of an effect above the
background incidence (in controls).

The margin of safety is a factor used to
convert a no observed effect level (NOEL)
derived from laboratory animal toxicity data to
a presumed safe lifetime daily dose for
humans.  The conversion factor accounts for
variability in sensitivity within and among
species and for varying confidence in the
quality of the data.

The multistage model is a mathematical model
that describes the dose-response relationship
for carcinogens at very low doses.   The model
assumes that a tumor can be induced from a
single cell only after that cell has undergone
several heritable changes caused by a substance.

Mutagens are substances that cause heritable
alterations in genetic material.
                                 69

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Mutagenicity


Mutation



NOEL
Ocular
Irritation
 One-hit Model
 Partition
 Coefficient
 Percutaneous
 Reactive
 Substances
Mutagenicity is the ability of an agent to
cause mutations.

A mutation is an alteration in genetic material
that is potentially heritable (i.e., able to be
transmitted to offspring).

The no observed effect level (NOEL) is the
highest dose, in a series of dose levels
tested, at which no adverse effect is observed
in the species tested.

Ocular irritation is a local inflammatory
reaction of tissues of the eye following direct
instillation of a substance in the eye.

The one-hit model is a mathematical model that
describes the dose-response relationship for
carcinogens at very low doses.  The model is
based on the concept that a tumor can be
induced when a single cell has undergone a
single heritable change caused by a substance.

Partition coefficient is the ratio of the
concentration of a substance in one solvent
(phase) to the concentration of the substance
in a second solvent (phase).  For biological
studies, the solvents are usually octanol/water.

Percutaneous is the transfer of a substance
through the skin into the body.

Substances that are normally unstable and
readily undergo violent change without
detonating; that react violently with water;
that form potentially explosive mixtures with
water; that generate toxic gases, vapors, or
fumes when mixed with water; that are capable
of detonation or explosive reaction if
subjected to a strong initiating source or if
heated under confinement; or that are readily
capable of detonation or explosive
decomposition or reaction at normal (ambient)
temperatures and pressures.
                                  70

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Reportable
Quantity (RQ)
Subchronic
Toxicity
Subcutaneous
Teratogen


Teratogenicity


TLV-TWA
UCR
Reportable quantity is the quantity of a
substance, as specified in 40 CFR 302, that,
when released into the environment, may present
substantial danger to public health or welfare
or the environment.  Therefore, the release of
a substance into the environment must be
reported if it exceeds an expressed quantity.

Subchronic toxicity is the capacity of a
substance to cause adverse effects resulting
from repeated exposure to a substance
throughout a limited period of time, for
instance, less than 10 percent of the lifespan
of laboratory rodents (e.g., 3 months in rat
strains).

Subcutaneous refers to beneath the skin.

The toxic concentration, 50 percent, is the
concentration in air of a chemical that elicits
a measurable adverse effect in 50 percent of a
group of treated animals above the background
incidence (in control animals) of that effect.

The toxic dose, low, is the lowest dose of a
substance that is toxic to at least one of a
group of treated animals.

A teratogen is a substance that causes birth
defects.

Teratogenicity is the ability of an agent to
cause birth defects.

The threshold limit value—time-weighted
average (TLV-TWA) is the concentration of a
substance in air averaged over a normal 8-hour
workday and a 40-hour work week, which causes
an adverse effect in "nearly all" workers
(except the most sensitive).  The TLV-TWA is
expressed in units of ppm and mg/m^.

The unit cancer risk is defined as the upper
limit on the lifetime probability that a
chemical will cause cancer at a dose of 1 mg/kg
body weight/day.
                                 71

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Weight-of-Evidence     A ranking or weighting of data for substances
                       to predict their potential for toxicity in
                       humans according to a defined set of rules.
                                 72

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6.0  BIBLIOGRAPHY

American  Conference of Governmental  Industrial  Hygienist  (ACGIH),
1985.  Threshold Limit Values  (TLVs) and Biological Exposure  Indices
for 1985-1986, ACGIH, Cincinnati, Ohio.

Armitage, P., and R., Doll, 1961, Stochastic Models for
Carcinogenesis, in;   "Proceedings of the Fourth Berkeley  Symposium
on Mathematical Statistics and Probability, Vol. 4," p. 19,
J. Neyman, ed., University of California Press, Berkeley  and
Los Angeles, CA.

Ashton, F. M., 1982.  "Persistence and Biodegradation of
Herbicides," In:  Biodegradation of  Pesticides, Matsumur  and  Krishna
Murti  (eds).  Plenum  Publishing Corporation, NY.

Barnthouse, L., J. Breek, T. Jones,  S. Kraemer, E. Smith, and
G. Suter, 1986.  Development and Demonstration  of a Hazard
Assessment Rating Methodology for Phase II of the Installation
Restoration Program (HARM II), Environmental Science Division, Oak
Ridge National Laboratory, Oak Ridge, TN.

Berkson,  J. (1944).  Application of  the logistic function to
bio-assay.  Journal American Statistical Association, 39:357-365.

Beckman,  D. A. and R. L. Brent, 1986.  "Mechanism of Known
Environmental Teratogens:  Drugs and Chemicals," Clinics  in
Perinatology, 13:649-687.

Centers for Disease Control (CDC), 1984.  A System for Prevention
Assessment, and Control of Effects from Hazardous Sites (SPACE),
U.S. Department of Health and Human Services (CDC), Atlanta,  GA.

Cogliano, V. J. (1986).  "The U.S. EPAs Methodology for Adjusting
the Reportable Quantities of Potential Carcinogens," in Proceedings
of the Seventh National Conference of Management of Uncontrolled
Hazardous Waste Sites, Hazardous Material Control Research
Institute, Silver Spring, MD, pp. 182-185.

Crump, K. S. and R. B. Howe, 1984.   "The Multistage Model with
Time-Dependent Dose Pattern:  Applications to Carcinogenic Risk
Assessment," Risk Analysis 4:163-76.

DeRosa, C. T., 1987.  Personal Communication, 13 January  1987.
Dr. DeRosa is a Branch Chief in the Environmental Criteria and
Assessment Office, Office of Research and Development, U.S.
Environmental Protection Agency, Cincinnati, OH.
                                 73

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Environ, 1985.  Documentation for the Development of Toxlcity and
Volume Scores for the Purpose of Scheduling Hazardous Wastes,
Environ Corporation, Washington, DC.

Environmental Monitoring and Services, Inc., 1985.  Technical
Background Document to Support Rulemaking Pursuant to CERCIA
Section 102, Volume 1, prepared for U.S. Environmental Protection
Agency Office of Research and Development and Office of Solid Waste
and Emergency Response, Washington, DC.

Haus, S. and T. Wolfinger, 1986.  Hazard Ranking System Issue
Analysis:  Review of Existing Systems, The MITRE Corporation,
McLean, VA.

ICF, 1985.  Draft Superfund Public Health Evaluation Manual, ICF
Incorporated, Washington, DC.

Kilgore, W. W. and M-Y, Li, 1980.  "Food Additives and Contaminants"
in Cassarett and Doull's Toxicology,  2nd ed., J. Doull, C. Klaassen
and M. Amdur (eds), Macmillan Publishing Co., pp. 593-607.

Klaassen, C. D., 1986.  "Principles of Toxicology" in Casarett and
Doull's Toxicology, 3rd ed., C. Klaassen, M. Amdur, and J. Doull
(eds), Macmillan Publishing Company,  pp. 11-32.

Kushner, L. M., R. C. Wands, and V. Fong, 1983.  "The Potential Use
of the ADI in Superfund Implementation," (MTR-83W16), The MITRE
Corporation, McLean, VA.

Lewis, R. L. and D. V. Sweet, 1985.   Registry of the Toxic Effects
of Chemical Substanc.es, 1983-84 Supplement, U.S. Department of
Health and Human Services (National Institute of Occupational Safety
and Health), Cincinnati, OH.

Mantel, N. and Bryan, W. R. (1961).   Safety Testing of Carcinogenic
Agents, Journal National Cancer Institute, 27:455-470.

Michigan, 1980.  Michigan Critical Materials Register, 1980,
Michigan Department of Natural Resources, Environmental Protection
Bureau, Lansing, MI.

Michigan, 1983.  Site Assessment System (SAS) for the Michigan
Priority Ranking System under the Michigan Environmental Response
Act (Act 307, P.A. 1982), Department of Natural Resources,
Lansing, MI.
                                 74

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National Academy of Sciences (NAS), 1975.  Medical and Biological
Effects of Environmental Pollutants;  Nickel, National Research
Council, Washington, DC.

National Fire Protection Association (NFPA), 1977.  National Fire
Codes, Vol. 13, No. 49.

Rosenblatt, D., J. Dacre, and D. Cogley, 1980, Preliminary Pollutant
Limit Values for Human Health Effects.  Environmental Science and
Technology, 14:778-784.

Rosenblatt, D., J. Dacre, and D. Cogley, 1982.  "An Environmental
Fate Model Leading to Preliminary Pollutant Limit Values for Human
Health Effects," in:  Environmental Risk Analysis for Chemicals,
R. Conway, ed., Van Nostrand Relnhold Co., NY.

Sax, N. I., 1975.  Dangerous Properties of Industrial Materials,
4th ed., Van Nostrand Reinhold Co., NY.

Sax, N. I., 1979.  Dangerous Properties of Industrial Materials,
5th ed., Van Nostrand Reinhold Co., NY.

Sax, N. I., 1984.  Dangerous Properties of Industrial Materials,
6th ed., Van Nostrand Reinhold Co., NY.

Schmidt-Bleek, P., W. Haberland, A. Klein, and S. Caroli, 1982.
"Steps Towards Environmental Hazard Assessment of New Chemicals,"
Chemosphere, 11:383-415.

Squire, R. A., 1981.  "Ranking Animal Carcinogens:  A Proposed
Regulatory Approach," Science, 214:827-880.

Tatken, R. L. and R. J. Lewis, 1982.  Registry of Toxic Effects of
Chemical Substances, U.S. Department of Health and Human Services
(National Institute of Occupational Safety and Health), Cincinnati,
OH.

Turner, M., 1975.  Some Classes of Hit Theory Models, Mathematical
Bioscience, 23:219.

U.S. Environmental Protection Agency (EPA), 1980.  "Guidelines and
Methodology Used in the Preparation of Health Effects Assessment
Chapters of the Consent Decree Water Quality Criteria Documents,"
Federal Register 45 (231), 28 November 1980.

U.S. Environmental Protection Agency (EPA), 1982.  "Appendix A -
Uncontrolled Hazardous Waste Site Ranking System; A Users Manual,"
40 CFR 300, Federal Register, 16 July 1982 (47 FR 31219).
                                 75

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U.S. Environmental Protection Agency (EPA), 1984.  "Proposed
Guidelines for Carcinogenic, Mutagenic and Reproduction Risk,"
Federal Register 49 (227), 23 November 1984.

U.S. Environmental Protection Agency (EPA), 1985.  "Final Rule for
Superfund Notification Requirements and Reportable Quantity
Adjustments," 40 CFR Parts 117 and 302.

U.S. Environmental Protection Agency (EPA), 1986.  "Final Guidelines
for Carcinogen Risk Assessment," Federal Register, September 24,
1986, 51 FR 33992.

Wilson, J. G., 1977.  "Current Status of Teratology," in Handbook of
Teratology, Vol. 1, J. G. Wilson and F. C. Eraser, eds., Plenum
Press, NY.

Zielhuis, R. W. and F. W. van der Kreek, 1979.  "The Use of a Safety
Factor in Setting health Based Permissible Levels for Occupational
Exposure," International Archives of Occupational and Environmental
Health. 42:191-201.
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                             APPENDIX A

            ENVIRONMENTAL PROTECTION AGENCY NOTIFICATION
          REQUIREMENTS:  CERCLA REPORTABLE QUANTITIES (RQ)
     Sections 103(a) and 103(b) of CERCLA require that persons in

charge of vessels or facilities from which hazardous substances have

been released in quantities that are equal to or greater than

statutory reportable quantities (RQs) immediately notify the

National Response Center of the release.   The RQ levels, which may

be 1, 10, 100, 1,000, or 5,000 pounds, reflect EPA's judgment of

which releases should trigger mandatory notification so that the

need for Federal removal or remedial action may be assessed.  They

do not reflect a determination that a release of a substance will be

hazardous at, or above, the RQ level or not hazardous below that

level.  It should be noted that EPA has also promulgated RQs for

radioactive substances (radionuclides).  Although the radionuclide

RQs are considerably smaller than those mentioned above, they are

not pertinents to the present discussion.

A.I  Type of Toxic Effect

     Each designated CERCLA hazardous substance is assessed in the

following six categories:  reactivity, ignitability, acute toxicity,

chronic toxicity, carcinogenicity, and aquatic toxicity.  For each

of the five categories, a substance receives a tentative RQ level

based on its intrinsic physical, chemical, and toxicological

properties; the lowest RQ for each of the six categories becomes the
                                 77

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"primary criteria RQ" for that substance.  The primary criteria RQ




may be raised one level (adjusted) before being set as a statutory RQ




based on the susceptibility of the substance to biodegradation,




hydrolysis, and photolysis.  Details of the system used to establish




and adjust RQ values are published in the May 25, 1983 Federal




Register (48 FR 12552), the April 4, 1985 Federal Register (50 FR




13456), the March 16, 1987 Federal Register (52 FR 8140), and in the




Technical Background Document to Support Rulemaking Pursuant to



CERCLA Section 102 (Environmental Monitoring and Services, Inc.,




1985).




     A.1.1  Acute Toxicity




     The acute toxicity of a substance is assessed based on the




LDrn or LCcr. of a substance administered by the oral, dermal, or




inhalational route.  Each of the five RQ levels has an U>CQ value




range for both acute oral and acute dermal toxicity, and an !•£,.„




range for inhalation toxicity.  For example, an RQ of 1 pound is set




for substances with an oral LD   less than 0.1 mg/kg, a dermal




LD5Q below 0.04 mg/kg, or an inhalational LC_0 below 0.4 ppm.




An RQ of 5,000 pounds is set for substances with an oral LDcn




between 100 and 500 mg/kg, a dermal I^cn between 40 and 200 mg/kg,



or an inhalational LC   between 400 and 2,000 ppm.  The RQ level




chosen for the acute toxicity category is the lowest of the RQs




derived from the available acute toxicity data by the modes of



administration listed above.
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     A.1.2  Chronic Toxicity

     The chronic toxicity RQ is determined by a composite score

assigned to a substance based on both minimum effective dose (MED)

levels (oral, dermal and inhalational) and the severity of the

effects caused by repeated or continuous exposure.   Teratogenic

effects are considered as chronic effects.  MED levels are assigned

a score from 1 to 10 that is inversely proportional to the logarithm

of the MED.  The type and severity of adverse effect caused by the

agent is scored on a scale from 1 to 10 with minor  effects, such as

enzyme induction, being assigned a score of 1 while scores of 9

and 10 are assigned to pronounced pathological changes.  The

composite score for a substance is the product of the MED score and

the effects score.  The composite scores, which range from 1 to 100,

are divided into five tiers, 81 to 100, 41 to 80, 21 to 40, 6 to 20,

and 1 to 5, that are associated with RQ values of 1, 10, 100, 1,000,

and 5,000 pounds, respectively.

     A.1.3  Carcinogenicity, Mutagenicity, Teratogenicity (GMT)
            Potential

     The RQ method considers teratogenic effects under chronic

toxicity (see above).  The severity index scores for substances

which cause teratogenic effects are very high.  Substances which

cause birth defects in offspring in the absence of  maternal toxicity

are assigned a score of 10; if maternal toxicity is present, the

severity index score is 9.
                                 79

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     The RQ method ranks carcinogenic potential through a two-stage,




combined weight-of-evidence and carcinogenic potency approach.




During the first stage, a qualitative assessment of the available




epidemiological and experimental data is conducted according to the




weight-of-evidence classification method presented in the EPA




"Guidelines for Carcinogen Risk Assessment" (Federal Register of




September 24, 1986; 51 FR 33992 through 34003).  Evidence from




animal and human studies are evaluated and the substance is assigned




to a category according to set of prescribed rules.  The weight-of-




evidence categories, include Group A (known human carcinogen—




evidence in humans is sufficient), Group B (probable human




carcinogen—evidence in humans is limited or inadequate, but animal




evidence is sufficient), Group C (possible human carcinogen—




inadequate or no evidence in humans and animal evidence is limited),



Group  D (not classifiable), or Group E (evidence of noncarcino-




genicity for humans).




     During the second stage, a quantitative assessment of the




animal data (for Group A, B and C) is made by estimating the dose of




the  substance that causes a 10 percent increase in tumor incidence




above  control levels.  This estimated dose is termed the FJD _.  A




potency factor (F) is calculated from the reciprocal of the ED10



according to the equation:




                              F = JL_
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Substances are assigned to potency groups of 1 (high),  2, or 3




depending on the magnitude of F.   Substances for which F is greater




than 100 are assigned to potency  group 1 (highest),  substances for




which F is greater than 1 but less than 100 are assigned to potency




group 2; substances for which F is less than L are assigned to



potency group 3 (Cogliano, 1986).




     The weight-of-evidence and potency classifications for a given




substance are combined through the use of a matrix that allows a




designation of potential carcinogens into hazardous categories of




high, medium or low.




A.2  Modifiers of Exposure




     A.2.1  Persistence




     RQs are adjusted based on the susceptibility of the substance




bring evaluated to the natural degradation processes of



biodegradation, hydrolysis, and photolysis (BHP).   The effects of




oxidation and volatilization are  not considered.   If a substance is




susceptible to BHP, the RQ value  is raised one level from that



assigned by the primary criteria  analysis to compensate for the



reduction in relative toxicity of the degraded products.  BHP




criteria are not used to lower the RQ values in the event that



substances are transformed to more toxic agents by BHP.




     A.2.2  Routes of Release




     The RQ system does not address specific routes of release




because it is only intended to trigger mandatory notification of the
                                 81

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National Response Center when a release to any medium exceeds a




given level.




     A.2.3  Presence of Incompatible or Reactive Mixtures




     The RQ system has categories that address the ignitability and




the reactivity of individual substances but the system does not




address reactivity of mixtures (since mixtures are not addressed




under the RQ system).  The ignitability and reactivity categories




each have only four RQ levels, 10, 100, 1,000, and 5,000 pounds.



Ignitibility RQs are associated with flash point and boiling point




characteristics of substances and range from 10, for substances that




are pyrolytic or self-ignitable, up to 5,000 for substances with a




flash  point of 100 to 140°F.  Reactivity RQs are assessed based on




the ability of a substance to react with water and/or itself and




range  from  10, for substances that react with water and/or have




extreme self-reaction, to 5,000 for substances that have slight




self-reaction  (e.g., polymerization with low heat release).




A.3 Use of Data




     A.3.1  Number of Substances Evaluated




     The RQ system assesses individual substances and not sites




 containing  groups or mixtures of substances.




     A.3.2  Quantity of Data on Each Substance




     The RQ system requires acute toxicity data (oral and dermal




LD5Qs  and/or inhalational LC^s), chronic toxicity data (MED




levels and  severity of toxic effects), aquatic toxicity data (LCcn
                                  82

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values), ignitability data, and reactivity data (reactivity with




water and self-reactivity).  Criteria for BHP are used to assess the




need to adjust (raise) the RQ values one level, if appropriate.




Incomplete data on a substance may result in the elimination of  an




RQ category or default to available data.  The consequence is that



substances receive RQs that are based on known hazards or properties




rather than unknowns.



     A.3.3  Clarity



     The EPA RQ system itself is clearly described in the Technical




Background Document and the May 25, 1983; April 4, 1985,  and




March 16, 1987 Federal Registers; however, the methods for applying




some components of the system are somewhat vague.   For instance,  the




specific criteria for raising an RQ one level based on BHP are not




presented.  Also, no guidance is provided with respect to preferred




sources of toxicity data and physical parameters; therefore, it  is




assumed that LDcn and LCrQ values published in any source may be




used.
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                             APPENDIX B




          SUPERFUND PUBLIC HEALTH EVALUATION SYSTEM (SPHE)






     The Superfund Public Health Evaluation (SPHE) system (ICF




Incorporated, 1985) is a method for estimating public health risks




at hazardous waste sites and developing goals for remedial




alternatives.  Tne SPHE system is not intended to rank toxic waste




sites.  Rather, it addresses the fourth phase of the five-step




remedial response process set forth in the National Oil and




Hazardous Substances Pollution Contingency Plan (40 CFR 300).  After




the priorities for remedial study have been established, the fourth




phase of the remedial response process calls for the identification,




evaluation, and selection of appropriate cleanup alternatives, and




for the analysis of these alternatives to identify the most




appropriate, cost-effective solution at a site.  The SPHE system




provides detailed guidance on how to conduct this fourth phase.




     Tne SPHE system calculates "Indicator Scores" (IS) for the




hazardous substances found at a site.  The IS is the product of the




measured concentration of a substance times a "toxlcity constant."




Toxicity constants are pathway-specific (i.e., water, air and soil)




and are derived separately for carcinogens (T ) and noncarcinogens




(T ).  Subsequent to the calculation of the IS for both




carcinogens and noncarcinogens, the topscoring 10 to 15 substances




from each of the two groups are designated as the initial indicator




substances.  From those two initial lists, the final indicator
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substances (unspecified number) are selected for use in a risk



assessment for the site.



B.I  Type of Toxic Effect



     B.I.I  Acute Toxicity



     The acute toxicity, per se, of substances found at hazardous



waste sites is not addressed by the SPHE system.




     B.I.2  Chronic Toxicity



     The SPHE system discriminates between the chronic toxicity



produced by nononcogenic substances and that produced by carcinogenic



substances (discussed in the following section).  For noncarcinogenic



substances, a toxicity constant (I ) is calculated for each route



of release (water, soil and air).  T  is calculated for a reference


                                      o

human  (who weighs 70 kg, breathes 20 m /day, drinks 2 liters of




water/day, and consumes 100 mg soil/day).  T  is based on the



minimum effective dose  (MED) of substance (in mg/day)* that causes



an irreversible effect and a severity factor (RV ) that ranges



from 1 to 10  (and is identical to the scale described for the RQ



method in Appendix A).



Thus,  for water,   WT  - 2 liter/day ' RV /MED,   , *
                     n                   e    (.oral;



       for soil,    STQ  - 0.0001 kg/day * RVe/MED(oral)



       and for air, aT  - 20 m3/day  ' RV /MED.. . ,   .  ,
                     n           *     e    (inhalation)
 *If MED  is  given in mg/kg/day, it must be multiplied by 70 kg before

  substituting  it into the equation.





                                 86

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The units for T  are the inverse of concentration.  Consequently,
               n


the IS (which is the product of a substance's toxicity constant



(1 ) and its concentration) is a unitless number.
  n


     The selection of the final indicator substances involves the



magnitude of the IS scores and consideration of five physical and



chemical properties for each substance (water solubility, vapor



pressure, Henry's Law Constant, organic carbon partition coefficient,



and persistence); however, the SPHE manual provides no "set of



precise decision rules on which to base the selection."  This allows



a great potential for inconsistency in the selection of final



indicator substances.



     B.I. 3  Carcinogenicity, Mutagenicity, and Teratogenicity (GMT)

            Potential



     The SPHE system requires the determination of toxicity constants



for carcinogenic substances by a method similar to that described for



chronic toxicants.  For carcinogenic substances,  a toxicity constant



(T ) is calculated from data for a reference human for each route of
  c
exposure (water, soil and air).  T  is based upon the EDin



dose to experimental animals in mg/kg/day that causes a particular



tumor to occur at 10 percent greater incidence than in controls) -



Thus, for water,    WTc = 2 liter/day/70 kg '  ED1Q



      for soil,     sTc - 0.0001 kg/day/70 kg '  ED1Q



      and for air,   aTc = 20 m3 /day/70 kg ' ED1Q



The units for T  are also the inverse of concentration.
               c
                                 37

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     In addition to calculation of TC, each potential carcinogen




is qualitatively classified according to the weight-of-evidence




criteria published by the International Agency for Research on




Cancer (IARC).  The SPHE manual clearly states that this




classification does not directly affect the IS; however, it is




implied that the weight-of- evidence classification should be




considered along with the physical and chemical properties




(discussed in chronic toxicity) in the selection of final. Indicator




substances.




B.2  Determinants of Exposure




     B.2.1  Persistence  The SPHE system allows the analyst to




consider environmental persistence as one factor in the selection of




the final list of substances which are used to estimate public




health risks resulting from exposure to toxic substances escaping




from waste sites.  The overall half-lives of many substances in air,




soil, and water are provided in an appendix.  The half-life for each




substance is to be used along with other physical data and, if




appropriate, the IARC weight-of-evidence carcinogenicity rating in




the final scoring of substances at a site.  The procedure for




assessing the relative importance of these factors is not




specified.  Rather, it is left to the judgment of the individual




analyst involved in the site scoring as to what weight persistence




should have in determining the final score of a substance.
                                 88

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     B.2.2  Routes of Release




     The SPHE system offers comprehensive analysis of exposure to




substances via air (due to volatilization and fugitive dust




emission), surface water (due to runoff, episodic overland flows,




and ground water seepage), ground water (due to seepage), onsite



soil (due to leaching), and offsite soil (due to runoff, episodic




overland flows, deposition of fugitive dust and tracking of




contaminated soil from a site to a previously uncontaminated site).




The frequency (i.e., whether chronic or episodic) and amount of each




type of release is also estimated and categorized.  However, the




SPHE system is not clear on how this information is to be used.




     B.2.3  Presence of Incompatible or Reactive Mixtures




     The SPHE system does not assess the hazard resulting from




incompatible or reactive wastes at a site.




B.3  Use of Data




     B.3.1  Number of Substances Evaluated




     The SPHE system selects a list of "initial indicator"




substances from all substances identified at a waste site.  The




10 to 15 compounds with the highest IS from each category of




potential carcinogens and noncarcinogens comprise the "initial




indicator" substances.




     B.3.2  Quantity of Data on Each Substance




     The SPHE system requires a variety of biological and physical




data on each substance identified at a waste site.  For the
                                 89

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selection of the list of "initial indicator" substances,  toxicity




data such as the human minimum effective dose (MED) for




noncarcinogens and the animal ED-» for carcinogens are required




for the calculation of toxicity constants.  In addition,  rating




constants for the severity of effects caused by noncarcinogens must




be assigned.  The organic carbon partition coefficient is also




needed for the ranking of the initial list of indicator substances.




There are no instructions concerning how to proceed in the absence




of such information.




     For the list of "final indicator" substances, physical data




including water solubility, vapor pressure, Henry's Law constant,




organic carbon partition coefficient, and persistence are also




required.  Information from IA.RC concerning the weight-of-evidence




relative to the carcinogenicity of each substance is also required.




Much of these data are not readily available, and little guidance is




presented in the SPHE documentation concerning how to proceed in the




absence of data.




     B.3.3  Clarity




     The SPHE system clearly presents the directions with which to




score substances in waste sites.  Details are provided for the




ranking of carcinogenic and noncarcinogenic substances,




quantification of human exposure characteristics, calculation of




toxicity factors for each substance, and the assessment of human



risk resulting from the release of substances from waste sites.
                                 90

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Worksheets and examples are provided which are useful in working




through this system.



     Ambiguity arises at several places in the SPHE system where the




analyst is directed to several air, water, and soil release models




and is required to choose the appropriate one based on the




professional judgment of the analyst.  Throughout the SPHE system,




numerous important decisions rely on the judgment of the site




analyst.  Ihis leads to a hazard assessment system which may be



affected by personal biases of individual analysts leading to




possible inconsistency in the scoring of sites.




B.4  Other Considerations



     A list of the "final indicator" substances is selected from the




list of "initial indicator" substances.  There is no set number of




"final indicator" substances, nor is there a set of precise decision



rules for their selection.  However, various chemical and physical




properties of each substance are to be used for ranking the final




indicator substances at each site.




     Each "final indicator" substance is subjected to a risk




characterization which is the ratio of the estimated exposure level




of the substance by all routes of exposure and the acceptable




exposure level according to the EPA's proposed guidelines for Health




Risk Assessment of Chemical Mixtures.  For each "final indicator"




the sum of the ratios for each route of exposure is the hazard




index.  Changes in the magnitude of the hazard index by various
                                 91

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remedial alternatives are utilized to determine which alternatives



would provide acceptable public exposures.




     The risk assessment calculations are based on many assumptions,




use of environmental models, and estimates.  Hie accuracy of the




estimates of the expected changes in constituent concentration in




release streams from a site depends on the models and data used to




make the estimates.  Throughout the risk estimation process, the




SPHE system relies upon the professional judgment of the analyst.




Simultaneously, a record of all assumptions and their "biases" is to




be kept.  The ultimate result is a strong potential for a lack of




consistency in the scoring among sites.
                                  92

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                             APPENDIX C

           PRELIMINARY POLLUTANT LIMIT VALUE  (PPLV)  METHOD


     The preliminary pollutant limit value (PPLV) method is designed

to predict (probable) acceptable environmental limits for pollutants

with respect to their ability to cause human health effects.

Details of the PPLV system are contained in Rosenblatt, Dacre and

Cogley (1980 and 1982).

C.I  Type of Toxic Effect

     The PPLV method provides a preliminary estimate of acceptable

levels of a given contaminant in various media (soil, water and

air).  The steps involved in calculating a PPLV include:

     •  Determination of an acceptable lifetime, daily dose (DT) of
        the contaminant for humans.

     •  For each medium (soil, water and air), identification of the
        possible medium-to-human pathways or routes of exposure
        (e.g., for soil some of the pathways include 1) root crops,
        2) other crops, 3) food chain animals eating contaminated
        plants, 4) contaminated runoff to waters to fish to man, and
        5) leachate to groundwater to man).

     •  Determination or estimation of relevant partition
        coefficients for the contaminant through all pathways,
        (e.g., between the media and food chain, within the food
        chain, between the media and humans,  and between the food
        chain and humans).

     •  Calculation of the maximum concentration of a contaminant in
        each pathway that would result in the delivery of exactly
        Dj (this is the single pathway PPLV which is also called
        the SPPPLV).
                                 93

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     •  Identification of  "critical  pathways" for each medium.

     •  Calculation of the PPLV for  each medium (or over all media)
        by "normalizing" the SPPPLVs;  normalization adjusts the
        contaminant concentration for  each pathway so that the
        target organism, man,  receives a total daily dose of exactly
        Dj; normalization  is necessary when there are several
        pathways within a  medium or  when pathways from different
        medium intersect;  normalization is done as follows:


                        v^n—^	  -i
                  PPLV - >    (SPPPLV)i
                        *—'i - 1

     C.I.I  Acute Toxicity

     The PPLV method does  not include  a factor which addresses the

acute toxicity, per se, of a. substance. Acute toxicity data is

utilized for calculation of the acceptable daily dose (DT)  of a

toxicant only if chronic data is not available, as discussed under

chronic toxicity.

     C.I.2  Chronic Toxicity

     Chronic toxicity is assessed in the  PPLV method through the

determination of D,_.  Essentially, this is a modification of the

ADI  approach.   If ADI values are available from  the  World Health

Organization, they are recommended for use as the D™.   If ADIs are

not  available,  the recommendation is that  the maximum concentration

level (MCL) in  drinking water, as established by EPA, be converted

to a DT by dividing the MCL by 35 (to  adjust for daily water

intake  and body weight).   If a TLV is  available,  the recommendation

is that it be converted to DT by multiplying by  0.0004 (to adjust

for  breathing rate, exposure time, and a safety factor of 100).  If
                                 94

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animal data must be used, it is recommended that the NOEL from a

lifetime study in animals be used by dividing it by a safety factor

of 100; if a NOEL from a subchronic (90 day) study is used, the

recommended safety factor is 1,000; if the LD5Q must be used, the

recommended safety factor is 86,950.  Additional safety factors may

also be applied in determining the D  to protect exceptionally

sensitive individuals such as embryos, infants, and aged individuals.

     C.1.3  Carcinogenicity, Mutagenicity, and Teratogenicity (GMT)
            Potential

     Although the PPLV system mentions the "special challenge" posed

by determining the D_ for carcinogens, exact instructions for how

to proceed are lacking.  Rather,  it is suggested that a D~ be

calculated based on several types of concentrations including:

     •  The limit of detectability for easily detected toxic
        substances in general.

     •  The concentration at which a "variety of potent but
        ubiquitious carcinogens"  are found in drinking water.

     •  The lowest available water quality criterion promulgated by
        the EPA.

There is no further guidance for  the calculation of PPLV for

carcinogens.  No additional consideration is given to the potential

effects resulting from exposure to mutagens.  Teratogenicity is

considered only as a possible additional safety factor to be applied

to the determination of the DT, as mentioned under chronic

toxicity.
                                 95

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C.2  Determinants of Exposure




     C.2.1  Persistence




     The PPLV system refers to the persistence of a chemical as the




resistance of the chemical to photochemical, hydrolytic, oxldative,




and blodegradative loss.  Although persistence is recognized as a




factor that affects the probability of exposure to a contaminant,




the PPLV method largely ignores it.  According to the authors,




persistence is "only estimated when the particular circumstances




warrant such consideration."  However, they do not explain what are




the circumstances that warrant consideration of persistence, nor how




persistence data should be used.



      C.2.2  Routes of Release




      The  PPLV  system categorizes the release of toxicants from waste




sites by  their release  to various media (soil, surface water,  ground




water,  or air).  Transport of toxicants through various pathways




within and between media  (e.g., food chain to humans) are also




 included, although percutaneous exposure is not considered.




      C.2.3   Presence of Incompatible or Reactive Mixtures




      The  PPLV  system does not include a factor for scoring  the




 hazard resulting from  reactive or incompatible wastes present  at a




 site.
                                  96

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C.3  Use of Data




     C.3.1  Number of Substances Evaluated




     The "limiting pollutant level" (i.e., the smallest SPPPLV) for




each toxicant at a waste site is calculated for each relevant




pathway and included in the calculation of the final PPLV for that




toxicant.  However, it is not clear exactly how each SPPPLV is




included in the final calculation of the PPLV because "subjective




judgments are made of the most likely among the significant pathways




for the site under consideration."




     C.3.2  Quantity of Data on Each Substance




     Calculation of the PPLVs used in this system requires an




extensive amount of data, much of which may not be available.  In




particular, intercompartmental partition coefficients (K) for each




chemical for each route of transport (e.g., soil to water, water to




plants, water to animals, plants to animals, plants to humans, and




animals to humans) are required for the calculation of PPLVs.




Values for such partition coefficients are presently available only




for a very limited number of substances.  In addition, physical data




on each substance, such as aqueous solubility and vapor pressure,




are required for the calculation of some SPPPLVs.  Such extensive




data are available for relatively few substances found at toxic




waste sites; the extensive data requirements, therefore, severely




limit the use of the PPLV system.
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     C.3.3  Clarity




     In order to properly assess the hazard resulting from release




of substances from toxic waste sites, the analyst needs to be




proficient in using up to 38 equations comprised of up to 43




components.  The complexity of this system makes the calculation of




PPLVs untenable for widespread use by individuals who are not highly




trained.




     Although the underlying scientific concept and numerical




calculations used to derive PPLVs, SPPPLVs, and DT appear to be




reasonable, the method for obtaining many of the factors in the




equations  (e.g., dietary intake factors, and intercompartmental




partition  coefficients) often relies heavily on professional




intuition  and assumptions that are based upon varying amounts and




quality  of experimental evidence.  Ihus, the resulting PPLVs must




often be regarded as tenuous.  In addition, the extensive need for




professional judgment on the part of the analysts using the PPLV




system is  expected to result in inconsistent scores between sites.




As  the authors state:  "One should not be surprised, therefore, if




two environmental engineers obtain different results from analysis




of  the identical situation.  3his may be the result of valid



differences in judgment."
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                             APPENDIX D




           SITE ASSESSMENT SYSTEM (SAS),  STATE OF MICHIGAN






     The Site Assessment System (SAS; Michigan, 1983) was modified




from the EPA HRS by the State of Michigan for the purpose of




assigning priorities to wastes sites, in terms of relative risk, for




further investigation and possible remedial action.  The methodology




used for the hazard ranking of substances was originally published




in the Michigan Critical Materials Register (Michigan, 1980).  That




method was modified for incorporation into the SAS.




D.I  Type of Toxic Effect




     In the SAS methodology for the hazard ranking of substances,




each substance is scored for environmental concern based on six




factors:  acute toxicity, genotoxicity (including carcinogenicity




and mutagenicity), subchronic/chronic toxicity (including




teratogenicity), bioaccumulation, persistence, and ecotoxicity.  The




values for each factor are added and the sum is multiplied by a




"data uncertainty multiplier" (to correct for the quality of the




data) to provide the potential toxicity score.




     D.I.I  Acute Toxicity




     SAS assesses acute toxicity by assigning scores for substances




based upon the lowest mammalian oral or dermal LD   or




inhalational LC,.,,.  For the oral and dermal modes of exposure, if




the LD   is less than 5 mg/kg, the score is 10; if the LD Q is 5




to 500 mg/kg, the score is 5; and if the LD,-,, is greater than 500
                                 99

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ing/kg, the score is 0.  For the Inhalational mode of exposure, if

the LC5Q is less than 0.5 mg/1, the score is 10; if the LCsn is

0.5 to 20 mg/1, the score is 5; if the LC^g is greater than

20 mg/1, the score is 0.

     D.I.2  Chronic Toxicity

     SAS assigns scores for subchronic/chronic toxicity by all modes

of exposure based upon both the magnitude of the lowest dose which

causes an  "irreversible adverse effect" in the most sensitive mammal

and whether the substance is teratogenic in mammals.  A score of 20

is assigned if the substance causes irreversible adverse effects at

doses lower than 0.5 mg/kg/day for oral or dermal exposure or

0.05 mg/1  for inhalational exposure and if it is teratogenic.  A

score of 10 is assigned if only one of the two preceding criteria

are met.   A score of 5 is assigned if irreversible adverse effects

are caused at  "low" doses.  Guidance as to the definition of "low"

dose  is not given.

      D.I.3 Carcinogenicjty, Mutagenicity, and Teratogenicity (CMI)
            Factor

      SAS includes teratogenic effects as a part of the chronic

toxicity assessment.  Carcinogenicity and mutagenicity are scored on

a weight-of-evidence basis.  If the substance has been demonstrated

to be both a positive or potential carcinogen in humans or animals

and a hereditary mutagen in a multicellular organism, it is assigned

a score of 20.  If only one of the two preceding criteria are met,

it receives a score of 10.  If the substance is positive in


                                 100

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bacterial mutagenicity tests, cell transformation assays, or tumor




promotion studies, it receives a score of 5.




D.2  Determinants of Exposure




     D.2.1  Persistence




     SAS assesses the environmental persistence of a substance by



assigning a persistence score of 5 if the half-life of the substance




in soil, air or water is longer than six months (26 weeks).  If it




is less than six months, it receives a score of 0.




     D.2.2  Routes of Release




     The routes of release in the SAS include ground water, surface




water, direct contact, and the atmosphere.  Hie consideration of all




routes, including the atmosphere, is a strong point.




     D.2.3  Presence of Incompatible or Reactive Mixtures




     All substances present in quantities greater than 100 kilograms




are rated for flammability, based either on the National Fire




Prevention Association method (see Section 3.1.2.3) or on chemical




flash point, and for their ability to react with themselves.



However, the reactivity of mixtures of chemicals is not assessed.




D.3  Use of Data



     D.3.1  Number of Substances Evaluated



     All substances identified at a site are scored for toxicity.




     D.3.2  Quantity of Data on Each Substance




     SAS employs a variety of toxicity endpoints and physical/




chemical data from which to calculate the final hazard score used in
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the ranking of waste sites.  It requires extensive amounts  of data




per substance to evaluate the six factors discussed above.   The




information required may be obtained from a variety of sources




including the International Agency for Research on Cancer (IARC),




the National Cancer Institute (NCI), the National Institute for




Occupational Safety and Health (NIOSH), the National Toxicology




Program (NTP), and the Michigan Critical Materials Register (MCMR).




If data for a given category of toxicity are not available, a score



of 0 is given.  A score of 0 due to absence of data is offset by the




multiplication of the toxicity score by a "data uncertainty




multiplier" which increases from 1.2 to 1.8 as more toxicity




characteristics have no data.




     D.3.3  Clarity




     SAS is a modification of the EPA HRS, and is similar in




clarity.  Step-by-step instructions, flow diagrams, worksheets, and




examples provide adequate information for understanding the scoring




process.  However, SAS is complicated by the high level of




professional judgment required to evaluate each component of the




hazard characterization.  The scorer must be able to locate and




assess the data to support the scores.  For instance, only "well




conducted" mammalian teratogenicity tests are to be used, but what




is meant by "well conducted" is not specified.
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D.4  Other Considerations




     SAS also considers ecotoxicity and bioaccumulation in its




hazard score for a substance.  Ecotoxicity is scored based on the




magnitude of the most sensitive indicator among either the avian




LDrQ levels, fish 96-hour LC5Q levels, or the chronic EC5Q



(effective concentration) to aquatic organisms.  Bioaccumulation of




the substance is scored based on the more sensitive of the following



two indicators of bioaccumulation:  (1) the bioaccumulation factors




for fish and (2) the logarithm of the octanol/water partition




coefficient of the substance.
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                             APPENDIX E




          HAZARD ASSESSMENT RATING METHODOLOGY II (HARM II)






     The Hazard Assessment Rating Methodology II (HARM II) was




developed by the Environmental Sciences Division of Oak Ridge




National Laboratory (1986) for use by the U.S. Air Force in




evaluating hazardous material disposal sites.  Details are contained




in Oak Ridge National Laboratory Publication No. 2582.




E.I  Type of Toxic Effect




     E.I.I  Acute Toxicity




     The toxicity factor in HARM II is unique among the systems




reviewed.  It incorporates "benchmark" health hazard scores for each




"significant" substance identified at a waste site.  The benchmark




health hazard scores are defined on the basis of "permissible




concentrations" for the following three classes of substances:




carcinogens, regulated substances, and nonregulated substances.




     The definition of permissible concentration of a substance in




HARM II as a concentration that will not cause adverse health




effects "under typical exposure conditions" is vague and could lead




to inconsistent interpretations.  For regulated substances, the




HARM II system uses the drinking water standards (permissible




concentrations of those substances) promulgated by EPA or NIOSH.




For carcinogens for which drinking water standards have not been




set, HARM II uses "permissible concentrations" as estimated by the




Carcinogen Assessment Group (CAG) of the EPA Office of Health and







                                 105

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Environmental Assessment.  For unregulated substances,  HARM II uses



a relative potency approach to define a benchmark.   In this



approach, a series of relative potency estimates for the substance



in question is prepared.  Each relative potency estimate is the



ratio of acute toxicity data (e.g., LD n or ^D-i *) ^or the
                                      j\J      lO


substance in question to the acute toxicity data for a single,



well-studied, structurally related substance.  The data used to



construct the series of ratios may come from any species of mammal



and may mix the types of waste toxicity.  The median ratio



determined from the above series of ratios is the "median potency."



The potency of the structural analogue used in the above exercise



relative to benzo(a)pyrene, the primary standard, is multiplied by



the median potency to derive the relative potency of the substance



in question.  The benchmark for an unregulated substance is the



product of its relative potency and the drinking water standard for



benzo(a)pyrene.  The toxicity data base for the chemicals is found



in the Registry of the Toxic Effects of Chemical Substances (RTECS,



Lewis and Tatken, 1982).



     The assessment of relative acute toxicity potential through the



use of "permissible concentrations" in the HARM II system involves



inconsistencies because the assumptions and formulae used by the EPA



Office of Drinking Water, NIOSH, and GAG are not identical.  Further
      = the lowest dose of a chemical that causes at least one

 death among a group of exposed experimental animals.




                                106

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inconsistencies can arise from the choice of structural analogues

and the calculation of median potency values for unregulated

chemicals.  These opportunities for lack of consistency are a

weakness which detracts from the usefulness of this method for

ranking sites.

     E.I.2  Chronic Toxicity

     Chronic toxicity, per se, is not evaluated by HARM II, although

some of the relative potency ratios may use chronic toxicity data.

This is a shortcoming for adequate assessment of the potential

danger associated with substances released slowly, over a prolonged

period of time.

     E. 1.3  Carcinogenicity, Mutagenicity, and Teratogenicity (GMT)
            Potential

     The HARM II ranking system does not assess carcinogenicity

except for those carcinogens which have either drinking water

standards or permissible concentrations estimated by GAG.  HARM II

does not assess  mutagenie and teratogenic effects.  This is a

shortcoming for  adequate assessment of the potential danger

associated with substances released over a long period of time.

E.2  Determinants of Exposure

     E.2.1  Persistence

     The HARM II system assesses the resistance of a substance to

environmental degradation by the same criteria as the HR.S.  In

HARM II, however, persistence is used in calculating the hazard

quotients of only those substances which have not been released from


                                 107

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the site.  Each persistence category is assigned a multiplier that




varies from 0.4 to 1.0 and operates on the sum of the toxicity and




bioaccumulation indices (c.f. E.4 Other Considerations).




     E.2.2  Routes of Release




     Surface water and ground water contamination are included in




the HARM II system; however, the airborne route of release is




omitted.  According to the authors, direct contact and fire and




explosion routes of release are also omitted because HARM II is



intended for use at protected Air Force installations which are




secure from the general public.




     E.2.3  Presence of Incompatible or Reactive Mixtures




     The HAKM II system does not include a factor for scoring the




hazard resulting from incompatible or reactive wastes present at a




site.




E.3  Use of Data




     E.3.1  Number of Substances Evaluated




     The HARM II system scores all "significantly toxic" substances




identified at a waste site.  However, it is not clear upon what




basis the decision of "significantly toxic" is made.




     E.3.2  Quantity of Data on Each Substance



     All the types of data necessary to calculate the median and




relative potency estimates for a substance are available in RTECS.




Potentially, 10 or more toxicity values per substance may be




needed.  The large amount of data required and the scientific
                                 108

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expertise needed to select structural analogues contribute to the




cumbersome nature of HARM II.  Furthermore, no guidance is provided




for the evaluation of substances that are not listed in RTECS, even




though it appears that LDcn values or other toxicity data




published in any source may be used to calculate potency estimates.



A substance without either a "permissible concentration" or an




LD_Q cannot be evaluated using the HARM II methodology.



     E.3.3  Clarity




     The HARM II system assesses many of the same factors as the EPA




MRS.  It also includes flow diagrams for the calculation of site




scores, extensive discussion of the parameters contained in each



scoring component, and numerous examples describing the application




of the system in simulated and real life case studies.   However, the




number and complexity of operations required to establish



"benchmark" health hazard scores make HARM II cumbersome.




E.4  Other Considerations




     The HARM II system ranks sites through the calculation of a




normalized human health hazard subscore.  The method for calculating




the normalized human health hazard subscore differs depending on




whether or not monitoring has detected the release of contaminants




from the waste site.  If contaminants have been detected, a hazard




quotient for each contaminant identified is calculated.  The hazard




quotient for a contaminant is derived by dividing the sum of the




estimated total intake of the contaminant from drinking
                                 109

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(concentration in ground water x 2 liters) plus the total estimated




intake from eating fish (concentration in surface water x fish



bioaccumulation factor x 6.5 grams) by the health effects benchmark




for the contaminant.  The hazard quotients for all contaminants are




added and a human health hazard index is assigned based on the




magnitude of the logarithm of the sum of the quotients.  The human




health hazard index ranges from 0 to 6.  The health hazard index is




then normalized (i.e., divided by 6 and multiplied by 100).  A human




health subscore is calculated by multiplying the normalized health




hazard index by a waste quantity factor.




      If contaminants have not migrated from the disposal site, a




health hazard index is calculated for each contaminant present at




the site.  The health hazard index is determined by multiplying the




persistence multiplier by the sum of the toxicity index of the



contaminant (based on the magnitude of the logarithm of the




benchmark for health effects) and the bioaccumulation index.  This




human health hazard index ranges from 0 to 9.  The highest value




calculated for any single contaminant is taken as the health hazard




index for the site.  This index is then normalized.  A human health




subscore is calculated by multiplying the normalized health hazard




index by a waste quantity factor.
                                 110

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                             APPENDIX F

             RCRA HAZARDOUS WASTE SCHEDULING METHODOLOGY


     The RCRA Hazardous Waste Scheduling Methodology (RCRA Method)

was developed to assist EPA in scheduling RCRA (Resource Conservation

and Recovery Act) hazardous wastes for further study as to whether

they should be banned from land disposal (e.g., landfill, surface

impoundment and landfarm).  To accomplish this, the RCRA Method

ranks RCRA waste streams based on both the toxic potential of the

waste stream and the total volume of the waste stream that is land

disposed (Environ Corporation, 1985).

F.I  Type of Toxic Effect

     F.I.I  Acute Toxicity

     The RCRA Method scores acute toxicity based on the lowest LD-Q

in any mammal via oral, dermal, or inhalational* exposure.  If the

lowest LD,-n is less than 50 mg/kg, the substance is considered to

have high acute toxicity and is assigned a score of 1.   If the lowest

LD_0 is greater than 50 mg/kg, the substance receives a score of 0.

If LD-0 data are unavailable, the lowest LDlo value is used.  If

no data are available, acute data for appropriate structural

analogues to the substance in question are used.
*Acute toxicity data from inhalation studies are usually reported as
 LC5Q (the concentration of a test substance in the air which
 causes the death of 50 percent of exposed experimental animals).
 If the LC5Q is the only data available, it is converted to an
 LD^Q using standard values for body weight and respiratory
 volumes.
                                 Ill

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     F.I.2  Chronic Toxicity



     For chronic toxicity, the RCRA Method computes an Equivalent


Dose Estimate (EDE).  The EDE is defined as that dose "at which the


estimated risk associated with a compound is comparable among all


compounds being evaluated."  For noncarcinogens, the EDE is the


acceptable daily intake (ADI) as established by either the EPA


Environmental Criteria and Assessment Office, the EPA Office of


Pesticide Programs, or the National Academy of Science (HAS).  In the


event the ADI has not been established by EPA or NAS, the EDE can be


calculated (1) by dividing the No Observable Effect Level (NOEL)*


from a chronic study by a "standardization factor" or by dividing the


product  of the Lowest Observable Effect Level (LOEL)** times a


"severity factor" by a standardization factor or (2) by dividing the


LD _ by  105.  The standardization factors correspond to the uncer-
   5U

tainty factors utilized in deriving ADIs (i.e., 10 for intraspecies


variability; 100 for intra-and interspecies variability; 1,000 for


the uncertainty associated with extrapolating from subchronic to


chronic  exposures as well as  intra- and interspecies variability).


 Severity factors were assigned as 2.14 for mild effects,  such as


biochemical changes and potentially reversible, mild organ changes, or


 4.68 for more  severe effects, such as teratogenicity,  reproductive or




  *NOEL = the  highest dose  of  a substance that did not  cause toxic

   effects when administered  to a group of experimental animals.


 **LOEL = the  lowest dose  of  a substance that caused  toxic effects

   when administered to  a  group of experimental  animals.



                                 112

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neurological dysfunction, or istologically described organ necrosis.

Based upon the magnitude of the EDE, a chronic toxicity score of 1 to

9 is assigned (the score ranges from 1, if EDE is equal to or greater

than 1, to a score of 9, if EDE is less than 10  ).  For noncar-

cinogens, the acute toxicity score is added to the chronic toxicity

score to give a final toxicity score.  The toxicity score of a waste

stream is considered to be the score of its most toxic constituent.

     F.I.3  Carcinogenicity, Mutagenicity, and Teratogenicity Factor
            for Carcinogenic Chemicals

     The RCRA Method utilizes the unit carcinogenic risk (UCR)*

factor for the calculation of EDE for carcinogens.   The UCR is

defined as the "upper limit" of the probability that the substance

will cause cancer at a dose of 1 mg/kg body weight/day over a

lifetime.  The UCR factor has been calculated by CAG for a

substantial number of carcinogens.  For other carcinogens that have

been designated by either the U.S. Department of Health and Human

Services (HHS) or the IARC, the UCR can be calculated from animal

data using either the multistage (when there are sufficient data) or

the one-hit model.**  For carcinogenesis,  the EDE is calculated as
 *UCR = the slope of the carcinogenicity dose-response curve at low
  levels of exposure.

**The multistage and one-hit models are linear extrapolation equations
  that are used to project the risk associated with a dose of a car-
  cinogen which is lower than any of the tested doses.  Both models
  assume that there is no threshold dose (i.e., all doses are
  associated with some risk).  In both models, the shape of the dose-
  response curve, between the lowest dose tested and the origin,
  approaches linearity at very low doses.
                                113

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a "standardization factor"  (10-6) divided by the UCR.  For




carcinogens, the chronic toxicity score is assigned based upon the




magnitude of the EDE according to the same range of scores (1 to 9)




described for noncarcinogens.  The final toxicity score of a




substance is the sum of the acute and chronic  toxicity scores.  The




toxicity of a waste stream  is considered to be the score  of its most




toxic constituent.




     Mutagenic and teratogenic effects are not considered in the




RCRA Method.




F.2  Determinants of Exposure




     F.2.1   Persistence




     The RCRA Method does not assess the environmental persistence




 of substances.




     F.2.2   Routes of  Release




     While  the RCRA Method  is directed at waste streams that are




 land disposed, it does not  consider pathway-specific  factors.  It is




 based  solely on  the toxicity and quantity of the waste stream.  It




 does not consider the  release of the waste stream.




     F.2.3   Presence of Incompatible or Reactive Mixtures




     The RCRA Method contains no factor for evaluating incompatible




 or reactive mixtures at wastes sites.
                                 114

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 F.3  Use of Data




      F.3.1  Number of  Substances  Evaluated



      The RCRA Method scores waste streams based on the one




 constituent  that has the highest  toxicity score multiplied by the




 total volume of  the waste stream  land disposed In the U.S.



      F.3.2   Quantity of Data on Each Substance




      The data required for assigning the toxicity factor in the RCRA



 Method have  already been compiled, the calculations completed, and




 toxicity factors assigned for 363 constituents hazardous under




 RCRA.  For other constituents, toxicity data for assigning a




 toxicity score may be  available from EPA, HHS, or IARC.  In the case




 of  substances for  which insufficient toxicity data exist, data from




 structural analogues (presumably  selected by the scorer) may be used




 in  combination with appropriate uncertainty factors.



      F.3.3   Clarity




      The RCRA Method is a straightforward scheme that ranks waste




 streams  on the basis of the toxicity of the single most toxic



 constituent  and  the total volume  to be land disposed.  Although the




 specific calculations used to estimate toxicity and volume factors




 are complex,  the calculation of the final score used for ranking




 purposes is simply the product of these two factors.  The RCRA




Method report is well referenced  and contains detailed appendices




that demonstrate how to calculate toxicity and volume factors.  In




 addition, it presents the actual  ranking of 363 constituents




hazardous under RCRA.




                                115

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                             APPENDIX G




               EUROPEAN ECONOMIC COMMUNITY (EEC) PLAN






     The EEC Plan was developed in order to classify "new chemicals"




with respect to their potential hazard to humans and the




environment, and to provide guidelines for developing a ranking




system for hazardous wastes sites.  Details were published by



Schmidt-Bleek et al., (1982).




G.I  Type of Toxic Effect




     According to the EEC Plan, hazard scores are assigned for each




of three media:  air, water, and soil/sediment.   In each case the




hazard score is the product of an exposure score times an "effects"




score.  The effects score takes into account mammalian oral and



inhalational subchronic toxicities, aquatic toxicity, mutagenicity




and dermal sensitization.  Subscores for each of these aspects of




toxicity are based upon data as described in the following



sections.  The subscores are combined as described below.




     For soil/sediment, the effects score is the mammalian oral




toxicity subscore plus one half of the score of the mutagenicity and




dermal sensitization subscores.  For air, the effects score is the




mammalian inhalational toxicity subscore plus one half the scores of




the mutagenicity and dermal sensitization subscores.  The effects




score for water is based upon the aquatic toxicity subscore (derived




from data on fish and daphnia) plus one half the score of the




mutagenicity and dermal sensitization subscores.
                                 117

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     G.I.I  Acute Toxicity

     Acute toxicity, per se, is not addressed by the EEC Plan.

However, a score of 1.0 to 1.5 is assigned based upon the skin

sensitization activity of the chemical.  In the event of

insufficient data, the highest possible score is assigned for

sensitization.  The use of dermal sensitization as a surrogate for

acute systemic toxicity is a shortcoming of this method because many

dermal sensitizers (e.g., nickel) are not acute systemic toxicants

when applied topically and vice versa (National Academy of Sciences,

1975).

     G.1.2  Chronic Toxicity

     The EEC Plan does not directly consider chronic toxicity;

instead, subchronic toxicity is evaluated.  The EEC Plan assigns a

score of 1 to 3 for mammalian toxicity based upon the NOEL observed

in either a subchronic (28-day) oral study or a subchronic (4 hours

of exposure/day) inhalation study.  In the event of insufficient

data, the highest possible score is assigned.

     G.I.3  Carcinogenicity, Mutagenicity, and Teratogenicity (GMT)
            Factor

     Mutagenicity effects are assigned a score of 1 to 3 in the EEC

Plan, although the specific test organisms (bacterial, mammalian,

etc.) or tests that are acceptable are not specified.  A total of 2

tests are scored; if both tests are negative, a score of 1 is

assigned.  For each positive test, 1 point is added.  Carcinogenicity

and  teratogenicity effects are not included in the system.  The


                                 118

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omission of carcinogenicity and teratogenicity data from the EEC




Plan is a shortcoming when attempting to rank hazardous wastes sites.




G.2  Determinants of Exposure




     G.2.1  Persistence




     The EEC Plan scores the environmental persistence of chemicals




by summing the scores assigned for biodegradability and those




assigned for abiotic degradability.  A total of 2 points is scored




for compounds that are resistant to biodegradation in soil or water;




one point is scored for "readily biodegradable" compounds.   (The




criteria for assignment of scores are not specified.)  For abiotic




degradation, scores are assigned based on either hydrolysis




half-life (shorter than 1 year = 1; 1 year or longer = 2) or




photodegradability ("good evidence for instability" = 1; "no good




evidence for instability" =2).  The persistence subscore is a term




in the calculation of the exposure score.  Assessment of this




characteristic is especially difficult for the EEC Plan because




guidance concerning the requisite data bases or references are




lacking.




     G.2.2  Routes of,Release




     Three routes of release are included in the EEC Plan:   release




into the air,  water, and soil/sediment.   However, water releases are




not classified with regard to surface or ground water, and the




meaning of release to soil/sediment is not defined.  No assessment




of toxicity due to accidental direct contact of people is presented.
                                 119

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     G.2.3  Presence of Incompatible or Reactive Mixtures




     The EEC Plan does not contain a factor which considers the




hazard due to incompatible or reactive mixtures.




G.3  Use of Data




     G.3.1  Number of Substances Evaluated




     The EEC Flan is designed to assess the potential risks due to




exposure to new chemicals prior to their disposal at wastes sites.




Therefore, it evaluates one chemical at a time, often using only its




physical and chemical properties.  It is not clear from the




description of the Plan whether only one chemical or all chemicals




would be evaluated for ranking a wastes site.




     G.3.2  Quantity of Data on Each Substance




     Numerous data are required on each chemical.  Several physical




and chemical properties for each chemical, such as log P, vapor




pressure, water solubility, and molecular weight are needed for the




proposed hazard scoring, as well as the following toxicity data:




subchronic toxicity for mammals, dermal sensitization, mutagenicity




tests,  and acute toxicity to fish and daphnids.  For chemicals on




which there are insufficient data, the maximum score for that




particular element is assigned.




     G.3.3  Clarity




     The EEC Plan does not actually rank hazardous wastes sites, but




rather  presents theoretical guidelines that could be followed to




develop a hazard ranking system.  It describes, in general, how a
                                 120

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decision-tree may be constructed for the purpose of regulating




wastes sites.  Ihe overall system is based on hazard assessments for




individual chemicals which are combined using a series of formulas




(few of which are clearly explained or derived) to achieve a final




score.  The overall Plan is not clearly presented.  The terminology




is often ill-defined or imprecisely used, making the EEC Plan open




to wide variation in interpretation.  These deficiencies result in a




somewhat confusing and ambiguous system.
                                 121

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                             APPENDIX H

     SYSTEM FOR PREVENTION,  ASSESSMENT,  AND CONTROL OF EXPOSURES
           AND HEALTH EFFECTS FROM HAZARDOUS SITES (SPACE)
     The SPACE for Health system was developed by the Centers for

Disease Control for State health agencies to prevent or control

human health problems related to exposure to hazardous wastes

(Centers for Disease Control, 1984).

H.I  Type of Toxic Effect

     H.I.I  Acute Toxicity

     The SPACE system uses the same evaluation methodology as the

EPA HRS for toxicity assessments; however, it scores the five most

toxic substances per site as opposed to the single most toxic

substance.

     H.I.2  Chronic Toxicity

     Since this system utilizes the same methodology as the EPA HRS

toxicity factor, in general, it does not consider chronic effects.

     H.I.3  Carcinogenicity, Mutagenicity, and Teratogenicity (CMT)
            Factor

     The SPACE system does not consider CMT effects.

H.2  Determinants of Exposure

     H.2.1  Persistence

     The SPACE system utilizes the same criteria as the EPA HRS for

assignment of the environmental persistence of substances.

Consequently, its persistence score takes into account only

resistance to biodegradation.
                                 123

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     H.2.2  Routes of Exposure




     The SPACE system includes factors which consider contamination



of soil and food chains in addition to ground water, surface water




and air.




     H.2.3  Presence of Incompatible or Reaction Mixtures




     Although the SPACE system instructs assessors to determine




whether or not reactive mixtures are present (and if so whether they




are sufficiently separated to be safe), it does not provide guidance




for identifying substances that will react/ignite when mixed.




H.3  Use of Data




     H.3.1  Number of Substances Evaluated




     The toxicity, quantity, and concentration of the five most




hazardous substances at a wastes site are included in the scoring of




a wastes site by the SPACE system.




     H.3.2  Quantity of Data on Each Substance




     Since the SPACE system utilizes the methodology described in




the EPA HRS for its toxicity assessments, its data requirements are




the same as those for the EPA HRS.




     H.3.3  Clarity




     The SPACE system outlines steps to be followed for the




inspection, monitoring, and assigning priorities for cleanup of




hazardous wastes sites.  A flow diagram allows one to see at a




glance  the entire process from identification of wastes sites to the




assignment of priorities and performance of the requisite health
                                 124

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studies.  This system is intended for use by State health officials




to rank a wide diversity of wastes sites but lacks specific details.




However, there is extensive referral to literature sources where the




reader may acquire in-depth information.  Although the scoring of




many of the individual components of a waste site is  abstracted



directly from the EPA HRS,  it is not clear how the overall site




score is calculated.




H.4  Other Considerations



     Although the SPACE system utilizes many of the same criteria




and methods for assessing toxicity as the EPA HRS, it goes beyond




the EPA HRS in several aspects of human health effect assessments.




For instance, in determining the potential for exposure to a




hazardous substance, the SPACE system requires that samples be




obtained not only from ground water, surface water, soil, and air



for contamination, but also that the food chain be monitored for the




possible presence of the hazardous substances.  Scores of 0 to 3 are



assigned based upon whether the substance is absent,  present above




background levels, present at or near the food tolerance level




promulgated by the Food and Drug Administration (FDA), or present




significantly above the FDA tolerance levels.




     The SPACE system can also extend the basis upon which human




exposure can be verified by monitoring the potentially exposed




population through sampling of biological fluids (blood and urine)




for the presence of the contaminant.  In the absence of the ability
                                 125

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to perform biological assays, or in the case of allegations  of past



(but not current) exposure, the SPACE system can utilize



epidemiological data.  These data may be gathered both from  current



interviews, questionnaires, or retrospective studies via review  of



hospital clinical data or death records/birth defects registries and



the like.  Positive findings from the aforementioned types of



studies can be used to raise the priority assigned a site.  However,




the overall impact of these scores on a site's priority is not clear



because, as mentioned previously, the exact way to devise an overall



site score is not clearly defined.
                                 126

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                             APPENDIX I

               EXAMPLE OF PROPOSED SCORING METHODOLOGY


     Toxicity values have been assigned to 30 hazardous substances

based on the methodology presented in Section 4.  This appendix

presents the supporting data and provides guidance on how the

methodology should be applied in order to assign toxicity values for

one organic chemical (1,1,2-trichloroethylene; TCE).  The data for

all of the substances are provided in tabular form in Appendix J

(n.b., one sheet is used per substance).*

I.I  Illustration of Methodology-TCE

     Table 1-1 presents the supporting data for assigning the

pathway-specific toxicity values to 1,1,2-trichloroethylene.  The

pathway-specific toxicity values are derived by adding together the

assigned oral, dermal, inhalational, and CM values as described in

Section 4 and in this section.

1.2  CM

     CM potential is assessed and incorporated into the pathway-

specific toxicity values.  Entries of CM data in the table are as

follows.  First, for weight-of-evidence, the positive responses

(based on the definition of a positive response in RTECS), are a

positive oral test in mice and positive inhalational tests in rats

and hamsters.  Thus, TCE has been shown to induce cancer in more
*For purposes of this paper, data tables are provided for only 30
 selected substances.  These substances are identified in Table 10.
                                 127

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                                     TABLE 1-1

                SUPPORTING  DATA FOR 1,1,2-TRICHLOROETHYENE
     Weight-of-Evidence
         Basis:       Positive. Mouse.  Oral
     Potency
         Basis:

     Matrix:
                              Category:     III
                      Positive. Hamster.  Rat.  Inhalation
     -6.67 me/ke/dav
III x Low
                                                    Group:

                                                    CM Value:
Law

2_
ORAL TOXICITY

     Acute Basis:      LD50 - 2402 mg/kg (mouse)

     Chronic  Basis:    ADI - 2402/105 - 0.024

     CM (from above):
INHALATION TOXICITY

     Acute Basis:
       ppm/4H:
     " 300° PPm/2H
                       1500 ppmAH
                              Acute Value:

                              Chronic Value:

                              CM Value:
                                                           ToxicityORAL
DERMAL TOXICITY

     Acute Basis:      Dermal Irritation - Severe     Acute Value:

     Chronic Basis:    Default to Chronic Oral	  Chronic Value:

     CM (from above):                                CM Value:
                                                           ToxicityDERMAL
                                                    Acute Value:
     Chronic Basis:     TLV-TWA - 50 ppm - 270 mg/m   Chronic Value:
       ADI*            32.13 _
     CM (from above):
 ADI - (TLV-TWA)(0.119).
                              CM Value:
                                         128

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than two animal species and is assigned to Category III according to




the rules presented in Table 6.  If no data had been available



regarding carcinogenicity or mutagenicity, the weight-of-evidence




value would have been 0.  Second, for potency, the EPA has




determined the ED1Q for ICE to be 6.67 ing/kg/day.  Since the



ED> ., is greater than 1.0 mg/kg/day, ICE is assigned to a low




potency group following the rules presented in Table 7.  Following




the matrix presented in Table 8, substances in weight-of-evidence




Category III with a low potency are assigned a CM value of 2.




1.3  Oral Toxicity




     The oral toxicity of TCE is assessed in the following manner.




The lowest mammalian oral LD5Q listed in RTECS is 2,402 mg/kg in




mice.  Following the rules presented in Table 4, the LDrn is




between 500 to 5,000 mg/kg resulting in an assigned acute oral



value of 1.  No chronic toxicity information is in listed RTECS and




a RfD has not been assigned.  Thus, the chronic value is determined




by using the magnitude of (LD50)(10~ ) = 0.024 mg/kg.  Following




the rules in Table 5, this value is less than 0.5 mg/kg and thus a




chronic oral value of 3 is assigned.  The toxicity   , value is




the sum of the acuteorai > c*iron:'-coral' anc* ^ values.  Thus, the



toxicity ral value for TCE is 6.




1.4  Dermal Toxicity




     The dermal toxicity of TCE is assessed in the following




manner.  No dermal LD-0 data are listed in RTECS, however, TCE  is
                                 129

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reported to be a severe dermal irritant.  Based on the irritation



criteria in Table 4, TCE is assigned an acute dermal value of 3.  No



chronic dermal data are listed in RTECS.  Since a dermal LD5Q is



not available, the chronic dermal value defaults to the chronic oral



value of 3.  The toxicity,    , value is the sum of the acute



dermal, chronic dermal, and CM values.  Thus, the toxicityHermai



value is 8.



1.5  Inhalational Toxicity


     The inhalation toxicity of ICE is assessed in the following



manner.  A mammalian LCcQ value is not available, however, the



lowest mammalian LC,  is 3,000 ppm for a 2-hour exposure to mice.



Since LC_. data are not available, the LC   may be used.  The
        5U                               lo


value reported is for a 2-hour exposure and must be converted to a



4-hour exposure using Haber's law which states that the product of



exposure concentration and duration of exposure is a constant.



Thus, the concentration for a 4-hour exposure period is calculated



from the equation:



      concentration4_fcour  -  (2-hour)(3,OOP ppm)   -  1,500 ppm

                                   4-hours



According to Table  4, the acute inhalational value is 2, because



1,500 ppm is between 200 and 2,000 ppm.  Since a TLV-TWA is



available for TCE,  a chronic inhalational score can be calculated by



the formula:



                      ADI  •   (TLV-TWA)(0.119)



Since the TLV-TWA for TCE is 270 mg/m3, the ADI is 32.13 mg/m3.
                                 130

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A  chronic  inhalational value  of  0 is assigned because the calculated


ADI is greater than 20 mg/m3.  The toxicity., ,  . _   . value is
                                          •'inhalational

the sum of the acute^^^ + chronicinhalat.Qn + CM


values.  3hus, the toxicity. , -  ..    . value for ICE is 4.
                           inhalational
                                131

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              APPENDIX J

SUPPORTING DATA FOR ASSIGNING TOXICITY
    VALUES TO HAZARDOUS SUBSTANCES
                  133

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SUBSTANCE NAME:  1.1-Dichloroethvlene
                                                             CAS  NO:  00075-35-A
CM
     Weight-of-Evidence
          Basis:        Positive. Mouse. Inhalation
                       Positive. Rat. Inhalation
     Potency
          Basis:

     Matrix:
                       ED1Q - 0.233 mg/kg/dav

                       III x Med	
                       LD50 - 200 me/kg (rat)
ORAL TOXICITY

     Acute Basis:

     Chronic Basis:    RfD - 0.009 mg/kg/day

     CM (from above):
DERMAL TOXICITY

     Acute Basis:      Default to Acute Oral

     Chronic Basis:    Default to Chronic Oral

     CM (from above):
INHALATION TOXICITY

     Acute Basis:      LC50 ~ 539 ppm/^H (mouse)
     Chronic Basis:
       ADI*
     CM (from above):
                       TLV-TWA - 5 ppm - 20
                       2.38
Category:  III



Group:      Med

CM Value:  3	




Acute Value:

Chronic Value:

CM Value:
                                                             ToxicityORAL




                                                        Acute Value:      _

                                                        Chronic Value:

                                                        CM Value:
     ToxicityDERMAL




Acute Value:     	2_

Chronic Value:     1


CM Value:        	3
                                                             ToxicityINHALATIONAL
 ADI -  (TLV-TWA)(0.119).
                                           135

-------
SUBSTANCE NAME:  1.1.1-Trtchloroethane
                                                             CAS NO: 00071-55-6
CM
     Welght-of-Evidence
          Basis:       In Vitro. Mutaeentcitv
     Potency
          Basis:

     Matrix:
Default
I x Low
Category:  I	


Group:     Low

CM Value:
ORAL TOXICITY

     Acute Basis:
ID50 - 5660 me/kg (rabbit)
     Chronic Basis:    TD^-43 mg/kg (rat cardio-
                       vascular anomalies)
                       ADI-43/1000-0.043 mg/kg/dav
      CM (from above):
 DERMAL TOXICITY

      Acute Basis:       LD50 -  1000 mg/kg  (rabbit)

      Chronic Basis:     ADI-1000/105-0.1 mg/kg/dav

      CM (from above):
 INHALATION TOXICITY

      Acute Basis:       LCLO " 100° pPm/7tH

      Chronic Basis:     TLV-TWA - 350 ppm -
                        1900 mg/mj
        ADI             226.1

      CM (from above):
Acute Value:

Chronic Value:



CM Value:
                                                             ToxicityORAL
                                 Acute Value:

                                 Chronic Value:

                                 CM Value:
                                                             ToxicityDERMAL
                                 Acute Value:

                                 Chronic Value:



                                 CM Value:
  ADI - (TLV-TWA)(0.119).
                                           136

-------
SUBSTANCE NAME:   1.1.2-Trichloroethvlene
                                                        CAS NO: 00079-01-6
CM
     Weight-of-Evidence
          Basis:        Positive.  Mouse.  Oral
     Potency
          Basis:

     Matrix:
                                                        Category:  III
                       Positive.  Hamster.  Rat.  Inhalation
                       ED10 ~ 6-
                       III x Low
Group:      Low

CM Value:  2
                       LD50 - 2402 mg/kg (mouse)
ORAL TOXICITY

     Acute Basis:

     Chronic Basis:     ADI - 2402/105 - 0.024

     CM (from above):
DERMAL TOXICITY

     Acute Basis:       Dermal Irritation - Severe

     Chronic Basis:     Default to Chronic Oral

     CM (from above):
INHALATION TOXICITY

     Acute Basis:
       ppm/4H:
                       LCLO " 300° ppm/2H (mouse)
                       1500 ppm/4H	
     Chronic Basis:     TLV-TWA - 50 ppm - 270 mg/m3
       ADI*            32.13	

     CM (from above):
Acute Value:

Chronic Value:

CM Value:
                                                             ToxicityORAL




                                                        Acute Value:     	3_

                                                        Chronic Value:    	3_

                                                        CM Value:        	2
                                                             ToxicityDERMAL
Acute Value:
                                                        Chronic Value:      0
                                                        CM Value:
                                                             ToxicityINHALATIONAL
 ADI - (TLV-TWA)(0.119).
                                         137

-------
SUBSTANCE NAME:  Acetone
                                                             CAS NO:  00067-64-1
CM
     Weight-of-Evidence
          Basis:       In Vitro. Mutagenicitv
     Potency
          Basis:

     Matrix:
Default
I x Low
                                                        Category:


                                                        Group:      Low

                                                        CM Value:
                        LJ>50.
     - 3000 mg/ke (mouse)
ORAL TOXICITY

     Acute Basis:

     Chronic Basis:    RfD - 0.1 mg/kg/dav

     CM (from above):
 DERMAL TOXICITY

      Acute Basis:       LD5Q - 20000 mg/kg (rabbit)

      Chronic Basis:    ADI-20000/105-0.2  mg/kg/day

      CM (from above):
 INHALATION TOXICITY

      Acute Basis:
      Chronic Basis:
        ADI*
      CM (from above):
      - 110000 mg/m /62M	
 11985 ppmAH (mouse)	

 TLV-TWA -  750 ppm - 1780 mg/m3
 211.82	
Acute Value:

Chronic Value:

CM Value:
                                 Acute Value:

                                 Chronic Value:

                                 CM Value:
                                                              ToxicityDERMAL
                                                        Acute Value:
                                                        Chronic Value:
                                 CM Value:
  ADI - (TLV-TWA)(0.119).
                                           138

-------
SUBSTANCE NAME:   Arsenic (as Arsenic Trioxide)
                                      CAS  NO:  01327-53-3
CM
     Weight-of-Evidence
          Basis:       Positive.  Human
     Potency
          Basis:

     Matrix:
ED1Q - 0.00703 mg/kg/dav

III x High	
ORAL TOXICITY

     Acute Basis:      LD5Q - 15.1 mg/kg (rat)

     Chronic Basis:    RfD - 0.0004	

     CM (from above):
DERMAL TOXICITY

     Acute Basis:      Default to Acute Oral

     Chronic Basis:    Default to Chronic Oral

     CM (from above):
 INHALATION TOXICITY

     Acute Basis:      Default to Chronic Inhalation

     Chronic Basis:    TWA - 10 ug (As)/m  -	
                       13.2 ue/m3 (of Arsenic
                                       trioxide)
       ADI             0.00157

      CM  (from above):
  ADI - (OSHA Air Standard-TWA)(0.119)
Category:  III


Group:      High

CM Value:  3	
                                 Acute Value:

                                 Chronic Value:

                                 CM Value:
                                      ToxicityORAL




                                 Acute Value:

                                 Chronic Value:

                                 CM Value:
                                                             ToxicityDERMAL
                                 Acute Value:

                                 Chronic Value:




                                 CM Value:
                                                             Toxicit
                                           139

-------
SUBSTANCE NAME:  Benzene
                                      CAS  NO:  00071-43-2
CM
     Welght-of-Evidence
          Basis:       Positive. Human
     Potency
          Basis:

     Matrix:
ORAL TOXICITY

     Acute Basis:

     Chronic Basis:



     CM  (from above):
ED10.
-3.7 mg/ke/dav
III x Low
LD50.
• A700 mg/lcg (moused
TDTfl — 900 mg/kg (reduced
	(fetal weights)
ADI-900/1000-0.9 mg/kg/dav
 DERMAL TOXICITY

      Acute  Basis:       Dermal Irritation -  Moderate

      Chronic Basis:     Default to Chronic Oral	

      CM (from above):
 INHALATION TOXICITY
      Acute Basis:
      Chronic Basis:
        ADI*
      CM (from above):
LC5Q -  9980 ppm  (mouse)
LC5Q -  17500 ppm/AH  (rat)

TLV-TWA -  10 ppm - 30 mg/m3
3.57	
Category:   III


Group:      Low

CM Value:
Acute Value:

Chronic Value:



CM Value:
                                      ToxicityORAL




                                 Acute Value:     	2_

                                 Chronic Value:   	1_

                                 CM Value:        	2
                                                              ToxicityDERMAL
                            Acute Value:
                            Chronic Value:
                                 CM Value:
  ADI - (TLV-TWA)(0.119).
                                           140

-------
SUBSTANCE NAME:   BenzoCa'ipyrene
                                                             CAS  NO:  00050-32-8
CM
     We ight-of-Evidence
          Basis:        Positive. Rat
                       Positive. Mouse
     Potency
          Basis:

     Matrix:
ORAL TOXICITY

     Acute Basis:
                       ED10 " °-00628 lag/kg/day

                       III x High	
                       Default to Chronic Oral
     Chronic Basis:    TDLQ 100 me/kg, mouse	
                       (decreased male/female indices:
                       decreased liveborn)	
                       ADI-100/1000-0.1 mg/kg/dav
     CM (from above):
                       Dermal Irritation. Mild
DERMAL TOXICITY

     Acute Basis:

     Chronic Basis:     Default to Chronic Oral

     CM (from above):
 INHALATION TOXICITY

     Acute Basis:      Default  to Acute Oral

     Chronic Basis:    Default  to Chronic  Oral

     CM  (from above):
Category:  III



Group:      High

CM Value:  3	




Acute Value:

Chronic Value:




CM Value:
     ToxicityORAL




Acute Value:

Chronic Value:

CM Value:
                                                             ToxicityDERMAL
                                                        Acute Value:

                                                        Chronic Value:

                                                        CM Value:
                                           141

-------
SUBSTANCE NAME:  Cadmium (as Cadmium Chloride)
                                                             CAS NO: 10108-64-2
CM

     Weight-of-Evidence
          Basis:


     Potency
          Basis:

     Matrix:

ORAL TOXICITY

     Acute Basis:

     Chronic Basis:



     CM  (from  above):




DERMAL TOXICITY

     Acute Basis:      LD^-233 mg/kg (guinea pig)

     Chronic Basis:    ADI - 233/105 - 0.00233

     CM  (from  above):
                       Positive. Rat. Inhalation
                       Positive. Mouse. Subcutaneous
                       ED1Q - 0.0173 mg/kg/day
                       III x Med
                            - 60 mg/k  (mouse)
                       TDTfl - 17 mg/kg (musculo
                                skeletal anomalies)
                       ADI - 17/1000 - 0.017 me
 INHALATION TOXICITY

      Acute Basis:
        ppm/4H:

      Chronic Basis:
        ADI
      CM (from above):
LC90-420 mg/m-V30M (dog)
7 ppm/4H	

TLV-TWA - 50 ug(Cd)/m3 -
81.53 ug/m3 (of Cadmium
	chloride)
0.00097	
                                 Category:   III



                                 Group:      Med

                                 CM Value:   J	



                                 Acute Value:

                                 Chronic Value:



                                 CM Value:
                                                             ToxicityORAL
                                                        Acute Value:

                                                        Chronic Value:

                                                        CM Value:
                                                             ToxicityDERMAL
                                                        Acute Value:
                                                        Chronic Value:
                                 CM Value:
  ADI - (TLV-TWA)(0.119).
                                           142

-------
SUBSTANCE NAME:   Carbon Tetrachloride
                                                            CAS NO: 00056-23-5
CM
     Weight-of-Evidence
          Basis:        Positive.  Mouse.  Oral
     Potency
          Basis:

     Matrix:
                      Positive. Hamster. Oral
                      Positive. Rat. Subcutaneous


                      ED10 - 0.0152 mg/kg/day

                      III x Med	
Category:  III




Group:      Med

CM Value:
ORAL TOXICITY

     Acute Basis:       LD5Q - 2800 mg/kg (rat)	

     Chronic Basis:     ADI-2800/105-0.28 mg/ke/dav

     CM (from above):
                                                       Acute Value:

                                                       Chronic Value:

                                                       CM Value:
                                                             ToxicityORAL
DERMAL TOXICITY

     Acute  Basis:
                            - 5070 mg/kg (rat)
     Chronic Basis:    ADI-5070/10J-0.0507 mg/kg

     CM (from above) :
 INHALATION TOXICITY

      Acute Basis:
        ppm/4H:
                       LC50 - 9526  ppm/8H  (rat)
                       19052 ppm/4H	
      Chronic Basis:    TLV-TWA - 5 ppm - 30 mg/m3
        ADI*            3.57	
      CM (from above):
 *ADI - (TLV-TWA)(0.119).
Acute Value:

Chronic Value:

CM Value:
                                                             ToxicityDERMAL
 Acute Value:
                                                        Chronic Value:
                                                        CM Value:
                                           143

-------
SUBSTANCE NAME:   Chlorobenzene
                                                             CAS NO: 00108-90-7
CM
     Weight-of-Evidence
          Basis:

     Potency
          Basis:

     Matrix:
In Vitro. Mutagenicitv
Default
I x Low
Category: I
Group : Low
CM Value: 1
ORAL TOXICITY

     Acute Basis:
LD50
2830 mg/ke (rabbit)
                                Acute Value:
     Chronic Basis:    ADI-2830/105-0.0283 mg/kg/day   Chronic Value:

     CM  (from above):                                  CM Value:
 DERMAL TOXICITY

     Acute Basis:      Default  to Acute Oral

     Chronic Basis:    Default  to Chronic Oral

     CM  (from  above):
 INHALATION TOXICITY

     Acute Basis:
     Chronic Basis:
       ADI*
     CM  (from  above):
    ,-15000 mg/m -3265 ppm
TLV-TWA - 75 ppm - 350 mg/mj
41.65	
                                      ToxicityORAL




                                Acute Value:      _

                                Chronic Value:

                                CM Value:
                                                             ToxicityDERMAL
                           Acute Value:

                           Chronic Value:


                           CM Value:
  ADI -  (TLV-TWA)(0.119).
                                          144

-------
SUBSTANCE NAME:   Chloroform
                                      CAS NO:  00067-66-3
CM
     Weight-of-Evidence
          Basis:        Positive. Rat. Oral
     Potency
          Basis:

     Matrix:
Positive. Mouse. Oral


ED1Q - 0.508 mg/kg/day

III x Med	
11*   ~
          up/kg (mouse)
ORAL TOXICITY

     Acute Basis:

     Chronic Basis:    RfD - 0.01 mg/kg/day

     CM (from above) :
DERMAL TOXICITY

     Acute Basis:      Dermal Irritation - Mild

     Chronic Basis:    Default to Chronic Oral

     CM (from above):
 INHALATION TOXICITY

     Acute Basis:
     — 5747 ppm (mouse)
     Chronic Basis:    TLV-TWA - 10 ppm - 50 me/in3
                       50 mg/m_
       ADI             5.95

     CM  (from above):





 *ADI -  (TLV-TWA)(0.119).
Category:  III



Group:      Med

CM Value:  3	




Acute Value:     	3_

Chronic Value:   	3_

CM Value:        	3
                                      ToxicityORAL




                                 Acute Value:      	1_

                                 Chronic Value:   	3_

                                 CM Value:        	3_
                                 CM Value:
                                      ToxicityDERMAL




                                 Acute Value:     	1_

                                 Chronic Value:   	1
                                       ToxicityINHALATIONAL
                                          145

-------
SUBSTANCE NAME:   Chromium (see Chromium. Hexavalenf)
                                      CAS NO: 13765-19-0
CM
     Weight-of-Evidence
          Basis:       Positive. Human
     Potency
          Basis:

     Matrix:
ORAL TOXICITY

     Acute Basis:
ED1Q - 0.00257 mg/kg/dav

III x High	
LD50 - 327 me/kg (rat)
	(as dlhvdrate)
     Chronic Basis:    ADI - 327/103 - 0.00327

     CM (from  above):
 DERMAL TOXICITY

      Acute Basis:       Default  to Acute Oral

      Chronic Basis:     Default  to Chronic Oral

      CM (from above):
 INHALATION TOXICITY

      Acute Basis:
Default to Chronic Inhalation
      Chronic Basis:     TLV-TWA - 50  ug(Cu)/m3 -
                        150.6 ug/m  (chromic  acid.
                        	calcium)
        ADI
      CM (from above):
 0.018
 *ADI - (TLV-TWA)(0.119).
Ca te gory:  III


Group:     High

CM Value:  3	
Acute Value:


Chronic Value:

CM Value:
                                      ToxicityORAL




                                 Acute Value:     _

                                 Chronic Value:

                                 CM Value:
     ToxicityDERMAL




Acute Value:     	3

Chronic Value:   	3




CM Value:        	3
                                                              ToxlcltyINHALATIONAL
                                           146

-------
SUBSTANCE NAME:  Chromium. Trlvalent (as Chromium Sulfate)   CAS NO: 10101-53-8

CM
     Weight-of-Evidence
          Basis:       In Vitro. Mutagenicity
     Potency
          Basis:

     Matrix:
Default
I x Low
ORAL TOXICITY

     Acute  Basis:      Default  to  Chronic Oral

     Chronic  Basis:    RfD -1.0 mg/kg/day	

     CM (from above):
DERMAL TOXICITY

     Acute Basis:      Default  to Acute Oral

     Chronic  Basis:    Default  to Chronic Oral

     CM (from above):
INHALATION TOXICITY

     Acute Basis:

     Chronic Basis:
Default to Chronic Inhalation
TLV-TWA - 500 ug(Cr)/mJ -
1.885 mg/m  (of Chromium
   	sulfatet
       ADI             0.224

     CM (from above):
 ADI -  (TLV-TWA)(0.119).
Category:  I	


Group:     Low

CM Value:  1
                                 Acute Value:

                                 Chronic Value:

                                 CM Value:
                                                             ToxicityORAL
                                 Acute Value:

                                 Chronic Value:

                                 CM Value:
                                                             ToxicityDERMAL
Acute Value:

Chronic Value:




CM Value:
2

2
                                          147

-------
SUBSTANCE NAME:  Copper  (as Cupric Chloride)
                                                             CAS  NO:  07447-39-4
CM
     Weight-of-Evidence
          Basis:       In Vitro. Mutagenicity
     Potency
          Basis:

     Matrix:
                       Default
                       I x Low
ORAL TOXICITY

     Acute Basis:      LDgp-31 me/kg  (guinea pie)

     Chronic Basis:    ADI -  31/105 - 0.00031 mg

     CM (from above):
DERMAL TOXICITY

     Acute Basis:      Default to Acute Oral

     Chronic Basis:    Default to Chronic Oral

     CM (from above):
INHALATION TOXICITY

     Acute Basis:

     Chronic Basis:
                       Default to Chronic Inhalation
                       TLV-TWA - 0.2 mg/nr3
                       0.423 mg/m3 (of Cupric
                       	chloride)
       ADI              0.05035

     CM  (from above):
 ADI -  (TLV-TWA)(0.119).
Category:


Group:      Low

CM Value:
                                                        Acute Value:      	3_

                                                        Chronic Value:    	3_

                                                        CM Value:         	1
                                                             ToxicityORAL





                                                        Acute Value:

                                                        Chronic Value:

                                                        CM Value:
                                                             ToxicityDERMAL
Acute Value:

Chronic Value:




CM Value:
                                          148

-------
SUBSTANCE NAME:  Creosote
                                      CAS NO: 08001-58-9
CM
     Weight-of-Evidence
          Basis:       In Vitro. Mutaeenicitv
     Potency
          Basis:

     Matrix:
ORAL TOXICITY

     Acute Basis:

     Chronic Basis:



     CM (from above):
Default
                       I x Low
                       LH.-Q - 433 mg/ke (mouse)
                       TDLO "
                       cular.  epidvdimal degeneration)
                       ADI-210/103-0.21 mg/kg/dav
DERMAL TOXICITY

     Acute Basis:       Default to  Acute Oral

     Chronic  Basis:     Default to  Chronic  Oral

     CM (from above):
INHALATION TOXICITY

     Acute Basis:
Default to Chronic Inhalation
     Chronic Basis:    TWA -0.1 mg/m3
       ADI*            0.0119	
     CM (from above):
 *ADI  - (OSHA Air Standard -  TWA)(0.119)
                                                        Category:   I	


                                                        Group:      Low

                                                        CM Value:
                                 Acute Value:

                                 Chronic Value



                                 CM Value:
                                                            ToxicityORAL
                                 Acute Value:

                                 Chronic Value:

                                 CM Value:
                                                             ToxicityDERMAL




                                                        Acute Value:     	3

                                                        Chronic Value:   	J


                                                        CM Value:          ]
                                          149

-------
SUBSTANCE NAME:  DDT
                                                             CAS NO: 00050-29-3
CM
     Weight-of-Evidence
          Basis:       Positive. Mouse
                       Positive. Rat
                       Positive. Hamster
     Potency
          Basis:

     Matrix:
                       ID10.
- 0.179 mg/kg/dav
                       III x Med
                       LD50 - 87 mg/kg  (rat)
ORAL TOXICITY

     Acute Basis:

     Chronic Basis:    RfD - 0.0005 ing/kg/day

     CM (from above):
 DERMAL TOXICITY
                     \;
     Acute Basis:      LD5Q - 300 mg/kg  (rabbit)

     Chronic Basis:    ADI-300/105-0.003 mg/kg/dav

     CM  (from  above):
 INHALATION TOXICITY

     Acute Basis:
      Chronic  Basis:
       ADI*
      CM (from above):
                       Default to Chronic Inhalation

                       TLV-TWA - 1 mg/m3	
                       0.119	
  ADI  - (TLV-TWA)(0.119).
                                                        Category :  III
Group :      Med

CM Value:
                            Acute Value:

                            Chronic Value:

                            CM Value:
                                                             ToxicityORAL



                                                                         •j
                                                        Acute Value:

                                                        Chronic Value:

                                                        CM Value:
                                                              ToxicityDERMAL
                             Acute Value:

                             Chronic  Value:


                             CM Value:
                                           150

-------
SUBSTANCE NAME:  Lead (as Tetraethvl Lead)
                                                             CAS NO: 00078-00-2
CM
     Weight-of-Evidence
          Basis:       Positive. Mouse. Subcutaneous
     Potency
          Basis:

     Matrix:
                       Default
                       II x Low
Category: U_


Group:    Low

CM Value:
ORAL TOXICITY

     Acute Basis:
                            - 12.3 mg/kp (rat)
     Chronic Basis:     RfD - 1.0 x 10'7

     CM (from above):
Acute Value:    	3_

Chronic Value:  	3_

CM Value:       	1_
                                                             ToxicityORAL
DERMAL TOXICITY

     Acute  Basis:       LD^g  -  547  me/kg  (dog)

     Chronic  Basis:     ADI - 547/105  - 0.00547

     CM (from above):
INHALATION TOXICITY

     Acute Basis:
       ppm/4H:

     Chronic Basis:

       ADI*

     CM  (from above):
                       LC5Q - 850 mg/m-VeOM (rat)
                       16 ppmAH	

                       TLV-TWA - 100 ug(Pb)/m3
                       156 ug/m3 (tetraethyl lead)
                       0.0186	
 *ADI - (TLV-TWA)(0.119).
                                                         Acute Value :
                                                         Chronic Value:  	3_

                                                         CM Value:       	1
                                                             ToxicityDERMAL
Acute Value:
 Chronic Value:   	3
                                                          CM Value:
                                          151

-------
SUBSTANCE NAME:  Lindane
                                      CAS  NO:  00058-89-9
CM
     Weight-of-Evidence
          Basis:       Positive. Mouse
     Potency
          Basis:

     Matrix:
ED10.
- 0.546 mg/ke/dav
II x Med
ORAL TOXICITY

     Acute Basis:      LD50 - 60 me/kg (rabbit)

     Chronic Basis:    RfD - 0.0003 mg/kg/dav

     CM  (from above):
 DERMAL TOXICITY

     Acute  Basis:       LD50 - 50  rag/kg  (rabbit)

     Chronic  Basis:     ADI-50/105-0.0005 mg/kg/dav

     CM  (from above):
 INHALATION TOXICITY

     Acute Basis:
      Chronic Basis:
       ADI*
      CM (from above):
Default to Chronic Inhalation
TLV-TWA - 0.5 mg/nvj
0.0595	
Category:  II


Group:      Med

CM Value:  2	
                                 Acute Value:

                                 Chronic Value:

                                 CM Value:
                                                             ToxicityORAL
                                 Acute Value:

                                 Chronic Value:

                                 CM Value:
                                                             ToxicityDERMAL
                            Acute Value:

                            Chronic Value:


                            CM Value:
                                                             ToxicityINHALATIOML
  ADI - (TLV-TWA)(0.119).
                                           152

-------
SUBSTANCE NAME:  Mercury (as Mercuric Sulfate)
                                                             CAS NO: 07783-35-9
CM
     Weight-of-Evidence
          Basis:        No Data
     Potency
          Basis:

     Matrix:
ORAL TOXICITY

     Acute Basis:

     Chronic Basis:


     CM (from above):
                       Default
                       0 x Low
     - 40 me/kg (mouse)
RfD - 0.002 mg (inorganic
	Mercuric Compounds)
DERMAL TOXICITY

     Acute Basis:       Default to Acute Oral

     Chronic Basis:     Default to Chronic Oral

     CM (from above):
INHALATION TOXICITY

     Acute Basis:

     Chronic Basis:
                       Default to Chronic Inhalation
                       TLV-TWA - 100 ug(Hg)/mJ -
                       147.9 ug/m3 (of Mercuric
                       	Sulfate)
       ADI             0.0176

     CM (from above):




 *ADI -  (TLV-TWA)(0.119).
                                 Category:  0	


                                 Group:     Low

                                 CM Value:  0
                                                        Acute Value:

                                                        Chronic Value:


                                                        CM Value:
                                                             ToxicityORAL




                                                        Acute Value:

                                                        Chronic Value:

                                                        CM Value:
                                                             ToxicityDERMAL
                                 Acute Value:

                                 Chronic Value:




                                 CM Value:
                                                             Toxicity
                                           153

-------
SUBSTANCE NAME:  Methyl Ethvl Ketone
                                      CAS NO: 00078-93-3
CM
     Weight-of-Evidence
          Basis:       No Data
     Potency
          Basis:

     Matrix:
Default
0 x Low
Category:  0	


Group:      Low

CM Value:  0	
ORAL TOXICITY

     Acute Basis:      U>50 - 2737 mg/kg  (rat)

     Chronic Basis:    RfD - 0.05 mg/kg/day

     CM (from' above):
DERMAL TOXICITY

     Acute Basis:       LD5Q  -  13000 mg/kg  (rabbit)

     Chronic Basis:     ADI-13000/105-0.13  mg/kg/dav

     CM  (from above):
 INHALATION TOXICITY

     Acute Basis:
       ppm/4H:
     Chronic Basis:
       ADI*
     CM  (from above):
LC50 - AO g/nr/2H  (mouse)
6794 ppmAH	
TLV-TWA-200 ppm-590 mg/mj
70.21	
                                 Acute Value:

                                 Chronic Value:

                                 CM Value:
                                                             ToxicityORAL
                                 Acute Value:

                                 Chronic Value:

                                 CM Value:
                                                              ToxicityDERMAL
Acute Value:
Chronic Value:
                                 CM Value:
  ADI -  (TLV-TWA)(0.119).
                                           154

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SUBSTANCE NAME:  Naphthalene
                                                             CAS  NO:  00091-20-3
CM
     Weight-of-Evidence
          Basis:       Positive. Rat. Subcutaneous
                       Whole animal. Mutagenicitv
     Potency
          Basis:

     Matrix:
                       Default
                       II x Low
ORAL TOXICITY

     Acute Basis:      LD^Q - 580 me/kg (mouse)	

     Chronic Basis:    ADI-580/105-0.0058 mg/kg/dav

     CM (from above):
                       Dermal Irritation. Mild
DERMAL TOXICITY

     Acute Basis:       	    	

     Chronic Basis:    Default to Chronic Oral

     CM (from above):
 INHALATION TOXICITY

     Acute Basis:
     Chronic Basis:
       ADI*
     CM  (from above):
                       Default to Chronic Inhalation

                       TLV-TWA - 10 ppm - 50 mg/m3
                       5.95	
Category:  II



Group:      Low

CM Value:  1	




Acute Value:

Chronic Value:

CM Value:
     ToxicityORAL




Acute Value:

Chronic Value:

CM Value:
                                                             ToxicityDERMAL
Acute Value:

Chronic Value:


CM Value:
  ADI - (TLV-TWA)(0.119).
                                          155

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SUBSTANCE NAME:  Polvchlorinated Btphenyls (Arochlor 1254)   CAS NO: 11097-69-1
CM
     Welght-of-Evidence
          Basis:       Positive. Rat
     Potency
          Basis:

     Matrix:
                       Positive. Mouse
                       ED10.
"0.05 mg/kg/dav
                       III x Med
Category:  III



Group:     Med

CM Value:
ORAL TOXICITY

     Acute Basis:

     Chronic Basis:



     CM (from above):
- 1010 me/kg (rat)
                                                        Acute Value:
                       TDLO " 35° rcg/kg (rabbit)        Chronic Value:
                       (resorptions. abortion, fetal death)
                       ADI-350/1000 - 0.035 mg/kg/dav

                                                        CM Value:
 DERMAL TOXICITY

     Acute  Basis:       Default  to Acute Oral

     Chronic  Basis:     Default  to Chronic Oral

     CM  (from above):
 INHALATION TOXICITY

     Acute Basis:
      Chronic Basis:
       ADI*
      CM  (from  above):
                       Default to Chronic Inhalation
                       TLV-TWA - 500 ug/mj
                       0.0595	
 ADI -  (TLV-TWA)(0.119).
                                                             ToxicityORAL
                                                        Acute Value:

                                                        Chronic Value:

                                                        CM Value:
                                                             ToxicityDERMAL
                            Acute Value:

                            Chronic Value:


                            CM Value:
                                           156

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SUBSTANCE NAME:   Pentachloroohenol (PGP)
                                                             CAS NO:  00087-86-5
CM
Default
II x Low
Group : Low
CM Value: 1
     Weight-of-Evidence
          Basis:        Positive.  Mouse.  Subcutaneous   Category:
     Potency
          Basis:

     Matrix:
ORAL TOXICITY

     Acute Basis:

     Chronic Basis:     RfD - 0.03 mg/kg/dav

     CM (from above) :
                            - 50 rag/kg (rat)
Acute Value:

Chronic Value:

CM Value:
                                                             ToxicityORAL
DERMAL TOXICITY

     Acute Basis:      LDgQ - 105 me/kg (rat)	   Acute Value:

     Chronic Basis:    ADI-105/105-0.00105 mg/kg/day   Chronic Value:

     CM (from above):                                  CM Value:
                                                             ToxicityDERMAL
INHALATION TOXICITY

     Acute Basis:
     Chronic Basis:
       ADI*
     CM (from above):
                       Default to Chronic Inhalation   Acute Value:
                       TLV-TWA - 500 ug/mj
                       0.0595
Chronic Value:
                                                       CM Value:
                                                             ToxicityINHALATIONAL
 ADI - (TLV-TWA)(0.119).
                                          157

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SUBSTANCE NAME:  Phenanthrene
                                                             CAS NO:  00085-01-8
CM
     Weight-of-Evidence
          Basis:       Positive. Mouse. Dermal
     Potency
          Basis:

     Matrix:
ORAL TOXICITY

     Acute Basis:
                       Default
                       II x Low
                            -  700 mg/kg  (mouse)
     Chronic Basis:    ADI-700/105-0 . 007 mg/kg/day

     CM  (from above) :
DERMAL TOXICITY

     Acute Basis:       Default to Acute  Oral

     Chronic Basis:     Default to Chronic  Oral

     CM  (from  above):
 INHALATION  TOXICITY

     Acute  Basis:       Default to Acute  Oral

     Chronic  Basis:     Default to Chronic Oral

     CM (from above):
Category:   II


Group:      Low

CM Value:
Acute Value:

Chronic Value:

CM Value:
                                                             ToxicityORAL




                                                        Acute Value:     _

                                                        Chronic Value:

                                                        CM Value:
                                                             ToxicityDERMAL




                                                        Acute Value:     	1

                                                        Chronic Value:   	3

                                                        CM Value:        	1
                                                             ToxicityINHALATIONAL
                                           158

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SUBSTANCE NAME:   Phenol
                                                            CAS NO: 00108-95-2
CM
     Weight-of-Evidence
          Basis:       Positive. Mouse. Dermal
     Potency
          Basis:

     Matrix:
                      Default
                       II  x Low
Category: II


Group:     Low

CM Value:
ORAL TOXICITY

     Acute Basis:      LD50 - 282 mE/kg/day (mouse)

     Chronic Basis:    RfD - 0.1 mg/kg/day	

     CM (from above):
                                                        Acute Value:    	2_

                                                        Chronic Value:  	2_

                                                        CM Value:       	1
                                                             ToxicityORAL
DERMAL TOXICITY
Acute Basis:
Chronic Basis:
CM (from above) :
LD^Q - 669 mg/kg (rat)
ADI -669/105-0. 00669 mg/kg/dav

Acute Value:
Chronic Value:
CM Value:
2
-^
INHALATION TOXICITY

     Acute Basis:
     Chronic Basis:
       ADI*
     CM  (from above):
                           —177 mg/m —46.07 ppm
                       TLV-TWA - 5 com - 19 mg/nr
                       2.26	
    ToxicityDERMAL




Acute Value:    	3

Chronic Value:  	1


CM Value:         ]
                                                              Toxicity1NHALATIONAL
  ADI  -  (TLV-TWA)(0.119).
                                           159

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SUBSTANCE NAME:  Tetrachloroethvlene
                                      CAS NO: 00127-18-4
CM
     Weight-of-Evidence
          Basis:       Positive. Mouse (NTP Btoassay)
                       Positive. Rat (NTP Bioassav)
     Potency
          Basis:

     Matrix:
     - 3.23 mg/kg/day
III x Low
Category: III



Group:    Low

CM Value: 2
     - 8100 mg/kg (mouse)
ORAL TOXICITY

     Acute Basis:

     Chronic Basis:    RfD - 0.02 mg/kg/day

     CM (from above) :
DERMAL TOXICITY

     Acute Basis:      Dermal Irritation - Severe

     Chronic Basis:    Default to Chronic Oral

     CM (from above):
INHALATION TOXICITY

     Acute Basis:
       ppm/4H:
     Chronic Basis:
       ADI*
     CM  (from above):
LC^ - 23000 mg/mJ/2H (mouse)
1699.13 ppm/4H	
TLV-TWA - 50 ppm - 335 mg/mj
39.87	
 *ADI -  (TLV-TWA)(0.119).
Acute Value:    	0_

Chronic Value:  	2_

CM Value:       	2
                                      ToxicityORAL




                                  Acute Value:    	3_

                                  Chronic Value:  	2_

                                  CM Value:       	2
                                                             ToxicityDERMAL
Acute Value:
Chronic Value:
                                  CM Value:
                                          160

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SUBSTANCE NAME:   Toluene
                                                             CAS NO: 00108-88-3
CM
     Weight-of-Evidence
          Basis:        Whole animal.  Mutagenicity
     Potency
          Basis:

     Matrix:
Default
II x Low
ORAL TOXICITY

     Acute Basis:       LD5Q - 5000 ing/kg (rat)

     Chronic Basis:    RfD - 0.3 mg/kg/day

     CM (from above):
DERMAL TOXICITY

     Acute Basis:      LD50 - 12124 mgAg (rabbit)

     Chronic Basis:    ADI-12124/105-0.121 mg/kg/day

     CM (from above):
INHALATION TQXICITY
     Acute Basis:
LC5Q -  10640 ppm/4H (mouse)
     Chronic Basis:    TLV-TWA - 100 ppm - 375 mg/m3
       ADI*            44.625	
     CM (from above):
Category:  II


Group:      Low

CM Value:  1	




Acute Value:

Chronic Value:

CM Value:
                                                             ToxicityORAL
                                 Acute Value:

                                 Chronic Value:

                                 CM Value:
                                                             ToxicityDERMAL
Acute Value:

Chronic Value:


CM Value:
                                                             ToxicityINHALATIONAL
 ADI - (TLV-TWA)(0.119).
                                          161

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SUBSTANCE NAME:  Vlnvl Chloride
                                      CAS NO: 00075-01-4
CM
     Weight-of-Evidence
          Basis:       Positive. Rat. Oral
     Potency
          Basis:

     Matrix:
                        Positive. Mouse. Inhalation
                        Positive. Human	
ED-.Q - 6.67 mg/kg/day

III x Low	
                                 Category:   III
Group:      Low

CM Value:
ORAL TOXICITY

     Acute  Basis:       LD5Q - 500 mg/kg  (rat)	

     Chronic Basis:     ADI-500/105-0.005 mg/kg/dav

     CM (from  above):
 DERMAL TOXICITY

      Acute Basis:       Default to  Acute Oral

      Chronic Basis:     Default to  Chronic Oral

      CM (from above):
 INHALATION TOXICITY

      Acute Basis:
        ppm/4H:
      Chronic Basis:
        ADI*
      CM (from above):
                                 Acute  Value:

                                 Chronic Value:

                                 CM Value:
                                                             ToxicityORAL
                                 Acute  Value:

                                 Chronic Value:

                                 CM Value:
                                                             ToxicityDERMAL
LCLO " 20 ppm/30M (guinea pig)    Acute Value:
2.5 ppmAH	
TLV-TWA - 5 ppm - 20 mg/m3
2.38	
Chronic Value:
                                 CM Value:
                                                             ToxicltyINHALATIONAL
  ADI - (TLV-TWA)(0.119).
                                         162

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SUBSTANCE NAME:   Zinc (as Zinc Phosphide)
                                      CAS  NO:  01314-84-7
CM
     Weight-of-Evidence
          Basis:        No Data
     Potency
          Basis:

     Matrix:
ORAL TOXICITY

     Acute Basis:

     Chronic Basis:    RfD - 0.0003 me

     CM (from above):
LD5Q - 25 mg/ke (rat)
DERMAL TOXICITY

     Acute Basis:      Default to Acute Oral

     Chronic Basis:    Default to Chronic Oral

     CM (from above):
INHALATION TOXICITY

     Acute Basis:      Default to Acute Oral

     Chronic Basis:    Default to Chronic Oral

     CM (from above):
                               Category:     0	
Default
0 x Low
Group :
CM Value:
Low
0
Acute Value:

Chronic Value:

CM Value:
                                                             ToxicityORAL
                               Acute Value:

                               Chronic Value:

                               CM Value:
                                                             ToxicityDERMAL
                               Acute Value:

                               Chronic Value:

                               CM Value:
                                          163

-------