Hazard Ranking System Issue Analysis:
      Indoor Air Contamination
               MITRE

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Hazard  Ranking System  Issue Analysis:
         Indoor Air  Contamination
                  Thomas F. Wolfinger
                     August 1987
                     MTR-86W132
                       SPONSOR:
                U.S. Environmental Protection Agency
                     CONTRACT NO.:
                      EPA-68-01-7054
                   The MITRE Corporation
                      Metrek Division
                     7525 Colshire Drive
                   McLean, Virginia 22102-3481

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  Department Approval:
MITRE Project Approval:
                            ii

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                              ABSTRACT
     This report presents an option for revising the air pathway of
the EPA Hazard Ranking System (HRS) to address situations of indoor
air contamination arising from uncontrolled hazardous waste sites.
The HRS is used by EPA to rank uncontrolled waste sites based on
their relative threat to human health and the environment.   Highly
ranked sites are placed on the National Priorities List for further
investigation and possible remedial action.  The revision option
is structurally similar to the current HRS air pathway.  The
revision option can be used to assess sites based on the degree of
contamination detected in the indoor air, relative to human-health-
based benchmark concentrations, and on the size of the population
potentially affected by the contamination.

Suggested Keywords:  Superfund, Hazard ranking, Hazardous waste,
Indoor air contamination.
                                iii

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                          TABLE OF CONTENTS

                                                                 Page

LIST OF ILLUSTRATIONS                                            vii
LIST OF TABLES                                                   vii

1.0  INTRODUCTION                                                  1

1.1  Background                                                    1
1.2  Issue Description                                             3
1.3  Organization of Report                                        5

2.0  BACKGROUND ON THE HAZARD RANKING SYSTEM                       7

3.0  A METHOD FOR EVALUATING INDOOR AIR CONTAMINATION SITES       13

3.1  Discussion of Indoor Contamination from Uncontrolled         13
     Waste Sites
3.2  Overview of the Indoor Air Pathway                           18

     3.2.1  Release Category                                      21
     3.2.2  Waste Characteristics Category                        23
     3.2.3  Targets Category                                      25
     3.2.4  Pathway Score                                         28

3.3  Step-By-Step Instructions for the Indoor Air Pathway         28

4.0  IMPLICATIONS                                                 37

5.0  BIBLIOGRAPHY                                                 39

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                        LIST  OF  ILLUSTRATIONS

Figure Number                                                    Page

     1          Basic HRS Structure                               11

     2          Structure of the Indoor Air Pathway               19




                           LIST OF TABLES

Table Number                                                     Page

     1          HRS Scoring Factors                                9

     2          Ranges of Estimated Levels of Organic Vapors      15
                in Ambient Air of Household Basements
                in Niagara Falls, NY

     3          Concentration Multiplier                          26

     4          Illustrative Table of Population Factor Values    27

     5          Illustrative Adaptation of Current HRS Ground     29
                Water Pathway Target Population Factor Matrix

     6          Worksheet 1:  Contaminant Record                  31

     7          Worksheet 2:  Concentration Multiplier            32

     8          Worksheet 3:  Toxicity-Concentration              33

     9          Worksheet 4:  Score Sheet                         35
                                 vii

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1.0  INTRODUCTION




1.1  Background




     The Comprehensive Environmental Response, Compensation, and




Liability Act of 1980 (CERCLA) (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, 12 July 1982).  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 further 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 tne current rfRS 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  Issue Description

     Several issues relevant to the HRS air pathway have been raised

by Congress and by public comments on the NPL and NPL rulemaking

actions.  An analysis of these issues and the options developed for

revising the air pathway as a result of the analysis are presented

in Wolfinger, 1987.  One of these issues relates to the  applicability

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of the HRS to assessing sites which may pose significant indoor  air




contamination problems.  These indoor air contamination sites  arise




as a result of the migration of air contaminants from an




uncontrolled waste site through the ground or air, and the eventual




accumulation of the contaminants in the air within buildings.   The




waste site from which the contaminants originated may or may not be




readily identifiable.  The present HRS evaluation of the air pathway




is applicable only to the release of contaminants directly into the




open air, subsequent transport in the atmosphere, and eventual human




exposure and other environmental effects.  Implicitly, the




evaluation assumes a relatively high population, generally low




concentration average exposure situation.  The structure and rating




factor values used in the current HRS targets category reflect this




assumption.  However, the phenomenon of contaminant migration  into




the confined atmosphere of buildings is somewhat inconsistent  with




these assumptions.  Transport of contaminants from a source in such




cases may be through the ground, as well as through the atmosphere,




and may result in relatively low population, high concentration




exposure situations.




     The purpose of this paper is to present a preliminary air




pathway evaluation mechanism applicable to indoor air contamination




sites, compatible with the current structure of the HRS.   This




mechanism is designed to be incorporated into the HRS.  Alternately,




it could be adapted for use to screen sites for further monitoring

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in support of possible NPL listing (e.g.,  as a result of a health




advisory).




     The evaluation mechanism presented is preliminary.   Thus,  a




number of questions that arise in the approach remain to be answered.




Of greatest importance are those questions associated with monitoring




requirements, the sources of detected contaminants,  and  the distance




at which targets are included in the evaluation.   Since  similar




questions are under study in respect to the other HRS pathways,




these questions could not be resolved as part of  this effort.




1.3  Organization of Report




     Section 2 presents background information on the Hazard Ranking




System (HRS).  Section 3 presents an overview of  the phenomena  of




indoor air pollution from uncontrolled waste sites.   The mechanism




for evaluating indoor contamination sites  within  the context of  the




HRS is also discussed in Section 3.   Section 4 discusses the




implication for program costs and NPL listing that might arise  if




the evaluation mechanism were adopted as part of  the HRS.

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2.0  BACKGROUND ON THE HAZARD RANKING SYSTEM




     The HRS is designed to screen uncontrolled waste sites based on




the information compiled in a site investigation.  The HRS addresses




three hazard modes:  migration, fire, and explosion, and direct




contact.  The migration mode site score (HRS score) is used to




determine whether the site is to be placed on the NPL for further




investigation and possible remedial action.  The latter two mode




scores are not used in computing the HRS score but are included in




the HRS as indicators of the need for emergency response.




     The migration mode consists of three potential migration




pathways representing the major routes of environmental transport




common to uncontrolled hazardous waste sites:  ground water, surface




water, and air.  Each pathway is structured similarly using three




factor categories:  release, waste characteristics, and targets.




     The release category reflects the likelihood that the site has,




is, or will release contaminants to the environment.  If available




monitoring data indicate that the site is releasing or has released




contaminants, then an "observed release" has been demonstrated.  If




no such observed release can be demonstrated, then the release




category is evaluated using route characteristics and containment




factors.  These factors are largely physical characteristics of the




sites and their surrounding environments.  It is important to note




that the ground water and surface water routes contain factors for




route characteristics and containment while the air route does not.

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This permits sites to be evaluated for their potential to release




contaminants to these two pathways in cases where documentation of




an observed release is lacking.  The current HRS requires that



ambient air monitoring data support a conclusion that the site is,



or has been, emitting contaminants before the site can receive a




nonzero air route score.  Wolfinger (1987) discusses options for




adding factors to the HRS air pathway that reflect the potential of




a site to release air contaminants.




     The waste characteristics category reflects the inherent hazard




of the contaminants that have been or might be released.   The factors




included in the waste characteristics categories address qualitative




and quantitative characteristics of the wastes and waste contaminants




found on the sites.  The targets category constitutes a measure of




the population and resources that might be adversely affected by the




release.  The factor categories and the rating factors contained in




them are illustrated in Table 1.




     For each pathway, the site is assigned a value for each




applicable factor.  The factor values are then multiplied by




weighting factors and summed within factor categories.  The resulting



factor category scores are then multiplied and normalized to form a




route score.  Thus, for each site, three route scores are produced,




each on a scale of 0 to 100.   These route scores are referred to as



follows:

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                                        TABLE 1

                                  HRS SCORING FACTORS
                                                  Pathway
 Factor Category
    Ground Water
    Surface Water
        Air
Release
Waste
  Characteristics
Targets
Monitoring data
    or
Depth to aquifer of
  concern
Net precipitation
Permeability
Physical state
Physical state
Containment
Toxicity/persistence
Quantity
Ground water use
Distance/population
Monitoring data

Facility slope and
  terrain
Rainfall
Distance to receiving
  water
Physical state
Physical state
Containment

Toxicity/persistence
Quantity
Surface water use
Distance/population
Distance to sensitive
  environment
Monitoring data
or
Reactivity/
  incompatibility
Toxicity
Quantity

Land use
Distance/population
Distance to
  sensitive
  environment

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     •  Ground water migration route score (S  )



     •  Surface water migration route score (S  )
                                              ST*


     •  Mr migration route score (S )



The overall site migration score, or HRS score,  (S ) then is



calculated as the root mean square  (ELMS) of the pathway scores:



                                  •>        99 1/2

               Sm = (l/1.73)[(Sgw)2 +  (Ssw)2 + CSa)2]





The RMS procedure was chosen  to emphasize the highest scoring route



while giving some consideration to  secondary and tertiary routes.



This procedure is illustrated in Figure 1.   (For a more detailed



discussion of the HRS see 40  CFR 300 or 47 FR 31180, 12 July 1982.)
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Observed Release
   0 or 45 pts
      or
     Route
Characteristics &
 Containment*
     0-45 pts


GW
SW
A
Waste
Characteristics
— 0-26 pts
— 0-26 pts
— 0-20 pts
                        'Not Included in Air Pathway
                        GW = Ground Water Pathway
                        SW = Surface Water Pathway
                        A   = Air Pathway
Targets
GW —
SW —
A —
0-49 pts
0-55 pts
0-39 pts
                                                                                                Pathway Score
                                                                                                  0-100 pts
                                                                                                 Normalized
                                                 FIGURE 1
                                         BASIC MRS STRUCTURE

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3.0  A METHOD FOR EVALUATING INDOOR AIR CONTAMINATION SITES




3.1  Discussion of Indoor Contamination from Uncontrolled Waste Sites




     The release of contaminants from an uncontrolled waste site




directly into the atmosphere is a common, well known phenomenon.  A




review of the processes that could result in the release of air




contaminants from uncontrolled waste sites leads to the conclusion




that nearly all waste sites either currently emit, have emitted, or




will emit air pollutants.  The exceptions are those sites whose




containment is such that it forms (and will continue to form) an




impermeable barrier between the contaminants and the atmosphere.




Whether the pollutants are emitted in sufficient concentration to




cause concern, or even be detected, depends on numerous site-specific




factors.  A review of the phenomena of contaminant releases from




uncontrolled waste sites into the atmosphere can be found in




Wolfinger, 1987.




     A less common, but nonetheless well known, phenomena is the




transport of gaseous contaminants through the soil and their eventual




escape into the interior of buildings.  Such inground gas transport




can occur directly as the result of pressure gradients or through




diffusion processes.   Alternately, the gas might be dissolved in,




and move through and with, the ground water, eventually volatilizing




and escaping into the air.  The relative importance of these two




basic inground transport pathways is unknown but can be expected




to be dependent on the nature of the contaminants and the
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characteristics of the soil surrounding the waste site.   Once the




contaminants have escaped from the soil, they can enter  the




atmosphere directly or, more importantly for this analysis, enter



into the basements of buildings near the waste site.



     Once inside the buildings, these contaminants may become




trapped, resulting in the buildup of contaminant concentrations in




the indoor air.  Contaminant concentrations in such instances may




reach high levels, as shown in Table 2.  Pellizzari (1982) indicates




that the contaminant concentrations illustrated in this table




probably arose from the Love Canal disposal site.  Several other




researchers have reported elevated concentrations of contaminants In




buildings that they believe resulted from uncontrolled waste site




releases, many significantly removed in distance from the source




(Kim et al., 1980; James, Kinman, and Nutini, 1985; Miner and



Beizer, 1985; and Pellizzari, 1982).  The weight-of-evidence




indicates that these contaminants could probably be traced to




uncontrolled waste sites.  However, no one has demonstrated




conclusively that the contaminant concentrations reported arose from




subsurface transport of air contaminants.  The contaminants may have




arisen from in-house sources or from infiltration of ambient air



contaminants.  Alternately, as Indicated in the analyses of Foster




and Chrostowski (1986 and 1987) and others, indoor air contamination



can arise from the use of contaminated water for purposes such as



showering, cooking, and other household activities.   These
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                               TABLE 2

            RANGES OF ESTIMATED LEVELS OF ORGANIC VAPORS
                IN AMBIENT AIR OF  HOUSEHOLD  BASEMENTS
                        IN NIAGARA FALLS, NY
         Chemical
Concentration Range (ug/m^)
Chlorobenzene
Dichloro benzene Isomers (3)a
Trichlorobenzene Isomers (3)
Tetrachlorobenzene Isomers (2)
Pentachlorobenzene
Chlorotoluene Isomers (2)
Dichlorotoluene Isomers (3)
Trichlorotoluene Isomers (4)
Tetrachlorotoluene Isomer
Bromotoluene Isomer
Chloronaphthalene Isomer
1, 2-Dichloropropane
Pentachlorobutadiene Isomer
1, 3-Hexachlorobutadiene
Benzene
ND
0.65
0.07
0.03
T
1.7
0.13
0.06
0.03
T
0.08
1

0.03
T
- 4.2
- 190
- 33
- 20
- 0.49
- 490
- 370
- 0.157
- 4.1
- 4.4
- 3.4
.4
T
- 0.41
- 520
aValues are the sum of the individual isomers detected.

ND:  Not detected.
 T:  Trace.

Source:  Pellizzari, Edo D., "Analysis of Organic Vapor Emissions
         near Industrial and Chemical Waste Disposal Sites,"
         Environmental Science and Technology, Vol.  16, No. 11,
         1982, pp. 781-785.
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considerations emphasize the Importance of determining the source of




detected indoor air contaminants when evaluating sites for possible




Inclusion on the NPL.




     As discussed in Wolfinger, 1987, releases of air contaminants




into the atmosphere typically result in low dosage, large population




exposure situations.  A large number of individuals might each be




exposed to a generally low contaminant concentration.  The degree of




exposure depends on numerous site-specific factors.  In contrast,




releases of air contaminants into buildings typically result in




situations of low population, sometimes high dosage exposure.  In




such situations, a much smaller number of individuals might be



exposed to fairly high contaminant concentrations.




     The phenomenon of off-site transport of contaminants through



the soil and into buildings is, overall, very different from the




more common ambient air transport phenomena addressed in the HRS air




pathway.  These differences have Implications for the structure and




assumptions underlying any site evaluation mechanism.  First, due to




the gaps in current knowledge about inground air contaminant




transport phenomena (particularly in the areas of unsteady-state




release and transport and contaminant retardation) and difficulties




in developing potentially needed data at a site, it would be very




difficult to assess the potential of a site to release contaminants




into buildings nearby.  Thus, no provision is made for a "potential




to release" option in the evaluation mechanism discussed below.
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Second, since each individual is exposed to a generally higher




concentration in an indoor contamination situation and there are




generally fewer exposed individuals, the population target factor




tables currently used in the HRS would be inappropriate for use in




assigning values to indoor contamination sites.  Rather, the factor



tables should reflect a high concentration, low population exposure




situation.  This implies that the population needed to achieve a



given value should be lower than in the current, "outdoor" HRS air




pathway.




     The third difference is that the interiors of most buildings,



particularly residences, may have measurable concentrations of the




same contaminants present at waste sites, even when the buildings




are not affected by waste sites.  Benzene, for example, is a fairly




common contaminant found in the basements of houses not affected by




waste sites.  Benzene may arise from infiltration of outside air,




smoking, or from oil or gas heaters.  As another example, a



household resident may keep an old container of pesticide, such as



DDT, for lawn and garden use.  The pesticide may escape from the can




while it is stored, resulting in a detectable concentration in a




garage or basement completely unrelated to any waste site.  Because




of this, it is generally difficult to determine whether contaminants




detected indoors arise from nearby uncontrolled waste sites or from




nonwaste related sources such as natural gas furnaces or solvents




and pesticides stored indoors.  A more complete discussion of the
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phenomena of building contamination can be found in Pellizzari,




1982; Pellizzari et al., 1985; and Wallace et al., 1984 and 1985.




     The following sections describe an HRS-compatible mechanism for




evaluating indoor air contamination from uncontrolled hazardous




waste sites.  This mechanism might be used in place of the current




air pathway in those situations where the risk posed by indoor




contamination is greater than that posed by outdoor contamination




(as indicated by comparing the indoor and "outdoor" pathway scores).




In such cases, the score from this indoor air pathway would be used




in place of the current air pathway score.




3.2  Overview of the Indoor Air Pathway




     The proposed indoor air pathway is structured so as to be




compatible with the current HRS air pathway (see Figure 2).  The




indoor air pathway score is the normalized product of an "observed



release" score, a waste characteristics score, and a targets score.




"Observed release" has a somewhat different interpretation in the




indoor air pathway than in the other HRS pathways.  In the current




HRS, an "observed release" is said to have occurred whenever




available monitoring data indicate that the site has released air



contaminants.  As a rule of thumb, an order of magnitude elevation




above background levels is considered "significant" in evaluating




sites using the current HRS, although each set of data is evaluated




on its own merits.  Alternate criteria for significance are




currently under EPA review (see Brown, 1986).
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Evidence
   of
 Release
X
Waste
Characteristics
- Toxicity
 Concentration
Targets
- Population
  within 1/2 Mile
  Radius
    Score (S,A)
=  (Normalized to
    Base 100)
                                FIGURE 2
              STRUCTURE OF THE INDOOR AIR PATHWAY
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     However, no such "significance" requirement is included in the




indoor air pathway for two reasons.  First, it is nearly impossible




to define a "background" concentration for a building since there is




a wide variation in indoor air contaminant concentrations between




buildings (Wallace et al., 1984 and 1985).  Also, in principle, no




data would be available on the "background" concentrations for the




particular buildings in question.  Second, no such requirement is




needed since the concentration factor included in the waste




characteristics category of the indoor air pathway precludes the




situation in which a site with nonhazardous exposure concentrations




would receive an indoor air pathway score (see Section 3.2.2).




     In  contrast to the current HRS, a very strict quality control




requirement needs to be placed on data used to show an "observed




release" in the buildings in question.  This restriction is




necessary to distinguish contaminant concentrations that arise from




uncontrolled waste sites from those that arise from other sources,




particularly indoor sources.  Moreover, as discussed above, the




indoor air pathway does not provide for a potential to release




option.  Thus, the use of the indoor pathway is intentionally




restricted to only those sites at which off-site contaminant




migration into buildings can be conclusively demonstrated.




     Two other significant differences are evident between the



indoor air pathway and the current HRS air pathway.   First,  since




high quality contaminant concentration data are required before the
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pathway may be used, a combined contaminant toxicity-concentration




factor is used in the waste characteristics category.  Second, the




targets category consists only of a population factor.  The




definition of the population-at-risk and the evaluation approach




differ from those in the current HRS air pathway, requiring fewer



people at risk to achieve the same factor value.




     The following discussion describes these factors in greater




detail.




     3.2.1  Release Category




     The release category in the indoor air pathway is very simple.




If the available data indicate that air contaminants have escaped




from an uncontrolled waste site into the interior of surrounding



buildings, then a release score of 45 is assigned to the site.  If




the data do not support such a conclusion, then a score of 0 is



assigned.  No provision is made for a "potential to release" option




within the release category.  Regardless of the indoor air pathway



score, the site should still be evaluated using the outdoor air



pathway to determine if the site could receive a higher HRS score




using the current air pathway.




     As stated above, it is crucial to determine that the




contaminants concentrations detected did not arise from indoor




sources or from some other source within or near the building.




Rather, the contaminants should be attributable to an uncontrolled




waste site.  For the purposes of the indoor pathway, a CERCIA
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contaminant whose presence in the atmosphere of the building  in




question cannot be attributed to a source other than a possible




uncontrolled waste site is considered a "critical" contaminant.   The




need to ensure that the contaminants arose from a waste site  places




restrictions on the nature and quality of data used to conclude  that




an observed release has occurred.  Detailed requirements for




determining that an observed release has occurred have not yet been




developed.  These requirements would include restrictions on




sampling equipment and protocols and may also include a requirement




for an indoor source inventory.




     However, the actual location of the waste sites contributing to




situations of indoor air contamination may not be known at the time




the contamination is investigated.  This has occurred several times




in the past, in particular, at the Love Canal disposal site.   Similar




situations have also occurred in the past in cases of ground  water




contaminant plumes having no readily identifiable source.  Several




approaches could be used to address the question of source




attribution in the indoor air pathway.  One approach is to employ a




"negative" approach, i.e., if a contaminant cannot be traced  to  any




known source within the building or any known source other than  a




possible uncontrolled waste site, then the contaminant can be




assumed to have escaped from a waste site.   This option addresses



the question of unknown sources and allows buildings themselves  to




be declared "sites".   An alternate approach would be to require  that
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an uncontrolled waste site that has received wastes containing the




critical contaminants be identified within a reasonable distance of



the contaminated building before the site is evaluated under this




pathway.  A third variation would be to require that outside




monitoring, such as soil gas or ground water monitoring, indicate




the presence of the critical contaminant below the surface.




     Alternately, the building in question may be located on the



site itself.  The indoor air pathway is to be employed, however,




only if the building is currently in use, or is vacant and not




associated with the waste disposal activity.  Thus, data from



on-site buildings used to support a waste disposal operation cannot




be used in this approach.  This restriction is imposed as required




in Section 101:22(A) of CERCLA.




     3.2.2  Waste Characteristics Category



     Two factors are reflected in the waste characteristics  category:




critical contaminant toxicity and concentration (as measured in the



buildings in question).  These factors are evaluated for each



critical contaminant and the resulting factors values multiplied to




form a combined toxicity-concentration value.  The maximum calculated



toxicity-concentration value is used in evaluating the site score.




     Critical contaminant toxicity is evaluated using the same




approach as in the outdoor air pathway (see 47 FR 31219-31243,




16 July 1982).  Critical contaminant concentration is evaluated




using a benchmark approach.  In such an approach, the concentration
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is evaluated based on its relative magnitude in comparison with a




given benchmark concentration.  Possible benchmark concentrations




include Threshold Limit Values (TLV), Short Term Exposure Levels




(STEL), and Acceptable Daily Intakes (ADI) via inhalation.  Threshold




Limit Values and Short Term Exposure Levels are defined in American




Conference of Governmental Industrial Hygienists, 1985.  Acceptable




Daily Intakes for some chemicals have been set by EPA (U.S.




Environmental Protection Agency, October 1986).




     Critical contaminant concentration is evaluated as follows.  If




the affected buildings are industrial or commercial, the benchmark




concentration of each critical contaminant is the 8-hour average




Threshold Limit Value (TLV) of the contaminant.  TLVs define the




levels below which occupational exposures to each particular



contaminant is expected not to pose an undue risk to the worker.




The benchmark concentration should reflect the types of exposure




situations associated with indoor air contamination.  Characteristics




of particular interest are the classes of exposed individuals (e.g.,




children as well as adults), the duration of exposures (e.g.,




longer-term for children, shorter-term for working adults), and the




temporal variations in inhalation rates (sleeping versus waking).




An adaptation of the proposed revisions to the HRS toxicity factor




discussed in DeSesso et al., 1986, recognizing the different



characteristics of indoor versus outdoor exposures, should be




investigated.
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     The critical contaminant concentration value  is  defined  based




on the ratio of the maximum detected concentration to the benchmark




concentration and using the scale shown in Table 3.   If the site




contains several buildings of different types, the maximum calculated




score should be used.  However, the benchmark concentration used in




these calculations must be consistent with the type of building



affected (i.e., residential versus industrial/commercial).  The use



of data from a commercial building and a residential benchmark, for




example, is not permitted even if residential buildings are also




affected.



     3.2.3  Targets Category




     A single target factor is used to reflect the population at risk




from the escaped contaminants.  For purposes of this calculation,



the target population consists of the population residing in the




area around the site plus any permanent, nonresident employees




working in the area.  Distance would be measured from the




contaminated buildings, and from the uncontrolled waste site as



well, if its location is known, as is currently done in the ground




water pathway.  Table 4 defines an illustrative population factor




evaluation method in terms of the population living or working



within a 1/2-mile target distance limit.  The distance of 1/2 mile




was chosen for illustrative purposes only.  A final distance could



not be developed since few data are available showing the geographic




extent of sub-surface air contaminant transport.  This distance is
                                 25

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                              TABLE  3

                      CONCENTRATION MULTIPLIER
     Ratio of Contaminant Concentration
	to Benchmark Concentration	Multiplier

Less than 0.1                                              0

Greater than or equal to 0.1 but less than 1.0             1

Greater than or equal to 1.0 and less than 10              2

Greater than or equal to 10                                3
                                 26

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                           TABLE  4

       ILLUSTRATIVE TABLE OF POPULATION FACTOR VALUES



Population On-site or Within 1/2
   Mile of Site or Building	Value

            0                                           0

            1                                           1

          2-10                                        2

         11-30                                        3

         31 - 100                                       4

     Greater than 100                                   5
                              27

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smaller than the 4-mile target distance limit used in the current HRS




air pathway, since no data are available indicating that uncontrolled




waste sites affect indoor air at substantial distances from the sites.




     An alternate approach is to adapt the current HRS target distance




factor value tables used for the ground water pathway.  One such




adaptation is presented in Table 5.   Such an approach might be better




than a strict 1/2 mile limit since ground water is considered to be




an important transport media in cases of building contamination.




     3.2.4  Pathway Score




     The score for the indoor air pathway is the product of the



release category score, the waste characteristics score and the




targets score normalized to a scale of 0 to 100.  The greater of this




score and the "outdoor" air pathway score could be used as the air



pathway score in computing the HRS migration score.




3.3  Step-By-Step Instructions for the Indoor Air Pathway




     This section presents preliminary step-by-step instructions for



evaluating sites using the indoor air pathway.   The instructions are




provided to illustrate how a site would be evaluated using the




approach described above.




     The pathway would be employed only when the available air




monitoring data include contaminant concentration data taken indoors




and when the contamination cannot be attributed to any nearby source



other than a possible waste site.
                                 28

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                              TABLE 5

           ILLUSTRATIVE ADAPTATION OF CURRENT HRS GROUND
           WATER PATHWAY TARGET POPULATION FACTOR MATRIX
                          Value  for Distance  to Nearest Building
                                 From Hazardous Substance
Population*

1
101
1,001
3,001
10
0
- 100
- 1,000
- 3,000
- 10,000
,000+
0
0
0
0
0
0
0
1
0
4
8
12
16
20
2
0
6
12
18
24
30
3
0
8
16
24
32
35
4
0
10
20
30
35
40
*Population within 3  miles
         Distance to Nearest  Building                  Value

             Greater than 3 miles                        0

               >2 to 3 miles                           1

               >1 to 2 miles                           2

             2,000 feet to 1  mile                       3

             Less than 2,000  feet                       4
                                 29

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     Step It  Determine the concentrations of CERCLA contaminants in

the building.   Record the data on Worksheet 1:  Contaminant Record

(Table 6).  Determine the potential sources of any detected

contaminants within the building.  Contaminants that cannot be

attributed to any nearby or indoor source other than a possible

uncontrolled waste site are considered critical contaminants.

Documentation of the rational for determining that a contaminant is

a critical contaminant must be provided by the analyst evaluating

the site.  If the concentration of any critical contaminant indicates

that an indoor observed release from a waste site has occurred,

assign a release value of 45.  Otherwise, assign a release value

of 0.

     Step 2;  For each critical contaminant, record the detected

concentration on Worksheet 2:  Concentration Multiplier (Table 7)

and determine the benchmark concentrations as indicated in the

preceding discussion.*  Record the benchmark values on Worksheet 2.

     Step 3;  Calculate the ratio of each critical contaminant

concentration to its benchmark value, and determine the concentration

multiplier as indicated in Table 3.  Record the multiplier for each

critical contaminant on Worksheet 2 and Worksheet 3t  Toxicity-

Concentration (Table 8).
*The recommended benchmark for commercial/industrial buildings is
 the Threshold Limit Value, as determined by the American Conference
 of Governmental Industrial Hygienists.  Benchmarks for residential
 buildings are under development.
                                 30

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                              TABLE 6
                  WORKSHEET 1:   CONTAMINANT RECORD
    Contaminant                                       Critical*
    CAS Number	Concentration	Units	Contaminant
 1.  	     	      	      	
 2.  	     	      	      	
 3.  	     	      	      	
 4.  	     	      	      	
 5.  	     	      	      	
 6.  	     	      	      	
 7.  	     	      	      	
 8.  	     	      	      	
 9.  	     	      	      	
10.  	     	      	      	
11.  	     	      	      	
12.  	     	      	      	
13.  	     	      	      	
14.  	     	      	      	
15.
                        Observed Release Score
    Rationale for considering contaminants to be critical
    contaminants (use additional sheets as necessary):
*Contaminants that cannot be attributed to any nearby or indoor
 source other than a possible uncontrolled waste site are considered
 critical contaminants.  This column is used to indicate that a
 contaminant is considered by the analyst to be a critical
 contaminant.
                                 31

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                               TABLE 7
               WORKSHEET 2:  CONCENTRATION MULTIPLIER
    Contaminant   Contaminant
    CAS Number    Concentration	Benchmark    Ratio	Multiplier
 1. 	    	     	    	     	
 2. 	    	     	    	     	
 3. 	    	     	    	     	
 4. 	    	     	    	     	
 5. 	    	     	    	     	
 6. 	    	     	    	     	
 7. 	    	     	    	     	
 8. 	    	     	    	     	
 9. 	    	     	    	     	
10. 	    	     	    	     	
11. 	    	     	    	     	
12. 	    	     	    	     	
13. 	    	     	    	     	
14. 	    	     	    	     	
15.
                                 32

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                               TABLE  8
                WORKSHEET 3:  TOXICITY-CONCENTRATION
    Contaminant                       Concentration
    CAS Number     Toxicity Score	Multiplier*    Product
 1. 	          	            	       	
 2. 	          	            	       	
 3. 	          	            	       	
 4. 	          	            	       	
 5. 	          	            	       	
 6. 	          	            	       	
 7. 	          	            	       	
 8. 	          	            	       	
 9. 	          	            	       	
10. 	          	            	       	
11. 	          	            	       	
12. 	          	            	       	
13. 	          	            	       	
14. 	          	            	       	
15.
    Maximum value calculated
*From Worksheet 2.
                                 33

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     Step 4;   For each critical contaminant, determine the toxicity




value as indicated in the Tables 4, 6, and 7 and page 42 of the HRS




User's Manual (47 FR 31219-31243, 16 July 1982).  Record the




contaminant toxicity values for each contaminant on Worksheet 3.




     Step 5;  Calculate the product of the toxicity factor value and




contaminant multiplier for each critical contaminant as indicated




on Worksheet 3.  Identify the largest value and record it on



Worksheet 3.



     Step 6;  Record the observed release value from Worksheet 1 and




the toxicity-concentration value from Worksheet 3 on Worksheet 4:




Score Sheet (Table 9).




     Step 7;  Evaluate the population exposed using the population




factor table (e.g., Table 4) and record the population value on



Worksheet 4.




     Step 8;  Compute the indoor air pathway score as indicated on




Worksheet 4.
                                 34

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                               TABLE  9

                     WORKSHEET 4:  SCORE SHEET
1.  OBSERVED RELEASE VALUE

2.  TOXICITY-CONCENTRATION VALUEa

3.  POPULATION VALUEb

4.  Multiply lines 1x2x3

5.  Divide line 4 by 2025                   Sąa
aFrom Worksheet 3.
bFrom Population Scoring Table (e.g., Table 4).
                                 35

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4.0  IMPLICATIONS




     The incorporation of this indoor air pathway would have several




implications for the HRS.  First, since the pathway requires that




fairly comprehensive, expensive monitoring data be developed in




order to evaluate the site, the potential costs of use of the indoor




air pathway may be significant.  These costs would arise from the




monitoring requirements, as the cost of calculating the waste




characteristics and targets scores would be negligible in comparison.




Current estimates of the cost to determine the presence of waste




site contaminants in indoor air in residential buildings range from




$4,000 to $4,500 per house, exclusive of labor costs (personal




communication, Turpin, 1986).  This cost reflects the minimum




necessary under the most favorable conditions.   Cost at complex




sites (e.g., those with nearby point sources) will be higher.




     Second, there are two important differences between the factors




used in this indoor air pathway and the other HRS pathways;  the lack




of a potential to release option and the use of a concentration




factor.  This first difference is particularly important since the




lack of a "potential to release" option in the current HRS air




pathway has been identified as a weakness in the current approach.




This weakness has been discussed by Congress in its deliberations on




CERCLA reauthorization.  In response to these concerns, an effort is




underway to develop a "potential to release" option for the HRS air




pathway (Wolfinger, 1987).   Thus, a potential to release option for
                                 37

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an indoor air pathway may also be required.  Further,  the use of a




concentration factor in this pathway raises the question of the use




of similar factors in the other pathways.




     Finally, several technical Issues remain to be resolved before




this indoor air pathway could be incorporated into the HRS.  These




include the development of benchmark concentration values for



residences, the preparation of monitoring requirements and guidance,




and the finalization of the target distance limit.
                                 38

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5.0  BIBLIOGRAPHY

American Conference of Governmental Industrial Hygienists,  ILVs
Threshold Limit Values and Biological Exposure Indices for  1985-86,
American Conference of Governmental Industrial Hygienists,
Cincinnati, OH, 1985.

Brown, Richard D., Hazard Ranking System Issue Analysis;  Use of
Significance in Determining Observed Release,  (MTR-86W101),  The
MITRE Corporation, McLean, VA, July 1986.

DeSesso, John et al., Hazard Ranking System Issue Analysis;
Toxicity as a Ranking Factor, (MTR-86W128), The MITRE Corporation,
McLean, VA, July 1986.

Foster, Sarah A. and Paul C. Chrostowski, "Integrated Household
Exposure Model for Use of Tap Water Contaminated with Volatile
Organic Chemicals," (86-12.3), Presented at the 79th Annual Meeting
of the Air Pollution Control Association, Held on June 22-27, 1986
in Minneapolis, MN, Air Pollution Control Association, Pittsburgh,
PA, 1986.

Foster, Sarah A. and Paul C. Chrostowski, "Inhalation Exposures to
Volatile Organic Contaminants in the Shower,"  (87-42.6),  Presented
at the 80th Annual Meeting of the Air Pollution Control Association,
Held on June 21-26, 1987 in New York, NY, Air  Pollution Control
Association, Pittsburgh, PA, 1987.

James, S. C., R. N. Kinman and D. L. Nutini, "Toxic and Flammable
Gases," Contaminated Land;  Reclamation and Treatment, Michael A.
Smith, ed., Plenum Press, New York, NY, 1985.

Kim, C. Stephen et al., "Love Canal:  Chemical Contamination and
Migration," Proceedings of the National Conference on Management of
Uncontrolled Hazardous Waste Sites, Held on October 15-17,  1980 in
Washington, DC, Hazardous Materials Control Research Institute,
Silver Spring, MD, 1980, pp. 212-219.

Miller, Joseph J. and Mark B. Beizer, "Air Quality in Residences
Adjacent to an Active Hazardous Waste Disposal Site," (85-73.7),
Presented at the 78th Annual Meeting of the Air Pollution Control
Association, Held on June 16-21, 1985 in Detroit, MI, Air Pollution
Control Association, Pittsburgh, PA, 1985.

Office of Technology Assessment, Habitability  of the Love Canal
Area;  An Analysis of the Technical Basis for  the Decision  on the
Habitability of the Emergency Declaration Area, Office of Technology
Assessment, Washington, DC, June 1983.
                                 39

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Fellizzari, Edo D., "Analysis of Organic Vapor Emissions near
Industrial and Chemical Waste Disposal Sites," Environmental Science
and Technology, Vol. 16, No. 11, 1982, pp. 781-755T

Pellizzari, E. D. et al., Interim Report on the Total Exposure
Assessment Methodology (TEAM) Study;  First Season, Northern New
Jersey, (Draft), U.S. Environmental Protection Agency, Washington,
DC, June 1985.

Rowe, William D., An Anatomy of Risk, John Wiley & Sons, New York,
NY, 1977.

Turpin, Rodney D., U.S. Environmental Protection Agency,
Environmental Response Team, personal communication,  January 1986.

U.S. Environmental Protection Agency, Damages and Threats Caused by
Hazardous Material Sites, (EPA-430/9-80-004), U.S.  Environmental
Protection Agency, Washington, DC, May, 1980.

U.S. Environmental Protection Agency, Superfund Public Health
Evaluation Manual. (EPA 540/1-86/060, OSWER Directive 9285.4-1),
U.S. Environmental Protection Agency, Washington, DC,  October 1986.

Wallace, Lance A. et al., "Personal Exposures,  Indoor-Outdoor
Relationships, and Breath Levels of Toxic Air Pollutants Measured
for 355 Persons in New Jersey," Atmospheric Environment,  Vol.  19,
No. 10, 1985, pp. 1651-1661.

Wallace, Lance A. et al., "Personal Exposures,  Outdoor
Concentrations, and Breath Levels of Toxic Air Pollutants Measured
for 425 Persons in Urban, Suburban and Rural Areas," Presented at
the 77th Annual Meeting of the Air Pollution Control Association,
Held on June 25, 1984 in San Francisco, CA,  Air Pollution Control
Association, Pittsburgh, PA, 1984.

Wolfinger, Thomas F., Hazard Ranking System Issue Analysis;   Options
for Revising the Air Pathway, (MTR-86W53), The MITRE Corporation,
McLean, VA, August 1987.
                                 40

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