SEPA
           Unnw SI«IM
           Environment*! P'O««ction
              Solid WMI«
DIRECTIVE NUMBER: 9285.4-06
TITLE: ATSDR Health Consultations Under CERCLA

APPROVAL DATE: November 21, 1991
EFFECTIVE DATE: November 21, 1991
ORIGINATING OFFICE:  OERR
121 FINAL
           D DRAFT
             STATUS:
            REFERENCE (other document!)
             [  ]  A- Pending OMB approval
             [  ]  B- Pending AA-OSWER approval
             [  ]  C- For review &/or comment
             [  ]  D- In development or circular i-.-*
                            headquarters
  DIRECTIVE    DIRECTIVE

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                         ted Slates ;rv/ironmer:ai Protection Agency
                              Washington. DC 20460
            OSWER Directive Initiation Request
                                                                      1. birective Numoer

                                                                      9285.4-06
                                    2. Originator Information
                                      Ma HO.
lame or uontact nenon                 Man c
SF Document Center Coordinator   OS-
Office
                                                      OERR
Telephone Code
  202-260-9760
      3. Title
             ATSDR Health Consultations Under CERCLA
      4. Summary ol Directive (include Onef statement of purpose)
        The purpose of this memo is  to clarify issues related to Agency for Toxic Subtances
        and Disease Registry (ATSDR) health consultations under CERCLA.  These clarifications
        apply to ATSDR health consultations requested by the Superfund removal remedial and
        site assessment programs.
      5. Keywords
                  Removal and Site Assessment
      6a. Does This Directive Supersede Previous Qirective(s)?
       b. Does it Supplement Previous Oirective(s)?
                                             ; I No
                                            V ! No
                                                Yes   What directive (number, title)
                                                       Yes    What directive (number, title)
      7 Draft .evel
         I  A - Signed 3y AADAA
                          8 - Signed by Office Director
       C •• For Review & Comment
         D - ;n Development
8.
Document
to
be
distributed
to
States
by Headquarters?

Yes , so

      This Request Maata OSWEflyOlfectlvaa System Format Standards.
      •,0. Name and Title of Approving Official
      9. Signature oM.ead Office Directives Coordinator
                                                              jDate
      i\j iiuc wi r^^^i \^v 11 iu wuMviQi
       Henry L. Longest II,  Director
       Office of Emergency and Remedial Response
                                                              i Date
                                                                       November 2i, 1991
      EPA Form 1315-17 (R«v. 5-87) Previous editions are obsolete.
   OSWER           Of'VER                OSWER                O
VE     DIRECTIVE          DIRECTIVE         DIRECTIVE

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            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON, D.C. 20460
                             NOV 2
                                     1001
                                                      OFFICE OF
                                             SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM

SUBJECT:  ATSDR Health Consultations  Under

FROM:
                                             Directive 19285.4-06
          Henry L. Longest  II, Director
          Office of Emergency and Remedi
                                               ponse
TO:
          Director, Waste Management  Division,
            Regions I, IV, V,  and VII
          Director, Emergency  and Remedial  Response Division,
            Region II
          Director, Hazardous  Waste Management  Division,
            Regions III, VI, VIII and IX
          Director, Hazardous  Waste Division
            Region X
           Director, Environmental Services Division
             Regions I, VI, and VII

PURPOSE AND SUMMARY

     The purpose of this memorandum is to clarify issues  related
to Agency for Toxic Substances and Disease  Registry (ATSDR)
health consultations under CERCLA.  These clarifications  apply to
ATSDR health consultations requested  by the Superfund removal,
remedial, and site assessment  programs.

     (1)  EPA Regions should consult  with Headquarters prior to
          using an ATSDR health consultation as the basis for
          selecting a residential soil cleanup  level for  lead,
          for CERCLA removal and/or remedial sites,  that  is
          greater or less than EPA's  recommended interim  range of
          500-1,000 ppm.

     (2)  Regions also should  consult with  Headquarters before
          taking actions based on other ATSDR health
          consultations that raise similar  nationally significant
          or precedent-setting issues for the Superfund program.

     (3)  Findings and conclusions of ATSDR health consultations
          are strictly site-specific  and do not establish
          national EPA policy.  ATSDR health consultations should
          not be applied to situations beyond the specific site
          for which they were  developed.
                                                        Printed on Recycled Paper

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BACKGROUND

     CERCLA section 104(i)(4) directs ATSDR to "provide
consultations upon request on health issues relating to exposure
to hazardous or toxic substances, on the basis of available
information, to the Administrator of EPA, State officials, and
local officials."  ATSDR defines a health consultation as a
response from ATSDR to a specific question or specific request
for information pertaining to a hazardous substance or site
(e.g., Does a given level of mercury in water pose a threat to
human health?).  Health consultations, because they often are
time-critical and require rapid response, are a more limited
response than an ATSDR health assessment.  EPA Regional staff
frequently have found ATSDR health consultations to be very
useful sources of information.

     Health consultations typically are performed as joint
efforts by ATSDR Regional offices and appropriate ATSDR
Headquarters staff.  The variety of topics encompassed can
include environmental health, environmental medicine,
epidemiology, toxicology, worker health and safety,  acute release
events, and site operations.  Physicians, toxicologists,
environmental engineers,  environmental health scientists,  and
emergency response coordinators are available on a 24-hour basis
for emergency response.  ATSDR can deliver recommendations
verbally or in writing, whichever is deemed most appropriate.
Because of the importance of timely response to these types of
requests, written health consultations are not routinely released
for public review, but recommendations may be discussed with
relevant federal, state,  or local agencies prior to release.

DISCUSSION

     Recently, there have been some CERCLA sites for which EPA
has selected, based (at least in part)  on ATSDR health
consultations, residential soil lead cleanup levels that have
been outside the range recommended by the Office of Solid Waste
and Remedial Response (OSWER).  OSWER has issued a directive and
a memorandum providing guidance on cleanup levels for lead in
soil at CERCLA sites:

     "Interim Guidance on Establishing Soil Lead Cleanup Levels
     at Superfund Sites," OSWER Directive #9355.4-02,  September
     1989

     "Update on OSWER Soil Lead Cleanup Guidance," Memorandum to
     Regions from OSWER Assistant Administrator,  August 29,  1991

     The August 1991 memorandum, which provides a progress report
on OSWER's efforts to revise the September 1989 directive,
reaffirms the recommended interim soil cleanup level of 500-
1,000 ppm total lead for CERCLA sites established in that
directive.  It also states that "OSWER believes that the best

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available approach is to use the EPA Uptake Biokinetic  (UBK)
Model as a risk assessment tool to predict blood lead levels and
aid the risk management decision on soil lead cleanup levels at
CERCLA/RCRA sites which are characterized as residential."
However, before issuing a final directive recommending the UBK
Model as the preferred method for setting soil lead cleanup
levels at CERCLA/RCRA sites, OSWER has decided to seek additional
review of the model, beginning with the Science Advisory Board on
November 7, and to evaluate its use at several types of sites.
In the interim, the August 1991 memorandum directs that
Headquarters be consulted before a Region uses the UBK Model as
the basis for soil lead cleanup levels outside the 500-1,000 ppm
recommended interim range.

     In parallel with this recent guidance on the use of the UBK
model, Regions should consult with Headquarters prior to using an
ATSDR health consultation as the basis for selecting a soil lead
cleanup level that falls outside EPA's recommended interim range
of 500-1.000 ppm.  This request for consultation applies both to
removal and remedial sites.  Headquarters consultation is needed
in these situations because of the potential precedents set by
using ATSDR findings as a basis for site-specific soil lead
cleanup levels that fall outside of OSWER's recommended range (as
published in Directive #9355.4-02)  and because of the national
significance of lead cleanups.  The consultation should be with
the OSWER Lead Technical Review Group.  The Headquarters lead
staff persons are Dr. Susan Griffin (FTS 260-9493)  and Karen
Tomimatsu (FTS 260-9861).

     By definition, ATSDR health consultations are limited and
situation-specific.  ATSDR's findings and conclusions are based
on review and analysis of individual circumstances specific to
the site in question.  They also are frequently prepared in
response to time-critical situations,  and therefore limited in
scope and depth of analysis.  Finally, ATSDR health consultations
are not subject to EPA review and consensus-building and
therefore may not always be consistent with published EPA
policies and guidelines.  For these reasons, the findings,
conclusions, and recommendations of an ATSDR health consultation
should not be considered national Superfund policy and should not
be assumed to apply to sites other than the one for which it was
developed.

DISCLAIMER

     This document is intended solely as guidance.   EPA decision-
makers may act at variance with any of the recommendations
contained in this document.  These recommendations are not
intended and cannot be relied upon to create any rights,
substantive or procedural, enforceable by any party in litigation
with the United States.  These recommendations may change at any
time without public notice.

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