EPA906-D-98-001
                                                     Interim Final
USER'S GUIDE FOR THE U.S. EPA REGION 6
DELISTING RISK ASSESSMENT SOFTWARE
                    (DRAS)
             Office of Solid Waste
                    Prepared by

        Multimedia Planning and Permitting Division
           U.S. Environmental Protection Agency
                     Region 6
                  Dallas, TX 75202
                  August 31, 2000

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USER'S GUIDE FOR THE U.S. EPA REGION 6
DELISTING RISK ASSESSMENT SOFTWARE
                      (DRAS)
                     Submitted to:
                  U.S. EPA Region 6
                   Dallas, TX 75202
                     Prepared By:

                  Tetra Tech EM, Inc.
                   One Dallas Centre
            350 North St. Paul Street, Suite 2600
                   Dallas, TX 75201

                        and

                  HydroGeoLogic, Inc.
             1155 Herndon Parkway, Suite 900
                  Herndon,VA 20170

                        and

                  HydroGeoLogic, Inc.
            13740 Research Boulevard, Suite N-5
                   Austin, TX 78750
                     Version 1.1
                   August 31,2000

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                            TABLE OF CONTENTS

                           	Page
1.0    INTRODUCTION 	 1
      1.1    OBJECTIVES 	 1
      1.2    BRIEF OVERVIEW OF THE SOFTWARE	 1
      1.3    USING THE  DRAS SOFTWARE IN SEVEN EASY STEPS  	 2

2.0    SYSTEM REQUIREMENTS	 4
      2.1    MINIMUM SYSTEM REQUIREMENTS  	 4
      2.2    RECOMMENDED SYSTEM REQUIREMENTS 	 4

3.0    INSTALLATION	 5

4.0    BRIEF OVERVIEW OF RUNNING THE SOFTWARE  	 6
      4.1    DELISTING LEVEL ANALYSIS VERSUS RISK AND
            HAZARD ANALYSIS 	 6
      4.2    DELISTING LEVEL ANALYSIS 	 6
      4.3    RISK AND HAZARD ANALYSIS	 6
      4.4    REQUIRED INPUT	 6
      4.5    OUTPUT	 7
      4.6    APPLICATION OF RESULTS TO EVALUATION
            OF DELISTING PETITION 	 7

5.0    GETTING STARTED: WALK-THRU WITH SCREENS 	 8
      5.1    HOW DO I START THE DRAS SOFTWARE?	 8
      5.2    WHAT ARE THE FEATURES OF THE DRAS USER-INTERFACE? 	 8
      5.3    ANALYSIS INPUT	 9
         5.3.1     Facility Information Tab	 9
         5.3.2     Waste Management Unit Tab	 10
         5.3.3     Chemical Input Tab 	 11
      5.4    ANALYSIS RESULTS	 12
         5.4.1     Delisting Results Tab 	 13
         5.4.2     Chemical-Specific Results Tab	 15
         5.4.3     Cumulative Results Tab  	 16
         5.4.4     Summary of Results Tab	 17
      5.5    PRESENTATION OF RESULTS — REPORTS  	 17

6.0    SUPPORTING INFORMATION	 18
      6.1    JUSTIFICATION AND DOCUMENTATION OF
            PARAMETER VALUES	 18
      6.2    U.S. EPA REGION 6	 18

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1.0    INTRODUCTION

This User's Guide has been developed as part of the U.S. Environmental Protection Agency (EPA) Region 6
Hazardous Waste Delisting Program.  It has been prepared to assist the user in applying the Region 6
Delisting Risk Assessment Software (DRAS) to determine whether a waste qualifies as not characteristically
toxic for the purposes of delisting (in accordance with Title 40 Code of Federal Regulations (CFR) Parts
260.20 and 260.22 and the Region 6 Delisting Program).

The Region 6 Delisting Program developed this software to compute the risks and hazards associated with
a specific waste stream  for which a delisting petition has been submitted. The Region 6 DRAS will assess
the toxicity of a petitioned waste by calculating: (1) chemical and waste volume-specific screening exit
values, and (2) cumulative carcinogenic risks and hazard indices (for non-carcinogens).

1.1    OBJECTIVES

The objectives of the User's Guide are:  (1) to provide general information about the Region 6 DRAS, (2)
to provide step-by-step instructions on using the software and interpreting the results of the risk assessment,
and (3) to troubleshoot difficulties commonly encountered in installation and operation of the software. This
information is intended to assist regulatory authorities, petitioners, and decision makers in the hazardous
waste delisting determination process.

Users are directed to the  Delisting Technical Support Document (DTSD) for detailed background information
about the algorithms, equations, and the dilution-attenuation factors (DAFs) used in the risk assessment. The
DTSD is available as a WordPerfect 6.1 file on the compact disc (CD).

Petitioners are directed to the Region 6RCRA Delisting Program Guidance Manual for the Petitioner (U.S.
EPA, 1996) for additional information necessary to satisfy the information requirements of a complete
delisting petition.

1.2    BRIEF OVERVIEW OF THE SOFTWARE

This software will assess the carcinogenic risk and noncarcinogenic hazard associated with a petitioned
waste's disposal to either of two types of waste management units (WMU):   1) landfills and 2) surface
impoundments. The software prompts the user to enter waste information which should be available in the
delisting petition. Once  all the general waste information and the chemical specific constituent concentration
data have been entered, the program will perform screening and cumulative risk and hazard calculations.
The screening risk evaluation will provide the user with Toxicity Characteristic Leachate Procedure (TCLP)
and total waste constituent concentrations associated with a IxlO"5 carcinogenic risk level and a hazard
quotient of 0.1 for the most sensitive exposure pathway. These TCLP and total values may be used as the
maximum allowable waste constituent concentrations for a multi-year standard exclusion (delisting). If the
waste constituent concentration exceeds these risk-based levels, the waste may not qualify for a multi-year
exclusion under 40 CFR §§260.20 and 260.22.

The cumulative risk assessment will provide the user with an overall carcinogenic risk and noncarcinogenic
hazard index (HI) for the petitioned waste as a whole, summing risks associated with each exposure pathway
for a given constituent and then summing risk for all waste constituents.  The assessment will also provide
the user  with the cumulative  carcinogenic and noncarcinogenic risks associated with a specific waste
constituent. If the waste exceeds the risk-based levels outlined in the DTSD, the waste may not qualify for
exclusion under 40 CFR §§260.20 and 260.22. The methods and data used in: 1) the determination of media
waste concentrations at the point of exposure; 2) the risk assessment algorithms is outlined and referenced

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in the DTSD
To obtain a copy of the DTSD, please contact:

Michael G. Morton, Ph.D.
Multimedia Planning and Permitting Division (6PD-O)
U.S. EPA Region 6
1445 Ross Avenue
Dallas, Texas 75202
214/665-8329
morton.michael@epa.gov

To avoid misinterpretation, the results of the screening analyses and the cumulative risk analyses are
displayed to the user on separate screens. The screening results display each waste constituent that exceeds
the screening risk levels, along with the exposure pathway for which the exceedance was determined and the
waste concentration (TCLP and total) that would allow the constituentto pass the screening levels (i.e., 1x10"
5 for carcinogens and 0.1 hazard quotient for non-carcinogens).

The cumulative risk interface screens provide: 1) the carcinogenic risk and noncarcinogenic hazard quotient
for each  pathway for a given constituent; 2) the cumulative  risk and HI for all exposure pathways of a
specific waste constituent; 3) the cumulative risk and hazard index (HI) summed for all waste constituents;
4) identification of chemicals that exceed their soil saturation value; and 5) identification of chemicals that
exceed Toxicity Characteristic (TC) Rule regulatory values.

The user may also enter the detection limit (DL) value associated with a given waste constituent and the
program will determine the risk and hazard associated with a fraction of the waste constituent DL value. The
default fraction used in the risk assessment is 0.5 (50% of the detection level). The program will track waste
constituent risks associated with actual measured concentrations and those risks associated with DL values.

1.3     USING THE  DRAS SOFTWARE IN SEVEN EASY STEPS
       Step 1: Installation (Windows 95). To install the DRAS software, insert the installation CD into
       the drive.  If your machine has AUTORUN enabled, a. DRAS installation screen will be displayed.
       Click on the "Install Delisting Risk Assessment Software" button to install the DRAS, then follow
       the on-screen instructions. If AUTORUN is not enabled, then, from the start menu, select RUN.
       Enter the  drive  letter for your CD drive followed  by SETUP.EXE in the dialog box or click
       "Browse" and click on the file SETUP.EXE on the CD drive.  Then follow the instructions. (For
       more information, see Section 3.0).

       Step 2: Open DRAS (Windows 95). To open the DRAS software select "Programs" from the Start
       menu and then select "Delisting Risk Assessment Software" (see Section 5.1).  On initial start-up
       the DRAS presents a series of introductory screens  describing the program. Click "Next" until
       reaching the last screen, then click  "Finish" to enter the analysis input part of the program. The
       introductory screens can be turned off by checking the box at the bottom of the analysis input screen.

       Step 3: Enter information for record keeping. To enter information for record keeping purposes,
       click the "Facility Information" tab  located at the top of the data entry screen (see Section 5.3.1).

       Step 4: Enter facility-specific information about  the  WMU. To enter information about the
       WMU, click on the "Waste Management Unit" tab.  Then select the WMU type ("Landfill" or
       "Surface Impoundment") and enter the WMU properties ("Waste Volume" and "Active Life") (see
       Section 5.3.2).

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Step 5: Enter chemical-specific information about a waste petitioned for delisting. To enter
chemical-specific information about a waste, click on the "Chemical Input" tab. Then select the
desired chemicals from the chemical list. After selecting the chemicals enter the maximum TCLP
concentration (mg/L), maximum total concentration (mg/kg), and, if necessary, its DL (see Section
5.3.3).

Step 6: Run analysis. To obtain detailed risk assessment results, click on the "Run
Analysis" tab at the bottom of the screen.  Clicking on the "Run Analysis" button generates the
Analysis Results  screen comprised of four tabs: Delisting Results, Chemical-Specific Results,
Cumulative Results, and Summary of Results (see Section 5.4).

Step 7: Print and/or save results. To print the risk assessment results, click on the "Print Results"
button at the bottom of the Analysis Results screen, and then select the desired reports to print. To
save the analysis results, click on the "Save  Analysis" button at the bottom of the Analysis Results
screen, and then choose the desired location and filename (see Section 5.5).

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2.0     SYSTEM REQUIREMENTS

This section summarizes the minimum and recommended installation and operating requirements.

2.1     MINIMUM SYSTEM REQUIREMENTS

The minimum system requirements for installing and running this software are as follows:

             PC:                 486 CPU
       •      Operating System:     Windows 3.11
             System Memory:      16 Mb RAM
       •      Disk Storage Space    6 Mb hard-disk space
             Other:               CD-ROM


2.2     RECOMMENDED SYSTEM REQUIREMENTS

The recommended system requirements for installing and running this software are as follows:

             PC:                 Pentium 133 MHZ
       •      Operating System:     Windows 95
             System Memory:      32 Mb RAM
       •      Disk Storage Space    30 Mb hard-disk space
             Other:               CD-ROM

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3.0
        INSTALLATION
The U.S. EPA Region 6 DRAS is installed from a CD installation disk. To install the software, the user
should perform the following steps:
                                                             United States
                                                            t Environmental Protection Agency
                                                       "...to protect human health and to safeguard the natural environment..."

                                                 WELCOME! This is the first step in setting up EPA Region 6's Delisting Risk
                                                 Assessment Software version 1.1, known as DRAS for short. In order for DRAS to run
                                                 properly, three steps must be performed in the setup process. These steps are:
                                                  1.
                                                       Install A dob e1 s A crob at Re ader 4.0 s o that the D elisting T e chnic al Supp ort
                                                       Document can be accessed from within DRAS;

                                                       Install the Microsoft Help software to permit access to the DRAS Help files,
                                                       and finally,

                                                       Install DRAS to begin performing Risk Assessments of your waste.
                                                                     Acknowledgements   il
                                                                     Install Acrobat Reader
                                                                     Install Microsoft Help
                                                                Install Delisting Risk Assessment Software
        •       Close all other applications.
        •       Insert disk into the CD drive.
        •       If   your   machine    has
                AUTORUN   enabled,   an
                installation  screen  will  load
                automatically  from  the  CD.
                Click the "Install Delisting Risk
                Assessment Software" button to
                install the  DRAS    If  your
                machine   does   not   have
                AUTORUN installed, then, to
                begin the installation process:
        •       For Windows 3.11 users: from
                the "File" menu, select  "Run."
        •       For Windows 95 and NT users:
                from the "Start" menu, select
                "Run."
                Click the "Browse" button and navigate to the CD drive.  Click on the setup.exe file and
                then click the "OK" Button.
        •       On the "Welcome" screen, click "OK."
                Select the destination directory on your hard-drive where this software is to be installed and
                click on the "Installation" button.
                When the installation is complete, click on the "OK" button to exit the installation process.

For Windows 3.11 users, the program can be started by double-clicking on the Delisting program group, and
then double-clicking on the Drasvl.exe file.

For Windows 95 users, the program can  be started by selecting "Programs" from the "Start" menu (on the
Windows tool bar at the base of your screen). Then select "Dras" from the list of available programs.

If you are experiencing difficulties installing the DRAS and are linked to a network version of Windows, it
may be necessary to use your local version of windows.  Check with your local network administrator to
determine the best option for installation.

If you are running virus scan software, it may be necessary to close the virus scan software prior to installing
the DRAS

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4.0    BRIEF OVERVIEW OF RUNNING THE SOFTWARE

The Region 6 Delisting Program has developed this Windows-based DRASto calculate delisting levels and
to perform a cumulative assessment of the total carcinogenic risk and noncarcinogenic hazard associated with
the disposal of the petitioned waste.

4.1    DELISTING LEVEL ANALYSIS VERSUS RISK AND HAZARD ANALYSIS

The DRASperforms two types of analyses: (1) a delisting level analysis and (2) a cumulative risk and hazard
analysis.  The results of these analyses may be viewed on screen, imported into word processing documents,
or printed in document-ready form. The results of the delisting level analyses are used in the evaluation of
multi-year delisting petitions, whereas the results of the risk and hazard analyses are used in the evaluation
of one-time delisting petitions.

4.2    DELISTING LEVEL ANALYSIS

The delisting level analysis computes chemical-specific delisting levels or "exit values"  for multi-year
delistings. These delisting levels are the maximum allowable total constituent concentration in the waste and
the maximum allowable waste leachate concentration. Delisting levels are calculated using default values
for the target risk and hazard quotient of 10~5 and  0.1, respectively.  The default target risk and hazard
quotient values  can be changed by the user, but this will impact the magnitude of the resulting delisting
levels. EPA Region 6 requires use of the default values in delisting petitions.

Because toxicity is only one of the waste characteristics which are examined in a delisting petition, a waste
which does not exceed its delisting levels is not automatically delisted. A waste that contains constituents
at concentrations that exceed their delisting levels may not qualify for delisting.

4.3    RISK AND HAZARD ANALYSIS

The cumulative risk and hazard analysis computes the cumulative carcinogenic risk and noncarcinogenic HI
of a waste petitioned for a one-time delisting to determine if the risk exceeds a 10"4 risk and/or if the hazard
exceeds a 1.0 HI.

4.4    REQUIRED INPUT

To calculate the delisting levels and the potential risks associated with a particular waste stream petitioned
for delisting,  specific information about  the petitioned waste is required.  EPA Region  6 requires  the
petitioner to input the following waste-specific information into the DRASto estimate risks associated with
potential  exposure to the petitioned waste stream:

               The maximum annual volume of the petitioned waste for a multi-batch delisting petition or
               the maximum total waste volume for a one-time delisting,
               The rate at which leachate flows from a surface impoundment into the subsurface,
               The maximum total concentration of each chemical constituent in the petitioned waste,
       •       The maximum TCLP concentration (estimated leachate concentration) of each  chemical
               constituent in the petitioned waste, and
       •       The number of years the petitioned waste is projected to be generated.

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4.5    OUTPUT

Delisting levels are presented on the tab entitled DelistingResults. These delisting levels are the maximum
allowable concentrations which can be present in the waste without exceeding the defined risk level (10~5)
or HI (0.1).  If the concentration in the petitioned waste exceeds the delisting level  for a given waste
constituent, the delisting level is reported in the table on the Delisting Results tab; otherwise, "N/A" is
reported in the table.  Further, instances of a chemical's total waste concentration exceeding the 10,000
mg/kg delisting ceiling are indicated in the results.  Also, when a chemical's TCLP concentration exceeds
its TC Rule regulatory value (see CFR §261.24(a), Table 1), this is incicated in the results. Finally, when
an organic chemical's calculated delisting level  is greater than its  soil saturation value (given in the
Appendices of the DTSD), this is indicated in the results.

The complete results from the risk/hazard analysis are presented on the Chemical-Specific Results tab and
the Cumulative Results tab and are summarized on the Summary of Results tab. In the risk and hazard
analysis, first the potential risk and hazard posed by disposal of the petitioned waste is calculated. Then the
calculated total risk level for the petitioned waste is compared to the standard risk level of 10"4 and the
calculated total HI for the petitioned waste is compared to the standard HI of 1.0.

4.6    APPLICATION OF RESULTS TO EVALUATION OF DELISTING PETITION

If any of the delisting levels are exceeded, the waste may not qualify for delisting. However, because toxicity
is only one of the waste characteristics which are examined in a delisting petition, a waste which does not
exceed the  delisting levels  is not automatically delisted.

A petitioned waste whose cumulative carcinogenic risk (as calculated in DRAS risk and hazard analysis)
exceeds the value of 10~4 may not be a candidate for delisting.

Exceeding  a hazard quotient of 1.0 (as calculated in DRAS risk and hazard analysis) does not necessarily
indicate that the petitioned waste should not be delisted. Not all noncarcinogenic hazards are additive (U.S.
EPA, 1989).  If the HI for a petitioned waste exceeds 1.0, the compounds should be segregated by the type
of effect induced and the mechanism of action. Separate hazard indices could then be derived for each target
organ(s) or mechanism of action.  This analysis is not a simple process and should only be performed by a
qualified toxicologist. The user is referred to the Region 6 DTSD for additional information.

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5.0    GETTING STARTED: WALK-THRU WITH SCREENS
5.1
HOW DO I START THE DRAS SOFTWARE?
To use the program for the first time, you must install the software from the CD to the hard-drive (see Section
3.0).

For Windows 3.11 users, the program can be started by double-clicking on the DRAS group, and then double-
clicking on the Drasl.exe file.

For Windows 95 users, the program can be started by selecting "Programs" from the Start menu (on the
Windows tool bar at the base of your screen).  Then select the "Dras" program from the list of available
programs.

5.2    WHAT ARE THE FEATURES OF THE DRAS USER-INTERFACE?
This software is optimized to work with the Windows 95 operating system, but is also backward compatible
with Windows 3.11. The software is likely to be compatible with the Windows 98 operating system, but has
not been tested in this setting. The  DRAS user interface is designed to operate similar to other Windows-
based programs. At the very top of the screen is a title bar which displays the software title. Directly below
the title bar is  the main program menu. The user can select among the following menu items: "File,"
"Detection Limits,"  and   "Help."    General  file
operations such as open and save can be accessed by
clicking on the "File" menu. The user can display the
list of DLs for all constituents by clicking on the
"Detection Limits" menu (note:  close the "Detection
Limits" menu to bring back the user-interface screen).
The user can access the  User's Guide, get information
about the  software,  or re-display the  introductory
screens by clicking on the "Help" menu.
                                          File Detection Limits Net
Facility Information f Waste Management Unit J
Region 6 Delisting Risk Assessment Program
Delisting Petition ID Number
i
\\\tD STjQ-f
\^-V * i t^-^ Facility Identification (Facility N ame, L
Chemical Input
ocation, etc.)
* irftfBft. ^ t '
^ aJF^Sk -T 1
£ ^" ^ y |
\0 Batch Identification
fy vW" DaiB ef lA!ssle Da
"\Jflj -rcCj Sample Ana^sis Ris
Name of User
e of Delisting
< Assessment
10/30/1998
i
How do I navigate through the DRAS software?

The user interface is set up as a series of Windows-
based  screens  and tabs through  which  the  user
navigates to enter data and view results. The user can
page through the program using two different methods: 1) by clicking on the command buttons at the bottom
of the screen, or 2) by clicking on one of the labeled tabs located at the top of the data entry and results
screens. These tabs allow the user to:

              Enter descriptive information about the waste being evaluated for delisting
               Select the waste management scenario and waste volume
               Select waste constituents and enter leachate and total waste concentrations
              Print reports and save, open, and edit delisting files

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introduction Should Not Appear Agas
How do I get HELP if I have a problem or a question?

Help can  be accessed by clicking on the pull-down  "Help"
menu screen and then selecting "Help Definitions"or  by
clicking on the "Help Definitions" button on the lower right of
the screen. The "Help Definitions" selection presents the user
with a screen containing links to help topics, a searchable index,
and an option to print the "Help" topic text.

The  first  time  the DRAS  is run, a series of screens  with
introductory information is displayed.   After  reading this
information, the user can click in the check-box at the bottom
of the screen to prevent these introductory screens from being
displayed  the next time the program is run. This introductory
information can be viewed at any time  by choosing "Show
Introduction Screens" from the pull-down "Help" menu. Also,
the User's Guide  can be viewed from the pull-down "Help" menu. Finally, the pull-down "Help" menu
includes an option for enabling the DL check screen when entering chemical concentrations.

5.3    ANALYSIS  INPUT

This section of the DRAS  is designated for the input of pertinent facility information, waste-specific
information, and chemical-specific information about a petitioned waste. There are three interface screens
in this section of the DRAS. 1) Facility Information, 2) Waste Management Unit, and 3) Chemical Input

5.3.1  Facility Information Tab

Are  the inputs on the Facility Information screen necessary?

The  Facility Information screen allows the user to enter information about a delisting petition analysis.
While the  inputs on this screen are not required to perform an analysis, this screen allows the user to enter
information that is necessary for record-keeping. In addition, this information entered by the user is printed
on all DRAS reports.  The user should enter the following information in the appropriate text box:

Delisting Petition ID Number — Internal tracking number forthe delisting petition which is being analyzed
in the DRAS. To  facilitate record keeping, each waste petitioned for a RCRA exclusion (delisting) should
be assigned a unique number. We recommend that the ID number incorporate the EPA region number and
year of the petition.  For instance, ID# R6-98-001  could be the ID number for the first delisting petition
received in Region 6  during 1998.

Facility Identification — The name and address of the facility petitioning for the delisting.

Batch Identification — Descriptive information about the batch of waste being analyzed. This information
is useful for distinguishing between several waste streams at the same facility.

Date of Waste Sample Analysis — Date the petition analysis was performed. This information is useful for
internal record keeping.

Name of User — Person who is performing the delisting risk assessment. Again, this information is useful
for internal record keeping.

Throughout the DRAS program, the facility name and petition identification number are displayed on-screen

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for the user's convenience and so that a printed copy of an individual screen will include identification of
the waste being evaluated.

5.3.2  Waste Management Unit Tab

A waste petitioned for a RCRA hazardous waste exclusion (delisting) is expected to be disposed of in a
WMU. The Waste Management Unit screen allows the user to enter facility-specific information about the
WMUwhere the waste is disposed. The DRASuses waste information entered on this screen to perform the
risk assessment. The information that can be entered is explained below.

What types of  WMUs can I select?

WMU— The DRAS predicts risks associated with the disposal of petitioned wastes for two types of WMU?,.
Landfill and Surface Impoundment. A Landfill scenario should be  selected to assess the potential risks
associated with the disposal of solid wastes petitioned for a  RCRA exclusion (delisting). The Surface
Impoundment scenario should be selected to assess the potential risks associated with the disposal of non-
solid wastes petitioned for delisting. If the user selects a landfill as the WMU, only the annual waste volume
must be entered. If the user selects a surface impoundment as the WMU, both the annual waste volume and
flow rate must be entered.

WMU Properties — Includes waste volume, facility active life, and type of delisting petition.

Waste Volume — The annual volume of waste to be petitioned for a RCRA exclusion (delisting).

Type of Delisting Petition — The choice of One-time batch or Multiple-year batch determines whether or
not a value for the active life of the delisting must be entered. If the delisting petition is for a one-time batch
delisting, the user should select the One-time batch option button. For a One-time batch, the default value
of Active Life is one year, and the Active Life input box will be grayed out.  If the waste to be delisted will
be disposed of in multiple batches over more than one year, the user should select the Multi-year batch
option button. Selecting this option button will activate the Active Life input box where the user should input
the number of years that the WMU is expected to accept the
petitioned waste.
                                                      Fie Oeiedion Limits Help
                                                                   _]  Waste M,
                                                                    R! * HO Facto	
                                                                    F.I I Faclor il pE.05
Active Life — Refers to the active life of the delisting
petition with regard to the waste entering the WMU. The
default value for a multi-year delisting is 20 years and the
default value for a one-time delisting is one year, however,
the user may input another value, as appropriate.  For a
multi-batch delisting, a facility is expected to have multiple
batches of waste delisted over an extended period of time.
Therefore, 20 years is selected as a reasonable maximum
value for the facility operational life. The default value for
a one-time delisting is one year since the waste to be delisted will be disposed into the WMU as a one-time
batch.

Flow Rate — The rate at which leachate flows from the bottom of the surface impoundment (including any
liner) into the unsaturated zone. This value is determined by the  depth of the surface impoundment, the
hydraulic  characteristics of the liner or sludge  at the base of the impoundment, and the  depth and
hydrogeological characteristics of the sediments comprising the unsaturated zone.

Petition ID and Facility Name— The Petition ID and Facility Name are displayed here as a reference for
the user. These data can only be changed on the Facility Information screen, as described above.
                                               10

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5.3.3   Chemical Input Tab

The Chemical Input screen allows the user to enter chemical-specific information about a waste petitioned
for delisting. The user first selects the chemicals that were detected in the petitioned waste and then inputs
the Maximum TCLP Concentration and Maximum Total Waste Concentration for each selected chemical.
The user may elect to enter concentrations below the DL in the petition data. The user indicates if a chemical
is below the DL by clicking in the DL column for the specified chemical.  The user also has the option to add
a new chemical to the list if the desired chemical is not in the list or if the user does not think that the
chemical properties are appropriate for the petitioned waste.

How do I select chemicals present in the petitioned waste?

List of Chemicals — There are four ways to choose chemicals to be analyzed:

1)     Begin typing the chemical name in the "Enter Chemical Name" box and if the chemical is found, hit
       the "Enter" key;
2)     Begin typing the chemical CAS (Chemical Abstracts Service) number in the "Enter Chemical CAS
       Number" box and if the chemical is found, hit the "Enter" key;
3)     Scroll through the list of chemicals and click in the box of each chemical to be analyzed, then click
       the "Select Checked Chemicals" button;
4)     Scroll through the list of chemicals and double click on each chemical to be analyzed.

If the user types in the chemical name or CAS number in the corresponding textbox, the program will then
search the list of chemicals for the  closest match to the typed value.  Once the correct chemical is
highlighted, the user can either double-click on the chemical or hit the "Enter" key to accept the chemical.
The user should be aware that since some chemicals have more than one name, it is possible that the program
may not find the correct chemical based on a search by chemical name. Therefore, if a name search is
unsuccessful, the user should search by CAS number or scroll through the list of chemicals to find the desired
chemical. Please note that the user also has
the option to add a new chemical to the list
with user-defined properties.

What if I suspect that a certain chemical
is  present  in  my waste,  but  at a
concentration below the DL1

Often the delisting  petition will contain
waste sampling  results  that report  non-
detect values for a number of the chemicals
analyzed.   The non-detect  concentration
may be reported as the method detection
limit   (MDL)   or   as   the   estimated
quantitation limit (EQL).  For the purposes
of  this  discussion,  the  concentration
reported  as  non-detect will be the  DL.
Several variables influence  the DL for a
chemical, including the instruments used,
the waste matrix, and the analytical test
method. In some cases the reported DL for
a chemical may exceed its delisting level at
the target risk level.  In such a case, the user may wish to discuss this issue with the lab to find out if there
is another available analysis method with a lower DL.
I, Analysis Input Region 6 Delisting Risk Assessment Program BIB
[ile Detection Limits Help
Facility Information | Waste Management Unit Chemical Inpul

Enieiing Chemicals
There are four ways to choose chemicals to be analysed:
1) Begin typing the chemical name in the "Enter Chemical
Name" box and if the chemical is found, hit the "Enter"
key;
2) Begin typing the chemical CAS number in the "Enter
Chemical CAS Nurnber"bo}: and if the chemical is found, hit
the "Enter" key;
3) Click m the boxes of the chemicals) to be analyzed, click
the "Select Checked Chemicals" button, and then enter the
concentrations ;
4) Double clack on the chemicals) to be analysed and then
enter the concentrations.
Iron 17439896} _*]
KobuM alcohol {78831}
Lophorone {78591}
r'epme {143500}
* gitf Sciavji^^^^^^a _i
Magnesium {7439954}
Manganese {7433965}
Mercury {7439976} J
inter Chemical Name
Select
r L rir- u L Checked
Enter CAS Number ChealK^

r, -I.LAI A CAS Maximum TCLP m Maximum Total m
Chem,calS to be Analyzed N(jmbef Concentration (mg/L) DL Concentration (mg/kg) »L
Lead 7439921 Enter Concentration No Entei Concentration No
To edit concentration, click on cell and enter new value.

Italics signify that the concentration for that constituent is a detection limit, not a measured concentration.
Create Chemical Delete Row Run Analysis Help

                                              11

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When a chemical is selected, and provided that the DL check screen option is turned on, the DRAS will
present a screen that asks the user whether the concentration that will be entered for the chemical is to be
treated as a DL or a measured value. Entering a DL will cause results for that chemical to be shown (on-
screen and in printed reports) in italics throughout the rest of the DRAS analysis. Also, the DRAS determines
the risk and hazard associated with a fraction of a  chemical's DL.  The default fraction used in the
assessment is  0.50, so, in conducting the  risk and hazard assessment  for a chemical whose waste
concentration (TCLP or total) has been entered as a DL, the DRAS first multiplies the waste concentration
by 0.50, then evaluates the risk and hazard. Further, all risk assessments are conducted twice: once including
those chemicals specified with concentrations that are DLs and once omitting them.  This enables the user
to know if these non-detects are driving the results of the risk assessment. Again, if the risk is impacted by
the non-detects, the user may wish find out if there is another available analysis method with a lower DL.

The DL check  screen option is accessed from the "Help" pull-down menu.
How do I enter the TCLP and total chemical concentrations for each chemical?

As the user selects chemicals and either hits the "Enter" key, double-clicks, or hits the "Select Checked
Chemicals" button, a table is built at the bottom of the screen, each line of which specifies a selected
chemical. The table cells below the column labeled Maximum TCLP Concentration are used to enter the
waste TCLP concentration. To enter a value, click on the cell for a chemical and type in the concentration.
Likewise, the cells below the column labeled Maximum Total Concentration are used to enter values for
that parameter. If the laboratory analysis method reports a non-detect, the user should enter the DL as the
concentration.
Can I edit the concentration values of a chemical?

Edit Constituents) — If the user accidentally enters an incorrect TCLP and/or Total Waste Concentration,
these values can be edited. To edit these values, the user should click on the cell containing the incorrect
value, then enter the new value.  The user may also click on the "Delete Row" button to remove a chemical
from the table.
How do I perform the risk assessment for the petitioned waste?

After entering all the waste- and chemical-specific values, the user should click on the "Run Analysis" button
to perform the risk assessment for the petitioned waste.
5.4    ANALYSIS RESULTS

This section of the DRAS provides the user with detailed risk assessment results for the petitioned waste.
The Analysis Results screen is comprised of four tabs: Delisting Results, Chemical-Specific Results,
Cumulative Results,  and Summary of Results.  Each tab contains a different form of the results of the
delisting analysis. The tabs and the information found on each of these tabs are explained below.
                                              12

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5.4.1   Delisting Results Tab
 The Delisting Results tab is the first screen in the Analysis Results Section of the DRAS. This screen lists
all chemicals whose TCLP and/or Total Waste Concentration exceed the delisting levels as computed by
the risk equations. The first and second columns of the table show the Chemical Names and CAS numbers,
respectively, for chemicals that exceed the delisting levels. The third column identifies the pathway and the
fourth  shows  the  resulting  Maximum Allowable TCLP Concentration (i.e., the limiting  TCLP
concentration). The fifth column shows fas Actual TCLP Concentration of the chemical. The sixth column
shows the Maximum Allowable Total Concentration (i.e., the limiting Total Waste Concentration) of the
chemical and the seventh column shows the Actual Total Concentration of the chemical.

The delisting level is the maximum allowable concentration of a waste constituent in a petitioned waste that
will not exceed the target risk level for that compound. For multi-year standard delistings, each waste
constituent in a petitioned waste must not exceed its delisting level. The delisting level is generated for each
Exceeding Pathway assessed by the DRAS. The DRAS selects a limiting delisting level  for the total value
and the TCLP value  for each waste
constituent.  The delisting level  for
the total waste constituent value is
called the Maximum Allowable Total
Concentration.  The delisting level
for the TCLP waste constituent value
is  called the  Maximum Allowable
TCLP Concentration.

What  are the  various exposure
pathways assessed in DRAS?

The  DRAS assesses the  potential
adverse effects associated with the
release and subsequent exposure of
waste constituents in a petitioned waste from a WMU. Exposure may occur through contact with various
contaminated media.  The following exposure pathways (Exceeding Pathways) are assessed in the DRAS.

For releases to ground water:

•      ingestion of contaminated ground water
•      dermal absorption while bathing in contaminated ground water
•      inhalation of volatile constituents emitted from contaminated ground water during showering

Deftsting Results f Chemical-Specific Results Cumulative Results Summary of Results
Petition ID Facility Name
TEST-98-001 JHydroGeoLogic, Inc.
CAS Exceeding AII.....^^^^! p Actual TCLP Aii^^fr^t.j Actaal Total
7440382 GW 4.13E-Q1 1 75E+00 N/A 5 QQE+04
Al5etUE listen
7440382 SWAt-utp IT .'A 1 7"E+OQ 3 40E-01 5 OOE+04
Aiseiuc Ecolo-icial
7440382 EWChr^juc H.'A 1 75E+00 1 jOE-01 5 OOE+04
7440382 Soil H.'A 1 75E+00 1 40E-03 5 OOE+04
<'7('£>i &r WA L93B-0! L20S+07 L2SE+Q7
Italics signify that the concentration for that constituent is a detection imit not a measured concentration.
The values in the "Maximum Allowable TCLP Concentration" and the "Maximum Allowable Total Concentration" are the maximum wa
concenhations which can be permitted withoul exceeding the defined cancer risk or hazard quoisenl levels set for the Delisting Level
given waste constituent. See Help for additional infofmation on the allowable tisklevei used to calculate a wasle constituent's "Delisti
Levels" (T CLP and Total).
3
le
3
f GaBack il PrintReports I Help SaveAnalysis j

For releases to surface pathways:

•      ingestion of contaminated surface water
•      ingestion of contaminated fish
•      ingestion of contaminated soil
•      inhalation of contaminated air
How are the delisting levels calculated?
                                              13

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For all standard multi-year delistings, the target risk level is used to calculate the delisting levels for a waste
constituent.  The target risk level for carcinogens is set at 10~5 and for noncarcinogens the target is set at a
hazard quotient of 0.1. Additional technical information on risk levels is available in Chapter 4 of the DTSD.

What role does the 10,000 ppm delisting ceiling play in the delisting analysis?

Using standard chronic risk assessment algorithms, the DRASgenerates delisting levels, which are protective
of exposure to the receptor for the defined exposure pathways. However, the delisting levels generated in
this manner for certain constituents can be extremely high in absolute concentrations (approaching that of
a pure compound). Under certain circumstances, the generated delisting levels may not be the appropriate
waste management concentration limits for the prescribed WMU. For these reasons, there is a need to assess
the  reasonableness of high concentration limits developed from the chronic risk models, particularly for
liquid and volatile organics.  The issue is  a general policy concern for all chronic risk  analyses, and
resolution is beyond the scope of the DRAS or this user guide. However, the DRAS has been programmed
to identify total waste constituents predicted at nominally high concentration levels (10,000 ppm or 1% by
weight or greater).  Delisting levels in excess of 10,000 ppm are highlighted in red text on the "Results"
screen of the DRAS. When the DRAS computes a delisting level that exceeds 10,000 ppm,  the petitioned
waste containing constituents in excess of this value will be reviewed on a case-by-case basis. In the DRAS,
the  delisting levels (exit values) are not altered to reflect this ceiling review. The DRAS provides the user
with the calculated delisting level, based on the waste constituent concentrations, the waste volume and the
risk level selected by the user.

How are soil saturation values, Maximum Contaminant Level (MCL) values, and TC Rule regulatory
values used?

Soil saturation  values (see Appendix A of the DTSD) represent the contaminant concentration in soil at
which the adsorptive limits of the soil particles and the solubility limits of the available soil moisture have
been reached.  Above this concentration, pure or free-phase compound is expected in the soil. If the soil
saturation limit is exceeded, formation of a nonaqueous phase liquid (NAPL) plume is possible for the
organic constituents. If NAPLs are present, significant contaminant migration may occur within this NAPL
phase, which is not accounted for in the EPA Composite Model for Leachate Migration with Transformation
Products (EPACMTP) fate and transport model.  Hence, calculated delisting values may not be accurate.

The DRAS compares soil saturation values with calculated delisting levels and notifies the user when a waste
constituent's total delisting level  exceeds its soil saturation value.  When the DRAS calculates a delisting
level greater than the calculated soil saturation, the delisting manager should consider setting the delisting
level equal to the soil  saturation.
In addition to calculating a waste constituent's delisting level for the ingestion of ground water based on the
pre-selected target risk level, the DRAS calculates the waste constituent's delisting level for the ingestion
of ground water where the ground water concentration is set at the constituent's MCL. In some cases, the
waste constituent's ground water ingestion delisting level based on the MCL will be less conservative than
that calculated according to the selected risk level. When the DRAS indicates that ground water ingestion
is the limiting ground water pathway, the user has the option of considering either of the ground water
ingestion  pathway delisting levels: the risk-based Maximum Allowable  TCLP Concentration or the
Maximum Allowable TCLP Based on MCL.

The TC Rule was promulgated in March, 1990 (55 FR 11798). This rule established regulatory levels for
40 nonhydrolyzing or mildly hydrolyzing constituents. A solid waste exhibits the toxicity characteristic if,
using the  TCLP, the extract from a representative sample contains any of the 40  TC Rule constituents at


                                               14

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concentrations equal to or greater than the regulatory level (published at 40 CFR §261.24(a) and given in
Table 4-1 oftheDTSD). These regulatory levels are not to be exceeded.  Because the DRAS generates exit
levels using different modeling and exposure scenarios, delisting levels for these 40 constituents may be
above or below the TC Rule regulatory levels.  Therefore, the DRAS compares a waste constituent's delisting
level forthe TCLPwaste constituent concentration, called the Maximum Allowable TCLP Concentration,
with the waste constituent's TC Rule regulatory level.  If the Maximum Allowable TCLP Concentration
exceeds the TC Rule regulatory level, the DRAS notifies the user of the TC Rule exceedance.

How are dioxin cogeners handled in the DRAS1

U.S. EPA Region 6 recommends that a risk assessment for all dioxin cogeners be completed by calculating
the Toxicity Equivalent Quotient (TEQ) for 2,3,7,8-tetrachlorodibenzo(p)dioxin (TCDD).  The TEQ is
calculated by converting the dioxin congener concentrations to a 2,3,7,8-TCDD dioxin concentration using
Toxicity Equivalent Factors (TEF) for all 17 dioxin cogeners. To  assess the risk to a mixture of dioxin
cogeners reported in a delisting petition using the TEF procedure:  1) review the delisting petition for all
polychlorinated  dibenzo(p)dioxin   (PCDD) and  polychlorinated  dibenzofuran (PCDF)  analytical
determinations from the sample; 2) multiply the congener concentrations in the sample by the TEFs listed
in Section 4.2.5 of the DTSD to express the concentration in terms of 2,3,7,8-TCDD TEQs; 3) sum the
products calculated in Step 2 to obtain the total TEQ for the delisting sample and; 4) use the delisting sample
total TEQ as the sample concentration of 2,3,7,8-TCDD to be entered into the DRAS under the name
TCDDioxin, 2,3,7,8- or CAS number 1746016.
5.4.2   Chemical-Specific Results Tab

Chemical-Specific Results is the second interface screen in the Analysis Results section of the DRAS. The
user is provided with a chemical-by-chemical summary of the risk and hazard analysis of each waste
constituent entered into the DRAS.  The  chemical-specific summary includes the Allowable Total
Concentration andAllowable TCLP Concentration for each Exposure Pathway and the actual carcinogenic
risk  or noncarcinogenic hazard
quotient predicted from exposure
to each Exposure Pathway.  The
section   also   presents   the
Maximum  Allowable  Total
Concentration   and  Maximum
Allowable  TCLP Concentration
for a given waste constituent. The
chemical name and CAS number
are shown at the top along with
information to tell the user if the
risk   assessment is   based  on
carcinogenic  effects   or
noncarcinogenic effects.  The two
tables  show   each  Exposure

Delisiing Results ] : Chemical; Specific Results] f Cumulative Result
Summary of Results
Petition ID , . Facility Name
Test-98-001 '' ' j ;';;" ' ;; j HydroGeoLogic, Inc.
Chemical-Specific Results for: CAS Number Carcmogen/Noncarcinogen
(Benzene J71432 jCatcnoge
TCLP Concentration |mg/L] h GQE+03
Exposure Pathway Pathway Allowable TCLP Cone. (rng/L) Actual Risk
GW Ingestion Pathway 4.54E-01 1.72E-02
GW Adult Derma! Pathway 3.34E+QQ 2.54E-03
GW Child Dermal Pathway 9.04E+OQ 1.11E-03
GW Inhalation Pathway 1.20E-01 4.40E-03
Air Volatile Inhalation Pathway 1 .78E+OQ 4.88E-04
Total Waste Concentration [my/kg] j-OoE+bs
Exposure Pathway Pathway Allowable Total Cone, (rng/kg] Actual Risk
SW Ingestion Pathway 2 G6E+07 2.83E-05
An Particuiate Pathway 5 12E+07 5.87E-12
Fish Ingestion Pathway 6 38E+06 1.51E-Q4
Soil Ingestion Pathway 2.62E+05 2.70E-02

Maximum Allowable
TCLP Concentration
(the TCLP D dialing Level)
J1.2QE-01
Maximum Allowable
Total Concentration
(the Total Deling Level)
Maximum Allowable
TCLP base on MCL
J9.00E-02
GoBack 1 PrirtFjeporfs j Heip I SaveAnalysis J

Pathway  in  column   1,  the
maximum allowable concentration in column 2, and the actual risk or hazard quotient in column 3 for TCLP
and Total Waste Concentrations.
How do I see the risk assessment for each chemical?
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The user can click on the "Next" and "Previous" buttons to scroll through the list of chemicals and view the
risk assessment that was conducted for each selected chemical.
5.4.3   Cumulative Results Tab

Cumulative Results is the third interface screen in the Analysis Results section of the DRAS.  The
Cumulative Results screen shows the cumulative Groundwater Pathway and Surf ace Pathway risk for each
carcinogenic chemical and the cumulative HI for each noncarcinogenic chemical. If any of these calculations
are based on DL values, the row containing that chemical is shown in italics. These values are then summed
for each chemical to compute the Chemical Cumulative Risk or Chemical Cumulative Hazard Index found
in the last column of the table.  Directly below the  "Carcinogen" results table, two total risk values are
displayed. The first Petitioned Waste Total Risk value does not include any non-detects, whereas the second
Petitioned Waste Total Risk value does include non-detects that were entered by the user.  Likewise, directly
below the "Non-carcinogen" results table is the Petitioned Waste Total Hazard Index, calculated both with
and without the non-detect values.

How are the Risk and HI values calculated?

The Chemical Cumulative Risk value is a measure of the total risk associated with disposal of a carcinogenic
waste constituent. This is computed by summing a waste constituent's carcinogenic risk from each exposure
pathway. Additional technical information on the generation of risk values is available in Chapter 4 of the
DTSD


Delisting Results J Chemical-Specific Results |
Petition ID

iCumujativeJesujli (
Facility Name

Summary of Results

Carcinogens |TEST-98-Oul JH.drc&oLogic, Inc.
r, .... Groundwater Pathway Surface Pathway -., . , n , . „. , •*•(
Chemical Name Cumulative Risk Cumulative Risk Chemical C™lat,ve Risk -j
Arsenic 398E-05 317E+QO 3.17E+00
fMn-Avai 1 SST-Of 3 12E+SG 3 12E+8B
DDT, p,p '• t. G4E-B5 20&*Q1 283E+LT!
TrirhhrnpfhttUtm f1 1 ?-] (TTFt ? R7F-HR 7^1P+m 7"=ilF+niLlJ
Petitioned Waste (without Detection Limits] Total Risk = (7 85E +01
Petitioned Waste (including Detection Limits] Total Risk = J4.23E+Q2
Noncarcinogens
r, .... Groundwater Pathway
Lnemicai Name Cumulative Hazard Index
Cadmium 2.42E-05
1 £#&!&£ ffofa/f / S&F-tZ?
Surface Pathway Cherrn
Cumulative Hazard Index Ha
2.11E+04
al Cumulative
2ard Index
2.11E»04

Petitioned Waste (without Detection Limits] Total Hazard Index
Petitioned Waste (including Detection Limits] Total Hazard Index
Go Back 1 Print Reports 1 Help
_| 5.veAn.Ns|
• |2.11E*04
• |2.14E*04


The Chemical Cumulative Hazard
Index value is a measure of the total
hazard associated with disposal of a
noncarcinogenic waste constituent.
This is computed by  summing a
waste constituent's noncarcinogenic
HI  for each exposure  pathway.
Additional technical information on
the generation of hazard indices is
available in Chapter 4 of the DTSD.

Petitioned   Waste  Total Risk
(without  DLs)  is  calculated  by
summing  the petitioned   waste's
carcinogenic  risk from only those waste constituents whose input TCLP concentration and Total Waste
Concentration were actual measured concentrations (not DLs).

Petitioned Waste Total Risk (including DLs) is calculated by summing the petitioned waste's carcinogenic
risk from all waste constituents. This includes constituents with a measured TCLP concentration and Total
Waste  Concentration, and constituents for which the DL was entered as the concentration.

Petitioned Waste Total Hazard Index (without DLs) is calculated by summing the petitioned waste's
noncarcinogenic hazard from only those waste constituents whose input TCLP concentration and Total
Waste  Concentration were actual measured concentrations (notZ>Z,s).

Petitioned Waste Total Hazard Index (including DLs) is calculated by summing the petitioned waste's
noncarcinogenic hazard from all waste constituents. This  includes constituents with a measured TCLP
concentration and Total Waste Concentration, and constituents for which  the DL was entered as the
                                              16

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concentration.

5.4.4   Summary of Results Tab

Summary of Results is the fourth screen in the Analysis Results section of the DRAS. This screen presents
a summary of the risks and hazards associated with disposal of the petitioned waste.  Also, this screen
identifies  those chemicals whose waste  concentration  exceeds their soil saturation  value  or TC Rule
regulatory level.  This screen repeats the facility and user information provided at the beginning of the
analysis along with the total risks and hazard indices displayed in the Cumulative Results screen. The risk
and HI values are calculated both with and without the non-detect values (DLs).
5.5
PRESENTATION OF RESULTS - REPORTS
Can I print and save the results of the analysis?

The results of the analyses performed with the DRAS can be printed to hard copy or saved electronically as
a file. The report form prints out all of the  WMU parameters, chemical input values, and the results of the
analysis. The user may click on the "Print Reports" button to printthe reports in the Analysis Results section
of the DRAS. The user also has the option to click on the "Print Preview" button to view the report before
printing the reports. The user selects which reports
to print or print preview by clicking on the boxes
beside  the various  reports.  The user may save a
report as an electronic file by clicking the "Print
Preview"  button followed by the "Export" button
(small envelope button). The user may choose which
application to  export the electronic file to under
"Format" and if the file will be saved as a disk file,
a Lotus Notes database file, or sent as an email file
under "Destination."
                                         - Print Reports-
                                          Reports to Print
                                          Copies-
                                                     " Inputs
                                                     ' Limiting Pathways/Concentrations
                                                     Cumulative Risk and Hazard Quotients
                                          Number of copies: J-j
                                                               Print Preview
                                                                           Print
                                                                        Cancel
                                                                                 Page/"Printer Setup
6.0
SUPPORTING INFORMATION
This section presents summary information that is required to perform U.S. EPA Region 6 Delisting risk
assessments, or supporting information that can be accessed.
6.1
JUSTIFICATION AND DOCUMENTATION OF PARAMETER VALUES
All values input to the delisting
risk assessment analyses must be
backed  up   with  supporting
documentation  including   lab
analysis results and  other waste
characterization data.
6.2
U.S. EPA REGION 6
Supporting information  for EPA
Region  6  Delisting includes this
User's Manual and the DTSD  As
Delistinp Results } Chemical-Specific Results
Delisting Results for
(HydroGeoLogic, Jnc
|11 55 Herndon Parkway
JHemdon.VA
Petition ID
|Test-98-OQ1
Performed by
(Tester
Performed on
J1 2/1 7/1 998
Date of Waste
Batch Identification Sample Analysis
| Paint Wassl S tream j 01 /01 ,J1 938
| Cumulative Results f Summary of Results]
Carcinogens
Petitioned Waste Total Cumulative Risk =
Petitioned Waste (ind DLs) Total Cumulative Risk =
Noncarcinogens
Petitioned Waste Total Hazard Index =
Petitioned Waste (ind. DLsj Total Hazard Index =
Chemicals that exceed Soil Saturation Values:
Benzene 71432
Chemicals that exceed TC Rule Values;
Benzene 71432
|518E-Q2
|519E-02
IQ.QQE+QQ
IO.OOE+OO


                                              17

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stated previously in this document, petitioners are directed to the Region 6 RCRA Delisting Program
Guidance Manual for the Petitioner (U.S. EPA; 1996) for additional information necessary to satisfy the
information and documentation requirements of a complete delisting petition.
                                              18

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