0000039

• / - ; • /UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OMlCC O*SOLID WASTt AND CMCffQf NCV AG3PONSI

OSWER Diractiva 9285.7-01C

MEMORANDUM

SUBJECT: Transmittal of Human Haalth Evaluation Manual, Part C:Risk Evaluation of Ramadial Altaryiajftvas.

FROM: Hunry L. Longast II, DiractorOffica of Emargancy andBruca Diamond, DiractoiOffica of Wasta PrograKs 'feftfbrcamant

TO: Ragional Hasta Managamant Division Diractors

Punaoaa

This diractiva transmits tha Risk Assassmant Guidanca forSuparfund, Human Haalth Evaluation Manual, Part C-Risk Evaluationof Ramadial Altarnativaa . Tha guidanca is to ba usad in thafaasibility study and salaction of ramady procass and supplamantstha Human Haalth Evaluation Manual Part A — Basalina RiskAssassmant, and Part B— Davalopmant of Risk-Basad PraliminaryRamadiation Goals.

Saction 121 of CERCLA raquiraa an avaluation of short-tarm andlong-tarm risks associatad with ramadial altarnativas. InSaptambar 1990, a Workgroup was formad to discuss tha davalopmentand usa of this risk information in tha ramady salaction procass.Tha intarim guidanca baing distributad today incorporataa commentson drafts of tha guidanca which vara racaivad from Haadquartars andRagional managamant.Qb-lactiva

firtottd on fl*eyow

risk-based benefits of alternatives, investigates potentialexposures to the communities and remediation workers during theimplementation of the alternative, determines the need forengineering controls to mitigate risks, and assesses the need fora five year review. The guidance will also be useful to those whoseek to evaluate risks of the selected remedy during and after itsimplementation. Part C of the guidance will ensure consistentdevelopment and use of risk information at these important decisionpoints in the Superfund process.Implementation

This document is being distributed as interim guidance pendingreview of the RAGS series by the Science Advisory Board (SAB). Itis our intention to begin updating and consolidating the series inFY 92. At that time, we will incorporate SAB's comments and theresults of ongoing, EPA-sponsored research projects. We alsostrongly urge RPMs and Regional risk assessors to contact theToxics Integration Branch of the Office of Emergency and RemedialResponse (FTS 260-9486) with any suggestions for furtherimprovement.

Attachment

cc: Regional Branch ChiefsRegional Section ChiefsRegional Toxics Integration CoordinatorsWorkgroup Members

Publication 9285.7-01 CDecember 1991

Risk Assessment Guidancefor Superfund:

Volume I —Human Health Evaluation

Manual(Part C, Risk Evaluation of

Alternatives)

Interim

Office of Emergency and Remedial ResponseU.S. Environmental Protection Agency

Washington, DC 20460

NOTICE

The policies set out in this document are intended solely as guidance; they are not final U.S.Environmental Protection Agency (EPA) actions. These policies are not intended, nor can they be reliedupon, to create any rights enforceable by any party in litigation with the United States. EPA officials maydecide to follow the guidance provided in this document, or to act at variance with the guidance, based on ananalysts of specific site circumstances. The Agency also reserves the right to change this guidance at any timewithout public notice.

This guidance is based on policies in the Final Rule of the National Oil and Hazardous SubstancesPollution Contingency Plan (NCP), which was published on March 8, 1990 (55 Federal Register 8666). TheNCP should be considered the authoritative source.

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CONTENTS

Page

NOTICE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , : . . . . . . . . . . . . . . . . . . . . . . i j

EXHIBITS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

DEFINITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v i

ACRONYMS/ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v j i i

ACKNOWLEDGEMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi

PREFACE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xii

1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.1 SCOPE AND OVERVIEW OF PART C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.1.1 Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11.1.2 Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

1.2 RELEVANT STATUTES, REGULATIONS, AND GUIDANCE . . . . . . . . . . . . . . . . . . 6

1.2.1 CERCLA/SARA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61.2.2 NCP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61.23 Other Relevant Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

1.3 LEVEL OF EFFORT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

1.4 IMPORTANCE OF RISK COMMUNICATION . . . . . . . . . . . . . . . . . . : . . . . . . . . . . . . 7

1.5 MANAGEMENT AND DOCUMENTATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

1.6 ORGANIZATION OF THE DOCUMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

2.0 RISK EVALUATION DURING THE FEASIBILITY STUDY . . . . . . . . . . . . . . . . . . . . . . . . 11

2.1 RISK EVALUATION DURING DEVELOPMENT AND SCREENINGOF ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

2.1.1 Consideration of Long-term Human Health Risks . . . . . . . . . . . . . . . . . . . . . . . . 112.1.2 Consideration of Short-term Human Health Risks . . . . . . . . . . . . . . . . . . . . . . . . 11

2.2 RISK EVALUATION DURING DETAILED ANALYSIS OF ALTERNATIVES . . . . . 12

2.2.1 Evaluation of Long-term Human Health Risks for Detailed Analysis . . . . . . . . . . 142.2.2 Evaluation of Short-term Human Health Risks for Detailed Analysis . . . . . . . . . . 15

2.3 CASE STUDIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

3.0 RISK EVALUATION AFTER THE FEASIBILITY STUDY . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

3.1 RISK EVALUATION FOR THE PROPOSED PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . 25

-HI-

CONTENTS (Continued)

Page

3.2 DOCUMENTATION OF RISKS IN THE ROD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

3.3 RISK EVALUATION DURING REMEDIAL DESIGN/REMEDIAL ACTION . . . . . . 25

3.3.1 Risk Evaluation During Remedial Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 263.3.2 Monitoring Short-term Health Risks During Implementation . . . . . . . . . . . . . . . . 263.3.3 Assessing Attainment of Selected Remediation Levels

During Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 263.3.4 Evaluation of Residual Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

3.4 RISK EVALUATION DURING FIVE-YEAR REVIEWS 27

3.4.1 Purpose of Five-year Reviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 273.4.2 Sites That Receive Five-year Reviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 273.4.3 Risk-related Activities During Five-year Reviews . . . . . . . . . . . . . . . . . . . . . . . . . 28

REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

APPENDIX A SELECTED REMEDIATION TECHNOLOGIES AND ASSOCIATEDPOTENTIAL RELEASES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

APPENDIX B QUANTIFYING POTENTIAL RELEASES FROM SELECTEDREMEDIATION TECHNOLOGIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

B.I SOILS HANDLING TECHNOLOGIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

B.2 THERMAL DESTRUCTION TECHNOLOGIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

B.3 SOLIDIFICATION/STABILIZATION TREATMENT TECHNOLOGIES . . . . . . . . . . . 44

B.4 REFERENCES FOR DETERMINING RELEASES RESULTING FROM REMEDIALACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

B.4.1 Various Remedial Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45B.4.2 Soils Handling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45B.4.3 Thermal Destruction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46B.4.4 Stabilization/Solidification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

APPENDIX C SHORT-TERM TOXICITY VALUES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Cl BACKGROUND ON EXPOSURE DURATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

C2 EXISTING SHORT-TERM TOXICITY VALUES . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

C.2.1 Toxicity Values for Assessing Risk of Noncarcinogenic Effects for Short-termExposure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

C.2.2 Specific Carcinogenic Risk Values for Short-term Exposures . . . . . . . . . . . . . . . . 54

APPENDIX D RADIATION REMEDIATION TECHNOLOGIES . . . . . . . . . . . . . . . . . . . . . . . . 57

-iv-

EXHIBITS

Exhibit Page

1-1 RELATIONSHIP OF HUMAN HEALTH EVALUATION TO THECERCLA PROCESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

1-2 SUMMARY OF RISK EVALUATIONS OF REMEDIALALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

1-3 RISK EVALUATION OF REMEDIAL ALTERNATIVES INTHE CERCLA PROCESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

2-1 ILLUSTRATION OF AN EXPOSURE PATHWAY FOR A REMEDIAL ACTION . . . . . . . 17

2-2 ILLUSTRATION OF CUMULATIVE EXPOSURES FROM MULTIPLE RELEASES . . . . . 18

A-l REMEDIATION TECHNOLOGY DESCRIPTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

A-2 REMEDIATION TECHNOLOGIES AND SOME POTENTIALLYSIGNIFICANT RELEASES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

D-l POTENTIAL RELEASES OF RADIOACTIVITY ASSOCIATED WITHRADIATION REMEDIATION TECHNOLOGIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58

D-2 DEGREE OF POTENTIAL SHORT-AND LONG-TERM RISKS ASSOCIATEDWITH RADIATION REMEDIATION TECHNOLOGIES . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

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DEFINITIONS

Term Definition

Applicable or Relevant andAppropriate Requirements(ARARs)

Exposure Pathway

Exposure Point

Exposure Route

Final Remediation Levels

Long-term Risks

Preliminary Remediation Goats(PRGs)

"Applicable" requirements are those clean-up standards, standardsof control, and other substantive environmental protectionrequirements, criteria, or limitations promulgated under federal orstate law that specifically address a hazardous substance, pollutant,contaminant, remedial action, location, or other circumstance at aComprehensive Environmental Response, Compensation, andLiability Act (CERCLA) site. ."Relevant and appropriate"requirements are those clean-up standards which, while not"applicable* at a CERCLA site, address problems or situationssufficiently similar to those encountered at the CERCLA site thattheir use is well-suited to the particular site. ARARs can be action-specific, location-specific, or chemical-specific.

The course a chemical or physical agent takes from a source to anexposed organism. An exposure pathway describes a uniquemechanism by which an individual or population is exposed tochemicals or physical agents at or originating from a site. Eachexposure pathway includes a source or release from a source, anexposure point, and an exposure route. If the exposure point differsfrom the source, a transport/exposure medium (e.g., air) or media(in cases of intermedia transfer) also would be indicated.

A location of potential contact between an organism and a chemicalor physical agent.

The way a chemical or physical agent comes in contact with anorganism (i.e., by ingestioru inhalation, dermal contact).

Chemical-specific clean-up levels that are documented in theRecord of Decision (ROD). They may differ from preliminaryremediation goals (PRGs) because of modifications resulting fromconsideration of various uncertainties, technical and exposurefactors, and all nine selection-of-remedy criteria outlined in theNational Oil and Hazardous Substances Pollution Contingency Plan(NCP).

Risks that remain after remedy implementation is complete (i.e.,residual risks).

Initial clean-up goals that (1) are protective of human health andthe environment and (2) comply with ARARs. They are developedearly in the process based on readily available information and aremodified to reflect results of the baseline risk assessment. Theyalso are used during analysis of remedial alternatives in theremedial investigation/feasibility study (Rl/FS).

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DEFINITIONS (Continued)

Term Definition

Remedial Alternative An action considered in the feasibility study intended to reduce oreliminate significant risks to human health and/or the environmentat a site. A range of remedial alternatives are considered in detailby the FS while the selection of a specific remedial alternative overothers is documented in the ROD.

Remedial Action The selected alternative that is documented in the ROD.

Risk-based Concentrations Concentration levels for individual chemicals that correspond to aspecific cancer risk level (e.g.. 10"6, 10"4) or hazard quotient (HQ)or hazard index (HI) (e.g., less than or equal to I). They aregenerally selected as preliminary or final remediation goals whenARARs are not available.

Short-term Risks Risks that occur during implementation of a remedial alternative.Some "short-term" risks can occur over a period of many years (e.g.,risk associated with air stripper emissions).

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ACRONYMS/ABBREVUTIONS

Acronym/Abbreviation Definition

ACGIH

AIC

APCD

ARARs

ATSDR

CEGL

CERCLA

CFR

ECAO

EEGL

EPA

HEAST

HHEM

HI

HQ

IDLH

IRIS

LOAEt

MCL

MRL

NCP

NIOSH

NOAEL

NRC

American Conference of Governmental Industrial Hygienists

Acute Inhalation Criteria

Air Pollution Control Device

Applicable or Relevant and Appropriate Requirements

Agency for Toxic Substances and Disease Registry

Continuous Exposure Guidance Level

Comprehensive Environmental Response, Compensation, and Liability Act

Code of Federal Regulations

Environmental Criteria and Assessment Office

Emergency Exposure Guidance Level

U.S. Environmental Protection Agency

Health Effects Assessment Summary Tables

Human Health Evaluation Manual

Hazard Index

Hazard Quotient

Immediately Dangerous to Life and Health

Integrated Risk Information System

Lowest-observed-adverse-effect-level

Maximum Contaminant Level

Minimal Risk Level

National Oil and Hazardous Substances Pollution Contingency Plan

National Institute for Occupational Safety and Health

No-observed-adverse-effect-leve!

National Research Council

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ACRONYMS/ABBREVIATIONS (Continued)

Acronym/Abbreviation Definition

ORD

OSHA

PEL

POTW

PPE

PRO

QA;QCRAGSRCRAREL

RfC

RfD

RI/FS

RME

ROD

RPM

RQ

RREL

SARA

SPEGL

TLV-C

TLV-STEL

TLV-TWA

TSC

Office of Research and Development

Occupational Safety and Health Administration

Permissible Exposure Level

Publicly Owned Treatment Works

Personal Protective Equipment

Preliminary Remediation Goal

Quality Assurance/Quality Control

Risk Assessment Guidance for Superfund

Resource Conservation and Recovery Act

Recommended Exposure Level

Reference Concentration

Reference Dose

Remedial investigation/Feasibility Study

Reasonable Maximum Exposure

Record of Decision

Remedial Project Manager

Reportable Quantity

Risk Reduction Engineering Laboratory

Superfund Amendments and Reauthorization Act

Shon-term Public Emergency Guidance Level

Threshold Limit Values - Ceiling

Threshold Limit Values - Shon-term Exposure Limit

Threshold Limit Values - Time-weighted Average

Superfund Health Risk Technical Support Center

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ACRONYMS/ABBREVIATIONS (Continued)

Acronym/Abbreviation Definition

TSCA Toxic Substances Control Act

VOCs Volatile Organic Compounds

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ACKNOWLEDGEMENTS

This manual was developed by the Toxics Integration Branch (TIB) of EPA's Office of Emergency andRemedial "Response, Hazardous Site Evaluation Division. A large number of EPA regional and headquartersmanagers and technical staff (see below) provided valuable input regarding the organization, content, andpolicy implications of the manual throughout its development.

ICF Incorporated provided technical assistance to EPA in the development of this manual, underContract Nos. 68-01-7389,68-W8-0098, and 68-03-3452. S. Cohen and Associates (SC&A) provided assistancein the development of Appendix D, under EPA Contract No. 68-D9-0170.

WORKGROUP

EPA HEADQUARTERS

Office of Emergency and Remedial Response: Rhea Cohen, David Cooper,Steve Golian, Jennifer Suiter, Ed Haulon,James Konz, Tracy Loy, Bruce Means

Office of Radiation Programs: Bob DyerOffice of General Counsel: Larry StarfieldOffice of Policy, Planning, and Evaluation: Pepi LecayoOffice of Waste Programs Enforcement: Steve EllsOffice of Health and Environmental Assessment: Kevin Garrahan

EPA REGIONAL OFFICES

Region 1: Ann-Marie Burke, Jeri WeissRegion 5: Alison Hiltner, Jae Lee,

Andrew PodowsltiRegion 6: Jon RauscherRegion 10: Judi Schwarz, Carol Sweeney

OTHER EPA OFFICES

Risk Reduction Engineering Laboratory: Pat LafornaraOffice of Air Quality Planning and Standards: Fred HauchmanOffice of Health and Environmental Assessment: Pei-Fung Hurst

STATE AGENCIES

Michigan Department of Natural Resources: Chris FlagaNew Jersey Department of Environmental Protection: Linda Cullen

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PREFACE

Risk Assessment Guidance for Superfund: Volume I — Human Health Evaluation Manual(RAGS/HHEM) Part C is one of a three-pan series. Pan A addresses the baseline risk assessment; Part Baddresses the development of risk-based preliminary remediation goals. Part C provides guidance on thehuman health risk evaluations of remedial alternatives that are conducted during the feasibility study, duringselection and documentation of a remedy, and during and after remedy implementation. Part C providesgeneral guidance to assist in site-specific risk evaluations and to maintain flexibility in the analysis anddecision-making process. This guidance does not discuss the evaluation of ecological effects that takes placeduring remedy selection and implementation, nor does it discuss the risk management decisions that arenecessary at a CERCLA site (e.g., selection of final remediation goals). The potential users of Part C arepersons involved in the remedy selection and implementation process, including risk assessors, risk assessmentreviewers, remedial project managers, and other decision-makers.

This manual is being distributed as an interim document to allow for a period of field testing andreview. RAGS/HHEM will be revised in the future, and Parts A, B. and C will be incorporated into a singlefinal guidance document. Additional information for specific subject areas is being developed for inclusionin a later revision. These areas include:

* development of short-term inhalation toricity values;short-term worker health and safety issues; anddetermination of attainment of final remediation goals.

Comments addressing usefulness, changes, and additional areas where guidance is needed should besent to:

U.S. Environmental Protection AgencyToxics Integration Branch (OS-230).Office of Emergency and Remedial Response401 M Street, SWWashington, DC 20460

Telephone: 202-260-9486FAX: 202-260-6852

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CHAPTER 1

INTRODUCTION

This guidance has been developed by the U.S.Environmental Protection Agency (EPA) to assistremedial project managers (RPMs), risk assessors,site engineers, and others in using risk informationat Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA) sitesto both evaluate remedial alternatives during thefeasibility study (FS) and to evaluate the humanhealth risk associated with the selected remedialalternative during and after its implementation.Pan C provides eeneral guidance to assist in si:e-

' sp&Tfic risk evaluations "and to maintain flexibilityin the decision-making process.

Risk assessment is one of many tools thatRPMs use in selecting the best remedy for a site.Other important tools (not addressed in thisguidance) involve the assessments of technicalfeasibility, applicable or relevant and appropriater e q u i r e m e n t s (ARARs), cost, andimplementabiUty.

This guidance is the third part (Part C) in theseries Risk Assessment Guidance for Superfund:Volume 1 — Human Health Evaluation Manual(RAGS/HHEM). Pan A of this guidance (EPA1989g) describes how to conduct a site-specificbaseline risk assessment; the information in Pan Ais necessary backcround for Part C Part B (EPA1991c) provides guidance for calculating risk-basedconcentrations that may be used, along withARARs and other information, to developpreliminary remediation goals (PRGs) duringproject scoping. PRGs (and final remediationlevels set in the Record of Decision [ROD)) canbe used throughout the analyses in Part C to assistin evaluating the human health risks of remedialalternatives. Exhibit 1-1 illustrates the majorcorrespondence of RAGS/HHEM activities withthe steps in the CERCLA remedial process.

The steps for conducting a risk evaluation ofremedial alternatives are discussed in general termsin Chapters 2 and 3; more detailed guidance forconducting short-term evaluations is provided inAppendices A through D. (See the box in the nextcolumn for a description of how the terms short-

SHORT-TERM RISK VS. LONG-TERM RISK

For the purposes of this guidance, short-termrisks are those that occur during implementation ofa remedial alternative. Some "short-term" risks canoccur over a period of many years (e.g., riskassociated with air stripper emissions). In contrast,long-term risks are those that remain after remedyimplementation Is complete (i.e., residual risks).

term risk and long-term risk differ in thisguidance.) The remainder of this chapter:

* presents the scope and an overview of Part C;

* discusses the statutes, regulations, andguidance relevant to the evaluation ofremedial alternatives;

* describes appropriate levels of effort for riskevaluations of remedial alternatives;

* discusses the importance of r iskcommunication;

* addresses the role of the RPM and the needfor documentation; and

* presents the organization of the remainder ofthis document

1.1 SCOPE AND OVERVIEW OFPARTC

L.l.1 SCOPE

As discussed in Section 1.2 below, some of thenine criteria that are described in the National Oiland Hazardous Substances Pollution ContingencyPlan (NCP) and that are used to evaluate remedialalternatives during the remedial investigation/feasibility study (Rl/FS), involve a direct use ofrisk-related information. Several aspects of thesecriteria (e.g., short-term risks to workers and

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EXHIBIT 1-1

RELATIONSHIP OF THE HUMAN HEALTH EVALUATIONTO THE CERCLA PROCESS

CERCLA REMEDIAL PROCESS

Scoping

— •*

RemedialInvestigation

FeasibilityStudy

Remedy Selectionand Record of

DecisionRemedial Design/Remedial Action — -^ Deletion/

five-year Review

HUMAN HEALTH EVALUATION MANUAL

PART ABaseline Risk Assessment

PARTBmeat of Risk-batedDevek

Preliminary Remediation Goals

PARTCRisk Evaluation of Remedial Alternatives

-2-

surrounding community, long-term effectiveness)are discussed in detail in this guidance. Othercriteria that do not directly involve health risk(e.g., implementability. cost) — with the exceptionof community acceptance — are mentioned brieflybut are not discussed in detail.

Remedial alternatives, in addition to beingevaluated for the degree to which they protecthuman health, are evaluated for their potential toprotect ecological receptors. RAGS/HHEMPart C does not address ecological risk assessment(see the next box). However, ecological guidancespecific to evaluating remedial alternatives in theCERCLA program will be developed followingfinalization of Agency guidance on ecological riskassessment.

EVALUATING ECOLOGICAL EFFECTS OFREMEDIAL ALTERNATIVES

Remedial actions, by their nature, can alteror destroy aquatic and terrestrial habitat Thispotential for destruction or alteration of habitatand subsequent consequences must be evaluatedso that it can be considered during the selection ofa remedial alternative and during itsimplementation.

This document does not address theevaluation of ecological risks. Future guidance forecological evaluations is planned, however. Atpresent, ecological evaluations should be based onthe best professional judgment of experiencedecologists and/or aquatic or environmentallexicologists.

The guidance in this document applies to sitescontaminated with non-radioactive hazardoussubstances and those contaminated withradionuclides. Appendix D provides additionalguidance specific to radionuclide sites.

Note that this guidance is limited to the use ofrisk assessment in evaluating remedial alternatives.Part C does not provide guidance on the riskmanacement decisions that must be made whenevaluating alternatives and selecting a remedy (e.g.,balancing of the nine NCP criteria, selection offinal remediation goals and levels) or engineeringjudgments that affect the evaluation of alternatives(e.g., determining whether an alternative is likelyto achieve remediation goals). These issues are

addressed in other guidance or in guidance tha icurrently is being developed,

1.1.2 OVERVIEW

The process of evaluating remedial alternativesbegins in the development and screening stage ofthe FS and extends into the detailed analysis stage.The major goal for the risk evaluation during thesesteps is to provide decision-makers with specificinformation that they may need in choosing amongalternatives. Additional risk evaluations may needto be conducted during the proposed plan, duringthe design and implementation of the remedy, andafter the remedy is complete (e.g., during "five-yearreviews"). These activities are discussed below andthroughout this guidance.

Exhibit 1-2 summai izes the levels of effort andpurposes of the risk evaluations of remedialalternatives, while Exhibit 1-3 illustrates whenthese activities take place within the context of theCERCLA remedial process.

Identification and Screening of Technologiesand Alternatives. During this stage, a range ofremedial alternatives is identified, if necessary, andeach alternative is evaluated with respect toeffectiveness, implemeniability, and cost. Thisprocess may consist of two steps: (1) identificationand screening of technologies and (2) developmentand screening of alternatives. These steps areoften combined into a single step (as reflected inthis guidance). Those alternatives that are clearlyunfavorable relative to other alternatives in termsof effectiveness (e.g., very high perceived risk) orimplementability, or that are grossly excessive incost are dropped from consideration after thisscreening. Pan of the evaluation of effectivenessinvolves human health risk (e.g., risks to thecommunity and remediation workers), and Chapter2 of this document provides guidance on evaluatingthese factors. RAGS/HHEM Pan C does notdiscuss evaluating factors such as implementabilityand cost

Detailed Analysis of Alternatives. During thedetailed analysis stage, alternatives are evaluatedaccording to each of the nine NCP evaluationcriteria, and then are compared to each other.Both long-term effectiveness (i.e., residual risk)and slum-term effectiveness (i.e., risk to thecommunity and remediation workers duringremedy implementation) are evaluated during thedetailed analysis. Chapter 2 and Appendices A

EXHIBIT 1-2

SUMMARY OF RISK EVALUATIONS OF REMEDIAL ALTERNATIVES

STACK

. Screening ofAlternatives(Sect km 2.1)

Deluded Annlysbof Alternative*

(Section 2.2)

I'roposed Plan(Section 3.1)

Record of Decision(Section 3.2)

Kenivriinl Design(Section 3.3)

Remedial Action(Section 3.3)

Five-year Review(Section 3.4)

LEVEL OF EFFORT"

Short-termRisk*

Qualitative

Qualitative orQuantitative*

Qualitative orQuant native'

Qualitative orQuantitative4

' Qualitative orQuantitative'

Quantitative

Generally notapplicable

l»n|»-lermRisk

Qualitative

Qualitative orQuantitative'

Qualitative orQuantitative*

Qnalitntivc orQuant iiativc'

Qualitative orQuantitative*

Quantitative

Quantitative

PRIMARY PURPOSE OF RISK EVALUATION*

Short-term Risk*

Identify (and eliminate from consideration)alternatives with clearly unacceptable short-termrisks.

l-valuitic shorl-lcrm risks of each alternative locommuniiy and on-sitc remediation workersduring implcmcniiiiion so thai these risks c;m Ix:compared among alternatives.

Refine previous analyse*, as needed, based onnewly developed information.

Document short -term risks that may occurduring remetty implenKniaiion.

Kclinc previous analyses, as needed, ;indidentify need for engineering controls or othermeasures to mitigate risks.

liasurc protection of workers and community bymonitoring emissions or exposureconcentrations, as needed.

Generally not applicable.

I.on|»-lerm Risk

Identify (and eliminate from consideration)alternatives with clearly unacceptable long-term risks.

Itviiluaic long-term (rcsiduiil) risk ol 'each alierniiiivcand its ability to provide continued proicciion overtime so that these risks can he compared amongjtliernaiivcs.

Uefinc previous analyses, a.s neeilcil. leased on newlydeveloped information.

Document risks that may remain alter com pie nun olremedy and determine need for hve-ycar reviews.

Kefine previous analyses, as needed, and identifyneed for engineering controls or other measures tomitigate risks.

Uvaluate whether remediation levels specified inROD have been attained and evaluate residual riskafter completion of remedy to ensure proieeiivencss.

Confirm that remedy (including any engineering orinstitutional controls) remains operational andfunctional and evaluate whether clean-up standardsarc still protective.

J Level ol'effort (i.e., qualitative or quantitative) refers only lo (he level of risk evaluation that is generally expected. Levels other than those presented here, orcombinations of levels, are possible. See the main text of this document for additional discussion on level of effort.b Purpose presented in this exhibit for each stage is only the primary purpose; other purposes may exist. See ihe main text of this document lor additional information.c Short-term risk refers to risks thai occur during remedy implement at ion.d Text hox in Section 2.2 lists considerations for deciding whether a qualitative or quantitative risk evaluation is needed lor these stages

EXHIBIT 1-3

RISK EVALUATION OF REMEDIAL ALTERNATIVES IN THECERCLA PROCESS

STAGES IN REMEDIATION

RemedialInvestigation

FeasibilityStudy

Selection ofRemedy

Remedial Design/Remedial Action

Deletion/Five-year Review

STAGES IN EVALUATING REMEDIAL ALTERNATIVES

Evaluate RisksDuring Screening

and DetailedAnalysis of

Alternatives

Develop ProposedPlan and

Document Risksof Alternatives

in Record of .Decision

Evaluate RisksDuring RemedialDesign/Rental

Actior

RevisitProtectivcness

Evaluate Attainment ofFinal Goals andResidual Risk

through D of this document provide guidance onthe evaluation of the risk-related aspects of long-term effectiveness (residual risk and permanence),and shon-ierm effectiveness. (As with thescreening of alternatives, Chapter 2 generally doesnot discuss evaluation of the other criteria, whichdo not directly involve human health riskconsiderations.) The resulting risk information isincorporated into the overall detailed analysisprocess described in the Guidance for ConductingRemedial Investigations and Feasibility StudiesUnder CERCLA (RI/FS Guidance; EPA 1988c).

Proposed Plan and ROD. Risk evaluations aregenerally conducted during the development of theproposed plan and ROD only when newinformation concerning risks of the remedialalternatives is generated. Chapter 3 providesguidance on the evaluation of risks for theproposed plan and ROD stage.

Remedial Design/Remedial Action (RD/RA).Risk-related evaluations may also be conducted forsome sites during implementation of the selectedremedy. These activities, discussed briefly inChapter 3, include: (1) refining risk evaluations asnecessary when designing the remedy;(2) monitoring potential short-term health impactson the community and workers; (3) assessingattainment of final remediation levels selected inthe ROD; and (4) evaluating residual risk.

Five-year Review. Under the NCP, five-yearreviews are required for sites as long as hazardoussubstances remain onsite above levels that allowunlimited use and unrestricted exposure, and arealso conducted as a matter of policy for long-termremedial action sites even if no hazardoussubstances are expected to remain after completionof the action. Chapter 3 briefly addresses theconsideration of risk during five-year reviews.

1.2 RELEVANT STATUTES,REGULATIONS, ANDGUIDANCE

As discussed in RAGS/HHEM Part A, there Isa hierarchy of requirements and guidance inCERCLA, beginning with the laws enacted byCongress, followed by the regulations, and then theguidance developed by EPA. This sectionaddresses this hierarchy within the context of therisk evaluation of remedial alternatives.

L.2.1 CERCLA/SARA

CERCLA, commonly called SuperfunU, wasenacted by Congress in 1980 in response to thedangers posed by sudden or otherwise uncontrolledreleases of hazardous substances, pollutants, orcontaminants into the environment. TheSuperfund Amendments and Reauthorization Act(SARA) was enacted in 1986. (All references toCERCLA in this guidance should be interpreted as"CERCLA as amended by SARA.")

Section 121 of CERCLA requires thatremedies be protective of human health and theenvironment, satisfy ARARs, be cost-effective, andutilize permanent solutions and alternativetreatment technologies to the maximum extentpracticable. Section 121(c) of CERCLA requiresa periodic review of remedial actions, at least everyfive years after initiation, for as long as hazardoussubstances that may pose a threat to human healthor the environment remain at the site. Theinformation in this manual provides guidance forevaluating the protectiveness of remedialalternatives at a site in terms of the human health-related aspects of these CERCLA requirements.Some considerations include protectiveness,effectiveness in terms of risk reduction, and degreeof hazard for substances remaining at the site.

1.2.2 NCP

The NCP is the main set of regulationsdeveloped by EPA to implement CERCLA. Themost recent NCP was published on March 8, 1990(55 Federal Register 8666-5865) and is codified at40 Code of Federal Regulations (CFR) Part 300.Section 300.430(e)(l) of the NCP describes a two-stage evaluation of remedial alternatives: ascreening evaluation of a range of alternatives, ifnecessary, followed by a detailed analysis of themost promising alternatives. The NCP alsodescribes activities that follow selection andimplementation of the selected remedialalternative,

_' Screening. NCP section 300.430(e)(7)indicates that, if necessary and to the extentsufficient information is available, alternativesshould be screened out if determined to beineffective, not implementable, or grossly excessivein cost Some aspects of effectiveness involveconsiderations of human health risk and arediscussed in this guidance.

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Detailed Analysis. The NCP establishes ninecriteria in section 300.430(e)(9)(iii) to use inevaluating alternatives in detail and in selecting aremedy. Parts of three of these criteria — overallprotection of human health and the environment,long-term effectiveness and permanence, and short-term effectiveness — directly relate to risks andtherefore are the focus of this guidance. Theactual selection of a remedy for any given siteultimately is based on consideration of the ninecriteria. This guidance also discusses theimportance of risk communication to thecommunity as it relates to the criterion ofcommunity acceptance.

Five-year Reviews. NCP section300.430(f)(4)(ii) provides that if a remedialalternative is selected that results in hazardoussubstances (or pollutants or contaminant)remaining at the site above levels that allow forunrestricted exposure and unlimited use, suchremedy should be reviewed at least every five yearsafter initiation of the selected remedial alternative.

1.2 J OTHER RELEVANT GUIDANCE

Three CERCLA program documents areimportant background for the guidance presentedin this document — RAGS/HHEM Parts A and B(EPA 1989g; EPA 1991c), and the RI7FS Guidance(EPA 1988c). Parts A and B provide guidance onconducting a baseline risk assessment and ondeveloping risk-based concentrations, respectively,that should be used in evaluating remedialalternatives. The activities conducted during a riskevaluation of remedial alternatives are somewhatsimilar to the activities conducted during a baselinerisk assessment (Chapter 2 discusses in moredetail the similarities and differences.) The RI/FSGuidance describes the major activities andanalyses that are conducted during the RI/FS. Seethe references at the end of this document forother relevant background guidance,

13 LEVEL OF EFFORT

The level of effort for risk evaluations ofremedial alternatives depends primarily on the site-specific questions that must be answered in orderto select and implement a remedy. In addition,site-specific factors such as the complexity of thesite, the number of alternatives considered for thesite, the available resources, and the amount ofavailable data may affect the level of effort. Inmost cases, a qualitative rather than a detailed

quantitative evaluation of both long-term andshort-term risks is all that is needed to select themost appropriate alternative. A quantitative riskevaluation of remedial alternatives will not need tobe conducted for all sites. In all cases, the baselinerisk assessment provides much of the risk-relatedinformation needed for the detailed analysis ofalternatives, especially for those alternatives thatinvolve limited or no action.

For many sites, the risk evaluations ofremedial alternatives during the FS are conductedin a qualitative manner. That is, the riskevaluations during both the screening and detailedanalysis stages for these sites will not be at allquantitative. At other sites, a more quantitativeanalysis of the long-term and/or short-term risksassociated with the remedial alternatives may beneeded during the detailed analysis. In thesesituations, the risk evaluation generally needs toincorporate more site-specific information.

A guiding principle is that the risk evaluationshould be tailored to provide the RPM withspecific information that he or she needs forsupporting the selection or design of a remedy(e.g., the relative risks associated with alternatives,the alternatives that best meet the remediationgoals). Because of the differences in informationneeds and available data for sites, in the complexityof sites, and in available methods, models, andresources for evaluation, all of the components ofthis guidance will not be applicable to all sites.

Chapter 2 provides some additional factors toconsider when deciding on the level of effort touse for the risk evaluation of remedial alternatives.

1.4 IMPORTANCE OF RISKCOMMUNICATION

As noted earlier, while overall protection ofhuman health and the environment is one of thethreshold criteria established by the NCP for use inevaluating alternatives and selecting a remedy.community acceptance of the remedy is amodifying criterion (NCP section 300.430(e)(9)(iii)). The CERCLA program encourages andpromotes public participation during all phases ofthe decision-making process at CERCLA sitesJust as risk information is used by RPMs and otherEPA staff to assist in evaluation of remedialalternatives during the FS and to evaluate theselected remedial alternative during and after its

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implementation, risk information also will beemployed by the public in their acceptance of aselected remedy. Good communication of the risksof the remedy to the public is crucial to thecommunity's acceptance of the remedy.

There is no single procedure for good riskcommunication. The actual mechanism used andthe messages delivered will vary from site to siteand will depend upon the public, their level ofconcern, the complexity of the site, thecontaminants of concern, and the proposedremedial alternative. RPMs are encouraged towork with the risk assessor and communityrelations coordinator for the site to develop theappropriate means to communicate risks from theremedial alternative or any residual risks. RPMsshould consider using fact sheets, public meetings,and the release of draft documents or "riskcommunication" summaries as vehicles for riskcommunication. Community Relations inSuperfund; A Handbook (EPA 1988a) offersguidance on planning and conducting CERCLAcommunity relations activities.

Regardless of the vehicles chosen for riskcommunication, the following rules, from SevenCardinal Rules of Risk Communication (EPA1988f), should be kept in mind.

• Accept and involve the public as a legitimatepartner.

• Plan carefully and evaluate your efforts.

• Listen to the public's specific concerns.

• Be honest, frank, and open.

• Coordinate and collaborate with other crediblesources.

• Meet the needs of the media.

• Speak clearly and with compassion.

As provided under the NCP, riskcommunication, public participation, andcommunity relations at CERCLA sites begin wellbefore the remedy selection phase. This isimportant, as communities near CERCLA sitesmay begin with a degree of outrage that must beaddressed before effective communication canbegin. Community relations, public involvement,and good risk communication continue throughout

the RI/FS process. A well-informed public will bebetter able to comment on — and provide input to• technical decisions. Establishing credibilitythrough community relations, public participation,and effective risk communication practices early inthe CERCLA process leads to greater communityacceptance of the selected remedy.

1.5 MANAGEMENT ANDDOCUMENTATION

One role of an RPM in the risk evaluation ofremedial alternatives is to make risk managementdecisions. The RPM must have a comprehensiveunderstanding of the risk evaluation in order tomake these decisions. The first box on the nextpage provides questions that RPMs and otherdecision-makers should ask about the risks ofremedial alternatives at their sites. The secondbox provides guidance on where to document theevaluations addressed in RAGS/HHEM Part C

1.6 ORGANIZATION OF THEDOCUMENT

The remainder of this guidance is organizedinto two additional chapters and four appendices,as follows:

• Chapter 2: Risk Evaluation During theFeasibility Study;

• Chapter 3: Risk Evaluation After theFeasibility Study;

• Appendix A: Selected RemediationTechnologies and Associated PotentialReleases;

• Appendix B: Guidance for QuantifyingPotential Releases from Selected RemediationTechnologies;

• Appendix C Short-term Toxicity Values; and

• * Appendix D: Radiation RemediationTechnologies.

In addition, several boxes, such as those below,provide useful information. A second kind of box,a "shadow" box, provides case studies. These boxesare presented at the end of Chapter 2.

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QUESTIONS RPMs SHOULD ASK ABOUT HUMAN HEALTH RISKS OF REMEDIAL ALTERNATIVES

• Which technologies can readily achieve all preliminary remediation goals (PRO*) in a given medium? Whatuncertainties are involved in this determination?

• Which alternatives will clearly not address the significant human exposure pathways identified in the baseline riskassessment?

• Are the expected residual risks or short-term nsks from one alternative significantly different from another?

• What other risk-based benefits (e.g., shorter time to achieving goals) are realized by. selecting one alternative overanother?

• Will implementation of specific technologies create new chemicals of concern or new significant exposures or risksfor the surrounding community?

• Is there a need for engineering controls or other measures to mitigate risks during implementation? Are suchcontrols available? How reliable are these controls?

• Does the remedial alternative result in hazardous substances remaining at the site such that a five-year review orreviews would be required?

DOCUMENTATION OF RISK EVALUATIONS

The risk evaluation conducted during the development and screening of alternatives (Section 2.1) and during thedetailed analysis of alternatives (Section 22) should be documented in the FS.

• The proposed plan (Section 3.1) should contain a summary of the risk evaluations for the alternatives, includingany new risk information identified during development of the proposed plan.

The ROD (Section 3.2) should contain the results of the risk evaluations of the alternatives and the preferredalternative, including any results developed since the proposed plan.

• Any significant changes identified during RD/RA (Section 3 J) in the risk evaluations should be documented (e.g.,in a memorandum).

• Each five-year review (Section 3.4) should contain a statement on proteaiveness and, if necessary, a recalculationof risk and/or a new risk assessment

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CHAPTER 2RISK EVALUATION DURING

THE FEASIBILITY STUDY

The FS generally is a two-step process ofevaluating remedial alternatives: (1) screening, ifnecessary, and (2) a more detailed analysis forthose alternatives thai pass the screening. TheRI/FS Guidance provides information onconducting the FS and describes all of theevaluations that are performed. Some of theseevaluations pertain to human health risk, and theguidance in this chapter assists in theseevaluations. (Ecological effects of remedialalternatives — not discussed in RAGS/HHEMPan C — also must be considered during the FS.)

2.1 RISK EVALUATION DURINGDEVELOPMENT ANDSCREENING OFALTERNATIVES

The overall objective of the development andscreening of alternatives is to identify anappropriate range of waste management options,some of which will be analyzed more fully in thedetailed analysis phase. This process usually takesplace relatively early in the RI/FS process, duringproject scoping (before the baseline riskassessment is completed).

The NCP specifies that the long-term andshort-term aspects of three criteria —effectiveness,implementability, and cost — should be used toguide the development and screening of remedialalternatives. At screening, those alternatives thatare clearly unacceptable in terms of effectivenessor implementability or are grossly excessive in costmay be eliminated from further consideration.

Consideration of effectiveness involvesevaluating the long-term and short-term humanhealth risks — among other factors — associatedwith a remedial alternative. The criteria ofimplementability and cost are not related to riskand, therefore, are not discussed in this document.

2.1.1 CONSIDERATION OF LONG-TERMHUMAN HEALTH RISKS

The long-term human health risks associatedwith a remedial alternative are those risks that willremain after the remedy is complete (i.e., residualrisks). Evaluating long-term risks might ideallyinclude an assessment of the risks associated withtreatment residuals and untreated wastes (for atreatment-based remedy), or an evaluation of theremedy's ability to provide protectiveness over lime(for a containment-based remedy). This approachmight simply involve comparing estimates of thefinal concentrations that a remedy is expected toachieve in a medium with the PRGs for thosechemicals in that medium. At the screening stage,however, this evaluation typically is based onprofessional judgment and the experience of theCERCLA program staff. Quantifying residual risksduring screening generally is not necessary. Forexample, a technology may be evaluated duringscreening for its potential to treat the classes — ortreatabiliry groups — of chemicals present at thesite (e.g., volatile organic, halogenaied organics,non-volatile metals) rather than its ability to meetchemical-specific PRGs. See Section 2.2.1 foradditional information on long-term risksassociated with remedial alternatives.

2.1.2 CONSIDERATION OF SHORT-TERMHUMAN HEALTH RISKS

The short-term human health risks associatedwith a remedial alternative are those risks thatoccur during implementation of the remedialalternative (e.g., risks associated with emissionsfrom an onsite air stripper). Because someremedies may take many years to complete, some"short-term" risks may actually occur over a periodof many years. Populations that may be exposed tochemicals during remedy implementation include:(1) people who live and work in the vicinity of thesite and (2) workers who are involved in siteremediation. As with the consideration of long-term risks, this evaluation is based primarily on

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many simplifying assumptions and on professionaljudgment at the screening stage and is intended toidentify alternatives with clearly unacceptableshort-term risks. Sec Section 2.2.2 and AppendicesA and D for additional information on evaluatingalternatives for short-term risks during screeningand development of alternatives.

2.2 RISK EVALUATION DURINGDETAILED ANALYSIS OFALTERNATIVES

The overall objective of the detailed analysis ofalternatives is to obtain and present theinformation that is needed for decision-makers toselect a remedial alternative for a site. Thisdetailed analysis usually takes place during thelater stages of the Rl/FS process (i.e., near the endof or after the baseline risk assessment, whenPRGs may have been modified). As discussedpreviously, two of the balancing criteria assessedduring the detailed evaluation — long-termeffectiveness and short-term effectiveness—involvean evaluation of risk. In addition, these criteriaare considered in evaluating the criterion of overallprotection of human health and the environment

The risk evaluations of remedial alternativesinvolve the same general steps as the baseline riskassessment* exposure assessment, toritityassessment, and risk characterization. The box onthis page discusses the connection between thebaseline risk assessment and the risk evaluations ofremedial alternatives.

The guidance provided in this section assists inassembling and using available site-specificinformation for the purpose of completing thedetailed analysis of remedial alternatives,specifically the evaluation of criteria that pertain tohuman health risks. The box on the next page listsseveral sources of information that can be used inthe risk evaluations that are conducted during theRl/FS. The box on page 14 addresses the questionof whether a quantitative evaluation is needed.The case studies at the end of this chapter provideexamples of a qualitative and a quantitativeevaluation of long-term and short-term risks duringthe detailed analysis.

CONNECTION BETWEEN THE BASELINERISK ASSESSMENT AND THE RISK EVAL-

UATION OF REMEDIAL ALTERNATIVES

A risk evaluation of remedial alternativesfollows the same general steps as a baseline riskassessment Detailed guidance on each step isprovided in RAGS/HHEM Part A. which must bereviewed and understood bv the risk assessorbefore a risk evaluation of remedial alternatives isconducted. Note, however, that the baseline riskassessment typically is more quantitative andrequires a higher level of effort than the riskevaluation of remedial alternatives. Otherdifferences (and mi^"'^) are listed below.

Evaluate Exponrt (Part A — Chapter 6)

• The source of release* for tbe baseline riskassessment is untreated site contamination,while tbe source of releases for the evaluationof remedial alternatives is the remedial actionitself (phis any remaining waste).

• Exposure pathways associated withimplementation of remediation technologiesmay indude some pathways and populationsthat were not present (or of concern) underbasdtoe condition*.

• 'The evaluation of short-term exposuresasioriatcd with remedial alternative* mayconsider a number of different releases thatoccur over varying duration*.

Evahute ToxJdty (Fart A — Chapter 7)

• The risk evaluation of remedial alternativesoften involves tess-than-Ufetime exposures thatrequire appropriate short-term toooary valuesto characterize risk or hazard.

• The risk evaluation of remedial alternativesmay include aa analysis of chemicals that werenot present under baseline conditions (i.e.,created as a result of tbe remedial alternative).

Characterize RUa (Fan A — Chapter 8)

• A risk evaluation of remedial alternativesgenerally considers risks to onsite workers, aswell as risks to the surrounding community.

• There are artrtftjonal uncertainties involved inevaluating risks of remedial alternatives thatare not considered in the baseline riskassessment (ej, confidence in performance ofremedies and patterns of predicted releases,confidence in ittainmeni of dean-up levels).

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SOURCES OF INFORMATION FOR RISK EVALUATIONS DURING THE FS

Baseline Risk Assessment Much of the data collected during the baseline risk assessment can also be usedto calculate the long-term residual risk associated with a remedial alternative. Some of the data may be applicableto calculation of risks during the remedial action. Some of the information from the baseline risk assessment that maybe useful for analyzing the risks associated with the remedial alternative includes:

• exposure setting, including exposed populations and future land use (RAGS/HHEM Pan A, Section 6.2);

• exposure pathways, including sources of contamination, chemicals of concern, fate and transport of chemicalsafter release, and exposure points (RAGS/HHEM Pan A, Section 6.3);

• general exposure considerations, including contact rate, exposure frequency, and duration (RAGS/HHEMPan A, Section 6.4);

» exposure concentrations, inciting monitoring data, modeling results, and media-specific risults(RAGS/HHEM Pan A, Se&on 6.5);

• estimates of chemical intake (RAGS/HHEM Pan A, Section 6.6);

• toxicuy information (e.g., changes/additions to Integrated Risk Information System [IRIS] and Health EffectsAssessment Summary Tables [HEAST]) (RAGS/HHEM Part A, Chapter 7);

• quamitauon of risks (RAGS/HHEM Pan A, Section 8.6); and

• uncertainties associated with tenacity assessment, exposure assessment, and baseline risk characterization(RAGS/HHEM Pan A, Sections 6.8, 7.6, and 8.5).

Tratability Studies. Treataoitity investigations are site-specific laboratory or 6ek) studies, performed either withlaboratory screening, bench-scale, or pitot-OTUe study (see Section S3 of the RI/FS Guidance). Generic studies fortechnologies (e.g., those performed by a vendor) can also contain useful information, Treaiabiliry studies may providerisk-related data such as (1) information on short-term emissions and (2) information on removal efficiencies of atechnology. This information may be especially useful when considering innovative technologies. Guide to ConductingTreotability Studies under CERCLA (under development by EPA's Risk Reduction Engineering Laboratory) providesa three-tiered approach to conducting treatabitity studies during screening, selection, and design of remedialalternatives. Chapter 5 of the RI/FS Guidance, especially Section 5.6, provides information on evaluating theapplicability of the treatabitity study results (e.£, determination of usefulness, documentation, usefulness of residualinformation, application of laboratory/ bencn/pikx studies to fuO-scale system).

Feasibility Studies or Other Analyses for Comparable Sits*. If a risk evaluation of one of the alternatives beingconsidered was conducted during the FS (or later stages) for a site with similar wastes and simitar conditions, someof the information that was developed may be helpful in characterizing the short-term or long-term risks associatedwith, that alternative. This type of information should be examined carefully to determine whether the analyses areappropriate for the site currently being evaluated Differences in the types of hazardous substances present,characteristics of environmental media, meteorological conditions, locations of receptors, or other factors could resultin large differences in the risk evaluation.

orThe Engineering and Technical Support Center of EPA's Risk Reduction Engineering Laboratory (513-569-7406

FTS 684-7406) can provide information concerning treaiabitity studies and evaluations of remedial technologies.

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FACTORS TO CONSIDER WHEN DECIDINGWHETHER A QUANTITATIVE RISK

EVALUATION IS NEEDED

The decision of whether to conduct aquantitative or qualitative risk evaluation dependson: (1) whether the relative short-term or long-term effectiveness of alternatives is an importantconsideration in selecting an alternative and (2) the"perceived risk" associated with the alternative.The perceived risk includes both the professionaljudgment of the site engineers and risk assessorsand the concerns of neighboring communities.Some factors that generally lead to a higherperceived risk are as follows:

• close proximity of populations;

• presence of highly or acutely toxic chemicals;

• technologies with high release potential, eitherplanned or "accidental";

high uncertainties in the nature of releases(e.g., amount or identify of contaminantsreleased) such as might exist with use ofcertain innovative technologies;

• multiple contaminants and/or exposurepathways affecting the same individuals;

• multiple releases occurring simultaneously(e.g., from technologies operating in doseproximity);

• multiple releases occurring from remedialactions at several operable units in doseproximity; and

• releases occurring over long periods of lime.

If consideration of these (or other) factorsleads to a high perceived risk for an alternative, amore quantitative evaluation. Including emissionmodeling and/or detailed treatability studies, maybe helpful in the decision-making process. Forexample, if one alternative considered for a siceinvolves extensive excavation in an area that is veryclose to residential populations, then a morequantitative evaluation of short-term risks may beneeded to evaluate this alternative. In addition,other factors, such as available data and resources,may affect the level of detail for these riskevaluations.

2.2.1 EVALUATION OF LONG-TERMHUMAN HEALTH RISKS FORDETAILED ANALYSIS

Evaluation of the long-term human healthrisks associated with a remedial alternativeinvolves: (1) evaluating residual risk and(2) evaluating the alternative's ability to provideprotection over time.

Evaluate Residual Risk. Because PRGsgenerally are based on chronic human health riskconsiderations (e.g., ARARs such as maximumcontaminant levels (MCLs), or risk-basedconcentrations), they usually provide the standardto use to evaluate long-term health risks. Whensite engineers are developing alternatives anddetermining whether a technology is capable ofachieving PRGst they are in effect evaluatingresidual risk. (Therefore, the results from usingRAGS/HHEM Pan B and other guidance onremediation goals are very important for this partof the analysis.)

Most of the time it will be sufficient for thedetailed analysis to indicate whether or not analternative has the potential to achieve the PRGs,rather than to quantify the risk that will remainafter implementation of the alternative. If moredetailed information concerning long-term risk isneeded to select an alternative (e.g., to determinethe more favorable of two otherwise similaralternatives), then it may be useful to determinewhether one alternative is more cenatn to achievethe PRGs than the other, whether (or to whatextent) one may be able to surpass (i.e., achievelower concentrations than) the PRGs, or whetherone may be able to achieve the goals in a shortertime.

Certain remedial technologies (e.g.,incineration) may produce new contaminants thatwere not present at the site under baselineconditions. The risks associated with theseadditional substances generally should beevaluated. Another consideration in evaluatingthe residual risk associated with some alternativesis the level of confidence in the ability of theremedy as a whole to achieve the site engineers1

predictions. For some technologies (e.g., ground-water extraction and treatment technologies), pastexperience has indicated that, in some situations,it may be difficult or impossible to achieve thepredicted goals. This information on the

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uncertainty associated with an alternative may bean important factor in selecting a remedy.

After the individual technologies comprising aremedial alternative have been examinedseparately, then the alternative as a whole shouldbe examined to determine the extent to which itmeets the PROs for all of the contaminated mediaand all of the contaminants of concern. Even ifPRGs will be met, potential cumulative effects onhuman health due to multiple contaminants,media, or exposures may need to be considered. Ifan alternative will not meet the PRGs for allmedia or contaminants of concern or if cumulativeeffects are a concern, this information should behighlighted in the presentation of the results of thedetailed analysts.

Evaluate Protectiveness Over Tit -..Evaluating whether an alternative is likely tomaintain the specified level of protectiveness overtime (often referred to as "permanence") involvesusing expert engineering judgment In particular,if an alternative relies on engineering orinstitutional controls to reduce or eliminateexposure to contaminated media, then the abilityof these controls to maintain protectiveness shouldbe considered. These types of remedies provideprotection by reducing or eliminating exposure tohazardous substances rather than eliminating thehazardous substances or reducing theirconcentrations, volumes, or toxicicy. Failure ofsuch remedies could lead to an increase inexposure and therefore an increase in risk. Forexample, if a remedy includes the capping ofcontaminated soils, then the potential futureexposures due to cap failure include direct contactwith soils and the leaching of contaminants toground water. The worst-case situation ofcomplete containment system failure is unlikely tooccur, however, because five-year reviews (seeSection 3.4) are conducted at all sites where wastesare managed onsite above concentration levels thatallow for unrestricted use and unlimited exposure.

2.2.2 EVALUATION OF SHORT-TERMHUMAN HEALTH RISKS FORDETAILED ANALYSIS

Short-term health risks generally include anycurrent baseline risks plus any new risks thatwould occur while implementing the remedy. Asdiscussed previously, the evaluation of potentialshort-term risks involves the same general steps asin the baseline risk assessment. These steps.

however, generally will not be conducted in thesame level of detail for the FS.

Other important points concerning level ofeffort should be emphasized here. For example,the Resource Conservation and Recovery Act(RCRA) has performance standards for manycommonly used CERCLA remedial technologies(e.g., incineration). The risks associated with manyof these technologies were analyzed in developingthese standards, and the standards were set suchthat the risks associated with operation of thetechnology would be acceptable. Therefore, adetailed evaluation of the risks associated withRCRA-regulated technologies generally would notbe necessary. On the other hand, depending onsite-specific factors such as the toxicity of sitecontaminants and the proximity of populations, amore detailed evaluation of short-term risks mayindeed be appropriate.

Detailed analyses may also be appropriate forless-characterized technologies (e.g., innovativetechnologies). In addition, alternatives withmultiple short-term releases or substantial baselinerisks may need a more detailed evaluation todetermine whether cumulative risks are expected tobe within acceptable levels.

Of special note is that the short-term riskevaluation for remedial alternatives during thedetailed analysis includes an evaluation of thepotential for short-term risks to two groups ofindividuals: (1) neighboring populations (whichinclude onsite workers not associated withremediation) and (2> onsite workers associatedwith remediation.

Appendices A through D provide informationthat can be used when a more quantitativeevaluation of short-term risks is needed to supportthe selection of a remedy. Chapter 8 ofRAGS/HHEM Pan A also provides guidance oncharacterizing short-term risk.

Evaluate Short-term Exposure. A qualitativeexposure assessment for remedial alternatives'during the detailed analysis generally involves —just as in the baseline risk assessment, but in a lessquantitative manner — using the concept ofreasonable maximum exposure (RME) to evaluaterelease sources, receiving media, fate and transport,exposure points, exposure routes, and receptorsassociated with a particular alternative.

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An important difference between the baselinerisk assessment and the risk evaluation of remedialalternatives involves exposure sources. For thebaseline risk assessment, the source of exposure isuntreated site contamination. For remedialalternatives, however, the potential sources ofexposure are the releases that result from theimplementation of remedial technologies. Inaddition, some remedial alternatives (e.g.,incineration, biodegradation) may result in newchemicals thai were not previously assessed for thesite.

The first step of the exposure assessmentinvolves identifying the types of releases associatedwith a particular waste management approach.During the detailed analysts, methods formitigating potentially significant short-termreleases should be examined, and releases that areexpected to be most difficult to control should behighlighted.

Appendices A and D of this guidance eachcontain two matrices that should assist incharacterizing the releases that may occur duringremedy implementation. Exhibit A-l provides abrief description of common remedial technologyprocesses, and Exhibit A-2 summarizes potentialreleases to different media during the normaloperation of various technologies. Exhibit D-lprovides a summary of releases associated withradiation remedial technologies, and Exhibit D-2includes a qualitative estimate of the potentialshort-term risks posed by a radiation remedialtechnology.

After the releases and their receiving mediahave been identified, the next step of the exposureassessment is to determine whether major exposurepathways exist. Characterizing site-specificexposure pathways involves identifying:

• the general fate and transport of thecontaminants that are released from thetechnology (e.g., downwind transport);

• the potential exposure points and receptors(e.g., nearby downwind residents); and

• potential exposure routes (e.g., inhalation).

Exhibit 2-1 illustrates an example of an exposurepathway for a remedial alternative. More detailedinformation concerning exposure pathways isavailable in Chapter 6 of RAGS/HHEM Part A.

The flow charts contained in Exhibit 6-6 of Part Aare particularly useful in determining thepopulations potentially exposed by releases into aparticular medium. Transfers of contaminantsfrom one medium to other media also areaddressed.

At this point, a quantitative exposureassessment — if needed — would involve {inaddition to identifying release sources, exposureroutes, and exposure points):

• quantifying releases;

• evaluating environmental fate and transport;

• determining exposure point concentrations;and

• calculating intakes.

All of these steps are discussed in Chapter 6 ofRAGS/HHEM Part A.

Throughout the short-term exposureassessment, the assessor must continually askwhether the potential exposure warrants the levelof quantitation being used. At times, the answermay not be known until the end of the exposureassessment For example, if short-term exposurewas estimated to be very simitar to long-termexposure, it would not be necessary to expendresources to obtain the short-term toxiciryinformation needed to quantitatively characterizerisk.

A major difference between the exposureassessment conducted during the baseline riskassessment and the one conducted during the riskevaluation of remedial alternatives is theevaluation of the timing and duration of releases.Because a number of different activities will takeplace during implementation, it is likely that thequantities of hazardous substances released to theenvironment will vary over time. For example, asseen in Exhibit 2-2, one remedy can have severaldistinct phases, each with different exposurepotentials. It may be important to determine thesequence of events and likely activities at eachphase of the remediation, so that the exposurepoint can be evaluated for each phase. This willalso ensure that appropriate short-term exposuredurations are identified and that the potential forreleases to occur simultaneously and thus result incumulative risk is considered. As seen in

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EXHIBIT 2-1

ILLUSTRATION OF AN EXPOSUREPATHWAY FOR A REMEDIAL ACTION

Exposure Medium(Air)

ExposurePoint

Transport Medium (Air)

InhalationExposure Route

Volatile OrganicCompounds

round WaterPump and TreatApparatus

ContaminatedGround Water

Exhibit 2-2, this issue is complicated by thepossible presence of baseline exposures.

Appendix B provides references — organizedbased on several important categories of remedialtechnologies — that can be consulted to quantifythe release of and therefore exposure tocontaminants. The information in Appendix Bincludes a brief discussion of considerations inrelease modeling and monitoring, a list of keytechnology-related parameters generally needed asinputs for models (e.g., meteorological conditions,o p e r a t i o n characteristics, soil/mediacharacteristics), an annotated list of primaryreferences, and a list of additional references.

Evaluate Short-term Toxicity. The releasesthat may occur during implementation of aremedial alternative, and hence the exposure-point

concentrations, generally last for varying durationsand correspond to less-than-lifetime exposures.Consequently, any toxicity values used to evaluatethe risks from these shorter exposures mustcorrespond to the duration of the release (orexposure). Three exposure durations, in additionto longer-term exposures, may be of concern atCERCLA sites undergoing remediation: singleexposure events (minutes, hours, or single day),very short-term exposures (up to two weeks), andshort-term exposures (two weeks to seven years)."Mote that the chronic toxicity values fornoncarcinogenic effects used most frequently in thebaseline risk assessment may not be appropriatewithout modification tor exposures of less thanseven years (otherwise they may be unnecessarilyconservative).

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EXHIBIT 2-2

ILLUSTRATION OF CUMULATIVE EXPOSURE FROM MULTIPLE RELEASES

Exposure

CumulativeResidual

Technology 1

Technology 2

Baseline (Uncontrolled)

Baseline (Uncontrolled)

Residual

Note: The graph illustrates how nearby populations at some sites could be exposed to both residual risksand risks from remediation technologies. The cumulative exposure illustrated is the sum of residualexposure and exposures associated with releases from Technologies 1 and 2. This exhibit is for illustrationpurposes only and is not meant to imply that this level of quantitation is neccesary or even desired.

Appendix C contains information concerningthe use of short-term toxiciiy values.RAGS/HHEM Pan A provides additionalinformation on assessment of contaminant toxicity.As discussed in Appendix C, the Superfund HealthRisk Technical Support Center (TSCi should beconsulted in all cases where short-term toxicitvvalues are needed.

Characterize Short-term Risks to theCommunity. During risk characterization,exposure and toxicity information is broughttogether to provide a measure or indication of themagnitude and timing of short-term health risks (ifany) from the remedial alternatives. As discussedpreviously, risk assessors may choose tocharacterize the short-term risks to the community(i.e., persons who live 01 we»k in the vicinity of thesite) quantitatively for some sites and qualitativelyfor others. When short-term risks are notexpected to be a problem for a site, a morequalitative evaluation generally is appropriate. Inthese cases, a qualitative evaluation of themagnitude, duration, and/or likelihood of theexposures and risks should be conducted, andassessors could describe short-term risks in aqualitative manner relative to the results of thebaseline risk assessment

A quantitative evaluation of short-term risks ismost likely to be useful when the types, levels,and/or availability of hazardous substances areexpected to change significantly as a result ofremediation. If quantitative exposure estimatesand toxicity data are available, then a morequantitative risk characterization may beconducted. The quantitative method that is usedto characterize these risks depends in pan on thetoxicity values that have been identified. Some ofthese toxicity values (e.g., subchronic referencedoses) must be combined with the results of theexposure assessment (i.e., intakes). The results ofrisk characterizations using this type of toxicityvalue will be of the same type as those generatedin the baseline risk assessment: hazard quotients(or indices) or excess individual lifetime cancerrisks. If the toxicity values incorporate exposureassumptions (e.g., as in one- and ten-day healthadvisories), then these values are compared withexposure concentrations to determine whether therisks are above acceptable levels. Appendix Cprovides additional information on short-termtoxicity values.

Cumulative effects from multiple releases ormultiple chemicals should also be considered, ifpossible. If the risk characterization is qualitative,then a discussion of the potential for cumulativerisks from multiple chemicals and/or exposurepathways (e.g., due to s imu l t aneousimplementation of several remedial technologies)should be provided. If the results of the riskcharacterization are more quantitative (e.g., cancerrisks and hazard quotients), then the informationconcerning duration and timing of releases can beused to calculate the cumulative risks or hazardindices for those releases that will occur at thesame time and affect the same populations. If theresults of the quantitative risk characterization arecomparisons with short-term toxicity criteria, thenthe total exposure concentrations can be calculatedfor releases that occur at the same time and affectthe same populations. These total exposureconcentrations then can be compared to the short-term toxicity criteria. See Chapter 8 ofRAGS/HHEM Pan A for additional guidance oncharacterizing short-term human health risks.

Characterize Short-term Risks to Workers.Worker health and safety issues should also beconsidered during the development of the FS. TheWorker Protection Standards for Hazardous Wasteat 40 CFR 311 and 29 CFR 1910.120 establishrequirements for worker protection at CERCLAsites, including requirements for planning (i.e.,health and safety plans, and emergency responseplans), training, and medical surveillance.Although the standards encompass areas that arenot directly related to worker r i sk(e.g., illumination and sanitation), they also specifyrequirements in areas that are directly relevant toworker health risks. Specifically, once a remedy isselected, the Worker Protection Standards requirethat implementation of that remedy proceed withthe following risk-related considerations:

• site characterization and analyses prior tocommencing remedial activities, specificallyrisk identification (see 29 CFR 1910.120(c));

• proper use of engineering controls, workpractices and personal protective equipment(PPE) for employee protection (see 29 CFRI910.120(g)); and

• preparation of emergency response plans thaispecify how the site employees will beprotected while responding to onsiie

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emergencies thai may occur (see 29 CFR1910.120(1)).

It is important to note, however, that factors notassociated directly with hazards particular to agiven site (e.g., risk of accidents during offsitemotor vehicle transport) are not usually consideredduring the FS, but instead should be addressedprior to remediation in the site health and safetyplan.

The exact nature of the assessment of workersafety issues for a remedial alternative will varywith each site. For many types of sites andremedial alternatives, the risks to workers will bewell-characterized and will not require muchadditional site-specific analysis. These issues willbe addressed in more detail in the site-specifichealth and safety plan. Thus, a qualitativeassessment of worker risk is appropriate for mostsites durinc the FS and can be based on threetypes of risk.

• Potential for exposure to hazardous substancesduring onsite remedial activities. The mostsignificant factor determining the potential forexposure to hazardous substances is the natureof the onsite contamination. Because onsiteremediation workers are equipped with theappropriate PPE and are required to useappropriate engineering controls, their riskgenerally should be minimal Factors thataffect the potential for exposure, however,include the likelihood of PPE failure. Ingeneral, more restrictive PPE is more likely tofail due to considerations such as workermobility and visibility constraints, andpotential for worker heat stress.

• Potential for injury due to physical hazards.Onsite remediation workers may be exposed tohazards other than exposure to hazardoussubstances. Hazards such as explosion, heatstress, and precarious work environments mayalso pose threats to workers.

• Potential for exposure during emergencyresponse activities (assuming the need arisesfor onsite emergency response). Pan of the

design of a remedial alternative shouldconsider the potential for worker exposureduring emergency responses thai may berequired in the event of remedy failure. Forsome remedial alternatives, it is possible thatemergency assistance would be handled in partby onsite workers, with offsite assistance (e.g.,county HAZMAT teams) as required.

Alternatively, it is possible that an emergencyresponse plan would require the evacuation ofonsite remediation workers and use of offsiteemergency responders.

23 CASE STUDIES

The following two case studies provideexamples of the evaluations of long-term andshort-term risks that are conducted during thedetailed analysis. Both case studies present anevaluation of only one technology for one ofseveral alternatives that are considered for thehypothetical site. An actual detailed analysiswould include a similar evaluation for othertechnologies and alternatives as well. The twosites considered in the case studies are identical inall respects, except one: the. XYZ Co. siteconsidered in Case Study #1 is distant fromresidential or worker populations, while the ABCCo. site considered in Case Study #2 is adjacent toa residential neighborhood. A more quantitativeanalysis was conducted in Case Study #2 becauseof concern for potential short-term exposures tothe neighboring community.

The sites presented in these case studies areabandoned industrial facilities that arecontaminated with various volatile organiccompounds (VOCs) and heavy metals. VOCscontaminate both the soil and ground water at thesites, while metals are found in the soil only. Anumber of leaking drums were stored aboveground at the sites and were removed prior to theRI. There are also two lagoons filled withhazardous sludges. City ground-water wells arelocated approximately 1/4 mile from the* sites.VOCs have been detected in the wells at levelshigh enough to force the city to use an alternatewater source.

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CASE STUDY #1:QUALITATIVE EVALUATION DURING DETAILED ANALYSIS

[Note: This case study presents an evaluation of only one technology for only one of several remedialalternatives; an actual detailed analysis would address other technologies and alternatives as well. All data inthis case study are for illustration purposes onlv.l

Remedial Alternatives

Based on the results of the development and screening of alternatives, the site engineers have identified fivealternatives (A through E) to be evaluated for use as remedies at the XYZ Co. site. One of the technologiesincluded in Alternative C is ground-water pumping and air stripping for the VOCs m ground water

Evaluation of Long-term Risks

Meeting PRGs for all contaminants in ground water is uncertain at this point due to the complex nature ofthe contaminated aquifer. If after remedy implementation it is determined that Alternative C does not meet PRGsfor all contaminants in ground water, theo the residual risk remaining after implementation will be examined todetermine whether other measures need to be taken to assure protectiveness. There are no residue risks for mediaother than ground water for the pump-and-treat/air stripping component of Alternative C.

Evaluation of Short-term Risks

The time-frame for air stripping of VOCs from ground water at the XYZ Co. site — and therefore the timeframe considered for evaluating short-term risks — is at least 20 years, and possibly as many as SO, depending onfactors such as the specific aquifer characteristics.

Releases and Receiving Media. The most likely release of concern from an air stripper is the release of aircontaminated with VOCs. The type of air stripper being considered for the XYZ Co. site generally achieves 99percent or better removal of VOCs from water. The vapor phase VOCs contained in the air stripper off-gases thencan be removed if necessary using air pollution control devices such as granular activated carbon columns or anafterburner, which generally achieve 90 to 99 percent destruction or removal of contaminants from the vapor phase.However, there will still be some small release of contaminants that may need to be examined further dunng thedesign stage of this remedy (if selected). Also, air pollution control devices will produce residues that in turn mayneed to be treated. Other releases associated with air stripping include treated water containing residual organiccontaminants that will be released to surface water, and, possibly, fugitive air emissions due to leaky valves andfittings.

Fate and Transport. Exposure Points, and Exposure Routes. The release of VOCs into the air during airstripping at the XYZ Co. site could result in inhalation of volatiles transported through the air. However, thenearest target population is over one mile from the site. Long-term average concentrations may be a concern, aswell as shorter-term or peak concentrations that may occur under certain conditions (e.g., temperature inversions).

Short-term Risks. The time period of exposure to air stripper off-gases (20 to 50 years) is a significant portionof a human lifetime. However, because the concentrations of VOCs in ground water are not unusually high, thereleases associated with the air stripper are well-characterized, and there is no nearby target population, quantitationof these risks is not needed to select a preferred alternative.

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CASE STUDY #2:QUANTITATIVE EVALUATION DURING DETAILED ANALYSIS

[Note: This case study presents an evaluation of only one technology for only one of several remedialalternatives; an actual detailed analysis would address other technologies and alternatives as well All data inthis case study are for illustration purposes onlv.l

Remedial Alternatives

Based on (he results of the development and screening of alternatives, the site engineers have identified fivealternatives (A through E) to be evaluated for use as remedies at the ABC Co. site. One of the technologiesincluded in Alternative C is ground-water pumping and air stripping for the VOCs in ground water. [For this casestudy, ontv benzene from the pump-and-treat component of the remedial alternative will be analyzed in detail. Inan actual analysts, each contaminant of concern and each component of the remedy may need to be analyzed in asimilar fashion,]

Evaluation of Long-term Risks

The RI has shown that the organic contaminants in the ground water are adsorbed to the aquifer material andare also dissolved in the ground water. The remediation goal for benzene will be readily met in the treated water.which will subsequently be discharged into the nearby surface water. Remediation of the water remaining in theaquifer, however, is much less certain. The residual concentration of benzene in this remaining water will dependon several factors, including the adsorptive characteristics of benzene with the aquifer material, the specific pumpingregimen, and the length of time that this technology is implemented. If, at a later stage (e.g., during the five-yearreview), it is determined that the contaminants are not being extracted at toe desired levels, the pumping regimenmay need to be modified (or some other approach may be needed). At a minimum, the pumping of ground wateris expected to be an effective barrier against further contaminant migration. Due to the uncertainty regarding theresidual concentration of contaminants that may remain in ground water, the permanence of the pump-and-treattechnology, in terms of future risks, is unknown at tbis time.

Evaluation of Short-term Rtoks

Short-term impacts due to air emissions from air stripping are expected to be the most significant risks fromthe pump-and-treat component of the remedy at ABC Co. site. [This case study does not consider fugitive emissionsfrom sources "upstream" of tne air stripper (e.&, separators, holding tanks, treatment tanks), although these sourcesmay have been evaluated in an actual risk assessment.) In order to assess these risks during the detailed analysisstage, exposure concentrations from the ABC Co. site will be estimated by combining emissions modeling withdispersion modeling. Before proceeding with this analysis, the following steps were taken.

* An appropriate atmospheric fete and transport model, derived from the SCREEN model developed by EPA'sOffice of Air Quality and Planning Standards was chosen. (A more complete listing and comparison ofatmospheric fate models is given in Table 3-2 of the Stiperjund Exposurt Assessment Manual [EPA 1988e].)

• Required inputs for tne atmospheric fate and transport model were obtained. These inputs included theemission rate of contaminants from the air stripper into the atmosphere (based on contaminant concentrationsin ground water, system flow rate efficiency of the air stripping process, and efficiency of the air pollutioncontrol device); atmospheric dispersion factors for contaminants; and meteorological data (wind speed, prevalentdirection, stability, mixing height, and temperature). More detailed parameters, such as surface roughnessheight and specific topographic features, were not required, for the model that was chosen.

(Continued)

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CASE STUDY #2:QUANTITATIVE EVALUATION DURING DETAILED ANALYSIS

(Continued)

• The population that will be affected by short-term releases was identified. This information was obtained fromthe baseline risk assessment, and was based on the population distribution and density of the surroundingcommunity, and meteorological data such as the prevailing wind direction.

• The toxicity characteristics of the contaminants were obtained from the baseline risk assessment.

Exposure Assessment. Releases are expected to occur during both the construction and the implementationstages of the pump-and-treat technology. The time frame for each of these stages varies and, therefore, the releaseand exposure potential also will vary. The most probable release of concern from implementation of the air stnpper[the focus of this case study] has been identified as the release of air contaminated with volatile organic chemicals(VOCs) from the stripping tower to the atmosphere. Benzene is one of the volatile contaminants in the groundwater being treated, and is expected to be present as a residual in the stripper off-gases. The following equation(EPA, Emission Factors for Superfund Remediation Technologies, Draft, Office of Air Quality Planning andStanJards, 1990) was used to calculate the benzene emission rate into the air stripper off-gases:

ER (g/s) = C x a* x (SE/100) x K

where ER = emission rate of benzene (g/s)C = concentration of benzene in water = 2.5 mg/LQto = influent water flow rate = 1700 L/minSE = stripping efficiency of tower for benzene = 99.99%K = constant to convert units = 1.67 x 10'5 (g-min/mg-s)

An SE of 99.99 percent is used in these calculations to determine the reasonable maximum emission rate of benzeneinto the air. Actual SEs would be between 90 and 99.99 percent, depending on several operating parameters.Solving this equation, ER = 0.071 g/s.

Because this system will use an air pollution control device (APCD) such as granular activated carbon (GAC)columns to remove contaminants from gases released to the atmosphere, ER is the rate of release of benzene fromthe ground water into the stripper off-gases rather than the rate of release of benzene directly to the atmosphere.The release rate of benzene to the atmosphere, therefore, can be calculated using the following equation:

q * ERx(l -DRE/100)

where q = mass release rate to atmosphere (g/s)ER 3 emission rate from air stripper to APCD = 0.071 g/sDRE » destruction/removal efficiency of APCD = 95%

A DRE of 95 percent is used to obtain a reasonable maximum release rate to the atmosphere. Applications ofsimilar APCD* achieve 95 to 98 percent destruction and removal efficiency for benzene in air. Solving for theatmospheric release rate of benzene, q » 0.0035 g/s.

Using Cue and transport modeling (analysis not shown], the atmospheric release rate of benzene is convertedto an exposure point concentration at a residence 250 m downwind of the site. The short-term air concentration(24-hour average) of benzene is estimated to be 6 x 10"4 mg/m3. The average annual longer-term concentration ofbenzene in air at the site boundary, as determined by the same, model, is estimated to be 3.4 x 10*4 mg/m3.

(Continued)

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CASE STUDY #2:QUANTITATIVE EVALUATION DURING DETAILED ANALYSIS

(Continued)

The only potential exposure pathway identified for releases from the air stripper is the air (inhalation) pathway.Because the toxicity criterion used to characterize short-term risk is a threshold concentration (see ToxicityAssessment below), a short-term intake does not need 10 be calculated. The longer-term intake is needed 10evaluate the cancer risk associated with inhalation of benzene. This intake is calculated by first obtaining the long-term site-specific exposure duration of 30 years from the baseline risk assessment. (An exposure duration of 30years is used because, while the lime for implementation of the pump and air stripping technology may be up to 50years, an individual is not expected to stay in the community for more than 30 years. If the maximum time forimplementation were less than the exposure duration identitled in the baseline risk assessment, then exposure wouldbe computed using the maximum implementation time as the exposure duration.) Using other exposure valuesobtained from the baseline risk assessment (e.g., inhalation rate of 20 m'/day), the longer-term (lifetime average)intake of benzene due to the air stripper is approximately 7 3 x 10'J mg/kg-day.

These concentrations and intakes are based on conservative steady-state assumptions regarding atmosphericconditions. Therefore, there is uncertainty surrounding the atmospheric data (which are inputs to the model) thatcould lead to higher (but probably lower) concentrations. For example, variations in wind speed and direction willresult in different contaminant concentrations for both maximum short-term and long-term exposure pointconcentrations. Some amount of published research data is available (mainly from water treatment plant studies)on the reliability of the APCDs used in air stripping. This information, combined with data from previous programexperience, indicates that the uncertainty associated with the effectiveness of the APCDs is low.

Toxicitv Assessment. To assess risk from exposure to the short-term benzene concentration (24-hour average),a toxicity criterion corresponding to a similar exposure duration is used. One such criterion, identified throughconsultation with the TSC, is EPA's acute inhalation criteria (AIC). The AIC provides a threshold level above whichacute inhalation exposure to benzene could result in toxicity to the most sensitive target organ (bone marrow andthe immune system). The AIC for benzene is 190 ug/m3. [In this case study, the AIC for benzene was assumedto be readily available. In an actual risk evaluation, this may not always be the case. When toxicity information isnot readily available — especially when, as in this case study, the longer-term exposure point concentration is notsignificantly different from the shorter-term point concentration (and the longer-term has toxicity information) — theneither delaying the assessment or expending resources to obtain the shorter-term toxicity information is notrecommended.]

To assess risk from exposure to the longer-term benzene concentration (annual average) for the 30-yearexposure duration, the inhalation cancer slope factor for benzene of 0.029 (mg/kg-day)"1 is identified from thebaseline risk assessment

Risk Characterization. Short-term risk to the community from benzene is determined by comparing theshort-term concentration of 6 x 10"4 mg/m3 (i.e., 0.6 ug/m3), with the AIC of 190 ug/m3, to result in a ratio of 0.003.Because this ratio is less than 1, short-term risk to the community solely from benzene is considered to be unlikely.

Using the longer-term intake of 73 x 10'5 mg/kg/day, and the slope factor of 0.029 (mg/kg/day)'1, the upper-bound excess individual lifetime cancer risk to the community from long-term exposure to benzene in theatmospheric releases from tbe air stripper is approximately 2 x 10* within EPA's acceptable risk range.

(Uncertainties associated with the site-specific exposure information and the toxicity information, discussed inmore detail in the baseline risk assessment, also are important to consider at this stage of the analysis.]

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CHAPTER 3RISK EVALUATION AFTERTHE FEASIBILITY STUDY

After the FS is completed, a remedy isproposed, and, if selected, is documented in theROD. Following this, the remedy is designed andimplemented, and then deletion/five-year reviews ofthe site take place. This chapter discusses the roleof risk information during these activities. Note,however, that not all of these risk evaluations nora significant level of quantitaiion may be neededfoi eveiv site. The euidinp principle is that riskevaluations after the FS should be conducted asnecessary to ensure that the remedy is protective.

3.1 RISK EVALUATION FORTHE PROPOSED PLAN

The purpose of a risk evaluation during theproposed plan stage is to refine previous analysesconducted during the FS, as needed. If newinformation becomes available during the publiccomment period for the proposed plan, additionalanalysis of the alternatives may need to beconducted at this time. If additional analysis isconducted, it should be conducted for all thealternatives, as appropriate, and not just for thepreferred alternative.

3.2 DOCUMENTATION OFRISKS IN THE ROD

Several risk-related analyses should bedocumented in the ROD. The comparativeanalysis section should include a discussion of riskas it pertains to the three risk-related criteria:long-term effectiveness, short-term effectiveness,and overall protection of human health and theenvironment The discussion of overall protectionof human health and the environment shouldinclude a discussion of how the remedy willeliminate, reduce, or control the risks identified inthe baseline risk assessment and whether exposurewill be reduced to acceptable levels. Thediscussion of long-term effectiveness (and

permanence) should address, where appropriate,the residual risk from untreated waste remaining atthe site. The pan of the decision summary thatfocuses on the selected remedy should present:

* the chemical-specific remediation levels to beattained at the conclusion of the responseaction;

• the corresponding chemical-specific risk levels;

• the points (or areas) of compliance for themedia being addressed; and

* the lead agency's basis for the remediationlevels (e.g., risk calculation, ARARs).

In addition, the ROD should indicate whether thesite will require five-year reviews (see Section 3.4).In some cases, additional risk information (e.g.,anticipated post-remedy cumulative risk for anenvironmental medium or for a site) may need tobe included in the ROD.

Interim Final Guidance on Preparing SuperfundDecision Documents (EPA 1989f), Role of theBaseline Risk Assessment in Super-fund RemedySelection Decisions (EPA 1991d), andRAGS/HHEM Pan B provide additionalinformation on documenting risks in the ROD.

3.3 RISK EVALUATION DURINGREMEDIAL DESIGN/REMEDIAL ACTION

. The activities during remedy design andimplementation that may involve consideration ofrisk include refining risk evaluations duringremedial design, monitoring short-term risks,evaluating attainment of remedial levels in theROD, and evaluating residual risk.

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3.3.1 RISK EVALUATION DURINGREMEDIAL DESIGN

The process of evaluating long-term and short-term risks, which began during the FS and mayhave continued during development of theproposed plan, also may continue during design ofthe selected remedy for some sites. The purposefor risk evaluations during the remedial design isto ensure that the selected remedy will beprotective. These evaluations can be conducted by:(1) refining previous analyses, as needed, and/or(2) identifying the need for engineering controls orother measures to mitigate risks. Methods forevaluating long-term and short-term risks arediscussed in more detail in Chapter 2.

3-3.2 MONITORING SHORT-TERMHEALTH RISKS DURINGIMPLEMENTATION

If the potential for short-term health effectsdue to releases during remedy implementationneeds to be assessed (e.g., due to high uncertaintyconcerning predicted risks to communities orremediation workers), a sampling and analysisstrategy to accurately determine exposureconcentrations should be developed. This strategymay need to consider the following elements:

• location of sampling;

• sample collection and handling procedures;

• chemicals to be monitored and methods used;and

• statistical considerations regarding the analysisof results.

The monitored exposure concentrations should becompared to short-term health-based benchmarks(see Appendix C) to help in determining whetherthe release presents a threat to human health.

33 J ASSESSING ATTAINMENT OFSELECTED REMEDIATION LEVELSDURING IMPLEMENTATION

The RPM, risk assessor,, and others should beinvolved in developing a sampling and analysisplan to measure whether the selected remedy hasattained the remediation levels in the ROD. As inthe baseline risk assessment, this sampling andanalysis should provide data that can be used to

develop RME estimates. This plan is si te-specificand may need to consider the same elementspresented in Section 3.3.2, plus the relevantremediation levels for the chemicals of concern.

The plan for measuring attainment shouldensure that sufficient data to evaluateprotectiveness of human health will be available.For example, at a minimum, those chemicals thatcontribute to major portions of the site risk shouldbe selected for measuring attainment. The two-volume set Statistical Methods for Evaluating theAttainment of Cleanup Standards (EPA 1988d)outlines a number of statistical methods that canbe used to measure attainment. EPA is developingadditional guidance on this topic.

3.3.4 EVALUATION OF RESIDUAL RISK

This step — which may be conducted atcompletion of the remedy and perhaps during afive-year review (see next section) — may beneeded to ensure that the remedy is protective.This step may be different from the assessment ofattainment of remediation levels selected in theROD because it may more closely consider theexpected land use and cumulative effects (e.g., dueto multiple chemicals or exposure pathways).Residual risk estimates can be conducted at anytime after the remedy has commenced until theend of the remedy. Typically, a final evaluation ofthe cumulative site risk may be done followingcompletion of the final operable unit to ensurethat residual risks from multiple contaminants,pathways, and operable units that affect the sameindividuals are at protective levels.

In general, the same equations, exposureparameters, and toxicity values that were used todetermine the baseline risk for a site can be usedto assess the final clean-up (risk) level that aremedy has achieved. The concentrations that areused to calculate these risks, however, are the finalmeasured concentrations of the contaminants thatremain at the site, not the remediation levels inthe ROD. The following are other potentialdifferences between the baseline risk assessmentand evaluation of residual risks.

* Significant levels of "new* chemicals (e.g., thatwere not identified during the baseline riskassessment but that may have resulted fromthe remedy or were not discovered until afterremedy implementation) should be consideredin evaluating residual risk.

-26-

• Changes in land use since the time of thebaseline risk assessment may require changesin exposure parameters (e.g., contact rates,exposure frequency and duration).

• Toxicity values may have been updated sincethe baseline risk assessment. The most recenttoxiciry values in IRIS and HEAST should beused in calculating residual risk.

For some sites where engineering orinstitutional controls rather than treatment-basedremedies are employed, the concentrations ofchemicals in a contaminated medium may remainthe same as the baseline concentrations. The riskwill have been reduced or eliminated, however, bymitigation or elimination of the exposure pathway(e.g., by mitigating direct contact with soil by usinga cap or institutional controls, or eliminatingingestion of contaminated drinking water byproviding an alternate water supply). These riskreductions and associated exposure assumptionsshould be clearly presented.

3.4 RISK EVALUATION DURINGFIVE-YEAR REVIEWS

Section 121(c) of CERCLA provides forreviews of remedies that result in hazardoussubstances remaining at the site no less often thanevery five years after the initiation of the remedies.The purpose of the reviews is to assure that humanhealth and the environment are being protected bythe remedial alternative that was implemented.

The remainder of this section briefly describesthe purpose of five-year reviews, the sites for whichfive-year reviews are conducted, and the risk-related activities that may be conducted duringfive-year reviews. More detailed guidanceregarding five-year reviews is available in Structureand Components of Five-year Reviews (EPA 1991e).

3.4.1 PURPOSE OF FIVE-YEAR REVIEWS

A five-year review is intended to ensure thai aremedy remains protective of human health andthe environment. The more specific goals of afive-year review are:

to confirm that the remedy (including anyengineering or institutional controls) remainsoperational and functional; and

to evaluate whether ciean-up standards (basedon risk or ARARs) are still protective.

The first goal may be accomplished primarilythrough a review of the operation and maintenancerecords for a site and through a site visit andlimited analysis. The second goal includes ananalysis of requirements that have beenpromulgated by the federal or state governmentssince ROD signature to determine whether theyare ARARs and whether they call into questionthe protectiveness of a remedy.

In addition to considering ARARs torsubstances designated as contaminants of concernin the ROD, the reviews may include changes inARARs for substances not addressed unde rcomciTtinants of concern. Where remediationlevels in the ROD wer? based on risk calculations(rather than ARARs), then new information —such as revised toxlci ty values or exposu reparameters — that could influence theprotectiveness of the remedy should be considered.Based on this analysis, the reviewer can determinewhether the original remediation levels set out inthe ROD are still protective.

3.4.2 SITES THAT RECEIVE FTVE-YEARREVIEWS

Two types of five-year reviews are conducted:statutory and policy. Statutory reviews areconducted for remedies selected after theenactment of SARA where, after the remedy iscomplete, hazardous substances are present abovelevels that allow for unlimited use and unrestrictedexposure. These sites generally include: (1) siteswith remedies requiring access or land-userestrictions or controls (i.e., remedies that achieveprotectiveness through the use of engineering orinstitutional controls); and (2) sites with remediesthat achieve proteciiveness for the current use, butinclude restrictions on activities due to limits onexposure (i.e., sites cleaned up to levels that wouldbe protective for a nonresidential land use, butwould not be protective for residential or otherland use). Policy reviews are conducted for: (1)sites with long-term remedial actions (LTRAs) orother remedies that require five years or longer toachieve levels that would allow for unlimited useand unrestricted exposure and (2) remediesselected before the enactment of SARA wherehazardous substances are present above levels t h a tallow for unlimited use and unrestricted exposure

-27-

Statutory reviews may be discontinued only iflevels of hazardous substances fall permanently toa point that would allow unlimited use andunrestricted exposure. Policy reviews for LTRAsshould be discontinued when the remediation goalsspecified in the ROD are achieved, assuming theselevels allow for unlimited use and unrestrictedexposure. Achievement of these levels must beverified by an appropriate period of monitoring.

3.4.3 RISK-RELATED ACTIVITIES DURINGFIVE-YEAR REVIEWS

Three levels of effort have been defined forfive-year reviews. The following are risk-relatedactivities conducted for the three levels.

* At Level I, the reviewer will consider the riskassessment information contained in the RODand ROD summary.

• At Level II, the reviewer will conduct arecalculation of the original baseline riskassessment using information obtained duringthe review (e.g., new toxicity data). Ifappropriate, additional data may be collected.Ongoing monitoring may provide such data.

• Ai Level I I I , the reviewer will reevaluate therisk assessment, and, if appropriate, conduct anew risk assessment. Such an assessment maybe appropriate in order to address a new sitecondition, such as a new exposure pathway.New data may be collected as necessary for therisk assessment. If possible, however, existingdata should be used.

The appropriate level of review depends onsite-specific conditions and the confidence level forthe selected remedy. The proposed level of thefirst review is to be included in the ROD. A LevelI review should be appropriate in all but a fewcases where site-specific circumstances suggestanother level either at the outset of the review orbecause findings of the review suggest the need forfurther analysis. A Level III review would not beproposed in the ROD, but would be initiated inresponse to specific concerns regarding theperformance of the remedy or the risks at the site.The level of effort, particularly for subsequentreviews, also depends on the initial findings of thereview. Structure and Components of Five-yearReviews (EPA 1991e) provides additionalinformation concerning the appropriate level forreviews and the activities that are conducted ateach level.

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REFERENCES

U.S. Environmental Protection Agency (EPA). 1988a. Community Relations in Superfund: A Handbook.Interim Version. Office of Emergency and Remedial Response. EPA/540/6-88/002 (OSWER Directive9230.0-3B).

EPA. 1988b. Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites. InterimFinal. Office of Emergency and Remedial Response. EPA/540/G-S8/003 (OSWER Directive 9283.1-2).

EPA. 1988c. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA.Interim Final. Office of Emergency and Remedial Response. EPA/540/G-89/004 (OSWER Directive9355.3-01).

EPA. 1988d. Statistical Methods for Evaluating the Attainment of Superfund Cleanup Standards Volume I:Soils and Soil Media. Office of Policy, Planning, and Evaluation. EPA 230/02-89-042.

EPA. 1988e. Superfund Exposure Assessment Manual. Office of Emergency and Remedial Response.EPA/540/1-88/001 (OSWER Directive 9285.5-1).

EPA. 1988f. Seven Cardinal Rules of Risk Communication. Office of Public Liason. OPA-87-020.

EPA. 1989a. Considerations in Ground Water Remediation at Superfund Sites*. Office of Emergency andRemedial Response. OSWER Directive 9355.4-03.

EPA. 1989b. Ecological Assessment of Hazardous Waste Sites: A Field and Laboratory Reference.Environmental Research Laboratory. EP A/600/3-89/013.

EPA. 1989c. Estimation of Air Emissions from Clean-up Activities at Superfund Sites. Office of Air QualityPlanning and Standards. EPA-450/1-89-003.

EPA. 1989d. Exposure Factors Handbook. Office of Health and Environmental Assessment. EP A/600/8-89/043.

EPA. 1989e. Interim Guidance for Soil Ingestion Rates. Office of Solid Waste and Emergency Response.OSWER Directive 9850.4.

EPA. 1989f. Interim Final Guidance on Preparing Superfund Decision Documents. Office of Emergencyand Remedial Response. OSWER Directive 9335.3-02.

EPA. 1989g. Risk Assessment Guidance for Superfund: Volume I — Human Health Evaluation Manual(Pan A, Baseline Risk Assessment). Interim Final, Office of Emergency and Remedial Response.EPA/540/1-89/002.

EPA. 1989h. Risk Assessment Guidance for Superfund: Volume II — Environmental Evaluation Manual.Interim Final. Office of Emergency and Remedial Response. EPA/540/1-89AW1A (OSWER Directive9285.7-01).

EPA. 1990a. Guidance for Data Useability in Risk Assessment. Office of Solid Waste and EmergencyResponse. EPA/540/G-90/008 (OSWER Directive 9285.7-05).

EPA. 1990b. Guidance on Remedial Actions for Superfund Sites with PCB Contamination. Office ofEmergency and Remedial Response. EPA/540/G-90/007 (OSWER Directive 9355.4-01).

-29-

EPA. I991a. Conducting Remedial Investigations/Feasibility Studies for CERCLA Municipal Landfill Sites.Office of Emergency and Remedial Response. EPA/540/P-91/001 (OSWER Directive 9355.3-11).

EPA. I991b. Risk Assessment Guidance for Superfund, Volume 1, Human Health Evaluation Manual.Supplemental Guidance; "Standard Default Exposure Factors". Office of Emergency and RemedialResponse. OSWER Directive 9285.6-03.

EPA. 1991C. Risk Assessment Guidance for Superfund: Volume I — Human Health Evaluation Manual(Pan B, Development of Risk-based Preliminary Remediation Goals). Interim. Office of Emergency andRemedial Response. OSWER Directive 9285.7-01B.

EPA. 1991d. Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions. Office ofSolid Waste and Emergency Response. OSWER Directive 9355.0-30.

EPA. 1991e. Structure and Components of Five-year Reviews. Office of Emergency and RemedialResponse. OSWER Directive 9355.7-OZ

EPA. 199U. Guidance on Oversight of Potentially Responsible Party Remedial Investigations and FeasibilityStudies-. Office of Solid Waste and Emergency Response.' EPA/540/G-91/010a (OSWER Directive9835.1(c)).

-30-

APPENDIX ASELECTED REMEDIATION TECHNOLOGIESAND ASSOCIATED POTENTIAL RELEASES

This appendix contains two exhibits designedto assist during the FS in identifying some of thepotential releases that are associated withcommonly used remediation technologies. ExhibitA-l briefly describes each of the process options ofeach technology in Exhibit A-2. Exhibit A-2summarizes several potential releases to air orwater of common remedial technologies. Processvariations for which potential releases are similarare combined under the technology category.Potential releases to surface water or ground waterare included in the "water" column. "Other"releases include treatment residuals that needfurther treatment or proper disposal. In mostcases, this column refers to sludge or solid residuesthat may also be hazardous.

Risk Reduction Engineering Laboratory(RREL; Cincinnati, Ohio) plans and conductsengineering, research, and development related to

treatment of solid and hazardous wastes. RRELpersonnel provide site-specific technical servicesinvolving specific treatment technologies andCERCLA response processes including:

• analysis of treatment alternatives,• treatabiliry studies,

remedial design review,• construction QA.QC methods, and• coniaminant source control and geotechnical

test methods.

Regional EPA CERCLA staff should directquestions regarding evaluations of remediationtechnologies, previous experience with remediationtechnologies, and releases associated withremediation technologies to the Engineering andTreatment Technical Support Center, RREL atFTS 684-7406 or 513-569-7406.

-31-

EXHIBIT A-l

REMEDIATION TECHNOLOGY DESCRIPTIONS

Technologies

SOIL AND sruncKSoil Huddling

Soil 1-jteavHiion, Transport,Dumping, and (trading

Thermal Destruction

Circulating Bed Incineration

iNotary Kiln Incineration

HuKli/ed Ued Incineration

Infrared Incincratkm

Pyrolysis

Description of Process

'Irtc&c processes use mcchani/cd equipment in OH we coniiiminalcd soil, l-or sometreatment techniques. .soil mutt be removed from ;i contaminated site and be inmsnortcdlor treatment. Soil is Ihcn returned and rejoiced at either the original cxciivjition oranother disposal site, (trading is a technique which can reduce in lilt nil ion intocontaminated soils and can also control runoff.

These arc destruction processes which control temperature and oxygen availability, andconvert hazardous materials 10 carbon dioxide, water, and other products of combustion.

Wastes and auxiliary fuel arc introduced into the combustion chamber. Air is forced upthrough Ihc chamber from the bottom 10 promote mixing and complete combustion.I'arliculaic and gaseous products of combustion exit from the lop of the cumhusiionchamber for treatment and disposal.

The combustion chamber is a rotating, inclined cylinder which mixes combusting materialsas it rotates. Wastes arc led into the chamber at the high end, along with air and auxiliaryfuel. Exhaust gases arc treated and released, and ash residue is collected on the low end ofthe kiln.

A bed of inert particles (e.g.. sand) lies al the bottom of the cylindrical combustionchamber. Air is forced up through the bed and the panicles are ftuidt/cd (i.e., (he panicles"float" in the uir&tream). Wastes and fuel arc injected ai the top of ihe chamber, into thefluidi/cd mass, where the mixture combusts. UK turbulent atmosphere in the chamberprovides good mixing of wastes to ensure complete combustion and efficient heat transfer.

. .trials are fed imo the furnace on a conveyor belt, and pass through on a wiremc*n twit. Healing elements provide infrared energy, oxidizing the materials. Waste gasesarc passed through H secondary combustion chamber; ash exits on the conveyor

Organics are slowly volatilized at lower temperatures lhan incineration processes. Waste isfed into the primary combustion chamber and thermally treated without sufficient oxygen 10completely combust. Volatilized organics pass to a secondary chamber and are incineraied.Solid residues from the primary chamber receive other treatment.

(Continued)

EXHIBIT A-l (Continued)

REMEDIATION TECHNOLOGY DESCRIPTIONS

Tedtnohtglc*

Wet Air Oxidation

Aqueous Thermal Decomposition

Description of IVmuss

The high temperature and high pressure propcriics of water iirc ulih/cd in destroyingwiislcs. Conianiinalcd solulHms arc i rcmcd at high temperatures (>dOO* (') ami pressures(3400 psi to 3700 psi). Contaminants arc oxidised 10 simple organic compounds as largeamounts of oxygen ore dissolved in solution.

Aqueous thermal decomposition works on the same principles as wei air oxidation, withoutthe addition ol excess oxygen.

Dechlorinalion

Glycolaie Dechlorinution

Biological Treatment

Composting

In-siiu Biode gradation

Slurry-phase Hiodcgradaiion

Solid-phase Uiodegradmmn

Using a specific solvent, chlorine atom(s) are removed from chlorinated haxardousmaterials, and toxic compounds are converted to less toxic, more water-soluble compounds.Reaction products are more easily removed from soil and more easily treated.

Contaminated material is mixed with bulking agents (e.g., sawdust, wood chips) and pkiccdin reactor vessels or piles. Aeration, temperature, and nutrient levels are controlled toencourage microNal growth. Microorganisms then metabolize contaminants, breaking themdown into less-harmful materials.

Microorganisms are encouraged to decompose contaminants in soil without excavating thesoil and placing it in a controlled reactor. Nutrients, oxygen, and other necessary materialscan be injected into the contaminated area.

The wastes arc mixed with water 10 achieve an aqueous mixture. 'Ilic mixture is thentreated in a bioreaciur, where it is mixed continuously 10 contact microorganisms andcontaminants. Tnc bioreiictor serves as a controlled environment for contaminantdegradation.

Soils are excavated and treated above ground so ihal treatment conditions can he closelymonitored and adjusted to conditions mat arc ideal lor niodegradation. Materials aretreated in ;i prepared area which can include volatile emissions collection anil leaehuiecollection.

(Continued)

EXHIBIT A-l (Continued)

REMEDIATION TECHNOLOGY DESCRIPTIONS

Technologies Description of Process

Vacuum/Vapor Extraction, Thermal Oesorplion

Low Temperature ThermalStripping

In-siiu Vacuum/Steam Infraction

Air, pressure, heat. and/or mechanical agitation provides ;i driving force for volatilizing andrenxjving contaminants from soil into an airstream tor further treiitmcm. Separatingcontaminants from soil simplifies the final treatment of conlaminanis.

VCK's arc removed from soil by applying a vacuum lu wells thai arc placed in (hecontaminated soil. VOC vapors are collected and treated above ground. Some systems alsoinjcet hot air or steam into contaminated /ones, raising temperatures and volatilizing organicchemicals.

ChemkHl Extraction A' Soil Wushlnjf

In-situ Chemical Treatmcni

Chemical Extraction & SoilWashing

In-situ Soil Flushing

Treatment chemicals are applied directly 10 contaminated soil. A variety ol compounds canbe applied, including neutralizing agents, oxklants. solidification/stabilization agents, andnutrients lor biological treatment.

Contaminants are washed from the excavated soil into a chemical solvent. The liquid istreated to remove and destroy contaminants, and the solvent is reused.

Inorganic or organic contaminants are extracted from soil by washing the soil with solvcnis.Solvents are recovered, contaminants are extracted, and the solvents are recirculatedthrough the soils.

InimuhllluUlon

Capping

SoJidilk t ion/Si iibiliziiiit in

In-silu Vitrification

Contaminated soil is covered with low-permeability layers of synthetic tcxliles or clay. Thecap is designed to limit infiltration of precipitation and thus prevent migration ofcontaminants away from the site and into ground wnicr.

Waste* arc convened to chemically stable lorms or arc hound in n stable matrix. Chcmic;ilreactions arc utilized to transform hazardous materials into new, non -hazardous niii tennis.The goal is to prevent migration of coniiiniinanis.

I'kxtrodes arc pkiced vertically into the contaminated soil region, and an decimal current isapplied. 'Ine MH! is UK Hod by the resulting high temperatures. When the melt anils andsolidifies, the resulting material is stable ami gla.vs-hkc, with contaminants bound in the solid.

(Continued)

EXHIBIT A-l (Continued)

REMEDIATION TECHNOLOGY DESCRIPTIONS

Technologies Description of Pim-ess

GROUND AND SURFACE WATKR

Nut u ml AM en tint Inn

Aeration/Air Stripping

Filtmllnn

Sedl men lu lion

Crtiniiliir Acllvuted Ciirhnn <<!AC)Adsorption

Ion Kxchunge

Chemical Treatment

Biological Treatment

Contaminants in an aquifer disperse and dilute through natural ground-water transport.Some natural degradation may occur.

Contaminants, usually volatile organic compounds, are transferred from liquid phase togaseous phase. By contacting contaminated water with clean air. dissolved VOCs ;irctransferred to the airsiream to create equilibrium between the phases. Ifte process takesplace in a cylindrical tower packed with inert material which allows sufficient air/watercontact to remove volatile* from water. Contaminants are then removed from theRtrslream.

Filtratkm removes suspended solids from liquids by passing the mixture through a porousmedium.

Solids that are more dense lhan liquid settle by gravity and can be removed from the liquidChemicals to aid settling may be added. Settled solids result in a sluilge'which may hetreated further.

(iAC is fKK.kcil in vertical columns, and coniiimmiiied water flows through it by gravity.GAC has a high surface area to volume ratio, and many compounds readily bond to thecarbon surfaces. Contaminants from water are thus adsorbed to the carbon, and diluentwilier has a lower contaminant concentration. Witter may be passed through sevcntl ofthese columns 10 complete contaminant removal, tycnt carbon (i.e., carbon that hasreached its maximum adsorption capacity) is regenerated by incineration.

As contaminated wutcr flows Ihrough the reactor vessel, ions of contaminants arc adsorbedto a synthetic resin in the vessel. The resin attracts and adsorbs contaminant ions, whilereleasing non-harmful ions into the treated water.

Chemicals can be added to contaminated waters to chemically change or to removeconstituents. Precipitation can be accomplished through pH control; solutions can beneutralized; contaminants can be oxidized; and solids can be settled out of solution

Microorganisms in controlled-cnvironmeni reactors are utilized to decompose contaminantsin water. Nutrients, pH, temperature, and oxygen availability are controlled 'Ihe organismsdegrade contaminants inio simpler, safer compounds

(Continued)

EXHIBIT A-l (Continued)

REMEDIATION TECHNOLOGY DESCRIPTIONS

Tedmologieft Description of Process

Membrane Separation

Kevcrsc Osmosis

Elect rodialysis

A scmi-pcrmcablc membrane is used to separate dissolved comamiittiins Irom liquids. Highpressure is applied in the contaminated solution, which drives only (he liquid through themembrane. The result ts a highly concentrated contuminaied solution on the high pressureside of the membrane, and a purified liquid on the opposite side of the membrane.

This process concentrates ionic species that are in aqueous solution. 'ITic solution is passedthrough aliernaie cation-permeable and iinKm-pennciiblc nKmbranes that have iin a|>plicdck'Ctric poicniial. 'Inis ptNcmial prtiviucs n driving lorcc I'or ion migratKMi.

EXHIBIT A-2

REMEDIATION TECHNOLOGIES AND SOME POTENTIALLY SIGNIFICANT RELEASES

Techftolufk* Air Wnler' Other11

SOU. AND SLUDGE TECIINOLOCIKS

Soil Iliindlintt

SIH! l-xciivaiion, Trtmsnort,Dumping. Screening andGrading

• Fugitive cniissitHix ofpaniculate* and volatile*

• Runoff or leaching ulcontaminants 10 surface orground water

• Seepage or lunoll lo ncitrhysoil

Thermal Instruction

Incineration: Rotary Kiln,Muklr/cd lied, CirculatingHcd, and Infrared

Pyrolysis

Wet Air Oxidation

Aqueous ThermalDecomposition

• Fugitive and slack emissionsof mciaJ fumes; paniculmcs,including meials and sales;and products of incompletecombustion, including organiccompounds, acid gases, CO,NO,, and SO,

• Fugitive and stack emissionsof metal fumes; puritculates,including meials and salts;unU products of incompletecombustion, including organiccompounds, acid gases, CO,NO,, and SO,

• Fugitive emissions of volatileorganic compounds

• Fugitive emissions of volatileorganic compounds

* Discharge of scrubber liquorand Mowdown

• Discharge of scrubber liquorand blowdown

* Discharge of metals andunoxidizcd oriranicsL "

• Discharge ot mciaK rindunoxidized organic*

• Disposal of ash and othersolid residues

• Disposal of ash anil othersolid residues

• Disposal of sludge residues

• Disposal of sludge residues

(Continued)

EXHIBIT A-2 (Continued)

REMEDIATION TECHNOLOGIES AND SOME POTENTIALLY SIGNIFICANT RELEASES

Trchnologki Air Water- Other*

DrfhlorlnflllfHt

Glycolaic Dcchlorinaiion * I'Ugitivc emissions of volatileorgiinic compounds

• Discharge of spent .solventsand degraded contaminantslo surface water, or leachingto ground water

Ilinloglcal Treatment

Composting

In-siiu HiodegraUaiion

•Slurry-prutse or Solid-phaseBtodcgradaiion

• Fugitive emtsMons ofptiriiculalcs und vobuilcorganics

• l;ugiiivc cmis-SHMW ol voluiitcorguoKS

• Fugitive emissions of volaiilcorganics

• Leaching of metals and/ororganics

• Leaching of mcuiLs and/ororganics

• Discharge of treated water

• Discharge of non-degradedbyproducts in slurry iKjuorand treated effluent

• Runoff to surface water or toground water (with solid-phase process)

• Disposal pf residual biomasswhich may containha/ardou.s metals .nulrefractory organics

Vncimm/Vftpor Extinction, TUcrmul Desorplinn

Low Temperature ThcrmiilStripping

In-siiu Vacuum/SteamInfraction

• Snick emissions of volatileorgiinics

• l-ugiiivc emissions ol. volatileorgiinics

• Tugitive cmissioivH of volatileorgiinics

• Discharge of .scrubberMowdown

• Discharge of contaminantcondcnsaic

• Discharge of contaminnnt orwater condensate

• Dispti&al or regeneration ofspent activiiicd c.irtxm

(Continued)

EXHIBIT A-2 (Continued)

REMEDIATION TECHNOLOGIES AND SOME POTENTIALLY SIGNIFICANT RELEASES

Technologies Air Water* Other*

Chemical Extraction & Soil Wnshiny

In-siiu Chemical Trcaimcni

Chemical or SolventIJCUildHNl

Sctil Waging

In-siiu Soil Flushing

• Fugitive emissions of voliiiilcorganic compounds

• Fugitive emissions of volatileorganic compounds

• Fugiiivc emissions of volatileorganic compounds

• Fugitive emissions of volatileorganic compounds

• Runoff of uncon tamedtreatment chemicals

• I'osl-cxtniciion discharge olwa-Stcwaicr with ex l rat ledconiaminanls

• Ptttl- washing discharge orwasicwiiicr with cxinicicdcontaminants

• Leaching of com am inn tedflush water, acids, bases,chetating agents, orsurfactants

• Possible solvent residuals intreated soil

• 1'os.siblc solvent residuals intreated soil

* Discharge of loam wnhmetals and organics

• Deposition of sedimentation. sludge residuals

* Deposition of untreated,contaminated fines

Immohilizntlnn

Capping

Solidification/Stabilization

• Fugitive emissions ofpariicuUiics and volatile*during cap construction

• Fugitive emissions olpaniculate* ami volatile*

• Leaching of contaminants toground water

• None likely

• Lateral movement of volatileorganic compounds alicrcapping

• Pole nt lal leaching to soilsand ground water olcontaminants from dcposiicdmaterial over time

(Continued)

EXHIBIT A-2 (Continued)

REMEDIATION TECHNOLOGIES AND SOME POTENTIALLY SIGNIFICANT RELEASES

Technologies

In-siiu Vitrification

Air

• Surface fugitive emissions ofvolatile organics and volatilemetals during the process

Water*

• Discharge of scrubbersolution

• Possible contamination nlground water under thetreatment area

Other*

* Potential lateral migration ofvaporized or leachedcon la m inn nt s into the soilthat .surrounds the vim licitmonolith

<;KOUNDWATKR AND SUKKACK WATKK TIXIINOLO<;II:SNon-Treatment Actions

Natural Atienuaiion

Pump without Treatment*

Air Stripping

FillnHion/Seltlinc

Granular Activated CarbonAdsorption

• Kmissions of volatile organiccompounds

• hmissiom of volatile organiccompounds

• Slack and fugitive emissionsof volatile organics

• Fugitive emissions of volatileorganic compounds fromsettling basin

• None likely

• Aquifer discharge to surfacewater

• Continued aquifer transportof coniaminanis

• Discharge of untreated waterto surface water or PubliclyOwned Treatment Works(POTW)

• Seepage of untreated water

• Discharge to surface water ofeffluent treated water withresidual metals, particulars,or nonvolatile organies

• Discharge of effluent watercontaining dissolved solids orun re moved particles

* Discharge of effluent withnon-adsorbabk:, lowmolecular weight compounds

* Disposal of sludge icsidualsfrom HOTW

• Disposal of backwash orcleaning residues

s

• Disposal of Tiller cake orsludge containing organics,mcials, or other inorganics

• Disposal and/or regenerationof spent carbon

(Continued)

EXHIBIT A-2 (Continued)

REMEDIATION TECHNOLOGIES AND SOME POTENTIALLY SIGNIFICANT RELEASES

Tvi-hniihifgle*

Ion Kxcliun|f«

Chemical Treatment

Biological Treatment

Air

• None likely

• fugitive emissions of volatileorganic UNiirx Hinds fromircnimcnl tanks

• tuni&sions of volatile organic*in aerobic treatment or dueto aeration

Wilier'

• Discharge ol backwash water

• Discharge of diluent withircnimcnl residues

• Discharge of effluent withunremovcd solids

Oilier11

• Dispusal and/or regenerationol spent resins

• Disposal of treatmentsludges

• Disposal of treatmentsludges

Membrane Separation

Reverse Osmosis

i

Etecirodialysts

• None likely

• None likely

• Discharge of effluentcontaining un filtered organics(depends on filler membraneused)

• Discharge of treated clllucni

• Discharge of concentratestream with contaminantsremoved irom treated water

• Discharge of concentratestream with contaminantsremoved from treated water

Notes:

" In general, seepage and leaching are more likely to affect ground wiitcr. hut could also contaminate surface water. Uunofl and discharge are releases that will nmsilikely contaminate surface water, hut coukl also contaminate ground water.

h Other releases include ircnimcnl residuals that need lurthcr treatment or proper disposal. In most cases, this column refers to sludge or solid residues thai may alsohe hazardous.

REFERENCES FOR APPENDIX A

Peavy, Howard S., Donald R. Rowe, and George Tchobanoglous. 1985. Environmental Engineering. McG raw-Hill, New York.

U.S. Environmental Protection Agency (EPA). 1987. A Compendium of Technologies Used in the Treatmentof Hazardous Wastes. Center for Environmental Research Information. EPA/625/8-87/014 (NTIS PB90-274093/XAB).

EPA. 1988. Technology Screening Guide for Treatment of CERCLA Soils and Sludges. Office of Research andDevelopment. EPA/540/2-88/004 (OSWER Directive 9380.0-25, NTIS PB89-132674).

EPA. 1989. Summary of Treatment Technology Effectiveness for Contaminated Soil, Office of Emergency andRemedial Response. EPA 540/2-89/-53.

EPA. 1990. National Technical Guidance Series, Air/Superfitnd Manual, Volume 3. Office of Air QualityPlanning and Standards. EPA-450/1-89-003 (NTIS PB89 180061/AS).

EPA 1990. The Superfund Innovative Technology Evaluation Program, Progress and Accomplishments FiscalYear 1989. Office of Solid Waste and Emergency Response. EPA/540/5-90/001 (NTIS PB90-216516/XAB).

EPA. 1991. Comments from Laurel Staley, Ed Bates, Ron Lewis, Ten Shearer, John Herrmann, PauldePercin, Ed Barth. Coordinated by Mary Gaughan, Superfund TechnotogyJ^eraoiuiraiioaGroup, Cincinnati,Ohio.

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APPENDIX BQUANTIFYING POTENTIAL RELEASES FROMSELECTED REMEDIATION TECHNOLOGIES

Remediation activities at hazardous waste siteshave the potential to cause emissions and impactsin addition to those being addressed. Potentialemission sources during remediation include pointsources of treatment residuals such as incineratorstacks; fugitive emissions from treatmentequipment leakage; and areal sources of volatileorganics and fugitive dusts from the disturbedsurface of & contaminated'land area. Uncontrolledreleases can result in exposures to contaminants insoils, surface water, ground water, and ambient airsurrounding the treatment equipment Thefollowing sections provide descriptions of severalcommon remediation activities to serve asexamples of the considerations involved inquantifying technology-specific releases. Thisappendix also contains a list of references that canbe useful in quantifying potential air releases for avariety of remediation technologies.

B.1 SOILS HANDLINGTECHNOLOGIES

Soils handling is a major component of nearlyall ex-situ technologies for treating contaminatedsoils. Soil handling activities include: excavation;transportation (e.g., to storage or treatment areas);dumping (e.g., onto trucks or piles); storage; andgrading the treated or replaced soil Any or all ofthese activities may result in fugitive dustemissions, the main type of release from soilshandling. These emissions can carry organicand/or inorganic contaminants, which may bebound to soil particles, for great distances awayfrom the site. Soil handling activities also canincrease volatile organic emissions by exposingcontaminated soil to the atmosphere, and throughagitation of the soil.

Some of the important parameters that mayaffect the fugitive dust emissions potential at acontaminated site are listed in the box below.These parameters depend on site and remedialactivity characteristics. Details can be obtainedfrom onsite observation or from vendors and/or

operators. Some or all of these parameters mayalready have been considered in the RI/FS.Fugitive dust emission factors (mass per unitoperation) or rates (mass per unit time, derivedfrom emission factors) for volatile organic,paniculate and/or metal contaminants during eachsoil handling remedial activity can be estimatedusing equations and procedures outlined in thedocuments listed in Section B.4. These emissionfactors or rates can be used as inputs to fate andtransport models, which are used to generateexposure point concentrations. Additionalinformation on exposure assessment can beobtained from Chapter 2 of this guidance andChapter 6 of RAGS/HHEM Part A.

KEY PARAMETERS AFFECTINGRELEASES FROM SOILS HANDLING

Area of working surfaceAgitation factorDrop height (when transferring soil)Storage pile geometrySoil moisture contentSoil silt contentMeteorological conditionsChemical characteristics

B.2 THERMAL DESTRUCTIONTECHNOLOGIES

Thermal destruction uses high temperatureand controlled conditions to oxidize and/or degradea-substance into simple combustion products suchas CO2, H2O vapor, SO2. NOr HC1 gases, and ash.Thermal destruction methods can be used todestroy organic contaminants in liquid, gaseous,and solid waste streams. Incinerators are by farthe best known and most studied thermaldestruction devices. In many cases, thermaldestruction techniques that do not have sufficient

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emission data can be assumed 10 have emissioncharacteristics similar to incinerators.

Emission sources from incinerators includeprocess emissions and fugitive emissions,incinerator process emissions include stack gas,bottom ash, and air pollution control deviceresiduals. Fugitive emissions include uncontrolledor undetected equipment leakage. Processemission estimation methods for organiccompounds, metals, particulates, and acid gases(HC1, SO2, and HF) can be obtained from EPA(1985a) (see Section B.4.1). Fugitive emissionsources and equations for estimating emissions aredetailed in EPA (1989) (see Section B.4.1) andHolton and Travis (1984) (see Section B.4.3).Fugitive emissions from soils handling prior toincineration can be estimated using the guidancegiven in Section B.I on soils handling.

Emissions from thermal destructiontechnologies generally can be estimated using anyone of the approaches listed below. (Thesemethods do not directly account for removal ofcontaminants by air pollution control devices thatmay be used to treat emissions from thermaldestruction devices.)

• Default approach: Thermal destruction devicesat most contaminated sites may be required tomeet the requirements under federalregulations such as RCRA or the ToxicSubstances Control Act (TSCA), since theserequirements are generally considered ARARs.RCRA requires at least 99.99% destructionand removal of regulated organic constituentsfrom wastes. TSCA requires 99.9999%destruction and removal for wastes containingPCBs and dioxins. Thus, organic emissionsfrom thermal destruction of hazardous wastecan be estimated by assuming that the aboverequirements of RCRA and TSCA will beexactly met, for pollutants covered by thoseregulations. Similar requirements can be usedto estimate HO emissions, but this approachmay not provide estimates for paniculate orair emissions.

• Trial run approach: Federal regulations suchas RCRA and TSCA require trial burns todemonstrate removal efficiencies. Whenevertrial burn data for the waste in question existthey can be used to estimate the emissionsthat might occur during actual remedyimplementation. Data obtained from trial

hums at different sites or different operableunits from the same site can be used torestimating emissions.

• Theoretical or empirical approach:Theoretical or applicable empirical equations— often called models — can be used toestimate emissions. These models correlateincinerator operating parameters and pollutantemission rates.

Some of the important parameters that mayaffect the emissions associated with thermaldestruction technologies are listed in the boxbelow. Many of these parameters are devicedependent and can be obtained from onsiteobservation or from vendors and/or operators.

Waste feed rateBurn temperatureResidence timeExcess air rateFacility size/typeAtomizationControl device efficiencyChemical characteristics

BJ SOLIDIFICATION/STABILIZATIONTREATMENTTECHNOLOGIES

Solidification/stabilization technologies areused to immobilize the toxic and hazardousconstituents in the waste by changing thoseconstituents into immobile forms, binding them inan immobile, insoluble matrix, and/or binding themin" a matrix that minimizes the material surfaceexposed to solvents. Except for emergingtechnologies that involve in-situ treatment, theimplementation of stabilization or solidificationgenerally involves several of the soils handlingactivities discussed in Section B.I. The box belowlists some of the key parameters affecting releasesassociated with solidification/ stabilization. Theseparameters depend on the s p e c i f i c

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solidification/stabilization process. These can beobtained from onsiie observation or from vendorsand/or operators.

KEY PARAMETERS AFFECTINGRELEASES FROM

SOLIDIFICATTON/STABIUZATIONTREATMENT TECHNOLOGIES

Binder typeBatch sizeWaste/binding agent ratioMixing time/efficiencyCuring timeMeteorological conditionsChemical characteristics

B.4 REFERENCES FORDETERMINING RELEASESRESULTING FROMREMEDIAL ACTIVITIES

Provided below are references containingdiscussions of remedial activities andmethodologies for determining releases associatedwith these activities. The references presentedunder the heading of various remedial activitiescontain information regarding the majority ofremedial activities that may occur at a site(including soils handling, thermal destruction, andstabilization/solidification). The remainingreferences contain information specific to theactivity listed in the heading. See the referencesprovided for the main text of RAGS/HHEM PanC, especially the Rl/FS Guidance (EPA 1988c), foradditional references.

B.4.L VARIOUS REMEDIAL ACTIVITIES

Primary References

Environmental Protection Agency (EPA). 1985a.Handbook: Remedial Action at Waste DisposalSites (Revised). Hazardous Waste EngineeringResearch Laboratory. EPA/625/6-85/006(NTIS PB87-201034/XAB).

Provides information on remedialtechnologies, selection of appropriateremediation technologies for a given wastesite, and planning remedial activities. Includes

discussions of ensile and offsite disposal ofwastes and soil, removal and containment otcontaminated sediments, and i n - s i t utreatments.

EPA. 1989. Estimation of Air Emissions fromCleanup Activities at Superfund Sites.Air/Superfund National Technical GuidanceStudy Series, Volume 3. Office of Air QualityPlanning and Standards. EPA/450/1-89/003(NTIS PB89-18006i/XAB).

This document provides a step-by-stepprotocol for estimating air quality impactsresulting from site remediation. Presentsemissions estimation techniques for thermaldestruction devices, air stripping of groundwater, in-situ venting, soils handling, andsolidification/stabilization.

Additional References

EPA. 1990. Emission Factors for SuperfundRemediation Technologies. Draft. Office ofAir Quality Planning and Standards.

EPA. 1988. Superfund Removal ProceduresRevision Number Three. Office of Emergencyand Remedial Response. OSWER Directive9360.03B.

EPA. 1986. Superfund Remedial Design andRemedial Action Guidance. Office ofEmergency and Remedial Response. OSWERDirective 9355.0-4A.

B.4.2 SOILS HANDLING

Primary References

EPA. 1985b. Af-42: Compilation of Air PollutionEmission Factors, Fourth Edition. Office ofAir and Radiation. NTIS PB86-124906.

This document contains emissions dataobtained from source tests, material balance

- studies, engineering estimates, and other" sources. Emission factors and equations are

derived from sand and gravel processing(Section 8.19.1), crushed stone operations(Section 8.19.2), surface coal mining (Section8.2.4), and fugitive dust sources (Seaion 112)

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EPA. I985c. Rapid Assessment of Exposure toParriculate Emissions from' SurfaceContamination Sires. EPA/600/A-85/002.

This document provides a methodology forrapid assessment of inhalation exposures torespirable paniculate emissions from surfacecontaminated sites. The methodology consistsof a site survey procedure and particulateemission factor equations for wind andmechanical emrainmem processes.

EPA. 1990. Development of Example Proceduresfor Evaluating the Air Impacts of SoilExcavation Associated with Superfiind RemedialActions. Office of Air Quality Planning andStandards. EPA/450/4-90/014 (NTIS PB90-255662/XAB).

This document identifies and definescomputational requirements for estimating airimpacts from remediation of CERCLA sites.The estimation of air impacts from twoexample sites employing soil excavation arediscussed. Modified Research TriangleInstitute (RTI) land treatment equations areused for calculating emissions fromexcavations.

Additional References

Baxter, R.A. and D.M. Wilbur. 1983. fugitiveParticulate Matter and Hydrocarbon EmissionFactors from Mining, Handling, and StoringDiatomite. AeroVironmem, Inc. Pasadena,California.

EPA. 1977. Technical Guidance for Control ofIndustrial Process Fugitive PaniculateEmissions. Office of Air Quality and PlanningStandards. EPA/450/3-77/010 (NTIS PB-272288/2).

EPA. 1985& Modeling Remedial Actions atUncontrolled Hazardous Waste Sites, Office ofEmergency and Remedial Response. Office ofSolid Waste and Emergency Response.EPA/540/2-85/001 (OSWER Directive9355:0-8).

Orlemann, J.A. and G.A. Juize. 1983. FugitivePaniculate Dust Control Technology. NoyesPublications. Park Ridge, New Jersey.

B.4.3 THERMAL DESTRUCTION

Primary References

HoltontG.A. and C.C. Travis. 1984. Methodologyfor Predicting Fugitive Emissions fo rIncinerator Facilities. Environmental Progress3:2. Oak Ridge National Lab., Health &Safety Research Division. Oak Ridge, TN.

Error analysis and Monte Carlo modelingtechniques are used to predict fugi tiveemissions caused by leaky pump fittings,sampling connections, flanges, storage tanks,and other non-stack equipment. Tenequations and three parameter value tables areprovided for emission calculations.

Travis, C.C, E.L. Etnier, G.A. Holton, F.R.O'Donnel, and D.M. Hetrick. 1984.Inhalation Pathway Risk Assessment ofHazardous Waste Incineration Facilities. OakRidge National Lab. Oak Ridge, Tennessee.ORNl/TM-9096.

This report-evaiuates the relative-importanceof plant design and waste physicochemicalvariables on human inhalation exposure andhealth risk using two hypothetical incinerationfacility designs of three sizes each, burningthree different generic wastes. Fugitiveemissions are calculated using equationsrelating incinerator facility operation andconfiguration to fugitive emissions.

Trenholm, A. and D. Oberacker. 1985. "Summaryof Testing Program at Hazardous WasteIncinerators." Proceedings — Annual SolidWaste Research Symposium. EnvironmentalProtection Agency. Cincinnati, Ohio. ReportNo. CONF-8504112.

This article summarizes the results of testsconducted at eight full-scale hazardousincineration facilities.

Additional References

CheremisinoEf, P.N. 1986. 'Special Report:Hazardous Materials and Sludge Incineration."Journal of the Air Pollution Engineering18:12(32-38).

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EPA. 1984. Performance Evaluation of Full-scaleHazardous Waste Incinerators. (Fivevolumes.) Industrial Environmental ResearchLaboratory. Cincinnati, OH. EPA-600/2-84-181 a-e (NTIS PB85-129500).

Lee, CC, G.L. Huffman, and D.A. Oberacker.1986. "Hazardous/Toxic Waste Incineration."Journal of (he Air Pollution Control Association36:8.

Oppelt, E.T. 1987. "Incineration of HazardousWaste, A Critical Review/ Journal of the AirPollution Control Association. 37:5.

Staley, LJ., G.A. Holton, F.R. O'Donnel, and CA.Little. 1983. "An Assessment of Emissionsfrom a Hazardous Waste Incineration Facility,Incineration and Treatment of HazardousWaste." Proceedings of the Eighth AnnualResearch Symposium. EPA-600y9-83/003.

Wallace, D.D., A.R. Trenholm, and D.D. Lane.1985. "Assessment of Metal Emissions fromHazardous Waste Incinerators." Proceedings —78th APCA Annual Meeting. Paper 85-77. AirPollution Control Association. Pittsburgh,Pennsylvania,

B.4.4 STABILIZATION/SOLIDIFICATION

Primary References

Cullinane, M.J., LW. Jones, and P.O. Malone.1986. Handbook for Stabilization/Solidificationof Hazardous Waste. Hazardous WasteEngineering Research Laboratory. EPA/540^2-86/001.

Hill, R.D. 1986. Stabilization /Solidification ofHazardous Waste. Hazardous WasteEngineering Research Lab. EPA/600/D-86/028.

This document discusses techniques such assorption, lime-fly ash Pozzolan process,Pozzotan-Portland process, thermoplasticmicroencapsulation, ar.d other techniques.

Additional References

Cullinane, MJ. and L.W. Jones. 1985. Handbookfor Stabilization/Solidification of HazardousWaste. Prepared for: EnvironmentalProtection Agency, Hazardous. WasteEngineering Research Laboratory. Office ofResearch and Development. EPA/540/2-86-001.

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APPENDIX CSHORT-TERM TOXICITY VALUES

The short-term effectiveness criterion forevaluating remedial alternatives includes anevaluation of the risks due to the short-termexposure of populations to contaminants duringremedy implementation. Such short-term risksgenerally include both baseline risks from existingsite contamination and new risks that would occurduring the implementation of a remedy. In somecases, potential exposures and risks due to short-term exposures should be quantitatively assessed;however, there is no simple or widely acceptedmethod for estimating such risks. Therefore, in allcases where short-term toricitv values are needed,TSC should be consulted. EPA's EnvironmentalCriteria and Assessment Office (ECAO; whereTSC is located) will maintain the data files for themost appropriate short-term toxicity values forevaluating risks from remedial alternatives. Toobtain the most up-to-date information, regionalEPA CERCLA staff must contact:

Superfund Health Risk TechnicalSupport Center

Environmental Criteria and Assessment OfficeU.S. Environmental Protection AgencyMail Stop 11426 West Martin Luther King DriveCincinnati, OH 45268Phone: 513-569-7300 (FTS-684-7300)FAX: 513-569-7159 (FTS-684-7159)

Requests from others must be submitted to theTSC in writing and must contain the followinginformation for consideration:

* CERCLA site name, site location, and 12-digitsite number;

* name and phone number of the RPM; and

* detailed description of the risk assessmentrelated question.

The remainder of this appendix provides somegeneral background on exposure duration issuesand an overview of some of the existing methods

for deriving short-term human health toxicityvalues.

Cl BACKGROUND ONEXPOSURE DURATION

In assessing short-term risks of remedialalternatives, the time frame (e.g., hours, days,weeks up to seven years) is generally of a muchshorter duration than that identified in thebaseline risk assessment Nevertheless, there area number of types of toxicity values that have beendeveloped to characterize risk due to these short-term exposures. Some of these types depend onconcentration- or dose-based threshold limits thatare used as guidance levels for protection ofspecific populations from specific exposures (e.g.,guidance levels intended to protect healthy workersfrom daily occupational exposure to chemicals inthe workplace). In this section, the types ofexposure durations commonly suggested or impliedby the toxicity value types (discussed later) arepresented.

Releases that may occur during remedyimplementation could last for varying durationsbut are expected, in most if not all cases, to giverise to less-than-lifetime exposures. Furthermore,releases that occur during remediation may resultin exposure levels much higher than thosepreceding remediation. Different risk levels maybe associated with these different exposuredurations (assuming the same dose rate) and withvarious exposure concentrations. Therefore, it isimportant that the dose- or concentration-basedtoxicity values that are chosen to characterize theshort-term risks be based on appropriate exposuredurations. Exposure durations associated withexisting methods for characterizing short-term risksinclude hours, days, weeks, months, and years(generally up to seven years).

Currently, RAGS/HHEM Part A defines threeexposure durations, apart from long-term exposure,that may be of concern at CERCLA sites: single

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exposure event, very short-term exposure, andshort-term (subchronic) exposure.

Single Exposure Event. The majority ofchemicals are capable of producing an adversehealth effect after a single exposure event,depending on the intensity of exposure. Fordevelopmental toxicants, irritants, andneurological poisons, a single, low levelexposure event can result in effects afterminutes, hours, or a day.

• Very Short-term Exposure. For some acutetoxicants, multiple exposures over several dayscould result in an adverse effect. For thesechemicals, the exposure is assessed over daysor weeks (up to two weeks).

* Short-term (Subchronic) Exposure. Exposurelasting anywhere from two weeks to sevenyears to low concentrations of a chemical canalso produce adverse effects; this exposure isassessed by averaging it over the specificduration.

During evaluations of remedial alternatives, itmay be important to assess exposure (and risk orhazard) for all relevant exposure durations. Boththe shortest time period of exposure, from peak oraccidental releases, to the cumulative exposureover the entire time period of the remedyimplementation, may need to be considered.Quantitative assessment is contingent, however,upon the availability of adequate exposurecharacterization. Exposure models used to predictconcentrations have not for the most pan beenvalidated over the short durations considered forsingle exposure events (e.g., minutes to hours). Atbest, meteorological data are collected on anhourly basis at a site removed from the location ofinterest; using these data to derive a model topredict exposure concentrations for durationsshorter than those for the meteorological data mayproduce results that could not be supportedscientifically. In addition, the need to evaluatepeak exposures as well as longer-term averageexposures during remedy, implementation dependson a number of considerations, including thedegree of risk or hazard associated with the longer-term exposure and the difference between thepredicted peak and average exposureconcentrations.

A review of the types of (duration-specific)toxicity values that are available (discussed later in

this appendix) indicates that a number of the t \pcscorrespond to various durations thai are relevantto releases during remedy implementat ion.Because a toxicity value generally is specific to acertain duration, however, risk may need to becharacterized separately for the three short-termexposure durations.

C2 EXISTING SHORT-TERMTOXICITY VALUES

In this section, commonly encountered short-term toxicity values are summarized. These valuesare: (1) concentration and dose threshold valuesprimarily for noncarcinogenic effects; and (2)specific short-term carcinogenic risk values. Asection is provided on each of these toxicity valuecategories.

C.2.1 TOXICITY VALUES FOR ASSESSINGRISK OF NONCARCINOGENICEFFECTS FOR SHORT-TERMEXPOSURE

Toxicity values designed to characterize therisk of noncarcinogenic effects are summarized inthe following subsections. Further information onthe suitability of these values for various CERCLAexposure scenarios can be obtained from the TSC.

C.2.1.1 Developmental Toxicant Reference Dose(R(D4I) and Reference Concentration

RfDdls and RfCdts are developed for chemicalsthat have been shown to cause adverse effects in adeveloping organism. EPA's Human HealthAssessment Group of the Office of Health andEnvironmental Assessment is in the process ofdeveloping RfD^, and RfCdt values and themethodology for their derivation. As proposed byEPA (EPA 198%), these values. will likely bederived from the no-observed-adverse-effect-level(NOAEL) or lowest-observed-adverse-effect-level(LOAEL) in a manner consistent with thederivation of reference doses (RfDs) and referenceconcentrations (RfCs), and without adjustment forshort exposure duration. RfDjjS are expressed interms of dose and RfCd(s are expressed as an airconcentration. Additional information on thesecriteria is available in EPA's ProposedAmendments to the Guidelines for the HealthAssessment of Suspected Developmental Toxicants(EPA 198%), or by contacting the Reproductive

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and Developmental Toxicology Branch of theOffice of Health and Environmental Assessment at202-260-7331 (FTS-260-7331).

Currently (i.e., at the date of publication ofthis guidance), developmental toxicity is consideredin the derivation of EPA criteria fornoncarcinogenic effects (including RfDs and RfCsfor subchronic and chronic exposure and drinkingwater Health Advisories [HAs]). That is, thesecriteria are set at levels considered protective fordevelopmental effects as well as for othernoncarcinogenic effects.

C.2.1.2 Subchronic Reference Dose (RID,) andReference Concentration (RTC,)

RfDss and RfCss are developed by ECAO andare used to characterize potential noncarcinogeniceffects associated with short-term exposures (twoweeks to seven years as defined in RAGS/HHEMPart A). To date, approximately 305 RfDss and 60RfC$s have been published. These RfDs and RfCsare developed based on NOAELs or LOAELsidentified from subchronic (i.e., usually >.90 daysbut less-than-chronic) toxicity studies. RfDjS areexpressed in terms of dose and RfCjS are expressedas air concentrations. Subchronic RfDs and RfCsare available in HEAST. The derivation of RfD,sis described in more detail in RAGS/HHEMPart A.

C.2.1 J One*day, Ten-day, and Longer-termDrinking Water Health Advisories (HAs)

Drinking water HAs developed by EPAprovide guidance to assist state and local officialsresponsible for public health protection duringemergency situations involving drinking watercontamination. HAs are derived in a mannerreasonably consistent with oral RID methodology.Accordingly, these HA values constitute suitablecriteria for evaluating short-term oral exposure.The HA concentrations include a margin of safetyto protect sensitive members of the population(e.g., children, the elderly, pregnant women)."One-day HA' is the term used to describe theconcentration of a chemical in drinking water thatis not expected to cause any adversenoncarcinogenic effects for one day of exposure,with a margin of safety. The "Ten-day HA"describes the concentration of a chemical indrinking water that is not expected to cause anyadverse noncarcinogenic health effects for two toten consecutive days of exposure, with a margin of

safety. The "Longer-term HA" is the concentrationof a chemical in drinking water that is notexpected to cause any adverse noncarcinogeniceffects up to approximately seven years ofexposure. ("Lifetime HAs" that are protective forexposure over a lifetime are also developed basedon chronic RfDs.)

In general, the HAs described here areprotective of only noncarcinogenic effects. Thesevalues are expressed as concentrations in drinkingwater but can be converted to mg/kg/day doses byusing the assumptions that were applied in theircalculation: consumption of 1 L/day by a 10 kgchild (one-, ten-, and longer-term HAs) and 2L/day by a 70-kg adult (lifetime HA).Approximately 140 HAs have been developed byEPA for each exposure duration. (HAs are brieflydescribed in RAGS/HKEM Part A.)

C.2.1.4 Acute Inhalation Criteria (AIQ

A report describing the derivation of AlCs forbenzene and beryllium is available through theTSC AlCs are derived as criteria for single, short-duration (up to an hour era few. hours) inhalationexposures, as may occur from releases duringremediation. The AlCs are based on noncancerendpoints and are expressed as air concentrations.AICs have been derived for a limited number ofchemicals using EPA RfC methodology, modifiedas required for this acute exposure scenario. Themodification consists of using the NOAEL (orLOAEL) as reported in the study withoutadjustment for exposure duration (hours/24 hours).Because these criteria are conceptually consistentwith inhalation RfCs, they are a good basis forassessing short-terra risks from single, very shortexposures. The TSC should be contacted foradditional AIC values.

C2.L5 Minimal Risk Level* (MRLs)

MRLs are derived by the Agency for ToxicSubstances and Disease Registry (ATSDR) fromhuman or animal studies for threshold effects onchemicals found at CERCLA hazardous wastesites. MRLs are developed for both inhalation andoral exposures; oral MRLs are expressed as dosesand inhalation MRLs are expressed asconcentrations in air. Estimates of exposureposing minimal risk to humans are made for themost sensitive noncarcinogenic endpoim (includingdevelopmental and reproductive endpoints) forthree different exposure durations (i.e., acute.

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intermediate, and chronic). These exposuredurations for which MRLs are derived are asfollows: acute MRL — 1 to 14 days; intermediateMRL - 15 to 364 days; chronic MRL — >365days. MRLs are developed using an approach thatis consistent with EPA RfD methodology (i.e.,identification of a NOAEL or LOAEL andapplication of uncertainty factors to reflect humanvariability and, where appropriate, the uncertaintyof extrapolating from laboratory animal data tohumans).

Acute inhalation MRLs differ from AIC inregard to adjustment for exposure duration. Theguidance for derivation of acute inhalation MRLsspecifies that "exposure periods of less than 24hours in the toxicity study from which the MRL isderived, can be adjusted to one day" (ATSDR1991); this adjustment is commonly carried out.No such adjustment is carried out in the derivationof AlCs, which are intended to serve as guidancefor acute, very short, and single exposures (e.g.,ranging from less than an hour to a few hours,perhaps as inadvertent releases duringremediation).

MRLs can be found in the ATSDRToxicological Profile documents in the HealthEffects Summary section, on the Levels ofSignificant Exposure figure (graph). The bottomof the dotted line on the graph represents theMRL. Except in the earliest ATSDR ToxicologicalProfiles, MRL values and the endpoints on whichthey are based are also identified in the textaccompanying the figure. To date, approximately62 acute MRLs (38 oral, 24 inhalation) have beenderived by ATSDR. As with other short-termtoxicity values, guidance regarding use of the MRLmust be sought from the TSC

C.2.1.6 Emergency Exposure Guidance Level(EEGL), Short-term Public EmergencyGuidance Level (SPEGL), andContinuous Exposure Guidance Level(CEGL)

EEGLs and CEGLs are exposure guidancelevels developed by the National Research Council(NRC 1986) specifically for military personneloperating under emergency conditions. Therefore,setting of these levels involves consideration ofvarious factors (such as age distribution, length ofexposure, and susceptibility) that are different fromthose related to the general population. Theseguidance levels are published in the NRC (1984-

1988) Emergency and Continuous ExposureGuidance Levels for Selected AirborneContaminants. To date, 43 chemicals have beenevaluated by NRC.

The EEGL is defined as the air concentrationof a substance that is acceptable for theperformance of specific tasks during rareemergencies usually lasting from I to 24 hours(i.e., it is a ceiling guidance level for a singleemergency exposure) (NRC 1986). EEGLs areintended to prevent irreversible harm or seriousimpairment of judgment or performance.Exposure at an EEGL might produce reversibleeffects, and therefore should not be consideredhygienic or safe. Acute toxicity is the primarybasis for establishing an EEGL. However, evenbrief exposure to some substances might have thepotential to increase the risk of cancer or otherdelayed effects. Derivation of an EEGL mayinvolve application of an uncertainty factor of tento extrapolate from animal data to humans, but noother species adjustments are applied. SomeEEGLs are based on extrapolation of oral data.EEGLs are based on the most sensitive or mostimportant noncarcinogenic health effects known.Because EEGLs are derived for healthy militarypersonnel during rare emergencies, and are notintended to protect against reversible effects, theyshould not be applied directly to the generalpopulation (NRC 1986).

The SPEGL is defined as a suitableconcentration for unpredicted, single, short-termemergency exposure of 1 to 24 hours of the generalpublic SPEGLs take into account the wide rangeof susceptibility of the general public The SPEGLis generally estimated by applying an uncertaintyfactor of two to ten to the EEGL, to account forsensitive groups — such as children, the elderly,and persons with serious debilitating diseases.NRC (1986) suggests that a safety factor of two(Le., EEGL x 0.5) is appropriate to protect moresensitive groups, such as children or the elderly,and that a safety factor often (i.e., EEGL x 0.1) isappropriate for fetuses or newborns. Because theSPEGL is derived from the EEGU theconsiderations discussed above with regard to theEEGL also apply to SPEGLs.

The CEGL is defined as a ceilingconcentration of a chemical in air to which militarypersonnel can be exposed for up to 90 dayswithout immediate or delayed adverse effects ordegradation of performance (NRC 19S6). CEGU

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are not derived for carcinogens. When data fromchronic studies are available, they can be used toderive CEGLs. A CEGL is generally estimated,however, by applying an uncertainty factor of 10 to100 to the EEGL (i.e., EEGL x 0.01 to 0.1),depending on the evidence for detoxification oraccumulation of the substance in the body. Wherethere is evidence of substantial detoxification, asafety factor of ten is recommended by NRC(1986). If there is no evidence of detoxification ordetoxification is slow, a safety factor of 100 mightbe more appropriate. If the substance accumulatesin tissues, such as halogenated biphenyls andmetals, even higher factors are recommended byNRC (1986). Other considerations discussed withregard to the EEGL also apply to CEGLs derivedfrom EEGLs.

C.2.1.7 Threshold Limit Values -• Short-termExposure Limits (TLV-STELs),Threshold Limit Values —Time-weighted Averages (TLV-TWA), andThreshold Limit Values — Ceiling(TLV-C)

TLVs- are -concentrations developed by theAmerican Conference of Governmental IndustrialHygienists (ACGIH) to protect workers fromadverse effects of occupational exposure toairborne chemicals. However, becauseoccupational exposure limits are not intended toprotect sensitive workers or other populations, arenot intended for the assessment of community airpollution or continuous exposure, may notincorporate the most recent lexicological data, maybe based on unpublished documentation that is notavailable for review, and may differ from EPAderivations with respect to weight-of-evidenceconsiderations and use of uncertainty factors, EPAdoes not endorse the general use of occupationalexposure limits in deriving EPA criteria. Inaddition, it should be noted that the TLVs for afair number of chemicals are derived by analogy toother chemicals because health effects data areinadequate or lacking.

The TLV-STELs are 15-mimite time-weightedaverage (TWA) exposures that should not beexceeded at any time during the eight-hour workday/40-hour work week and should not occur morethan four times a day, with at least 60 minutesbetween successive exposures in the STEL range(ACGIH 1990), The TLV-STEL is established toprevent workers from suffering irritation, chronicor irreversible tissue damage, or narcosis of

sufficient degree to increase the likelihood ofaccidental injury. Use of the TLV-STEL should belimited to very short, single exposure events.STELs are recommended for substances with acuteeffects recognized from high short-term exposuresin either humans or animals (ACGIH 1990).Approximately 115 TLV-STEU have beenpublished by ACGIH.

The TLV-TWA is the time-weighted averageconcentration for a normal eight-hour workday/40-hour workweek to which nearly all workers may beexposed, day after day, without adverse effects.The TLV-C is a concentration that should not beexceeded during any pan of the working exposure.The ACGIH uses the TLV-C for substances thatare particularly fast acting and hence are bestcontrolled by a ceiling limit In excess of 500TLV-TWAs and fewer than 50TLV-Cs have beenpublished by ACGIH.

C2.1.8 Permissible Exposure Levels (PELs) andRecommended Exposure Units (RELs)

PELs are enforceable occupational exposurestandards developed by the Occupational Safetyand Health Administration (OSHA). They aremeant to protect workers against catastrophiceffects (such as cancer, cardiovascular, liver, andkidney damage; and lung diseases) as well as moresubtle effects resulting in central nervous systemdamage, narcosis, respiratory effects, and sensoryirritation. The PELs are generally adopted from(existing) secondary guidance levels (e.g., ACGIH'sTLV-TWAs and TLV-STELs and therecommended exposure limits [RELs] developed bythe National Institute for Occupational Safety andHealth [NIOSH]), and nearly 400 are availablefrom OSHA. EPA's reservations concerning theuse of TLVs as the basis for criteria to protect thegeneral population (see Section C.2.1.7) apply alsoto PELs and RELs.

C2.L9 Other Miscellaneous Methods

The following are some other methods thatrisk assessors or RPMs may encounter.

• Immediately Dangerous to Life and Health(IDLB) Guidelines. IDLH guidelines aredeveloped by NIOSH. These air concentrationlimits are for 30-minute exposures under whatare essentially emergency conditions, andgenerally far exceed corresponding TLV-TWA,TLV-STELs or PELs. IDLH guidelines wete

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determined only for the purpose of respiratorselection. These guidelines are intended to bethe maximum air concentration from which, inthe event of respirator failure, a worker couldescape within 30 minutes without experiencingany escape-impairing or irreversible healtheffects (NIOSH 1985). Many of the IDLHexposure levels are so high that they definelevels at which severe toxic effects(unconsciousness, incapacitation, intolerableirritation or death) would be likely (AJexeef etal. 1989). Therefore, the IDLH guidelines arenot suitable as benchmark euidelines for acuteexposure and mav be hicher than would beuseful even as a guideline for immediateevacuation.

* CERCLA Section I02(a) ReportableQuantities (RQs). RQs are developed by EPAbased on, among other factors, acute toxiciry,chronic noncarcinogenic toxicity, andcarcinogenicity. RQs define the quantity inpounds above which a release is consideredpotentially hazardous (or, at least, warrantsreporting) under CERCLA section 102(a).The documentation for RQs may containhealth effects information that would be usefulin determining criteria for short-term exposurebut are not by themselves useful incharacterizing risks from releases that mightoccur at a CERCLA site.

C.2.2 SPECIFIC CARCINOGENIC RISKVALUES FOR SHORT-TERMEXPOSURES

There is relatively little guidance available oncharacterizing risks from short-term exposure tocarcinogens. For cancer endpoints, most of thecurrently available values are specific to lifetimeexposure. Many experimental investigations ofcarcinogenicity involve high-dose, long-durationexposure to compensate for the small number ofanimals that are used. Carcinogenicity data onshort-term or single exposures are virtuallynonexistent for most chemicals. For mostchemicals, the current scientific view is that anyexposure, no matter how short in duration, canresult in a carcinogenic risk. Characterizing thisrisk is complicated, however, because of factorssuch as age at first exposure and mechanism of thecarcinogen's action. Consistent withRAGS/HHEM Part A and the Guidelines forCarcinogen Risk Assessment (EPA 1986a), thepreferred approach would be to consider

cumulative dose, averaged over a l i fe t ime. Thismethod is discussed in Section C.2.2.1.

Several investigators have reported additionalmethods to characterize the effects from short-termexposure to carcinogens. Some of these methodsare currently being investigated by EPA but arenot recommended for short-term carcinogenicassessments at this time. However, briefsummaries of these methods are provided belowwith documentation for the interested reader topursue.

C.2.2.1 RAGS/HHEM Part A Method

RAGS/HHEM Part A currently recommendsthat lifetime average exposures always be used toestimate carcinogenic risks. That is, because thecancer toxicity values (i.e., SFs) are based onlifetime average exposures. Part A recommendsthat less-ihan-lifetime exposures be converted toequivalent lifetime values for the assessment ofrisk. (This is also the recommended approach inEPA's Guidelines for Carcinogenic RiskAssessment [EPA 1986].) In this manner, risksfrom short-term exposures-would be averaged overa 70-year lifetime, with modifications for specificchemicals if appropriate, and, therefore, mayappear to be relatively minor in comparison torisks from longer-term exposures. While adjustingless-than-lifetime exposure to an equivalentlifetime exposure may be valid for relatively longexposure durations, this adjustment for short-termexposures may underestimate the risk for"early-stage" carcinogens (i.e., DNA-damagingagents).

C.2.2.2 Office of Research and Development(ORD) Interim Method forVinyl Chloride

EPA's ORD (EPA 1989a) used a study byDrew et al. (1983) to determine that the lifetimecarcinogenic risk from vinyl chloride inhalationincreases when exposure occurs early in life. Drew

„ et al. showed that the effects from exposure tovinyl chloride depend on both age at initialexposure and duration of exposure. His datashowed that children face higher risks than adultsfor exposures of a given duration. Cog] i a no statedthat if risk for partial lifetime exposures isestimated by ignoring the age at initial exposureand considering only the duration, the risk will beunderestimated for children and overestimated foradults over 30. He proposed that risk for pa ma]

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lifetime exposure to vinyl chloride be: (1)estimated as being proportional to the remainingIrfetime of the exposed individual, and (2) adjusteddepending on the length of exposure. The authoralso stated that, at this time, this analyticaltechnique is applicable only to vinyl chloride andshould not be applied to any other substances.The TSC should be contacted for further guidanceon assessing risks from vinvl chloride.

C.2.2J EEGLs for Carcinogens

The NRC (1986) has developed a method forderiving EEGLs (1 to 24-hour exposure guidelines)for inhaled carcinogens when the computed cancerrisk associated with the toxicity-bascd EEGL (seeSection C2.1.6) is more than one in 10,000. Inthese cases, the EEGL is lowered so that the riskis not more than one in 10,000 (IxlO"4). The NRCmethod draws on the analysis of Crump and Howe(1984) and appears to employ a higher level ofacceptable lifetime risk (i.e., IxlO"4) than theRAGS/HHEM Part A method. This method isdiscussed in further detail in Criteria and Methodsfor Preparing Emergency Guidance Level (EEGL),Short-term Public Emergency Guidance Level(SPEGL), and Continuous Exposure Guidance Level(CEGL) Documents (NRC 1986). The 24-hourEEGL for a carcinogen is estimated as follows:

where:

EEGL = dx 25.600 x2.8

Rlevel of risk at d

25,600 =

2.8

l i f e t i m e exposure level ( a i rconcentration), as computed by aregulatory agency or by the NRCCommittee on Toxicology inaccordance with procedures used byregulatory agencies (multistage model)associated with "acceptable" level ofcancer risk, e.g., IxlO"6 level of risk.

number of days in a lifetime (25,600days = 70 years); application of thisduration factor assumes t h a tcarcinogenic effects are a linearfunction of the total (cumulative)dose,

a factor to account for uncertaintiesregarding which stage ofcarcinogenesis is affected by thesubstance and for the likely youth ofmilitary personnel; the NRC (1986)states that "the maximal additionalrisk that these considerationscontribute is a. factor of 2.8," based onthe "data of Crump and Howe(1984),' and

R = target acceptable risk level (e.g.,IxlO"4) for one day of exposure.

The reservations with this method concern thechoice of a higher target risk level (IxlO"4) incombination with other assumptions of thismethod, and the origin of the above uncertaintyfactor of 2.8. The origin of this uncertainty factoris not explained adequately by NRC (1986), nor isit apparent in the cited paper (Howe and Crump1986).

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REFERENCES FOR APPENDIX C

Drew, R.T., Boorman G.A., Haseman J.K., McConnell, E.E., Busey, W.M., Moore J.A. 1983. The Effect ofAge and Exposure Duration on Cancer Induction by a Known Carcinogen in Rats, Mice, and Hamsters. Toxic.Appt. Pharmacoi 68:120-130.

Crump, K.S., Howe, R.B. 1984. The Multistage Model with a Time-dependent Dose Pattern: Applicationsto Carcinogenic Risk Assessment. Risk Analysis 4 (3): 163-176.

National Institute of Occupational Safety and Health (NIOSH). 1985. NIOSH Pocket Gmde to ChemicalHazards. U.S. Department of Health and Human Services. Washington, DC

Environmental Protection Agency (EPA). 1986. Guidelines for Carcinogenic Risk Assessment. 52 FederalRegister 33992.

National Research Council (NRC). 1986. Criteria and Methods for Preparing Emergency Exposure GuidanceLevel (EEGL), Short-term Public Emergency Guidance Level (SPEGL), and Continuous Exposure Guideline Level(CEGL) Documents. Prepared by the Committee on Toxicology. National Academy Press. Washington, DC

Alexeef, G.V., Lipsett, MJ., and Kizer, K.W. 1989. Problems associated with the use of ImmediatelyDangerous to Life and Health (IDLH) values for estimating the hazard of accidental chemical releases. Amer.Ind. Hyg. Assoc. J. 50(11):598-605.

EPA. 1989a. Internal memorandum from J. Cogliano to S. Bayard. Status of Vinyl Chloride Assessment.Office of Health and Environmental Assessment.

EPA. 1989b. Proposed Amendments to the Guidelines for the Health Assessment of SuspectedDevelopmental Toxicants. 45 Federal Register 9386-9403.

American Conference of Governmental and Industrial Hygienists (ACGIH). 1990. Documentation of theThreshold Limit Values and Biological Exposure Indices. Cincinnati, OH.

Agency for Toxic Substances and Disease Registry (ATSDR). 1991. Guidance for the Preparation of aToxicotogical Profile.

Howe, R.B. 1991. Personal communication, telephone conversation with W. Stiteler, Syracuse ResearchCorporation, January 30, 1991.

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APPENDIX D

RADIATION REMEDIATION TECHNOLOGIES

This appendix presents two exhibits designedto assist the RPM with the process of using riskinformation to evaluate and select remediationtechnologies for sites contaminated withradioactive substances. The first exhibit, ExhibitD-l, summarizes the potential routes by whichradioactivity may be released to the air, groundwater, surface water, or other media when remedialtechnologies are implemented. Similar to ExhibitA-2 in Appendix A, Exhibit D-l groups processvariations with similar potential releasemechanisms under the technology categories.Exhibit D-l includes ground and surface waterreleases under the "water" column, and includesother unique release mechanisms under the "other"column. The reader is referred to EPA's report,Assessment of Technologies for the Remediation ofRadioactivity Contaminated Super-fund Sixes(EPA/540/2-90/001), for descriptions of eachtechnology listed in Exhibits D-l and D-2.

The second exhibit. Exhibit D-2, presents aqualitative estimate of the potential short-termrisks posed by each technology during itsimplementation phase, and its potential long-termrisks anticipated after cleanup. Potential short-term risks and potential long-term risks areclassified as being low, moderate, or high, or somecombination of these levels. This classificationscheme is based on the potential for releases ofradioactivity arising from the use of thesetechnologies to lead to potential short- and long-term risks. Under this scheme, "low* means a lowpotential for releases of radioactivity assuming areasonable worst-case scenario and therefore, a lowpotential for human health or environmental risk."Moderate" means a moderate potential for releaseand risk, and "high" refers to a high potential forrelease and risk.

Although the determinations of low, moderate,and high potential risks presented in Exhibit D-2are based on the professional judgment ofexperienced risk assessors, they are provided onlyto the RPMs for making preliminary technologyscreening decisions. The actual risks associatedwith a remedial alternative at a specific site mustbe evaluated on a case-bv-case basis. That is,technologies rated as high potential risk should notnecessarily be eliminated from consideration, norshould technologies rated as low potential risk beconsidered safe, without evaluation of site-specificfactors.

The Agency recognizes that otherdeterminations of degree of potential risks arepossible and may be acceptable, (In fact, ifremediation technologies are properly designedand excuted, few, if aoy, of the potential releasesand risks may be expected.) Therefore, the RPMis encouraged to consider all qualified sources oftechnical information when selecting a radiationremedial technology based on site-specificconditions.

Potential releases of mixed radioactive andnonradioactive hazardous substances are notcovered in this appendix due to the limited numberof technologies currently available, and thecomplexities involved in identifying releasepathways and mechanisms. Because releases ofmixed waste contaminants will warrant additionalrisk evaluation and considerations, RPMs shouldconsult with a radiation protection specialist priorto selecting a remedial design for these types ofsites.

-57-

EXHIBIT D-l

POTENTIAL RELEASES OF RADIOACTIVITV ASSOCIATED WITHRADIATION REMEDIATION TECHNOLOGIES

Technologies* Air W«ier- Other*

son, AND SI,UIM;E TECHNOLOGIESNatural AttcnuaikHi(Non-trcaimcni Acikm)

Soil II 11 ml lint*

Soil Kxcavalkm,Transport, and OlfsiicDisposal

< •

• Potential cmisskNU ofHKlkvietivc pariirufciic* andVOkllilCS

• Kcsuspcnskm of nidiiKictivcpiirtktikiiCK

• I-nhaiKcd cmisskuvs ol vuUmlcradionuclidcs

• (jHilinucil mtgnukm ol r; id KHHI elideslo griMind wilier and jxKsihlc ii;ms|'HMito surface wiucr

• Internal nitlialion exposure due ingamniH-cmilling r.idiomiclide.s insoil

• 1-nhiiiKCd runolTor k'iiching ofraclkmuclklcs 10 surlacc w.ncr orground water

• Sccpiigc/runoli u> soil

• 1 Enhanced external nidiiinonexposure of workers duringexcavation, handling, shipping, anddisposal

* OH si re migrnnon of riitliiKichviiydue to transport by cont;tmnuiedvehicles or equipment

Soil Washing. Extraction, & Rioremediallon

Soil Washing wiih Water • Resuspcnskm of radioaciive soilpan ides and enhancedemissions of votaiiteradionuclides during hfindlingand treaimcnt

• Spilb, leaching, andAx runoff ofresidual radioniidides in washed soilor in process water

• Accumulation of dissolved orsuspended radionuclides in recycledwater/solvents

• Enhanced external radiationexposure froni gamma-cmitiingradionuclKlcs in soil

(Continued)

EXHIBIT D-l (Continued)

POTENTIAL RELEASES OF RADIOACTIVITY ASSOCIATED WITHRADIATION REMEDIATION TECHNOLOGIES

Technologies* Air Water* «lherk

Soil Washing. Extraction, A BtorcnwdlatlM (Continued)

Chemical Extraction

HkwcmcUiaiion

• Potential emissions of volatilechemicals and radioactivepaniculate* and votoiites duringhandling and treatment

• Areol or fugitive emissions ofradkxiciivc part teu laics amivolatile:*

• lothatisi Mack umissKHis ofincincniicd bkxiorbani*ctmtuining residual ratlkiaciivity

• Spills, leaching, and/or runoff ofresidual radionuclides in processwater

• Accumulation of dissolved orsuspended radionuclides in recycledwater/solvents

• Discharge of process w;iicrconsuming residual railkiaciiviiy

• In-nlvcncni spills or IciKhing olrndionuclidcs

• Spills or leakage of exiraci wiihhigh concentrations of radioticiivccontHminanis and solvents fromstorage tanks

* Internal radiation exposure frombioniass containing residu;ilgamma-eniiuing radkmuclklcs

Immnhil tuition

Capping • Coniinucd emissions of somevolatile rndkwuclidcs altercopping

• leaching and hori/onuil migralion olradionuclidcs to ground water wuhrnin wilier inlilir.ilion

• Partial reduction ol externalradiation exposure

(Continued)

EXHIBIT!)-1 (Continued)

POTENTIAL RELEASES OK RADIOACTIVITY ASSOCIATED WITHRADIATION REMEDIATION TECHNOLOGIES

Technologies*

In-siiu Vitrification

Air

• Volatilization of certainradionuclides during treatment

• Cracks or fissures in vitrifiedmass may act us conduits for therelease of volatile radionuclidcs

Water*

• Possible leaching and migration ofradionuclides lo ground water due tosoil matrix destabtlizaiion

Other*

• External radiiiiion exposure inradium contaminated soils due tothe buildup of radon decayproducts

GROUND WATER AND SURFACE WATER TECHNOLOGIES

Niitur.il Attenuation(Non-ircaimcni Action)

*

!• ill nil ion

Granular ActivatedCarbon Adsorption

Ion I'xch.mgc

• Potential buildup of volatileradionuclidcs (eg, radon) inground-water and municipalwilier distribution systems

• Fugitive emissions of volatileradionuclidcs

• Potential slack emissions ofvolatile nidionuclidcs uponsaturation or breakthrough

• P<Mcmi;il for off-gassing ofvolatile nidioaclivc decayproducts In tin parent nuclidcson resin columns

• Continued transport of radionuclidcs10 the aquifer and possible dischargeto surface water

• Discharge of elilucni water containingdissolved radioactive MHids

• Discharge of treated water containingresidual raditKtciivc contamination

• Possible release of railiunuclidcs dueto backllushing and/or regcncr;iiiiMi

• Discharge of treated water containingresidual radioactive coniuminaiitm

* Ptissil le release of riidHMiuclKlcs dueto back flushing or rcgcneriition

• Poicmial deposition ot radioiictivcscdimcni.s in surface water overlarge areas (eg, river basins)

• Potential leaching of radinnuchdcsfrom filter cakes or sluOge

• Internal radiation cx|io.siuc Ironiradioactive cakes or sludge

* Potential external radiationexposure due to the sorption andbuildup of gammn-emittingradionuclides

• Potential external raduiiioiiexposure due to the buildup olgamma-cunning r<Khonuctiilcs

(Continued)

EXHIBIT D-l (Continued)

POTENTIAL RELEASES OF RADIOACTIVITY ASSOCIATED WITHRADIATION REMEDIATION TECHNOLOGIES

NOTES

* Source for radiation remediation technologies: US Hnvironmemut Protection Agency (LI'A). I WO. A\*e*smcnt of Technologies for the Remediation ofHntluntctivefy Contaminated Sttpcrfttntl Sues. UP A/540/2-90A»01.

' In general, seepage and teaching arc mure likely to affect ground water, but could also lead to surface waier contamination. Runoff and discharge arcreleases thin will most likely contaminate surface water, but may also lead to ground-water coniaminaiion.k Other releases include treatment residuals requiring further remediation and/or special handling and disposal considerations. External radiation exposuredue to the presence of gamma-emitting radionuclides in treatment residues should abo be considered as a potential human health exposure pathway, eventhough this pathway does not involve the physical release of radionuclides into the environment. The risk assessor should also consider other commontechnologies used to remediate ground water and surface water contaminated with radioactive substances, such as aeration, evaporation, distillation andsolvent extration, not included in Exhibits D-l or D-2.

EXHIBIT D-2

DEGREE OF POTENTIAL SHORT- AND LONG-TERM RISKS ASSOCIATED WITHRADIATION REMEDIATION TECHNOLOGIES

Technologies*Potentfnl for

Short-term Kbitsrolenlliil Tor

lx>ii|*-tmn Risks Comments

SOIL AND SlfUDGK TECHNOLOGIES

Natural Aitcnuaiion(Non-treatmentAt I M Hi)

High High • The No Action alternative will not meci the two NCI* threshold criteria: (1)protection of human health and environment, and (2) compliance with AKAU.s

• Migration and release of nidioaciivc contaminants would he expected to coiilmncunless a hilled or mitigaied

Soil Handling

Soil lixaiviiiion,Transport, and Olf&itcDisposal

• •

Moderate/High None/Low • During excavation, the potential Tor short term radiation risks in remedial workersonsilc and lo the general public oil sue may be moderate to high

• Once the source or sources ol radioactivity has or have been removed, thepotential for long-term risks should be minimal or non-exisieni. depending on thekrvcl of residual radiotieiiviiy remaining on sue

Soil Wishing, Extraction, & Hlorr mediation

Soil Washing withWiiicr

Chemical Extraction

Moderate

Moderate/High

Low

Low/Moderate

• During excavation and MM! witting, the potential Tor short-term radiation risks lorcnK'diiil workers unsite and to ihe general public oflsilc may be mtKleraie

• Depcniling on UK level ol residual radioactivity reniiiining, the potential lor long-term risks may he low to moderate

• During excavation and chemical extraction, the potential for short-term radiaitiHirisks lo workers onsite and to Ihe general public olfsitc may be ni(Klcr;iic io high

• 'Ihe potential lor lung-term risks depend upon Ihe chemical ;ind radiologicalcharacteristics of the treated soil recycled back into native soil

otsl

(Continued)

EXHIBIT D-2 (Continued)

DEGREE OF POTENTIAL SHORT- AND LONG-TERM RISKS ASSOCIATED WITHRADIATION REMEDIATION TECHNOLOGIES

'lrt:liiH>l4>Kiek*Potential forShort-term

Risks

Potential forI Hift-tvrm

RisksComments

Still Wtislilnit, RxIraclkHi, & HUHtintdlulloM (CiHilIniK-d)

Diorc mediation Moderate Moderate • Accidental spillage of radkuiciiviiy from hiotrcatmcni solutions, off-gassing of volatileradtonuclkies, and elevated external radiation exposures may contribute to the potcnit.il Tormoderate short-term radiation risks

• Long-term risks depend upon the chemical and radiological characteristics of the treatedsoil recycled back into native soil In general, these risks should be tow 10 moderate

Immoblllxntlon

Dipping

In-situVitrification

Low/Moderatei

Moderate/High

Moderate/High

Moderate

• Short-term radiation risks to workers and offsite populalions should be low to moderate,provided that the source or sources of radioactivity are not excavated before capping

• Since the sources of radioactivity will be Mi in place, long-term risks to human health andthe environment may be moderate to high depending on the exient to which the cap iscapable of preventing the migration of radionuclides in the future

• Initially, both radiation and physical hazards contribute to the moderate to high potentialfor short-term radiation risks posed by the use of this technology, primarily to onsiieworkers

• Since the siabilily and king-term integrity tit vitrified soils containing radioactive materialsremain unverified in the field at the present time, and since the buildup of radon decayproducts in vitrified soils may increase external exposure rates with time, potential long-term radiation risks lo the general public may be moderate to high

(Continued)

EXIIIBITD-2 (Continued)

DEGREE OF POTENTIAL SHORT- AND LONG-TERM RISKS ASSOCIATED WITHRADIATION REMEDIATION TECHNOLOGIES

Technologic**Potential forShort-term

Risks

Potential forI ,oii|{-term

RisksComments

GROUND WATKR AND SURFACE WATER TECHNOLOGIESNaturalAttenuation(Non-trcmmeniAction)

High High • The No Action alternative will not meet the two NCP threshold criteria: (I) protection ofhuman health and environment, and (2) compliance with AUAHs

* Releases of radioactive contaminants to ground water and surface water would beexpected to continue unless abated or mitigated

Filtration Low/Moderate I-ow • The potential for short-term radiation risks to workers and the public will depend on ;inumber of factors, including: (1) the concentrations of radhinuclidcs in the ground orsurface waters; (2) the efficiencies ol filtration systems; (3) ihc breakthrough lime, .nut,(4) the change-out or rcgcneraiion cycle time In general, these potential risks ;ircexpected to be low to moderate

• 'Ihc potential for long-term risks will also depend on the factors listed ahuvc. hut willdepend primarily on the concentration of nidionuclides in ground water or surface waterremaining to be treated (ie, conecntraiions (and risks) may be expected to full oil withtreatment) Potential risks to the general public may be expected to bo low *lne handlingand disposal of filter materials and sludges containing radionuclidcs may pose risks inworkers if radioactivity concentrations exceed federal or stale standards

(Continued)

EXHIBIT D-2 (Continued)

DEGREE OF POTENTIAL SHORT- AND LONG-TERM RISKS ASSOCIATED WITHRADIATION REMEDIATION TECHNOLOGIES

Technologies*

GROUND WATKR

GranularAciiviilcil Carbon

Ion Exchange

Potential forShort-term

Risks

Potential forLong-term

RMuComments

AND SURFACE WATKR TRCIINOI.OGIES

1 .uw/Modcrutc

Low/Moderate

*

IJDW

Low

• 'IlK buildup of radon and radon progeny on activated charcoal may increase boihpotential short- and king-term risks of external radiation exposures 10 workersKegeneralkm of (»A(* may release nttlionuclkles ihal arc not well sorlxd Disposal ofspent (iAC containing elevated concentrations ol lend 210 (and chemical umi<imin;mis)may pose handling problems lluiklup of radon and other radionuclidcs on (iAC alsodepends on: (1) Ihe concentrations of railionuclides in the guuuul or surliuc waters; (2)collectkm cllieicncics; (3) (iAC breakthrough lime, and; (4) the change -oul orregeneration cycle lime

• Similar to the potential risks posed by the treatment of radionuclidts in ground water andsurface water using fill ration or carbon absorpikm techniques. Ihe potential for short- andlong-term risks posed by the colleclion of radionuclides on ion exchange resins dependsprimarily on the radionuclide -specific colleclion efficiency and water concentrations Ingeneral, these potential risks may be low to moderate

* Source for radiation remediation technologies: U.S. Bnvironmental Protcclkxi Agency (EPA). 1990. Assessment of Technologies for theContaminated Sttperftintl Sites. Office or Solid Waste and Emergency Response. EPA/S40/2-90/D01.

of