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Risk Assessment presentation given by Claire Marcussen, June 2010 at a Protect Gainesville's Citizens Community Information Session.
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1
Presented By:
Claire Marcussen
Senior Environmental
ConsultantJune 24, 2010
Use of Risk Assessment to
Support Cleanup at Superfund
Sites
2
Overview*
• What is Risk Assessment?
• Uses
• Risk Assessment Process
• When are Risk Assessments Conducted?
• Determining when Cleanup/Controls are Needed
* Interject opinions on the Koppers Risk Assessment
and Feasibility Study
3
What is Risk Assessment?
• A systematic approach to determine the human
health effect and environmental impacts associated
with actual or threatened releases:
– Chemicals
– Radionuclides
• A required component to support cleanup decisions
at Superfund sites
• Must follow regulatory protocols
4
Uses
• To support cleanup decisions
• Identifies chemicals and media requiring cleanup
• Prioritizes areas for cleanup
• Allows owners/operators to make focused decisions
• Supports property transactions/due diligence
• Develop cleanup levels
• Aids in site re-use
5
Types of Risk Assessments
• Deterministic (most common)
– Calculations straightforward; not resource intensive
– Use of point estimates to come up with a risk values
– Use of established default assumptions
– Easier to describe and communicate
• Probabilistic (uncommon)
– Much more complex approach
– Used when simpler methods do not clearly support need for action (so why did they use it??)
– Uses statistically derived distributions of exposure factors and toxicity values to calculate risks
– Provides more detailed understanding of variability of risks (i.e., identifies what factors impact risks most)
– Difficult to communicate in a transparent manner.
6
Risk Assessment Process
Hazard IdentificationHazard Identification
Exposure AssessmentExposure Assessment Toxicity AssessmentToxicity Assessment
Risk CharacterizationRisk Characterization
7
Hazard Identification
• Conceptual Site Model = Road map
– Describes the sources, release and transport pathways, human and ecological receptors
– Ensures risk evaluation is focused on the right issues
– Koppers: continue to discover new sources (drums?)
• Data Evaluation
– Identifies useable data
– Is data complete (e.g., data gaps?)
– Koppers: for years never sampled for dioxin (risk driver requiring more delineation)
• Chemical Screening Step
– Reduce list of chemicals to those likely to drive risks at site (focuses risk assessment)
Conceptual Site Model
Dust
Leaching to
Groundwater
Surface
soil
Groundwater
Discharge
Garden
Data Evaluation
• Ensure that relevant data are available:
– To evaluate current and future exposures (on/offsite)
– Direct contact to surface soils (e.g., current 0-6”; future
0-6 ft to address site rework)
– Inhalation exposure (e.g., dust concentrations or
modeled dust concentrations)
• Ensure analytical methods are adequate
– Sensitivity: Can detect levels below “safe” levels
– Complete: Include methods that can detect site-related
chemicals (e.g. PAHs, metals, dioxins)
Chemical Screening Step
• Standardized approach
• Compare maximum site concentration to a
conservative health-based screening value
– Florida’s Soil Cleanup Target Level (SCTL)
– EPA’s Regional Screening Level (RSL)
– Residential exposure assumptions
• 10-6 cancer risk level,
• Noncancer hazard of 0.1
• Contributions from Natural Background
• Koppers: used commercial screening levels!
Example Chemical Screening Step
YesNA0.015 mg/kg39 mg/kgPAHs
No34 mg/kg210 mg/kg100 mg/kgChromium
NA
170 mg/kg
14 mg/kg
Natural
Background
Yes4.5 ng/kg45 ng/kgDioxin
No150 mg/kg160 mg/kgCopper
Yes0.39 mg/kg25 mg/kgArsenic
COPC?Residential
Screening
Level
(RSL/SCTL)
MaximumChemical
NA = not applicable
Screening Levels versus Cleanup Levels
(Default Residential Level – Arsenic)
Site-specific
cleanup
goal/level
No further study
warranted
Response action
clearly
warranted
“Zero”
concentrationScreening
Level
Very high
concentrationResponse/
Cleanup level
0.39 mg/kg
(10-6 risk)
3.9 or 39 mg/kg
(10-5 - 10-4 risk)100 mg/kg
(2x10-3 risk)
14 mg/kg =
Background (3.5x10-5)
13
Risk Assessment Process
Hazard IdentificationHazard Identification
Exposure AssessmentExposure Assessment Toxicity AssessmentToxicity Assessment
Risk CharacterizationRisk Characterization
14
Exposure Assessment
• Cornerstone - - “no exposure/contact = no risk”
• Components
– Identify Completed Exposure Pathways
– Estimate Exposure Concentrations
– Calculate Chemical Intake/Dose
15
Exposure Pathways
• Completed Exposure Pathway
– Chemical source and chemical release(s)
– Receptor point
– Exposure route
16
Exposure Point Concentration
• Daily concentration you are exposed to
• Must address current and future likely exposure
scenarios
– Future outdoor industrial worker (widespread exposure)
• Area-wide average exposure concentration
– Future commercial or residential development (localized
exposures)
• Source Area exposure concentrations
– Offsite residential/commercial areas (localized)
• Koppers diluted exposure concentrations assuming
all receptors are exposed to the entire site
17
Exposure Point Concentration
• Exposure point concentration
– Maximum detection (for screening)
– Average concentration (most common for risk assess.)
– Area-weighting (not commonly used)
. . . . .
. . . . .
. . . . .
. . . . .
. . . . .
. . . . .
0.5 acre
XX
XX5 acres
X
X
X
X
X
X
X
X
X
X
X
Residential
Exposure
Areas
Commercial/Industrial
Exposure Areas
18
Chemical Intake
• Amount of chemical that enters the body
– Behavioral factors: frequency and duration of exposure
– Physical factors: body weight, skin surface area,
ingestion/inhalation/dermal contact rates
– Biological factors: bioavailability, absorption
– Koppers RA: used nonstandard absorption factors which
lowers risk and HI; ignored future residential use
• Intake (mg/kg/day) = Csoil x Contact Rate x ED x EF
BW x AT
19
Chemical Intake
• Default Exposure Assumptions*
6
350
0.2
2800
10
200
15
Residential
Child
250350Exposure Frequency (days/yr)
3300 (2373)5700Skin Surface Area (cm)
17 (20)20Inhalation rate (m3/day)
2524Exposure Duration (years)
0.20.07Soil adherence factor
(mg/cm2)
50/100100Soil Ingestion rate (mg/day)
70 (71.5)70Body weight (kg)
Industrial/
Commercial
Residential
Adult
Exposure Factor
*Probabilistic risk assessment uses a range of values; Koppers evaluated recreational and
worker exposure and not future residential risk
20
Risk Assessment Process
Hazard IdentificationHazard Identification
Exposure AssessmentExposure Assessment Toxicity AssessmentToxicity Assessment
Risk CharacterizationRisk Characterization
21
Toxicity Assessment
• Use EPA and FDEP approved toxicity values to evaluate cancer and noncancer health effects
• Rely on chronic (long- term) exposures over time– Chronic = Lower doses cause long-term health effects
– Acute = Higher doses cause short-term health effects
• Cleanup for chronic effects is more stringent and is protective of acute effects
• EPA and FDEP Toxicity values have undergone peer review
• Koppers: used nonstandard toxicity values in the PRA (tend to be much lower than standard values)
22
Toxicity Assessment
• Noncancer = reference doses; chronic target organ effect
– Many different “safe” dose levels based on different organs
– Use lowest “safe” dose to ensure protection for all effects
• Cancer = cancer slope factors*
– Many slope factors based on different types of cancer
– Use the most stringent slope factor to cover all types
• Special cases
– Toxicity equivalency factors (TEFs)-- polycyclic aromatic
hydrocarbons (PAHs) and dioxins
* Carcinogens must also be evaluated for noncancer effects as well.
Toxicity Assessment
• Toxicity Equivalency: Some chemicals are
members of the same family and exhibit similar
toxicological effects; however, they differ in the
degree of toxicity
– Applies to PAHs and Dioxins
– TEF applied to adjust the measured concentrations of
individual PAHs and dioxins as a fraction of the toxicity
of benzo(a)pyrene for PAHs and 2378-TCDD for
dioxins.
– TEF x soil concentration =
toxicity equivalent concentration (TEQ)
Kopper’s Toxicity Assessment
• Deterministic used EPA established CSF value for dioxin
• PRA used a range of toxicity factors (lowers risk/HI)
• PRA ran a second dioxin risk calculation without the EPA
dioxin CSF reducing risk by factor of 60
• EPA has a noncancer RfD value for dioxin; Koppers did not
evaluate noncancer effects to dioxin.
5E-04
2E-03
Risk
Commercial
Residential
Receptor
Group
12892004.5 (72)
9200
Site-wide
Exposure
Weighted
Conc. (ppt)
1118 (850)
HIEPA Regional
Screening Levels
(ppt)*
(HI=1/Risk=1E-06)
* EPA May 2010 Regional Screening Level Table (value in parentheses
is noncancer based).
25
Risk Assessment Process
Hazard IdentificationHazard Identification
Exposure AssessmentExposure Assessment Toxicity AssessmentToxicity Assessment
Risk CharacterizationRisk Characterization
Exposure ToxicityRisk
Risk Characterization
Evaluate two effects:
Cancer Risks versus Noncancer Hazards
27
Carcinogenic Risk
• Carcinogens = cancer risk
• Cancer risk = cancer slope factor x dose
– Probability of an individual developing cancer over
a lifetime
– Expressed as 1 in one million, 0.000001, or 10-6
– Risks from each chemical are additive to arrive at a
total site risk for each exposure scenario
Risk chem1 + Risk chem2 + Risk chem3
28
Why Use Risk Numbers to Identify
Problems?
• Superfund and State regulations require to clean up
sites to levels that do not contribute “significantly”
above the risk that occurs from all other causes of
cancer in the general population.
• American Cancer Society indicates that 1 in 2 men
and 1 and 3 women will develop some type of
cancer in their lifetime based on studies in the
general population*
* www.cancer.org/docroot/PRO/content/PRO_1_1_Cancer_Statistics_2009_Presentation.asp
29
Why Use Risk Numbers?
• EPA Regulation requires managing site risk within a range
10-6 to 10-4
• FDEP manages site risk > 1 x 10-6 *
• General population risk is 5 x10-1 and 3 x10-1 for men and
women.
• Ideally we would like 0 risk but not realistic
• EPA/FDEP Goal ����do not let site risks contribute significantly
above general population risks
Higher riskLower risk
10-6 10-5 10-4
* Unless background is above cleanup level
FDEP Target
EPA Target
10-1
Noncancer Hazards
• Noncarcinogens = noncancer hazard quotient (HQ)
– Ratio of site chemical intake/safe dose
– mg/kg/day site = Hazard quotient (HQ)
mg/kg/day safe dose
– HQchem1+HQchem2+HQchem3 = total HI
– FDEP and EPA threshold = 1.0
31
Summarizing Risks/HIs
• To prioritize what areas require cleanup at large sites, risks and HIs should be segregated by:
– Exposure Areas onsite and offsite
– Exposure population (residential, commercial, etc.)
• Should identify chemicals driving risk and hazards onsite and offsite– Chemicals contribution > 10-6 risk
– Chemicals contributing > 1 HI
• Koppers: did not break site down into smaller areas for risk assessment
– Assumed entire site was the exposure area
– They only segregated ditch area
Koppers Deterministic Risk/HIs Summary
Dioxin, arsenic, PAH9E-050.04Recreational Older
Child
Dioxin2E-050.02Utility Worker (0-6 ft)
Dioxin1E-050.3Construction Worker
(0-6 ft)
Dioxin, arsenic, PAH3E-04 (4E-05)0.09Indoor Worker
Dioxin, arsenic, PAH5E-04 (8E-05)0.2Outdoor Worker
Dioxin
Dioxin and arsenic
2E-05
4E-06
0.01
0.02
Onsite Trespasser-Soil
Onsite Trespasser-Ditch
Chemicals of
Concern
Risk*+HIScenario
*Residential onsite risks would be greater than the receptor risk with most
frequent exposure (e.g., worker risks); thus, site-wide residential risks would
>1E-04 which is above FDEP and EPA thresholds.
+Parentheses = PRA risk result
Koppers Risk/HIs Summary
• Koppers did not evaluate future residential, worker, or recreational risks to 0-6 feet soils – Typically done for sites expected to be redeveloped
– Exposure concentrations higher in 0-6 ft for arsenic, PAHs, and PCP; dioxin similar
– Risks/HIs will be slightly higher using 0-6 ft for these scenarios.
• Even without calculating residential risk, since worker risk unacceptable so would residential risks (e.g., higher frequency and longer duration)
• Subsurface soils concentrations are higher or the same, so surface soil risk conclusions would also apply to subsurface soil.
When Risk Assessments Occur
Feasibility Study
Remedial Design/
Implementation
Detailed
Analysis of
Alternatives
Remedial
Action
Objectives
Remedial
Investigation
(RI)
Baseline Risk
Assessment *
Refine
Preliminary
Cleanup goals
based on risk
and legal levels
Risk evaluation
of remedial
alternatives
Evaluate:
Residual risk
Demonstrate
attainment
5-year review
* Note that the baseline conditions have changed since the RI,
as the site is no longer an active industrial facility. Thus, a risk
assessment has been recently revisited and submitted again
with the FS. Needs careful review!
35
When are Cleanup/Controls Needed?
• Cancer Risks > Threshold (varies EPA vs FDEP)
– Risk > 10-4 generally require cleanup or controls (EPA)
– Risk < 10-6 generally do not require cleanup (FDEP)
– Risk > 10-6 and <10-4 case-by-case basis (EPA and
FDEP)
• Case- by- Case (target 10-6, 10-5, or 10-4)
– Contribution from natural background or other sources
not related to the site
• FDEP and EPA will not cleanup below background
– Environmental Setting (industrial versus residential)
36
When are Cleanup/Controls Needed?
• Noncancer HI > 1.0
– Thresholds are consistent across EPA and States
– Can be no action if background metals are higher than
noncancer-based screening level
• Uncertainties
– Risks are only as good as the data
– Importance of delineating contamination (lack of data
does not mean “no risk”)
Developing Cleanup Levels
• Typically conducted as part of the FS
– Considers background levels
• FDEP and EPA will not cleanup below background
• Arsenic frequently is cleaned up to background levels and not the 1E-06 level in Florida and other States
– Considers noncancer effects (e.g., make sure final cancer risk-based level is also protective of noncancer effects)
– Considers cumulative exposure to all site chemicals of concern
Developing Cleanup Levels
• Koppers FS did not calculate cleanup levels for surface soil COCs (dioxin, arsenic, PAHs, PCP)– Need risk or HI-based cleanup goals for remedies to
achieve; to know how much soil needs to be cleaned up
• Koppers Risk Assessment did not calculate risks to 0-6 ft soil for site-redevelopment (e.g., soils reworked for site re-use)– Exposure Concentrations are higher for arsenic,
pentachlorophenol and much higher for PAHs; dioxins similar to surface soil concentrations
– Risks for subsurface soils would also be unacceptable for the same scenarios as surface soil.
– Need health-based cleanup goals for subsurface soil
39
Questions?