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Human and Ecological Risk Assessment - Earthjustice

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Section 1.0Introduction1.3.2 Exposure PathwaysThe releases, <strong>and</strong> hence media concentrations <strong>and</strong> risk estimates in this report, werebased on leaching to groundwater <strong>and</strong> groundwater transport to nearby wells <strong>and</strong> surface waterbodies. This analysis did not address direct releases to surface water, which are permitted underthe National Pollutant Discharge Elimination System (NPDES) of the Clean Water Act. Thus,the estimated media concentrations <strong>and</strong> risks do not take into account contributions fromNPDES-permitted releases, including discharges due to flooding or heavy rainfall. Uncertaintiesassociated with this decision are described in Section 4.4.1 of this report.EPA recognizes that there are exposure pathways in addition to the groundwaterpathways addressed in this report that could be of concern to human health <strong>and</strong> ecologicalreceptors, including fugitive dust eroded <strong>and</strong> transported by wind from uncovered CCWl<strong>and</strong>fills, <strong>and</strong> erosion <strong>and</strong> transport of CCW constituents from uncovered l<strong>and</strong>fills onto adjacentl<strong>and</strong> <strong>and</strong> eventually into downslope waterbodies. These “aboveground” pathways were addressedin the 1998 risk assessment, <strong>and</strong> in 2002, EPA conducted a draft screening analysis (U.S. EPA,2002a) to evaluate risks from these pathways.1.3.3 <strong>Risk</strong> LevelsTo evaluate the significance of the estimated risks from the pathways assessed in thisassessment, EPA compared the risk estimates to a risk range (for carcinogens) or to a specificrisk criterion (for noncarcinogens) that are protective of human health <strong>and</strong> the environment:• An estimate of the excess lifetime cancer risk for individuals exposed to carcinogenic(cancer-causing) contaminants ranging from 1 chance in 1,000,000 (10 -6 excess cancerrisk) to 1 chance in 10,000 (10 -4 excess cancer risk). For decisions made to screen outcertain constituents from further consideration, a 1 in 100,000 (10 -5 ) excess lifetimecancer risk was used. 2• A measure of safe intake levels to predicted intake levels, a hazard quotient (HQ) greaterthan 1 for constituents that can produce noncancer human health effects (an HQ of 1 isdefined as the ratio of a potential exposure to a constituent to the highest exposure levelat which no adverse health effects are likely to occur)• An HQ greater than 1 for constituents with adverse effects to ecological receptors.1.3.4 MethodologyIn 1998, EPA conducted a risk assessment for fossil fuel combustion wastes (whichinclude CCWs) to support the May 2000 RCRA regulatory determination (U.S. EPA, 1998a,b).Since then, EPA has added to the waste constituent database that was used in that effort,exp<strong>and</strong>ing the number of leachate <strong>and</strong> total waste analyses for 41 CCW constituents. The CCWrisk assessment subjected these waste <strong>and</strong> leachate constituent concentrations to the tiered riskassessment methodology illustrated in Figure 1-1.2 The typical cancer risk range used by the Office of Solid Waste <strong>and</strong> Emergency Response is 10 -4 to 10 -6 .April 2010–Draft EPA document. 1-3

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