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5 Meeting Program Goals
Pages 113-122

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From page 113...
... . Of the four guiding principles of the RSU, two bear on the scientific or technical aspects of the programs (protecting public health and the environment and fostering compliance through regulatory flexibility and simplicity)
From page 114...
... Wastes that are currently classified as nonhazardous may also be reclassified as special and subject to more stringent disposal requirements. Although DTSC indicated at the public meetings that the new waste-cIassification system will be more protective of human health and the environment, the documentation fails to support this contention.
From page 115...
... It is incumbent upon DTSC to provide an analysis that gives the probability that the exit-level TTECs derived for the protection of human health would be protective of ecological, nonhuman receptors. The second issue concerning ecological risks is identical to that of using a two-tiered system for human health.
From page 116...
... California has determined that the federal Resource Conservation and Recovery Act (RCRA) classification system was not sufficiently protective of human health or the environment and that it was necessary for the state to identify and manage those wastes that might not be classified as hazardous under RCRA but that might pose risks to Californians.
From page 117...
... This has been done for human health risks from exposure via groundwater, surface water, air, soil, and food exposure pathways. Incorporating exposure data including information on the environmental fate and transport of chemicals, as well as the identification of potential receptors (human and ecological)
From page 118...
... were to change the maximum concentration limits on which a TTLC or SERT was based, how would DTSC account for this change in value? Would the new information be considered on an "as available basis," or would there be a systematic review similar to that provided for reviewing the minimum risk levels developed by the Agency for Toxic Substances and Disease Registry for chemicals found at Superfund sites?
From page 119...
... OTHER CONSIDERATIONS FOR DTSC's APPROACH Other areas where DTSC might expand the utility of its proposed wastecIassification system or where the system might be improved are briefly discussed below. Integration of lT[Cs and SERTs to give just one value protective of human health and the environment via groundwater or other possible exposure pathways.
From page 120...
... However, DTSC's proposed approach is seriously lacking ecological exposure scenarios and subsequent risk assessment values. Use of a toxicity value such as an LC50 for fish or EPA's ambient water quality criteria does not constitute an ecological risk-assessment with some exposure assessment and, therefore, should not be called such in the DTSC documentation.
From page 121...
... Although these issues are policy related, scientific methods may be used to analyze short-term and long-term risk at different points in the waste management system, and can allow multipathway, multimedia comparisons of risk at one waste-management location versus another. The committee supports the use of the multipathway, multimedia risk analysis, but points out that this is currently only being proposed for the location of disposal.
From page 122...
... On a larger scale, determining the results of the proposed non-RCRA hazardous-waste program by inclusion of a meaningful evaluation system would lend significant credibility to DTSC's desire to meet the objectives of the RSU. To validate the intended effects on protection of human health and other organisms as well as the environment and the regulated community, DTSC should consider the development of a formal, periodic evaluation process.


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