In May 1993, Administrative Browner of the U.S. Environmental Protection Ag
ency (USEPA) announced that an indirect exposure health risk assessment was
required for all hazardous waste combustion facilities seeking a Resource
Conservation and Recovery Act permit. These types of risk assessments evalu
ate the health and environmental effects from inhalation of emissions (dire
ct exposure) and from contact with environmental media and consumption of f
ood products impacted by the emissions (indirect exposure). Completion of a
n indirect exposure risk assessment is often complicated by the various met
hodologies available for generating results and by the requirements of the
regulating community. To minimize this complexity and to maximize consisten
cy between risk assessments, the USEPA developed a number of detailed guida
nce documents. Site-specific conditions and toxicological data gaps, howeve
r, continue to present challenges not addressed by these guidance documents
. This paper presents some of the specific challenges encountered by the U.
S. Army Center for Health Promotion and Preventive Medicine when performing
indirect exposure health risk assessments for several demilitarization com
bustion facilities.