This page intentionally left blank.

The hazard severity ranking charts presented in TG-248 and TG-230 are not entirely consistent with each other (see Tables 2-2 and 2-3 in Chapter 2 of this document). In general, the table provided in TG-230 (Table 2-2) is more detailed and contains probability ranges that differ somewhat from those that appear in TG-248 (Table 2-3). Moreover, the greater detail provided in the TG-230 table includes probabilistic operational definitions that more clearly distinguish between hazard types than those provided in TG-248. Specifically, TG-230 associates “catastrophic,” “critical,” “marginal,” and “negligible” hazard types with health outcomes involving the development of severe illness in >25%, 10-25%, ≤10%, and 0% of exposed personnel, respectively. Marginal and negligible hazards are also associated with the development of mild illness in >10% and 0-10% of exposed personnel, respectively. These definitions present a minor ambiguity in the distinction between critical and marginal hazards, insofar as both include a 10% level of severe illness among exposed personnel, but that ambiguity can easily be resolved by adjusting the definition of marginal hazard to refer to the threat of severe illness in <10% rather than ≤10% of exposed personnel.

In the hazard probability ranking chart (see Table 2-5 in Chapter 2), the probability ranges used in the table are not properly defined. The notation used should be modified (e.g., change affected-personnel percentages [P]

as follows: unlikely, P ≤ 10%; seldom, 10% < P ≤ 25%; occasional, 25% < P ≤ 50%; likely, 50% < P ≤ 75%; and frequent, P > 75%).

The terminology in Tables 3-3 and 3-4 of TG-248 appears to be inconsistent, because the term “extremely high” is used in Table 3-3, but the term “extreme” is used in Table 3-4. The term used in FM 100-14 is “extremely high.”

A risk-assessment summary table is presented in Appendix F of TG-230 (Table F-1). It appears to be useful for working through the steps of the risk-management framework. However, the table is not introduced or discussed in the main body of the document. The subcommittee recommends that the table be moved into the main body and discussed. “Commander’s Summary OEH Chemical Risk Assessment” is a possible title. Note that there is a disparity between the “operational risk estimate” in Table F-1 of TG-230 and the risk assessment matrix in Table 3-3 of TG-248. The “risk level” in Table F-1 seems to be equivalent to the “risk estimate” in Table 3-3. Because FM 100-14 uses “risk estimate,” “risk level” in Table F-1 should be changed to “risk estimate.”

A few specific comments on the text pertaining to criteria pollutants in RD-230 are provided below.

Page 19, ozone. Delete the last sentence. The 8-hour standard is not more “conservative”; it is lower, but the rationale for that is not conservatism. Also, the 1-hour standard is not being revoked in attainment areas. That subject is under litigation.

Page 20, particulate matter. The last paragraph should include a few sentences about particle size and its importance.

Page 20, sulfur dioxide. Delete the sentence about acid rain. This section is about health, so a discussion of the ecological effects of acid rain is too sweeping to be accurate. Also, delete the sentence about visibility. If visibility is to be discussed, it should be part of the section on particulate matter. Sulfur dioxide is a major precursor to secondary particles, but that is only part of the problem of visibility.

Page 20, carbon monoxide. There are 1-hour and 8-hour NAAQS.

Page 21, nitrogen dioxide. Second sentence states “NO₂ can irritate the lungs, cause bronchitis and pneumonia, and lower resistance to respiratory infections.” Reference to bronchitis and pneumonia should be deleted and replaced with “changes in pulmonary function,” because pulmonary function changes are caused by NO₂, while the other changes have only been associated with respiratory infections and NO₂. Delete the reference to acid rain for the reason listed above. The last sentence refers to the pollutant standard index (PSI), but the PSI is not discussed for the other criteria air pollutants. PSI should be mentioned for all or none. The statement that nitrogen dioxide at 200 ppm is considered by EPA to be “very unhealthy” should be corrected. According to the reference (EPA 64 Fed. Reg. 43530 [1999]), 1-hour levels from 0.65 to 1.24 ppm are considered “very unhealthy,” and that term is equated to an air quality index of 201-300. Nitrogen dioxide at 200 ppm is likely to be lethal or close to lethal and not realistically ambient.

Page 38, paragraph “the analyses…”, L4. Many cities do not “frequently, if not routinely, exceed the NAAQS.” That statement is true for ozone, and one could argue about particulate matter, but it is not true for the other criteria pollutants. It is also a complicated issue, because the NAAQS are actually “design values,” not specific numbers as implied by the tables. Regardless, this information is not useful to the RD-230. The sentence should be deleted because it is both incorrect and irrelevant to deployment situations.

Page 53. Section 3.4 header is listed as “3.3.”

Pages 59-60. Subheadings under Section 3.4.5 are all erroneously listed as 3.4.6.

Page 61. Equation 3-17 title refers to the “Stern” model. It should instead refer to the “Bowers” model.

Page 62. Table RD 3-7 refers to Section 3.2.4 in the rationale box. It should refer to Section 3.4.6.3.

Page 64. The first paragraph cites USEPA 1989b as the Exposure Factors Handbook (EFH). The EFH was issued in 1997 (USEPA 1997c).

This page intentionally left blank.