Abstract

This article questions the basis for benzene as the carcinogenic surrogate in deriving health risk-based 'clean-up levels' for gasoline-impacted soil and groundwater at leaking underground storage tank properties. The epidemiological evidence suggests that acute myelogenous leukemia (AML) associated with chronic occupational benzene exposure can be best described by sigmoid dose-response relationships. A review of the molecular toxicology and kinetics of benzene points to the existence of threshold mechanisms in the induction of leukemia. The toxicological and epidemiological literature on chronic exposure to unleaded gasoline indicates that the benzene exposures required to induce a measurable carcinogenic response are substantially greater than exposures likely to be encountered from exposure to gasoline at contaminated properties. Thus, assuming that theoretical cancer risks associated with exposure to benzene from gasoline reflect actual health risks associated with such environmental exposures to gasoline and using these theoretical cancer risks and cancer potency factors for benzene to dictate soil and groundwater clean up of gasoline are not scientifically defensible.

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