ML19347F766
| ML19347F766 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 12/29/1980 |
| From: | Orton C RHODE ISLAND HOSP., PROVIDENCE, RI |
| To: | Shum E NRC |
| Shared Package | |
| ML19347F763 | List: |
| References | |
| 18189, NUDOCS 8105260267 | |
| Download: ML19347F766 (2) | |
Text
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Dr. Ed Shum p
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Dear Dr. Shum:
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As re:;uested by the State of Rhode Island Radiation Commission, I have made a 2 th: rough reviey of the potential radon exposure calculations pre:;ented in Table 4 of the tiRC's " Soil Decontamination Criteria" for the UtiC facility in Rhode Island.
Thank you for sending me copies of the two EPA Standards Proposals and the Memoranda of.Dr.'s Magno and Rouse. Unfortunately, few of my questions were addressed in these documents to my satisfaction.
Indeed, even more questions have now been raised.
I might at this point repeat what I told you on the telephone-I am by no mear.s an expert in the field of radon and its carcinogenic effects.
I am simply
.trying to understand the basis of the tiRC Criteria on' behalf of the State Radiation Cc=.ission.
~ Following are my observations to date:
(a)
According to BEIR'III, in mine atmospheres of Rn the absolute risk of radiation induced lung cancer is - 20 deaths / year /WLM/100(tttis is an average over various age-at-diagnosis groups).
6 The normal death rate from lung cancer:400/ year /10 (averaged over all age group 2 at time of death).
Hence the % increase in death from lung cancer.20 x 100
~ TD6
= 5%/WLM (This is in good agreement with the risk estimates in Table 1(A) in the EPA Federal Register Report Vol. 45, tio. 79 regarding proposed standards for cleanup of sites).
26 (b) The tiRC calculation (Table 4) for 3.0 p Ci/g Ra yields 0.15 WLM radon /
year and this will result in about a 50% increase in lung cancer for a 70 year exposure.
(c) My calcylations ucir.g 3 = 0.7, X = 0.3h-1, and 1 p Ci/1 Rn = 0.01 WL and 2 p Ci/m -sec, yields 1.7 WLM radon / year i.e. this will result in about l
a 600% increase in lung cancer.
(flote:
this' Rn level is equivalent to l
- 0.07 WL i.e. about 5 times the maximum specified in the EPA Interim Cidanup Standards. Table B).
(d) tiote:
in.one respect the above calculations of risk ~may be underestimates since they use data based on Rn.in mine atmospheres, where dust particles carry much of the Rn.
In homes, a significant portion of the Rn will be attached to ions, which are more readily " trapped" in the branchi w"
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(e).The 3 p Ci/g Ra1imitwaschosenbecIuseitisaboutequaltothe
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226 226 a in the soil 2
upper range of natural background concentrations of R
in the mining and mill %g regions of the Western U.S. (p. 9 of ref. 2).
This seems to be inappropriate in this region.
It should be noted
~
that these Ra levels were not determined in relation to the potential hazard.
~ Oc6stions still not answered:'
. ~
What is tee appropriate value for A for modern, well-insulated homes?
(1-2 h-1 1s clearly not correct).
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Why is the 3 p Ci/g Ra criterion applicable in this iegion?
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What is the appropriate value.for B (Table 4)? Values such as 0.7 are,
c" r quoted in the literature..
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~~..c :v What relevance does the dose conversion factor of 5 rem /WLM, which.
refers to dusty mine atmospheres, have for atmospheres found in homes it should probably be significu.tly higher (see BEIR III).
Cc = ent:
The proposed criteria do 'not meet the current EPA guidelines of kee;:ing the potential average annual indoor Rn decay product concentration,.
including background, below 0.015 WL.
Even without including background, the proposed levels are about 5 times too high. Also, in this region.
(as opposed to uranium mining and milling regions of the U.S.), they do
' not meet the requirement of keeping exposures ALARA.
As you probably realize, I ain not at all satisfied with the responses I have received to my questions.
Since there is considerable urgency concerning this matter, I hope you will be able to make a detailed response within the next few weeks.
Thank you for your attention.
Yours 'truly, r
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Colin G 'Orton, Ph.D.
Vice-Chairman, RI. State Radiation Commission
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cc: Dr. Joseph Yacovon'e Mr. James Hickey
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