ML20062J416

Forwards Radon Info in Response to Request.Info Should Be Made Available to Aslab & Parties in Radon Proceedings

ML20062J416
Person / Time
Site:	Peach Bottom, Hope Creek, Crane
Issue date:	10/10/1980
From:	Ellett W ENVIRONMENTAL PROTECTION AGENCY
To:	Ahearne J NRC COMMISSION (OCM)
References
NUDOCS 8010220541
Download: ML20062J416 (150)

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.8 O '.i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C.

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e Hencrable Jchn F. 1hearne To - 3 r<//3sf-Chairman Nuclear Regulatery Commissica Washingten, D.C. 20555

Dear Dr. 1hearne:

The informatien you requested on raden frem Dr. David Rosenbaum, Deputy Assistant Administrater for Radiation Programs, is enciesed.

Please =ake it available to the Appeals Beard and the parties involved in the raden pecceedings.

Sincarely yours, William H. Elleet, Ph.D.

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Chief, Biceffects Anal 7si's 3 ranch

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Criteria & Standards Divisics (ANR 460)

Office of Radiatica Progra=s 5 Enclosures Ltr dtd 10/6/80 f:-:m W. Ellett te Senater Baucus Radiation Policy Ccuncil Decisien Paper Secticn 4 "Radiatien Health Risk Estimates",

EPA /8-70-013 RPC '"ask Ferce Pesitics Paper en Raden in Structures Ltr dtd 10/6/80 from A. Richardsen to Senater 3aucus 10/17...To GGC for Apprcpriate Action...Cpys to: Chm, Cars,0PE,ECO. 80-1880 Ss o 9,#

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i OCT 6 1980 t

Bonerable !enz Bensus United States Senate Washington, D.C. 2C510 i

l Dear Senator Bauenst j

In a m. to the Office of Radiation Progress' Staff, l

Mart Smolensky, a investiga*or for your Subcommittee, asked a number of i

questicas relating to EPA estimatas of the lang caneer riska free radon exposures. Estimates af this risk for the total U.S. pepulati m are a i

functim of the population's average lifetime exposure to rades in the i

hee and work plaen and how much a given lifetime exposure increases the

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risk of lang ennaer. Neither of these quantities are knows with aneh j

accuracy, but infomatico is seemulating which indicates the publie risks fue rados warrant aerious attention.

l l

A Badiation Policy Council (IPC) Task Force, which I shaired, i

recently examined the redon quantion and what the proper Federal role should be. Their report cetlines what is knous about has radan geta into the home evim==mt, what average exposure levels might be, and the potential ocesequences. A copy of this interagency Task Force j

report is emelosed.

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! A 3aden exposures are usually expressed in tems of the concentration i

(f of short half-life radas daughter produsta, using a unit callsd the l

l Working Level (1dL). As outlined in the Task Force report, the amount of

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raden daughters in homes varies enormonely depending on the ventilation, i

f local soology and a namnber of other factors. Although everage exposures are not well known, there is some concensus that the mean 5.3. exposure is about 0.004 idL (Tables II-1 and III-1 in the RFC report). The actual I

amount of reden in homes emuld be more or less than this and one of the aims of the emersing Federal program is to get better data ces national e,p _.

As illustreted in. Table II-2 of the RFC report, a wide range of i

i risks have been estimated for reden exposures. These risk estimates l

vary by a factor of eight er acre depending en the assumpticas made in l

applying epidemiological data free occupational exposures (underground sinars) to the general population. EPA has made a straightforward projecticut of the observed occupational risks to the generel population.

I I must emphasize that we da not know if the general population would l

l have a greater or matter response than miners. This is a ecumen feature l

cf all radon risk estimates and is a major scures of uncertainty.

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I Searing this in =ind, EPA has used three risk models to estimate the lung l

i cancer risks from lifetime esposures. These estimates are doem ented in s 1979 EPA /ORP report

• Indoor Radiation Exposure Due to Radium-225 in Florida Phosphate Lands.' A copy is enclosed which outlines in same detail the various approaches we tutve used to estimate lifetime risks.

If we assime children and adults have equal sensitivity, 0.004 M. yielda a lifetime risk of about a000 cases per sillion persons exposed for a lifstine, page 52 of the EPA report.

(For the same population base, we i

would expect about 25,000 additional esses due to causes not associated with radon.) These estimates are for a stationary population having l

11rf0 death rates vita an aversge age at death from all causes of about l

71 years, so that the avernse annual risk associated with raden is about.

60 cases per year per million population. For a U.S. population of 240

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aillion persons, this amounts to en estimated lung cancer death rata per l

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year et aoout 14,0C0 cases. As pointed out in the 1979 EPA report,

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oited above, if exposures during childhood are 3 times more dangerous I

than adult esposures, the annual risk sasceinted with radon would be j

increased to about 20,000 cases per year. On the otherMand, the less conservative risk model used in the 1979 report yields an aversge annual

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i risk of about 7,000 cases per year in a population of 240 million.

l

• ie recognise that estimating the rhka due to ionizing radiation is l

an' uncertain business and t3at other investigators have made estimates f

of risks due to redon that are both larger and smaller than those made l

One of i

by EPA - Table II-2 in the RPC report illustrstes this point.

l the most recent estimates is one made by the National lesdemy of I

Sciences' DF.II Committee in 1980. Alt.W. their methodology was quite l

i different from that used by EPA, lifetime risk estimates using their sodel yields results that are alaest identical to the EPA estimata of N)

14,000 cases per year citen above, c.f., Table IT-2 in the RPC report.

t Even so, we are not convinced that the risics from indoor rsdon are well l

understood. Projecting risks from occupational eroosures to a ;;eneral population may not be very accurate. However, in the absence of relevant data showing that risks to the teneral population are likely to te less, l

l we believe current estimates of risk should be used.

• he 3sdiatien Felicy Council has recently mecamended ttst

-ca.sidersble Federsi attenzien te dir-eted at the tsden preeles and placed Nsocasib111t7 on TPA to provide leadership in a nuster of 'rens.

Their septaneer'25 decision paper concerning the indoor esden rceles is I

enolosed. Expeditious action by EPA and ett.: agencies is required by I

these.IPC-epproved recessendatiens.

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I hope this letter and the enclosures provide sufficient intersation f

i en now 2A risk estimates for esden were made. If you have questions, plasse contaos as by phone at (703) 557-9380.

I Sincerely yours, W1311am H. C1stt, Ph.D.

Chief, Bioeffects Analysis 3rsach criteria & Standards Otvision (ATt-460) l Office of Radiation Pregrsas t

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3 Eneleeures e.e w/o Enclosures) l

!*r. Werk Stevens, Office cf !.agislative Affairs, UA l

. P. mark Smolonsky

r. David Rosanbaum (A:tR-*.59) 6 i

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- r-ANR 360:W.Elett: awe 10-6-30 (CMf2,1021, X79380) l l

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9/17/80 U.S. Radiation Policy Council Decision Paper Reccmendations for Council Action Based on Reports by Three Task Forces Introduction At its May, 1980 meeting the Council created task forces to

. examine the following issues:

Control of radon in inhabited structures 1) 2)

Occupational radiation exposure regulations

.(

3) 1.ow-level radioactive wasta management a)

Preparation of a directory on current radiation protection responsibilities and activities Task forces began work immediately on the first three issues. The first act of each Task Force was the preparation of a work plan which included a statement or restatement of the objective (s); a brief stenary of the basic issue (s); a sumary of Federal activities; a study design including assign-ments and schedule; and a plan for public involvement. These work plans were submitted to the Working Group and approved in early June,1980.

The j

fourth task, preparation of a directory, was not undertaken due to the un-i willingness of any agency to assume the lead.

It will be undertaken in the near future by the Rad 1ation Policy Council staff if the recuested FY 1981 resources are forthccming.

Each Task ~ cree prepared a cosition pacer, dated August 15, which laid out the background and on-going activities, the basic issues or problems, and ways to address these issues and problems.

These position pacers were sent to the Working Group and sumaries of each placed in the Federal Register (vol. 45, No.169, August 23, 1980, so 57512-19).

Af ter reviewing tne pos1:1on papers, the Working Group met and reviewed the conclus1ons in each pacer.

Many of ne issues raised or solutions suggested, particularly in tne occupational execsure area, l

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.t incorpqrated in the development of issues for the long-term agenda (see j

I item V). However, certain specific issues or solutions were identified by the Task Forces that the Working Group believes can be addressed now.

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Reconnendations Based on the position papers, the Working Group reccmmends that the j

Council take the following actions.

o Radon Based on currently available information, radon and its progeny j

appear to be one of the major sources of radiation exposure for the general l

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population. However, the existing data base on the levels of radon &nd its progeny in structures and f actors affecting these levels is extremely limited.

Information on the health effecte is derived mainly from studies of uranian miners exposed to raden in an occupational setting.

The Working Group and the 1

j Radon Task Force believe that a systematic assessment must be done before any I

dec1sions' can be made on a national radon control strategy.

Though numerous acencies have been involved in various raden assessment activites, the Federal l

effort clearly needs to be better focused.

There is also a need for providing consistent advice to State and local governments as well as Federal agencies e

on radon control during the assessment period.

Consequent'y, the Workinc f

Grouc recommends that the Council:

I R 1) endorse the development of a Federal strategy to assess the prevelance and levels of radon and its progeny in inhaoited structures in the United States; R 2) recuest EPA prepare a monitoring and health effects assessment 1

1' strategy for review by the Working Group no later than, cvember and for consideration by the Council at 1ts Decemoer meeting, l

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t R 3) request E8A bring to the Council, if or when the assessment l

indicates the need for control, a schedule for the development of l

health or technology based national standards, including related statutory authority; l

R 4) request EPA take the lead, in the interim, in offering consistent Federal advice and guidance to State and local goverments and other Federal agencies with regard to specific situations where radon has 3

been, or may be, identified as a potential problem R 5) direct the RPC staff to prepare a recommendation designating I

the responsibilities of Federal agencies in the area of radon assess-ment and control; and

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R 6) request the Interagency Radiation Research Cemittee include i

l in its research strategy the effects of radon at low levels.

l o Occucational Radiation Excesure Reculations Numerous issues arise j

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in establishing or revising regulations for occuoational exposure to l

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radiation.

Since 1960 the foundt. tion for such regulation has been I

tne Federal guidance, initially the responsibility of the FRC and l

51nce 1970, of the EPA.

Present occupational exposure regulations are based on guidance written in 1960 and now felt to be in urgent need of revision by a numeer of agencies.

Once this current need to revise the guidance has been met, it is felt the other issues raised by the Task Force can be addressed, and in f act most of them have i

been incorporated in the recomended lon9-tent agenda (item V).

Fcr the i

near term need, the Workinc Grouc recommends the Counc11:

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J OE 1) request E?A provide to the Working Group at least two weeks l

1 pr1er to each each Council meeting a recort on the status of its

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INDOOR RADIATION IIPOSURE DUE TO RADIIDf-226 IN FLORIDA PHOSPEAM LANDS F

'3 Richard J. @s' ~ d William H. Ellett, Ph.D.

f Joseph E. Fitzgersid, Jr.

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Samuel T. Windham Philip A. Cuny I

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e i V Revised Printing i

July 1979 i

Criterut and Standards Division Offi'ce of Radiation Programs U.S. Environmental Protection Agency Wasnington, D.C. 20460 l

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t FREFACE l

1 The Office of Radiation Programs of the Environmental Protection l

Agency endeavors to protect public health and preserve the environment l

by carrying out investigative and control programs which encompass various sources of radiation. Pursuant to this goal, the Office's j

(

Criteria and Standards Division and Eastern Environmental Radiation Facility initiated a study in June 1975 to examine the radiation l

impact of living in structures built on phosphate lands. This study i

was carried out in conjunction with the Florida Department of Health and Rehabilitative Services and the Folk County Health Department.

The purpose of this report is to present the findings of that study; these include estimates of the radiation levels, evaluations of the cost-effectiveness of controls, and possible actions that can be taken l

to reduce such levels. Readers of this report are encouraged to inform the Office of Radiation Programs of any omissions or errors.

Constants or requests for further information an also invited.

j We wish to express our gratitude to the staffs of the Florid.

Department of Rehabilitative Services and the Polk County Health i

Department for their ocoperation and assistance.

Staffs of the Eastern Environmental Radiation Facility in Montgomery, Alabama, and 3

the Environmental Monitoring and Support Laboratory in Las Vegas, j

j ij l

Nevada, contributed substantial efforts in sample and data analysis.

We also offer our thanks to officials of the phosphate industry for their help.

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William A. M ms, Ph.D.

Act.ing Deputy Assistant Administrator

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for Radiation Programs (ANR 458)

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h TABLE CF CONTENTS Summary and Findings.......................

1 Section 1".0 Introduction.....................

4 2

Section 2.0 Problem Descriptica.................

7

( l; Section 3 0 Observed Radiation Levels..............

17 Section 4.0 Radiation Health Risk Estimates..

29 l

l A'alysis of Control' Alternatives.

56 j

Sectica 5.0 n

t Section 6.0 Alt.=rnatives for Radiation Protection........

76 j

f Secticn 7.0 Socio-Economic Impact.

90 I

Section 8.0 Implementaticn of Radiatica Protection Measures...

97 i

References............................

101 l

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Classary.....b 107

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Appendix A Study Design - Techniques and Procedures l

i Appendix B Calibration of Track-Etch Films Appendix C Radiation Exposure Control Measures i

Appendix D Evaluation of Field Data Annex Individual Structure Data 1

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6 SECTION 4.0 RADIATION HEALTH RISK ESTIMATES

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THE RISK TO HEALTH DUE TO THE INHALATION CF RADON DAUGHTERS l

4.1 4.1.1 The Epidemiological Data Base i

The carcinogenic nature of inhaled radon and its daughter products became knew through observatico of fatal lung disease in a

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some groups of underground miners. The malignant nature of their I

disease was recognized as early as 1879 and specifically identified as bronchiogenic cancer in 1913 (Lu71). The associatica between these cancers and tbs miners' exposure to rade was first made in 1924.

f Although there has been 'some argument that occupational hatards 5

other than raden may be important, extensive studies have excluded many suspected causes of excess lung cancer among underground miners j

such as pneumoccasioses, water in tbs mines, heredity, fungal growths, l

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as well as a number of metals in the ore, i.e., nickel, chromium, l

arsenic, and bismuth (Fr48, Hu66).

Exhaust fumes from diesel engines j

are often mentioned as a causative factor for lung cancer among Yet from 1869 to 1878, well before the diesel engine uranium miners.

was patented in 1892, lung cancer caused 75 percent of siner deaths at Schneeberg (Ha79).

The observation of excess lung cancer mortality in workers in a variety of bard rock and metal sines indicates that uranium are dust is not critical to the development of lung cancer 29

l (Fr 8, Hu66, Lu71). The only ccamen factor identified in all miner u

groups studied is the presence of radon and radonMenghter aerosols in therespiredair(hi76).

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The general recognition of the radon problem nas resulted in a number of epidemiological studies in various countries, including the U.S. A., Canada, Czechoslovakia, Sweden, and Great Britain.

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cancer deaths in U.S. uranium miners have been the subjindt of an m

extensive epidemiological study led by the U.S. Public Health Service (Lu71, Ar74, Ar76), which has proiided much information m the etiology of radiatico-induced lung disease.

Nevertheless, this study and to a lesser extent other studies of cancer deaths amorig under-ground mi$ers have limitaticns when used for the purpose of providing risk estimates applicable to the general population.

The relative importance of these limitaticca has been considered in the risk e

,,i estimates made belew.

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'he estimates of the risk to miners have continued 'a r se as more epidemiological data have accumulated.

In this regard it is of l

interest Oc compare recent informatica en radicgenic lung cancer with that availaole in 1970-1971 when the Federal guide for occupaticnal expcaure of siners was.1duced from 12 to 4 Working Level Months ('au) per year (Fe71). These guides were based almost exclusively en the

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experience of U.S. uranium miners exposed to high concentrations of radon daughters.

At that time 70 lung cancer cases had been observed l

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While this number of cases exceeded the expected in the study group.

number of 12, about half of the cancers followed exposures of more than 1800 WLM (Lu71).

Figure 5 shows the number of lung cancer cases observed in the U.S. uranium miner study group through September 1968, and their estimated levels of exposure in WLM. TIeexpectednumberofdeaths depends en the number at risk at each dose level and is based on white

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males in the four watern states where the uranium mines w re in

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operation (LuT1). Three things are worth noting in these early the small number of deat.*is in each broadly defined exposure results:

category, the relatively constant ratio of expected-to-observed deaths below 1800 WLM, and finally the absence of any significant difference For these reasons alone, it is easy to appreciate why below 120 WLM.

early estimates of the risk due to radon inhalaticn were controver-sial; there was essentially no dose respmse information available.

d More recent data, described below, differs censiderably from these F

1968 results.

A fundamental limitatica in this and similar investigaticas of lung cancer mortality is that the U.S. study is still in progress.

Survivors in the U.S. study are continuing to :sa of lung cancer with the result that more recent data show a much larder number of lung cancer deaths than was or4 3 n=" y projected (Na76).

Another very d

serious limitation, peculiar to the U.S. study, is that the cumulative expcaures to the 4000 workers involved were quite large, aversging 31 i

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WHITE U.S. URANIUM MINERS (1960 - 1968)

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120 380 840 1800 3720 CUMULATED EXPOSURE IN WLM I

I RESPIRATORY CANCER MORTALITY REPORTED FOR U.S. URANIUM MINERS (Lu 71).

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l nearly 1000 WLM per miner. There is some evidence that at such high f

i levels of exposure the risk per unit exposure is somewhat less than

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l occurs at radon daughter exposures belcw a few hundred working level

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months (Lu71, Na76). In addition, the lung cancer mortality data for I

Japanese atcaic bomb survivors also shows a trend for increasing lung cancer risk per unit dose at lower doses (Un77).

For this reason it

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i is advisable in risk analysis to limit the use of epidemiological data i

f e miners to that obtained at moderate exposure levels, i.e.,-a few hundred working level months.

I The limited information available from the study of the U.S.

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uranium miners can be augmented by using results derived from epi-l l

demiological studies of miner health in other countries and in other types of =4 *4"! operations. The occupatienal environments in these f

mines differed substantiany from those in the U.S. underground t

uranium mines so that the ?_=1_mtive exposure from radon decay 1

products was much saaner (M176, Se76, Sn74).

In addition, the reported fonow-up period in scme of t$sse studies is icnger than for l

the U.S. stucy population.

In au study groups, however, some miners are stin alive and the final number of lung cancer cases is expected s

The absence of data from acepleted lifetime toucw-up to be lar ger.

studies can lead to a biased underestimation of the risk due to the f

Mhalatien of radon daughters, unless appropriate risk models are utill:ed wnica recognise that current studies have not been l

completed.

This important topic is discussed telcw.

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l The direct proportionality of cancer risk to radon decay product I

exposure at levels likely to be experienced in the environment cannot l

be demonstrated for either human populations or by antaal studies because of the large number of subjects needed.

As shown below, the i

available data indicate that the use of a linear response curve for humans exposed to low concentraticas of radon decay products is not L

expected to greatly overestimate or underestimate their cancer risk i

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provided that the exposures do not exceed a few hundred working level f

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months.

Figure 6 illuserstes the observed cancer excess in Canadian uranium miners who were exposed to much lower concentrations of radon decay products than are common in U.S. uranium mines, (c.f. Figure 5).

Although this study may not be fully adequate to establish a quanti-l l

tative-esttnate-of the risk per~ working level month because data on i

smoking histories is incomplete, these data' have been shown to be l

consistant with a linear dose response relationship at relatively low 9

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levels of exposure and strongly argue against a threshold dose fer

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radiocarcinogensis in the lung (M176).

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t Figure 7 shows results obtained by J. Seve and co-workers, from l

their study of uranium siners in Czechoslovakia whose sining experi-l l

ence started after 1948 (Se76).

In that country, excess lung cancers i

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had been observec in uranium siners exposed before World War II.

An appreciation of this led to-better ventilatica of the ursnium mines and resulted in relatively low levels of exposure to siners entering the work f:rce after 1947.

The average follcw-up period in this

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Reseiratory Cancer Mor:slity Ecyceted in Czechoslovanan t~raniur'

?.iners (1948 - 1972). Average for all.ges, (See text), (Se 75) j 1

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group is twenty three years.

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l e$posum and excess cancer shown represents an overall average for i

This study also found that the absolute workers of various ages.

cancer risk increased substantially with the age at which a worker W

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It should be noted also that epidemiological data of the kind i

F illustrated in Figures 6 and 7 will always overestimate the exposure The to radon decay products needed to initiate a lung cancer.

i t

r exposure considered in these studies is that a~*'='isted throughout

(

The dose received but ineffective j

the working life of these miners.

f in producing cancer between the period of cancer initiation and 1*J I

anifestation is not discounted, For chronic exposure, the same reascaing applies to deter *ning the minimum exposure level at which a i

significant number of cancers occur; an apparent threshold dose will exist, unless the cancer is initiated on the last day of exposure.

s i

i 4.1.2 RiskEstimates(orUndergroundMiners g

Estinates of the cancer risk due to the inhalation of raden decay I

products can be sade either on the basis of the dose delivered *w the

{

basal cells of the beenchial epithelium or the a'='1stive exposure in I

e i

WLM.

In 1972 the NAS-BEIR Comnittee used the former method to prepare

{

their risk esttnates so that other types of ionining radiatien could be considered also (Na 72).

More often estimates of the risk due *A l

radon decay products are based en the cumulative exposure in WLM i

i f

(LuT1, Ar76, Na76, UnT7, M176, Se76, Sn74).

37

~

~

9 i

The dose to the bronchial epithelium has been calculated by i

i several investigators (Wa77, Ha74, Ha72).

While valuable, these l

studies indicate that tbs dose (in rada) is highly dependent en a I

i One i

number of factors which have varying degrees of certainty.

t l

t important, but as yet poorly known, parameter is the depth below the i

j I

aucosal surface at which the sites in irradiated tissues giving rise l

l

(';

to lung cancer are located. This distance, which is likely to differ l

l 1

in various porties of the respiratory tract, is not known with any

(

u In additim, no information is available on the degree of accuracy.

l uniformity of deposited daughter products in various parts of the bronchial tree. Furthermore, the g situ abrorption and removal I

pattern of the rad a decay products lead-214 and bismuth-214 is poorly l

r Recent experimental evidence indicates that to postulate understood.

L f

their complete decay in the aucus near the brtxichial epithelium, as is i

,! y>

usually done, is likely to be in error (Ja77).

Because of the uncer-t l

l l

tainty in calculated doses, the Agency prefers to base estimates of l

f the risk due to redon decay products en tne cumulative exposure in i

i I

working level scnths.

i i

2e 1972 NAS-BEIR Report used two types of analyses in esti=ating i

the radiatien-induced cancer risks from folicw-up studies of exposure t

i groups (Na 72). One, called tne absolute risk estimate, is the num-erical increase in the number of excess cancers per unit of exposure, aversged over all age groups. The otner, tne relative risk est:= ate, is the estimated percent increase in excess cancer per unit exposure t

36 i

j

. ~. _....,

p,,

I i

Kither'of these models will yield the same number of excess cancers 1

J j

for a given study population if based on data frca a lifetime fonow-1 Because exposed persons have been fonowed for a shorter up period.

i In the exposed duration, a choice between these models is needed.

l groups studied, the risk of radiogenic lung cancer, but apparently not l

au cancers, increases with the participants age in about the same idence of lung cancer, i.e., the relative

. manner as the " natural" inc In contrast, the absciute risk estimates risk remains constant.

j

[

derived from the U.S. study are not cons

• ant but have continued to N

I increase as the length of the fo now-up period is increased (Na76).

\\

f Lung cancer mortality among Japanese survivors has shown a similar Moreover, analysis by age shows the Czechoslovakian i

pattem (3e77).

and Canadian lung cancer data to be grossly inconsistent with the l

abso).ute risk hypothesis (M176, Se76).

i More recently, the Japanese cobert data on lung cancer mortality

(

l for those exposed to high LET bomb radiation at age of 50 cr more have i

m been examired for the time of occurrenge of excess lung cancer after i

l j

exposure (La78). Because of their age, a near lifetime fo new-up i

study of this group is pcssible; the youngest surviving member was i

nearly 80 at the time of the study.

Lung cancer mortality was i

l compared for two dose ranges, those highly exposed, where three times the expected number of cancers was cbserved, and a control group receiving 0 to ten rads (" tissue ker=a" in air)..The time to l

occur-ence of the lung cancers is the same for the two groups, as would be expected if the increase.in lung cancer nortality fonews the t

l 39 l

- - - - - - - - - ~. ~ _ _ _ _ _

i l

t t

l l

j This is similar temporal pattom predicted by a relative risk model.

)

i to observed patterns of lung cancer observed in animals 411 ewing l

1 plutenium inhalation (Na 76).

In the analysis of these data as they l

apply to human health riska the 1976 NAS Ieport stated, "as already indicated, the steepness with which lung cancer death rates in the f

Battelle (Northwest Laboratory) beagles rose as a fanction of age strongly suggests that the relative risk estimate is the appropriate i

one to use in the present ocatext of assessing lung cancer risk fros l

(3 l

alpha emitters." Fce these reasons, relative risk estimates are s.

l thought to pmvide a better projection of the risk of lung cancer than However, both types are included in the set l

absolute risk estimates.

I t

of risk estimates made below.

As..an alternative to. these. two models, an age-dependent absolute l

I

. risk model with age-dependence somewhat different frem that for l

natural cancer incidence would also be compatible with the observa-tions made on uranium miner populations.

It should be noted that the l

ll l

l estimated risks using such a model would be much closer to those v

i calculated en the basis of relative risk than for an age-independent absolute risk model.

As yet, parameters for age-dependent lung cancer s

risk models have not been published.

I The estinate of the acsolute risk due to exposure to raden decay I

products in the genersi envircnment contained in this report are based on recent mortality ag erience of U.S. uranium miners (Na76).

Comparacle U.S. data on relative risk are not availacle, the most recent relative risk cc=pilatien was in 1972 fcr the NAS-cE3 report 30

. _ _ ~ -. _ _. _ _. _,, _. _. _

t i

o 5

9 9 ',

f v

t.

t l

~

l

\\

I i

l t

(Na72).

Since that time, enough new cancers have occurred so that absolute risk estimates based on this group have more than doubled (Na76).

• The effect of this longer follow-up period on their relative l

risk is unknown,.but any be substantial, Therefore the estiastes of j

t relative risk made here are based on studies of underground miners in r

i Czechoslovakia and Sweden. Relative risk data for the Ontarfa miners have not been published. However, an oral presentation indicates the l

[

results of the Ontario study (MiT6) agree with those for Czech and f

u Swedish miners (He78).

s The percent increase in excess cancer per iiLM for C.cheslovakian uranium miners is shown in Table 6.

These data have been recalculated i

i TABLE 6 CBSERVED INCREASE IN LUNG CANCER FATALIT! RATE j

g C:ECESLOVAEIAN URANIUM MINERS j

Mean Exposure (WLM)

% Increase per WLM l

3.6*

l 39 j

l

(~

v 1.0*

l 80 I

1.6 i

124 f

174 2.9 2.2 242 2.0 343 488 1.8 1.4 716

'Not significant at the 55 level of confidence l

41

._.._.m_.

t l

l 1

from References Se73 and Se76 on the basis of an assumed nin uyear latent period between the start of ex;csure and the occurrence of a i

radiation-induced lung cancer.

At the exposure levels which occurred in the Czech uranium miners, the average risk would appear to be i

increased by about 2-3 percent per WLM.

Table 7 shows the percent increase per *4LM observed in Swedish I

miners.(Sn74,.Ha76)..In this. case the. increase may be as great as 4 -

l percent per WLM at icwer levels of exposure.

The variatiens in the percent increase in lung cancer found in these epidemiological studies l

are not due to statistical sampling variation alene.

Each study l

t reflects differences in the age distribution of those expcsed, the duratien of the exposure, and the follcw-up periods.

Given the j

variatiens shown in Tables 6 and 7, the best that can be done is to i

l propose a range within which the actual risk may lie, as described in

)

Section 4.1.3 l

m v

TABLE 7 t

CBSERVED DiCREASE Di LUNG CANCER FATALC RATE v

S*4EDISH IRON AND CIC !CIERS Mean Exposure ('4LM)

% Increase per '4LM

s 2

aa 4.2 218

3. 3 -

i 696 2.5

'Not sigr.ificant at 5% level.

l l

I I

l 42 1

1 l

i

i I

I.

I i

4.1.3 Applicability of Underground Minor Risic Estimates to the -

General Population As in most cases where the results of epidemiological studies of occupational exposures an applied to the general population, there is uncertainty in the artent of comparability between the persons at Very little information is available on those risic.

],

non-occupationany exposed.- i recent case control study by Axelson and Edling (1179) is suggestive that the mortality per W M for Swedish

{'

residents in homes having presumably high levels of indoor rados daughters is comparable to that observed in underground miners.

However, the sample size is saan and the exposure estimates too tentative to anow definite conclusions.

sasd miners with increased Since the only conson factor in underar risk of 3.ung cancer mortality is exposure to raden and radon daughter aerosols, the comparability of mine atmospheres, indoor and outdoor, should be considered.

Jacobi, el g., (Ja59), studied aerosol

,1 l

particle size distributions indoors, outdoors, and in radium mines, l

v l

• • nding similar distributions in each place. Measurements by George l

(Ge75a), George,',e,,,t g., (Ge75b) and others (Ha76, Lo77, Le75) would lead to similar conclusions. Ho neman has also concluded that the difference between =ine and atmospheric aerosol particle distri-butions was negligible, with the possible exceptions of the immediate vicinity of diesel engines and remote areas of the mine where aerosol concentrations were low (Ho68).

9 43

_---.._.c l

In general, mine atmospheres are not expected to differ greatly frca envirtzzmental atmospheres of the same quality.

Dusty atmospheres have low, unattached redon-daughter fractions, clean atmospheres havs high unattached fractions. ilell-ventilated areas have low raden-daughter ratios, poorly ventilated areas have high ratios.

There is no feature which would uniquely identi.^f either sine or environmental atmospheres,.as shoun in. Table 8.

.s TABLE 8 Comparison of Typical Aerosol Characteristics Environment Aerosol Ventilated Mines Outdoors Indoors ActivitT Pledian

- 0.'7("' ' d O.ON.30(*)

0.10-0.20("b 1

. Diameter ( um) 10 (drilling)(*)

I Concentration 3

6 (c) 4 5

(a) 4 5

(a,d (particles /cm 3) go _3a 3o,3o 3o,3o v;

0.04(*)

0.08(*)

0.07(*)

Uncombined Fraction (Range)

(0.002-0.12)

(0.005-0.25)

(0.003-0.20)

Raden-Caughter 1.0,1.0,0.4,0 3 (*}

1.0,0.9,0.7,0.7 (a,d) 1.0,0.3,0.8,0.7 (*'d' Ratio Range to to to 1.0,0.3,0.03,0.03 1.0,0.3,0.5,0.3 1.0.0 5,0.3,0.2

References:

(a) Ge75a (d) Ea76 (b)

Ge75b (e) In73 (c) Ge72 (f) Lo77 44

i I

ii There are several reasons for believing that the percent increase j

i i

in lung cancer per unit exposure to a general population could be either mors or less than that for miners.

Alpha particles from radon i

daughters have ranges in tissue comparable to the thickness of the

[

brd =1 mucus and epithelium. The *Melmass of the br@+=1 l

l epithelium of underground miners may be greater than is comen in the The BEIR Comittee estimated that the shielding general population.

l provided by the thicker epithelium of miners reduced their dose (and l

i risk) per unit exposure by a factor of two compared to the general l

(

.1 l

population (Na72).

On the other hand, miners'. lung cancer mortality data reflect a high frequency of cigarette making which tends to increase their lung i

cancer risk relative to the general population.

The degree to which f

smoking in conjunction with exposure to radon daughters may increase 6

Whil's a the incidence of radiation-induced lung cancer is not known.

i study of U.S. uranium miners has suggested a very strong association 14 between cigarette smoking and radiation-induced lung cancer, the

'T l J correlation between age and acking history in this study precludes j

I early j"Wt, particularly since the study also indicates that nonmokers have a leger latent period for radiogenic lung cancers I

(Ar76).

Some Swedish data on underground miners show that smoking may increase radiogenic cancers by a factor of about two to four (Ra76),

however, these results my be dependent on the duration of follow up.

Axelson and Sundell (Ax78) have reported that in a life span study of 19 exposed siners who died of lung cancer, the lifetime risk of lung 45

. ~ ~....

. _ _...~,

l i

De latency period, f

cancer in non-smokers exceeded that of sackers.

i however, wss such shorter for mokers.

A sample size this small, of Unfortunately, the Japanese course, precludes definitive ja W ts.

data are, as yet, too incomplete to yield comparable risk estimates for cigarette makers or non-smokers or even by sex (Be77).

W.is-oommon is all m'intions_at risk, frca environmental

'dhile the frequency of acking in U.S. uranium minar-was not

[

radon.

l very different from that of other male industrial workers at that l

time, it exceeds the current level of cigarette use, particularly by females (St76).

It is not clear that this will be true in the Cigsrette sacking ammcg younger females is contim'*as to j

future.

If j

increase are may approach or exceed cigarette maki=g by males.

so, relative risk estimates for exposure to radon daughters based on the current incidence of lung cancer mortality, which is now alacst f

l l

wholly due to male deaths, will be too low.

Conversely, if cigarette j

l f

smoking in the U.S. becomes less commen for both sexes sometime in the i

future the incidence of lung cancer may decrease and relative risk l

i Clearly t

estimates based en the current incidence will be too high.

cigarette making is likely to be a factor in determinir4 the proba-bility that a lung cancer is induced by exposure to radon daughters.

mdon daughter De Agency recognizes that estimates of the risk due *A

• nh=1stien have a wide range and may be *Ao high or *Ao Icw, depend-I ing, among other factors, on :he prevelance of cigarette soking in the future.

46

~~~~~"'~'mm.mma_%,.m,,

I I

Essed on T-bles 6 and 7 and the considerations outlined above, l

l tne range of the fractional increase in lung cancer due to radon decay products in the general environment is thought to lie between one and five percent per 'nLM.

Studies utilizing longer follow-up times and

However, relatively low exposures tend to support the latter figure.

if miners are atypically sensitive to radon daughters because of other characteristics in their occupational environment the fractional increase for the genersi population could be as low as one percent per WLM or less.

(\\

Another characteristic of the population at risk that differs from underground miners is age. The estimated risk for miners is It averaged over adult age groups only, children not being at risk.

is assumed in the ahsolute risk estimates given below that the risk While this due to radon daughters is the same for children as adults.

has little effect on the estimates of risk made with an absolute risk model, relative risk estimates are more dependent on the assumed sensitivity of children to radiation. The Japanese experience, as l'

reported in the 1972 BE3 heport, indicates that children irradiated at the age of nine or less have a relative risk rate of fatal solid j

tumors ten times that of adults (Na72).

However, none of the observed cancers is this gmup has been lung cancer, a cancer of old age.

1 (There is, of course, no informatien on lung cancer due to occupational exposure of children to raden decay products.)

The Agency believes that while it may be prudent *4 assume,some allowance for the extra sensitivity of children, the factor adopted should be less than a factor of ten. Therefore, in the Tables below, a 47

l three-ftrid greater sensitivity for cirildren is assumed in some of the i

relative risk calculations of mortality due to inhaled radon decay i

products.

O=htive exposures for a given concentratica of radon daughters differ between miners and the general publio.

For radca decay pro-duct exposures occurring to nonoccupationally exposed persons, i

consideration must be,given to the fact that the breathing rate (miste-volume, etc.) of miners is greater and the cumber of hours exposed per month less. than. in, tha. general population.

Radon decay j

product exposures to underground miners are calculated on the basis of f

a working level month (defined as exposure for 170 hours0.00197 days <br />0.0472 hours <br />2.810847e-4 weeks <br />6.4685e-5 months <br /> to one werking level).

Exposure to radon daughters in the general environ-mer.t occurs for an average of 730 hours0.00845 days <br />0.203 hours <br />0.00121 weeks <br />2.77765e-4 months <br /> per month.

The breathing rate over this period of time is less than an average breathing rate j

. appropriate for underground miners engaged in physical activity.

l Assuming that the average underground miner (comparatively few of whom

[

work at the mine face) is engaged in a mixture of light and heavy l

.s

,)

activity throughout the working day, his monthly inta5ce of air on the i

5.

l job is about 3 x 10 liters (In 75).

An average man (reference man)

{

is assumed to inhale 2.3 x 10" liters per day (males) or 2.1 x 10" l

liters per day (females) (In 75).

The average intake fer both sexes is 6.7 x 10 liters per month, 2.2 times more 6. hart for miners ac 0

b work. Therefore, an annual exposure to 1 WI. corresponds 'a nearly 27 WLM for exposures occurring in the general environment.

l In the case of radon in residential structures, the time the r

residence is occupied must be considered also.

Cn the averags, j

i i

l 48 9

4 r

I

i l

Americans spend about 75 percent of their time in their place of i

j 5 liters of residential air is t

residence (No76) so that about 5 x 10 I

Bis corresponds to about 20 EM per year for a i

inhaled each month.

f radon decay product concentration of 1 WL in residential structures.

l Children respire a greater volume of air relative to the mass of t

j irradiated bronchial tissue than do adults, so that their exposure to t

f radon daughters is almost a factor of two greater for a few years t

This increase has been included in the section 4.1.4 risk f

(In75).

b estimates.

(i t

4.1.4 Risk Estimates for the General Public i

w Estimates of cancer risk in.this report have been derived frca an the competing risk from analysis that considers the following factors:

causes of death other than radiation, the fractional and absolute increase in lung cancer per unit exposure, the duration of the eroo-f sure, the period between the time of expcaure and the occurrence of a clini M iy identifiable cancer (latency), and the length of time a i

person is at risk following the latent period (plateau period) (Bu?8).

m yj l

Se risk estimates below assume a fixed latent period of 10 years for lung cancers (Na76).

Although there may be some correlation between l

latency and age, relative risk estimates are not too sensitive to this j!

Increasing the latency period to 30 years reduces the parameter.

estimated risk by between 20 and 40 percent depending on the sensi-tivity assumed for children. In the case of lung cancer, it is assumed that following the latent period an individual remains at risk 1

While for some cancers a l

for the duration of his or her lifetime.

I 49 I

~

h-a l

L 4 ' '

-- n. ~.

. a e-

. - w.s

• vm *..:. :'-

I

.. ;.,... y.

'i I

shorter plateau at risk may be appropriate, the U.f,. miner data as well as the Japanese bomb survivor data reflects a cont 4_-u4mg increase in radiogenic lung cancers beyond 70 years of age.

In these risk estimates it is assumed that the population at risk is subject to lifetime exposure and the distribution of ages is that in a stable (stationary) population (Un75).

The Agency recognizes that residential dwemar are seldom occupied by one family group for i

i their lifetimes. However, this has little effect on the ultimata h

health impact if another family occupies the structure.

The health risk to a particular family is a function of the time they occupy the dwelling and to a lesser exten't their ages.

For most practical pur-poses, the risk due to occ'apancy of less than 70 years can be found by taking a fraction of the risk given below as proportional to the years i

of ocet$pancy. For example, 7-year occupancy would be expected to yield one-tenth the estimated risk of lung cancer due to lifetime j

t exposure, approximately 70 years.

Residences which serve primarily as

' ~.

t i

j children's or geriatric's homes would be obvious exceptions.

l t

i The excess cancers due to radiation change the cause of death and 2

the age at which death occurs in the populatica at risk. The EPA i

analysis provides estimates of the number of premature deaths, the i

cumoer of years of life lost per excess death, and the total nu=cer of years of life lost by the population at risk.

These parameter's are P

included in the risk estimates presented belcw.

l l

3ased on the assumptions discussed above, Table 9 lists the estimated number of premature fatalities due to lung cancer that =ay l

l l

l 80

i

~~

1 i

i I

oc. car in, a population of 100,000 persons occupying structures having a j

radon decay pmduct concentration of 0.02 E.

The total nunber of.

i years of life lost by the population at risk is also tabulated.

These estimates are based on relative risk models which assume a 3 percent increase in lung cancer per EM. Two cases are compared in this Table:. (1) that adults and children have the same sensitivity, and (2)

~

that childrec below the age of ten are three times more sensitive than i

adults.

It is seen that the latter assumption increases the estimated l

[. T risk by about 50 percent.

j l

Table 9 l

Estimated Risk of Lung Cancer Per 100,000 Exposed Individuals Due to Lifetime Residency in Structures Havi.4 an Average Radon Daughter Concentration of 0.02 E Relative Risk Model' l

Excess cancer Deaths Total Tears Lost l

l Child Sensitivity a Adult 2,000' 30,000 Child Sensitivit7 = 3 x Adult 3,000 50,000

' Assumed mortality 3 percent per iiLM (see text)

/

i a

Table 10 presents absolute risk estimates for a radon decay product concentration of 0.02 E and lifetime exposure.

This Table I

has been calculated on the assumption that absolute risks are independent of me age at which exposure is received.

"'he esti= ate of the number of years of life lost, compared to the relative risk for the same ags sensitivity, is about the same, c.f. Tables 7 'and 8.

The j

estimated number of excess fatalities is a factor of two less than that estimated using the relative risk model.

This is within the l

51

'N g.

7 9y+

,s !.

"3 i,

J'

v -

uncertainty of the relative risk estimates since the range of values i

for the percent increase in lung cancer per EM is between 1 and 5 I

percent per EM, vis a vis the 3 percent increase assumed in Table 10.

Table 10 l

[

Estimated Risk of Lung Cancer Per 100,000 Exposed Individuals l

Due to Lifetime Residency in Structures Having An Average l

Radon Daughter Concentration of 0.02 'A i

Absolute Risk Model' Excess Cancer Deaths Total Years i

~

Lost l

Child Sensitivity : Adult 1,000' 27,000 eThe assumed ri.pk coefficient is 10 excess lung cancer deaths per EM for 100 person years at risk (Na 76).

i I

For comparison purposes, it is of interest to estimate the number of excess lung cancers in the U.S. due to ambient levels of radon j

decay products in non-contaminated areas.

The concentration of radon decay products in structures has not yet been surveyed extensively.

Most sensurements reported in the literature are for either a short

)

duratica, i.e., single samples, or in contaminated areas.

An excep-tion is the icng-term radon measurement program of the Environmental Measurecents Laboratory in the Department of Energy.

Their sensure-i ments of radon decay products indicate average background levels in l

l residences of 0.004 *E (Ge 78).

An ambient indoor background of this 1

level yields calculated risks one-fifth of those shown in Table 9, l

l 1.e., from about 400 *A 600 cases.

This is about 10 to 20 percent of the expected tct.a1 national lung cancer sortality of 2900 per 100,000 l

in a statienary population having the 1970 U.S. sortality rates.

This 1

l i

52 l

l I

1 i

percentage of lung cancer mortality is not necessarily attributable to raden exposures alone, since many cofactors have been i= plicated in It is emphasized that these risk esti-

"the etiology of lung cancer.

I i

mates are not precise and that the actual risk from radon daughter exposures could be a factor of tuo or more larger or smaller.

l It should also be noted that the risk estimates made here are-They j

based on a risk analysis using U.S. national health statistics.

1 have not been adjusted for the age, sex, or other dsImographic factors To the pertinent to persons living on phosphate lands in Florida.

's extent that the incidence of lung cancem in these areas is higher by i

about 40 percent than the naticnal average, the estimated health l

impact of reden exposures given above may be low in Florida In contrast, the persons living on phosphate lands could f

residents.

have demographic characteristics which differ frem the national average in such a way as to lower their riska compared 'a those listed I

For example, if the housing were used primarily by the very above.

old, there would be appreciably less has1th impact.

w 1

j I

l 4.2 The Health Risk Due to External Radiation Exposure j

J Unlike the highly icnizing alpha particles from raden daughters, external radiatial exposures are due to lish:17 ionizing secondary particles from interactions along the path of gamma-ray penetration.

High energy gamma.nys penetrate through the body causing a relatively Since all organs and uniform exposure to all tissues and organs.

tissues are exposed, the complete spectrum of cancers outlined in the l

53 1

eww w s.se.-9 ewo -

w.s,ym.mm -py w ym epp,,e m m e mw o m a,o.,a,,.a mvww-r-

e

7

~

___1 _ _ __ l j

)

I

't 3 ;.

1 '

)i 1972 MA3-BEIR Report (Na72) would be expected.

In addition, some a

j' genetic risk, resulting frem irradiation of the gonads, would be expected to occur.

j In the case of external penetrating radiatica, data presented in 3

the 1972 NAS-BEIR Report (No 72) yields the following estimates for 1

lifetime 1diole body exposure to 100,000 persons as shown in Table 11.

t i

TABLE 11

~;.. -

l' Estimated Lifetime Risk of Excess Fatal Cancer tand Genetic l

Abnomalities Per 100,000 Individuals Exposed

[g to an Annual Dose Rate of 100 mreu 4

s l

Excess Fatal Cancers Total Years Lost 470 a) 6500 a)

I Relative risk 150 b) 2700 b) 84 a) 1900 a)

Absolute risk 68 b)~

1700 b) a) life time plateau b) 30 year plateau j

Sericus genetic abnormalitiese

]

all succeeding i

1stgene.jation generations s

)

2-40 10-200 1i jl

• Birthrate 25 per year i

i These estimates are based on the assumption that the number of f

health effects observM -t relatively high doses and dose rates can be i

extrapolated linearly to the low levels of radiation usually found in i

i the environment.

Table 11 11-ta only fatal cancers.

The 1972 NAS-i j

BEIR Cosmaittee has estimated that a ocuparable number of non-fatal 3

cancers could be induced also.

I i

34 i

i

- ~, - -.

w -m.

=-= n--===- - -

-===----n--

- - - - - - ~ ~ ~ - - - - - - - -

- -^-- ^ ^ ^ - ~

~

t i

i F$ternal exposure to natural background radiation in Florida, from both cosmic, radiation and radiation from rLdioisotopes presert in the soil, is about 59 millires per year, except in regions contaisi.4 The estimated lifetime risk associated with this anomalous sources.

background is therefore about 605 of the values listed in Tatie to.

l

( ,

m e

e 4

1 5

55 i

+.--

. ~.

l I

1 REFERENCES Ar 74 Archer, A.E., Saccamanno, G. and Jones, J.H., Frequency of Different Histologic Types of Bronchosenic Carcinoma as Related to Radiation Exposure.

Cancer, 2:2056 (1974).

Ar 76 Archer, A.E., Gillam, J.D. and Wagoner, J.K.",

Respiratory l

Disease Mortality Among Uranium Miners.

Ann. N.Y. Acad.

l Sci., E :280, (1976).

j i

At 78 Atomic Energy Control Board, Canada, Investigation and j

f ;

Implementation of Remedial Measures for the Radiation

('

Reduction and Radioactive Decentamination of Elliot Lake, Ontario; Dilworth, Secord, Meagher and Assoc., January 1978.

1 Ax 78 Axelson, O. and Sundell, E., Mining, Lung cancer, and Smoking. Scand. J. Environ. Health, 4:46-52, 1978.

i Ax 79 Axelson, O. and Edling, C., Health Hazards from Radon Daughters in Dwei WE* in Sweden, presented at the Park City l

Environmental Health Conference, April 4-7, 1979 (to be published in Proceedings).

Be 77 Seebe, G.W.,

Eato, H. and Land, C.E.,

Mortality Experience of i

Atomic Bomb Survivors 1950-74, Life Span Study Report 8, RERF l

TRI-77, Radiation Effects Research Foundation, 1977.

i p

Bu 78 Bunger, B.M., Barrick, M.K. and Cock, J., L Na Table

)

/

Methodology for Evaluating Radiation Risk.

CSD/ORP Tec.%ical j

Report No. 520/4-78-012 Wune 1978)).

Ca 66 Cathcart, J.B., Economic Geology of the Fort Meade Quadrangle, Polk and Hardee Counties, Florida, Geological Survey Bulletin 1207, 1966.

j Co 78 Colorade Division of Occupatien and Radiological Health, Personal Communication, 1978.

De 78 Department of Health and Rehabilitative Services, Study of l

Radon Daughter Concentrations in Structures in Folk and l

Hillsborough Counties, Florida, January 1978 f

Fe 60 Federal Radiation Council, Background Material for the Development of Radiation Protection Standards, Report No.

1, Washing ca, D.C., May 1960.

101 i

f t

l

• =+m wmem m omam m m

-w,e v n n --

er -+ - -,

l 1

Undergrcund M* + g of Uranium Crys,, 34 E 576, 35 g 9218.

i Fe 71 Fi 78 Findlay, W and A. Scott, Dilworth, Secord, Meagher and Assoc / Acres, Inc., Personal Communication,1978.

l

~

5'o 72 ' ' FEunta$n,' F.'C2 and M.5.' Zellars,' A Program of' Ore ' Control in

'l l

the Central Florida Phosphate District, GeologF of Phosphate, Dolonite, Limestone, and Clay Deposits, Proc. 7th Forum on l

Geo. of Ind. Min. Geo. Div. Int. Res. DNR Spec. Pub.17 (H.S.

i Puri, ed.), 1972 The Fr 48 Fried, 3.M., Bronchosenic Carcinoma and Adenoma.

W m i - and. T*

• nu Co... Saltimore 1948 I

Ce 72 George, A.C. and Hinchliffe, L., Measurements of Uncombined

( '.

Radon Daughters in Uranium Mines. Health ?hysics, 2J:791-803 (1972).

l Gecrge, A.C., Indoor and Outdoor Measurements of' Natural Ge 75a l

Radon Daughter Decay Products in New !crk City Air, pp.

741-750 in The Natural Radiation Environment. II, l

CONF-720805, J.A.S. Adams, W.M. Louder anc T.F. Gesell,.

l editors, U.S. Energy Research and Developasnt Administration, Washingtour,1975 Ge 75b George, A.C., Hinchliffe, L. and Sladcwski, R., Sine l

Distribution of Radon Daughter Particles in Uranium Mine Atmospheres, Amer. Ind. Eyg. Assoc. J., H:484 490 (1975).

l Ce 78 George, A.C. and 3reslin, A.J., The Distributien'of Ambient Radon and Radon Daughters in Residential Buildings in the New i

j Jersey-New !crk Area, presented at Natural Radiation Envircament III, Houston, TI, 1978 (in press).

l t

+

Gu 75 Guimond, R.J. and Windham, S.T., Radioactivit/ Distribution j

in Phosphate Products, Syproducts, Effluents, and Wastes Technical Note ORP/CSD-75-3, U.S. Environmental Protection I

Agency, Washington, D.C., August 1975 t

Ha 72 Harley, N.H. and Pasternack, 3.S., Alpha Absorption Measure-Health monts Applied to L:.mg Doses frca Radon Daughters.

Physics.21:771.(1972)..

Ha 74 Harley, J.H. and Earley, N.H., Permissible Levels fer Occupational E: posures to Raden Daughters, Health Physics, E,1974.

Ha 75 Earley, N.H., Perscnal ec=::unication,1976.

i 102 t

"*Yfv#ww n%-

I I

i I

Ha 79 Harting, F.H. and Hesse, W., Der Lungenkrebs, die Bergkrankheit in den Schneeberger Gruben.

Vierteljahrisschr.

l

f. gericht1. Med. u. offentl. Sanitatswesen, J,0,:296 309, f

0 jl:102-129,11:313-337 (1879) l Ho 68 Holleman, D.F., ram = tion Desimetry for the Respiratory Tract _

of Uranium Miners, C00-1500-12, U.S. Atomic Energy i

Commission, Wasnington, 1968.

t i

Ho 77 Hofmann, W. and Steinhaus1er, F., Dose calculations for i

Infants and Youths Due to the l'ah=1stion of Radon and Its l

Decay Products in the Normal Environment.

pp. 497-500, in

/

Vol. 27 of the Proceeddana of the 4th International Congress i

('I of the Internatica=1 Radiation Protection Association, f

)

puolisnec ey the Congress,' Paris,19TT.

j i

Hu 66 Hueper, W.C., Occupatica=1 and Environmental Cancers of the i

Respiratory System. Springer-Verlag, New York, Inc., New l

Yort 19eo.

i In 73 International Atomic Energy Agency, Tah=1stion Risks from l

Radioactive Contaminants, Technical Report Series, No. 142, l

i International Atomic Energy Agency, Vienna 1973 i

In"75 Report' of the T'ask Gro'up on Refe'retice ' Man, ICRP Report #23, Pergamon Press, N.I., 1975.

Ja 59 Jacobi, W., Schraub, A., Aurand, K. and Muth, H., Ober das j

Verhalten der Zerfall-produkte des Radens in der Atmosphea*

~%

i

_)

Beitr. Phys. Atmosphare, 3:.2u4-257 (1959).

l t

Ja 72 Jacobi, W.g Relations Between the Inhaled Potential-Energy of 40 n Daughters and the Absorbed-Energy in the 222 n and R

R 3ronchial and Pulmonary Region. Health Physics, 21:3 (1972).

James, A.C., Greenhalgh, J.R., and Smith, H.,' Clearance of l

Ja 77 Lead-212 Ions from Rabbit 3ronchial Epithelum to 31ood.

j Phys. Med. Biol., 2,2:932 (1977).

l i

n 72 Cement, A.W., Miller, C.R., Minx, R.P., and Shielen, B.,

l Estimates of Ion 9dng Radioactive Doses in the United States l

1960-2000, ORP/CSD 72-1, U.S. Environmental Protection i-Agency,- Waahfanton, - D.C'., Augustc1972. w La 78 Land, C.E., and J. E. Norman, The Latent Periods of l

Radiegenic Cancers Cecurring Among Japanese A-Semb Survivors, I

l IAEA-SM-224/602.

i 103 l

=

=

=

8 4

I l

i i

Le 75 Letcoe, N.M. and Inculet, I.I., Particulates in Domestic l

Premises II Ambient Lefvels.and Indoor-cutdoor Relationship.

~

Ar'h. Environ. Health, E :565-57D T1975). '

c Lo 66 Lowder, W.M. and Becic, H.L., Cosmic-Ray Ionization in the t

Lower Atmosphere, J.Geophys. Res. 71, 4661-68, 1966.

l Lo 77 Lowder, W.M.,

Personal ecamunication, 1977.

Lu 71. Lundin,. F.E.,s Wagoner,. J.L. and Archer, V.E'., Radon Daughter Exposure and Respiratory Cancer Quantitative and Temporr.1 i

k,'

Ascects, NICSH-NIEES Joint Menograph No. 1, USPHS USDHEW, I

National Iachnical Internation Service, Springfield, VA 22151,1971.

Mi 76 Report of the Royal Ccamission on the Health and Safety of Worxers tu Mines, Ministry of the Attorney General, Province of Cntario, 1976.

Mo 76 Final Repert en Study of the Effects of Building Materials on

• Population Dese Equivalents, 'De' artment at' Environmental p

I Health Sciences, School of Public Health, Harvard University, Cambridge, MA 02115.

Na 72 The Effect on Populations of Excesure to Low Levels of Ioni=1r4 Radiation, Report of the Acvisory Consittee en the i

7 31ological Effects of Ionizing Radiation, Division of Medical Sciences, National Academy of Sciences, PB-239 735/AS, National Technical Informatien Service, Springfield, VA i

i 22151.

t Na 75 National Council on Radiatien Protection and Me:surements f

Natural Backgrcund Radiation in the United States, NCRP Report No. a5, Washington, D.C., November 197=

l Na 76 Health Effects of Alena-Emitting P: rticles in the Reseiratory l

Tract.

Report of the Ad Hcc Ccmm3 : tee on " Hot Particlesa of the Advisory Ccamittee on the 31rlogical Effects of Ionizing Radiation, Division of Medical Sciences, National Academy of Sciences, EPA 520/4-76-013, Nat.ional Technical Information

{

Service, Springfield, VA 22151.

j ca 72 cakley, D.T., Natural Radiation Exposure In Ihe United States, CRP/SD72-1, U.S. Environmental Protection Agency, l

Washingten, D.C., June 1972.

t l

104 l

I

i I

l Pe 70 Peterson, Paul, Letter of R.L. Cleer of the Colorado State Health Department transmitting the Recommendation of Action for Radiation Exposure Levels in Dwem a r Constructed on or with Uranium Mill Tailings, U.S. Public Health Service, i

[

u= P4aEton, D.C., July 1970.

Ra 76 Radford, E.P., Report to the National Institute of t

Occupational Health on the Status of Research on Lung Cancer l

in Underground' Miners in Europe, 1976. Order #96,3825, i

NIOSH, Ci=4aanti, CH.

t Ro 78 Roessler, C.E., Wethington, J.A., and Belch, W.E.

Radioactivity of Lands and Associated Structures, Four:6 l

Semiannual Technical Report, University of Florida, Gainesville, February 1978.

j l

(\\

Se 73 Seve, 7. and Piscek, 7., Lung Cancer Risk in Relation to Long-Term Exposure to R:1 don Daughters in Pmceedings of the Second European Congress of Radiation Protection.

Ed. by E. Bujdeso Akademia Elado', Budapest (1973).

j Se 76

Seve, J., Kunz, E. and Placek, Y., Lung Cancer in Uranium l

Miners and Long-Ters Exposure to Radon Daughter Products.

i Health Physics, E:433, (1976).

l Sn 74. Snihs, J.O., The Approach to Radon Problems in Non-Uranium l

Mines in Sweden, pp. 900-911 in Pro W 4 ara of the Third l

Internati*mi Congress of the International Radiatton i

Proteccton Association.

Edited By W.S.

Snyder. CONF-730907-PI, National Technical Information Service, Springfield, 7A 22151 (1974).

l I

I

')

St 76 Sterling, T.D. and Weinkam, J:H., Smoking Characteristics by Type of Employment.

J. Occup. Med., M:743 (1976).

{

1 St 77 Stewasser, W.F. Phosphate Rock,1975 Mineral Tearbook, sureau of Mines, Department of Interior, 1977.

Tr 75 Tmin, R.E., Letter to Governor Reuben Askew, U.S.

Environmental Protection Agency, Washington, D.C., September l

i 22,1975.

i Un 75 Lifetables, United States, 1969-1971, vol. 1, No. 1, DHEW Publication (HRA) 75-1150, Natianal Center for Health Statistics, DHEW,..May 1975..

Un 76 United States Environmental Protection Agency, EnW_ronmental Radiation Protection Requirements for Normal Cperations of i

Activities in the Uranium Fuel Cycle, Final Inf-.~:nmental i

Statement, Volume 1, EPA 520/4-76-016, Washington, November 1976.

i 105 i

3

~.,

l

~

j Un 77 Sources and Effects of Ionizi:rg Radiation, UNSCEAR 1977.

Wa 74 Wang, E.L. Economic Signifiamsce of the narida Phosphate Industry Internation circular 8653, Bureau of Mines, Department of Interior,1974.

,. s.:....

.. a.,.

Wa 77 Walsh, P.J., Dose to the Trashoobroneht 1 Tree Due to Inhalation of Radon Daughters, pp. 192-203 in Tenth Midyear Topial Symposium of the Health Physics Society.

Rensselaer Polytecanic Institute, Troy, 5.I.12131,1977.

Wi 78 Windham, S.T., Savage, E.D., and Ph"i t ps, C.R., The Effect of Home Ventilation on Indaar Radon and Radon Daugh*ar Levels, EPA 520/5-77-011, U.S. Environmental Protection Agency, Montgomery, AL,1979.

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t POSITION PAPER ON 2ADON IN ST3UCTURIS l

AEGCST 15, 1980 l

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Position Paper on ladon in Structures i

The Task Force reviewed the physical and biological bases for concern i

i about radon exposurse to the general public and azamined the status of l

Federal activities in four areas: epidemiological studies, regulatory

[

t authorities, progrees to measure radon levels in homes, and the I

coordination of Federsi radon research. The Task Force concluded that Council attention to this problem is warranted because of the possible

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prevalence of relatively larg's exposures, a trend toward even higher i

exposures due to improved energy efficiency in inhabited structures, the

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risk from such exposures, and the potential large population at risk.

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The Task Force considered whether enough information is available to j

start a national progran on radon control. It concluded wide ranging programs should not be undertaken until more is known about the prevalence I

l of high exposures and voys of controling them. The thrust should be 4

towards developing an information base that will allow good policy

[

~

7 decisions. The Task Force also concluded that although current Federal l

i j

t authority cannot address some radon exposure situations, it would be l

premature to request additional authority until the technical basis for l

?

decoruining radon levels and reducing them is more fully established.

The Task Force makes five recommendations:

l 1.

The Radiation Policy Council should take responsibility for the i

overall development of Federal research and policy related to the assessment and control of indoor radon exposure.

j l

l

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2.

De Radiation Policy Council should sponsor an expert comunittee i

to evaluate and provide guidance on Federal scientific programs related to radon exposure and control. De committee's basic mission would be to provide the Council with technical evaluations and reconnendations for research.

3.

Me Radiation Policy Council.should encourage the timely j

acquisition and analysis of epidemiological data by Federal agencies.

Moreover, the Council should request Federal agencies to make the data obtained in epidemiological studies of exposed miners and other groups

]

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available to as many analysts as possible.

I 4.

De Radiation Policy Council should defer considering a Federal l

Radiation Protection Guide for indoor radon exposure.

5.

De Council should prepara raccummendations on the appropriate division of responsibilities between the various Federal agencies for radon control. Legislative as well as administrative approaches should be cessidered.

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TABI.E OF CCNTENTS i

Page l

i I.

Introduction l.

Statement of-objective....................................

1 f

2.

Task Forca activities.....................................

1

[

3.

Task Force participants................................... 2 l

i II.

seeksround l

1.

Physical and radiological characteristics of radon........ 3 l

(

2.

Typical exposure si tuations............................... 6 3.

Es timate s of heal th risk due t o rados progeny............ 10 III. Status of Federal Programs i

i 1.

Status of Federal programs to asasure radon in homes....19 l

l

2., current status and needs for coordination of i

i t

Federal research..................................... 23 l

3.

Current status of epidemiological studies................ 27 f

i 4.

Current regulatory authorities........................... 27 IV.

Summary of Issuee............................................ 32

+

7.

Rec ommenda ti ons.............................................. 3 7 F

VI.

Summary of Public Comments................................... 44 References........................................................ 46 Appendix I.

Epidemiological Studies of Persons Exposed to Radon and Radon Progeny....................................... 48 l

Appendix II.

Earthquake Hazards Reduction Act of 1977............ 54 f

i Appendix III. Public Comments.................................... 61 i

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FIGUEZS AND IA3LZS 1

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Page 4

I Figure II-1 Uranium-23 8 Decay Serie s.............................. 4 s.

Figure II-2 Excess Lung Cancer in Miners......................... 12 I

Table II-I U.S. Population Exposures..............................

9

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Table II-2 Eatinated Risk frcus Radon............................ 17 i

Table III-1 Indoor Radon Leve1s.................................. 22 1

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Introduction 1.-

Statement of objective I

The objective of this Task Force effort is to provide a program plan leading to a consistent nacienal policy for the protection of the public from unduly large exposures to radon in inhabited structures.

2.

Task Force activities:

May 20, 1980 - Initial Task Force Meeting May 28, 1980 - Foranlation and approval of draft Work Plan by the m

Task Force.

June 10, 1980 - Work Plan accepted by the RPC Working Group June 27, 1980 - Notice of Inquiry published in the Federal Register sanouncing establishment of the Task Force. The Work Plan was published as part of this notice and the public was invited to comment on issues posed.in the Work Plan or any additional issues relating to radon in inhabited structures.

July 17, 1980 - Task Force review of draft sections of the position paper.

(

'/

August 7,1980 - Task Force discussion of public comments, review, and revision of the draft position paper.

August 12, 1980 - Presentation of the draft position paper to the Working Group of the Radiation Policy Council.

l August 15, 1980 - Submission of position paper to the Radiation Policy Council.

O

i Drafts of the various sections of this position paper were prepared by Task Force sub-groups consisting of Task Force members and Federal resoures persons. All drafts were reviewed and revised by the Task Force as a whole. Public commeants are sumarized in Section 7I of the position I

paper and reproduced in Appendix III.

l 3.

Task Force participants:

i h=hers of the Task Force were William H. Ellett, U.S. Environmental Protection Agency, Chairman.

i f

Edwin B. Shykind, U.S'. Department of Commerce Wayne M. Lowder, U.S. Department of Energy l

David M. Scott, U.S. Department of Health 'and Human Services l

James L. Christopulos, U.S. Department of Housing and Urban t

Developpant i

David N. Zugschwerdt, U.S. Department of Justice l

Ralph M. Wilde, U.S. Nuclear Regulatory Comission I

In addition, the following scientists served as resource persons to I

the Task Force:

Frank E. Lundin, Sureau of Radiological Health, U.S. Department of Health and Human Services Wayne A. Cassact, Center for Radiation Research, National Bureau of l

Standards, U.S. Department of Commerce Howard D. Ross, Office of Conservation & Solar Inergy, Department of

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• Allan C.3. Richardson, Office of Radiation Programs, U.S.

l Environmental Protection Agency l

Ronald C. Bruno, Office of Radiation Programs, U.S. Environmental l

Protection Agency II.

Background

1.

Physical and radiological characteristics of radon l

Much of the radioactivity in the natural environment is due to the decay of the primordial isotopes uranium-238 and thorium-232, which have C._

half lives of well over a billion years. These radionuclides are the generators of what are known as radioactive decay series, i.e., the decay of one radioactive atos gives rise to another radioactive atos, which in turn decays to form a third radioactive atom, etc. The uranium-238 de:ay series is shown in Fig. II-1.

The immediate predecessor of radon-222 is s

radium-226, which has a 1600 year half life. All substances of natural origin contain raditsa to some degree. Ordinary soils and rocks contain about 1 picoeurie (pci) of radium-226 per gram, corrssponding to 2.2 j

disintegrations per minute per gram. This is also the production rate for 1

raden-222 acome. Radium concentrations of a factor of ten larger or smaller than this value are not unusual under natural circustances (UN 77). Some industrial waste sacerials contain concentrations ranging from 10 pci per gram to well over 300 pCi per gram (EP 75, N179).

Radon-222, the immediate decay product of radium-226, is an inert gas having moderata solubility in veter. Radon-222 has a 3.3-day half life, which means that radon can diffuse through dry poreus soils or be 3

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transported in water considerable distances before it decays. Radon-220, i

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another radon isotope formed from raditan-224 in the thorium-232 decay I

chain, has a 55-second half life and therefore is usually a less important f

I source of exposure to the general public than raden-222. The Task Force, therefore, has not considered it in any detail and its properties are not l

t included in this discussi a.

l Raden-222 and two of its iWiate progeny, poloniiss-213 and l

polonium-214, are alpha particle emitters. Unlike x-rays and the electrons they produce as secondary radiation, alpha particles are heavy l

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doubly charged particles which produce a large number of excitations and s

ionizations along a very short path in tissue. For this reason, alpha i

particles are classified as a high LET slinese energy transfer) radiation.

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Because of their dense nattern of ionisation they can cause more radiation f

i damage per unit absorbed dose than x-and gamma radiation, and consequently the tsrnational Council on Radiological Protectice has assigned a quality

[

I factor of 20 to alpha particle doses (I? 77). This means that for equal doses, measured in rads, the dose equivalent, in ress, attributed to alpha s

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perticles is 20 times larger than for x-rays.

i Alpha particle irradiation is demonstrably carcinogenic (3A 76).

Moreover, reducing the does rate appears to have little or no effect on the amount of biological damage per unit dose that they cause (NA 76).

This is enought to be due to lack of effective repair processes for alpha particle damage. At low doses the frequency of cancer from high LZT radiation increases at least proportionally with dose but increases more slowly at high doses because cell killing reduces the population of 5

l the cella, at risk. Moreover, for high LET particles, there is some evidence of greater cancer risk per unit dose for protracted exposures than for high dose rate acute exposures (MA 78, MU 78). De current controversy concerning reduced effects of x-rays at low doses and dose rates does not extend to radiocarcinogenesis due to alpha particles (3C 80).

l A significant increase in lung cancer has been observed at cumulative occupations 1 exposures that are comparable to those which could occur from lifetime exposure to the most highly exposed members of the general public 7

C. )

(EE 79). The possibility of a threshold dose for lung cancer induction following alpha particle irradiation cannoc be positively excluded.

l f

However, we are aware of no radiobiological or epidemiological support for i

I a threshold for lung cancer induction due to radon progeny exposures and

(

l do not believe public policies should be based on an assumed threshold.

t t

2.

Typical exposure situations j

Radon progeny exposures are measured and expressed in a specialized 1

l unit called the working level (WL) which differs from more cannon measures of the concentration of radioactivity in air, such as p01 per liter.

Formally, a working level is any combination of the short half life radon progeny (see 71. II-1) which ultimately emics 1.3 x 105 million I

3 electron volts (Mev) of alpha-ray energy in one liter of air. This is the j

i snount of alpha-ray energy emitted by an equilibrium mixture of 100 pci

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per liter each of polonium-218, lead-214, bismuch-214 and polonium-214 f

I The more general definition applies to any combination of shcre half life l

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1 rados progeny. This is convenient since the relative amount of each can 1

change with time. The working level was originally developed as a measure of exposure to workers in uranium mines and the comumen unit of cumula:ive esposure is the working level month (WLM), i.e., occupational exposure to air containing one working level of radon progeny for 170 hours0.00197 days <br />0.0472 hours <br />2.810847e-4 weeks <br />6.4685e-5 months <br />, a working month. Continuous residential exposure of a member of the general population to one working level in residential air for one year would result in about 20 WM if it is assmed that the breathing rate is less for comen indoor activities than for mining and that 75% of the time is (t-spent indoors (EP 78).,

outside air typically has a rados progeny concentration of about one thousandth of a workinc level. Ambient levels are subject to rather wide variationa that reflect the similar variations in the parent raden-222.

l Soil moisture, standing water and snow cover influence the vertical diff'usion este of radon and thus the effective dilution at ground level.

Rados progeny attached to the atmospheric aerosol can also be washed out of the lower atmosphere by precipitation.

Indoors, the situation is quite different. Because chere is less rapid radon dilution due to the limited exchange race between indoor and outdoor air (typically one air change per hour in present structures),

radon progeny concentrations in buildings are usually much higher than in outside. air. Indoor levels vary considerably throughout the year depending on ventilation races, particulate concentrations and many other fac. ors.

One set of data on the a u.1 average radon progeny levels on the first floors of residential structures in uncoutaminated areas shows a 7

l aman value of 0.004 WL (.08 WLM per year) with some indication that 5I of typica1' residences might have a concentration greater than.01 WL, (.2 WI2f per year) (GI 80). Radon progeny levels also vary with location within the structure. In the study cited above, the average concentration in basements was two times greater than in living areas. High levels of

~

i radon progeny ~are often found where enere are high concentrations of raditas in soil or in building satarials. Several of the identified locations are discussed in Section III below.

l

^

l It is possible that not all pathways for radon entry into structures J

have been properly identified, but current belief is that the most

'significant pathway in most cases is radon migration from soil into basements through cracks and places where piping enters. Ground water may also be a.significant radon source. Many wells have substantial quantities of radon in solution even though their radium content is relatively low.

Water use in the home (showers, washing machines, etc.) results in the release of radon into the home atmosphere (GIS 80). Ihis problem of elevated concentrations of radon in water is being studied extensively but its geographical extent is not well known (HES 79). A third source of indoor atmospheric contamination is the building material, where some of the radon produced by radium decay enters the pore spaces and diffuses into the room air. An occasional source of high radon in buildings is the l

use of reprocessed weste materials to fabricate new building zacerials such as gypsum board and cinder blocks. Because reprocessinF of wastas is not a well-developed industrial practice in the U.S.,

the occurrence of such situations is probably not cousnon. However, it has occurred in several areas (see Section III-1).

8

i i

For purposes of perspective, Table II-1 indicates approximate escinates of U.S. population exposure to various sources of radiation.

i

% e exposures are given in terms of annual effective (whole-body) dose

[

equivalent as defined by the ICIP, a quantity that can be considered as

[

l roughly proportional to overall risk (IP 77). This perspective is i

l Particularly important in the assessment of possible future trends in I

radiation exposure resulting from the introduction of energy conserva-j tion p-setices that reduce air exchange rates and from a more widespread i

ure of radium-rich waste meterials in building construction. In the

( \\

former case, there can be little doubt that a significant reduction in the j

l Table II-1 f

U.S. population exposure due to various source of radiation 1 j

Annual Collective Effective Source Whole 3ody Dese - 106 eerson res/v

?

Cosmic rays 6

Terrestrial Radiation 6

i Internally deposited radionuclides l

.~.

Radon and progeny (0.004 WL)

= 10(2) l I,/

All others 8

I Medical diagnostic x-rays 10 Fallouc t1 Building materials 41 Airline travel

.1 (1) UNSCZAR - 1980 (Draft) (NA 80)

Reduct m of average air exchange rates in houses by (2) d ene-half without additional controls would increase this collective dose to E 20 x 106 person res/y.

1 I

l l

- +- - - -

l average indoor-outdoor air exchange rate in U.S. housing will have a substantial impact on the radiation exposure of the U.S. population in the absence of the introduction of appropriate practical control measures.

However, it appears likely that such measures can be developed as part of an overall research and development program. This perspective highlights the importance and urgency of research into the magnitude and range of

+

present radon exposures, the effect of various environmental parameters on such exposures, noteably air awh= age ratas and heating and sir conditioning practicas, and the efficiency o'f possible radon control 7,

/

methods.

l l

3.. Estimates of health risks due to redon progeny i

l The short half life daughters of raden-222, (polonium-218, lead-214, I

bismuch-214 and polonium-214) each decay in less than 30 minutes-the first daughter, polonium-218, having a half life of just over three minutes. This is long enough for most of the charged polonium atoms to become attached to microscopic dust particles in air. Inhaled aerosols m

are quite small, usually less than a few tenths of a micremeter in diameter. Upon inhalacion, such small particulates have a good chance of being retained on the moist epithelium lining of the bronchial tubes in the lung (I18 66). While most of such inhaled material is eventually cleared f ce the bronchi via mucus, this process is not fast enough to prevent exposure of the bronchial epithelium to alpha particles f ca polonium-218 and polonium-214. The dose delivered by these charged particles which ultimately results in cancer cannot be characterized adequately because the location of the irradiated cells that eventually 10 i

~

~

l give rise to lung cancer is not known with any precision.* Indeed, there is even some lack of agreement as to which cells are involved. Merefore, most estimates of the lung cancer risk due to inhaled raden progeny are in i

terms of a person's potential exposure to rados progeny Jacher than the I

does absorbed in lung tissues.

Dare is a well-documented history of a very high incidence of lung cancer among underground miners esposed to radon progeny. Moreover, the histological type of lung cancer most twely observed is rather i

uncemen in the general popnistion. These miners were exposed to high

(

levels of radon progeny ecepared to those normally occurring in the general environment. Although health studies of underground miners i

i provide a basis for estimating riska due to radon exposures in f

non-occupational situations, such estimates are not hard predictions. The l

l I

doses the miners received are not accurately known and'the number of

~

ezeess cases at a given dose level has considerable statistical j

uncertainty, as is shown in Figure II-2 reproduced from Archer's reporr l

i AR 79. There are also,Sucertainties in extending these results to members t,,.,/

of the general population because of significant physical, environmental, j

and demographic differences between the miners and the general public.

3 These include possible contributions to lung cancer promotion by i

unidentified occupational factors and the fact that the miners were all adult males, many of whom were frequent cigarette smokers.

• A commonly used conversion factor for the " average" dose to bronch! # rem a uniform deposition of radon progeny in uranium miners is 0.5 rad (10 res) per WLM. However, the actual pattern of deposition is believed to be highly non-uniform.

I 11

e O

80 i

70 E

AG ua R,

o

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,.0 o

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xJ y

o 2

o j 501 c

2 3a ua g 40 3

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=

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~~

O CZECH. UR ANIUM Q SWEDEN LEAO, ZlNC (A).1RON lR.J) 20

"" A UNITED STATES UR ANIUM

~

$ CANADA URANIUM 4

I 95% CONFIDENCE LIMITS a

l 10

~~

~

RC l

0

.. g s 4

I l

I I

f 1

I O

100 200 200 400 500 600 700 CUMULATIVE WORKING LEVEL MONTHS Figure II-2 Excess lung cancer in various miner groups as a function of their cumulative exposure. Note the degree of stattstical uncertainty in the number of lung cancer attributacle to radon daughters. (See AR 79 for full discussion).

12

i

~

A number of published estimates of the lung cancer risk from inhaling radon progeny were reviewed by the Task Force. All of these estimates are based on the epidemiological data from various stadies of uranium and other underground miners. In addition each estimate depends on how these l

occupational data are applied 1.o the general population. Dese risk l

estimates and the assumptions on which they are based are discussed

~

~

briefly below.

Neeriesi estimates of the frequency of lung cancer due to radon t

progeny depend on several assumptions. These include: the shape of the f

(

L dose response curve, the duration of exposure, the length of the latent

{

period before radiogenic cancers are manifest, and the length of time i

following the latent period over which the cancer risk is expressed. The occupational data base for lung cancer risk includes few persons under 20 and few of the workers have been followed for their entire lifetimes.

f l

Therefore, the miner results have to be projected forward in time to

(

estimate the effects of lifetime exposure on risk. The various projection models used to apply the occupational data to the general population j

~.

'_.)

differ considerably. Moreover, the selection of risk coefficients differ o

i depending on which sets of miner data are considered, Fig. II-2.

The net result is a considerable range in the americal risk estimates prepared by l

various investigators.

i The United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCZAR) carefully reviewed the risk experienced by underground miners in their 1977 report (UN 77). They did not develop a model to proj.ect the results of their analysis ont.o a general population having

-lifetime exposures but rather assumed a 40-year expressien period for lung 13 e..

J 1

cancer regardless of age at exposure. D e UNSCEAR risk estimate is 200-450 fatal lung cancers for 106 person WD(,

i.e., one million persons 4

exposed to 1 WLM at sometime in their adult life. na 40-year expression period used by UNSCEAR may not be appropriate for a general population t

which includes persons exposed at all ages nor does it take account of the i

l increase in the risk of radiogenic lung cancer with advancing age, factors i

i which are considered to varying degrees in some of the other risk i

3 estimates. Although the UNSCEAR risk estimate has the virtue of m

simplici'ty, it may not be too applicable to non-occupational exposure regimes.

4 Most of the other estimates of radon risk are based on lifetime exposure at a given ambient concentration of radon progeny (WL). We have expressed these other risk estimates in the units used by UNSCZAR hy asstaning an average lifetime exposure of 70.7 years.

De NRC published an estimate of lung cancer risk due to radon progeny in their Ceneric Invironmental Impact Statement on Uranium Mining, (NR 79). mis estimate was made by averaging the results of risk estimates for radiogenic lung cancer using the four models given in the 1972 BEIR Report and assuming a 1 W1M exposure is equal to 5 rem. De average risk for the four models was 360 per 106 person WLM.

EPA has published two estimates of radon risk (IP 78). One is an absolute risk estimate based on a risk coefficient developed by an Ad Hoc National Academy of Sciences Comenittee on the health effects of alpha emitting particles in the respiratory tract (NA 76). IPA applies this risk coefficient to a model population having the competing, age specific risks of death'due to all causes experienced by the U.S. population in 14

[

i r

i a...

1970, i.e., a competing risk cohort analysis (3U 78). This absolute risk model yields an estimated 350 fatal lung cancers per 106 person WI2f.

The other EPA estimate is based on a relative risk model, i.e., the percentage increase observed in exposed miners (3% per WI2f) is projected i

across the population at. risk (EP 78). Again a competing risk cohort l

analysis was utilized, but unlike the absolute risk model, the analysis based on relative risk takes account of how lung cancer frequency changes with age in the 1970 U.S. population. The relative risk nodel yields an estimated 860 lung cancer cases per 106 person WI2f.

( i The National Academy of Sciences published in August 1980 the 3EIR III Import which analyses the miner data in a more detailed fashion than in previous studies (NA 80). The BEIR III model uses age dependent

~

absolute risks. This analysis takes account of the fact that the observed lung cancer incidence in exposed miners increases with age, but only after age 35. When the new 3EIR risk coefficients are applied to lifetime exposure, a competing risk cohort model yields an estimated 850 lung cancer cases per 106 gI2g, I j In response to the Radiation Policy Council's request for comuments on this Task Force's work plan, the National Council on Radiation Protection and Measurements proposed a risk estimate based on a "to be published paper" by N. H. Harley and 3. S. Pasternack, see AppenM t III. These risk estimates are based on the risk coefficient suggested by NAS in 1976, and used by EPA in their " absolute ris,k" estimate, but includes two additional censiderations: no cancers are expressed before atre 40 and radiation de. mage from alpha particles is assumed to be repaired at 3.5 percent a year so that exposure; occurring early in life have little effect. For 15.

.a a

li h

r.

4 li

{'

lifetime exposure, this model yields 130 lung cancer deaths per 106

).

person WU(, substantially less than other recent estimates.

l In 1979 Victor Archer, who has been principal NIOSE investigator in s)-

the U.S. epidemiology studies of uranitsa minars, published a review paper 4

of the results of mine studies in both U.S. and other countries (A1 79).

i j

From this review he concluded char the risk per WLM increases as the 1

l cumulative exposure decreases so that for environmental levels of exposure the risk coefficient is 30 cases per WLM per 106 person years at risk.

i l

Using this risk coefficient, an EPA competing risk analysis yields 1050 l

.V fatal lung cancers per 106 person WLM. This is the highese risk estimate found in this review.

i l

It should be noted that in all of these risk estimates it is assumed i

that children are no more harmed by radiation than adults. There is no l

evidesce either way on this for lung cancer, a disease of old age.

I j

However, for many other cancers that normally occur earlier, the Japanese survivor data indicates children irradiated under ten years of age have a such greater relative risk than similarly exposed adults (3E 78). An IPA 3

Y analysis indicates that if exposures occurring during childhood are three times more dangerous than for adults, the estimated relative risk from lifetime exposure is 50% greater than if children are no more sensitive i

i than adults (ZP 78).

i l

Table II-2 summarizes the estimated risks frem occupational radon

)

progeny exposures outlined above. *The range of these estimates is a factor of eight, which is some indication of how uncertain they are at i

this time. Much of this uncertainty is because the miners have not been followed for a life time and different projection models are used to predict their future mortality.

16

Table II-2 Estimated Life Time Risks of Fatal Lung Cancer Frea Radon Progeny 1

cases per 106 Estimator Person WIM i

UNSCIAR 200-450 50-year esposure

~

to adults NRC 360 all ages, 1967 j

U.S. population l

t (L

EPA - absolute risk 350 cohort (stationary i

populatica) l EPA - relative risk 860 i

BEIR III 850 Victor Archer

[

absolute risk 1050 NCIP-absolute risk 130 all ages, 1975 U.S. population f

J l

i I

I l

l f

l 17 E

r

.._ _ __1 u__'

I t

' Because smoking is a very important esuse of lung cancer and because many of the U.S. miners studied were also frequent cigarette smokers, i

there is censiderable interest in how sucking affect.s the risk due to radon progeny exposures. Early studies indicated that almost all of the excess cancers observed in U.S. uranium miners were among smokers and that the cancer causing agents had'a strong synergistic (multiplicative) effect. More recent studies indicate that lung cancers took a longer time l

to develop in the non-smokers and that while smoking does increase risks due to radca, the difference between smokers and non-smokers is not as

.m large as previously thought (LU 79).

A recent report by Radford and Renard (presented at the 1980 Radiation Research Society Meeting) on 1276 Swedish iron miners born between 1880 and 1919 and followed for most of their lifetime, also indicates more risks to non-smokers than previcualy thought. The mean cumulative lifetime exposure to these iren miners is. relatively low, 85 WLM. Fcr s'tokers, the observed lung ca'icer deaths were 2.6 times scre o

4 frequent than expected for sackers in Sweden. For non-sacking siners lung 7

cancer deaths were 8.4 times more frequent than expected for non-smokers d

in Sweden. Swedish smokers (who smoke less than U.S. smokers) normally have about seven times higher mortality due to lung cancer than Swedish non-smokers. So even thoutfh the non-smokers had a greater relative risk, overall they experienced a icwer risk of lung cancer death. Ecwever the difference between the two groups was =uch smaller than has been observed in follow-up studies of younger populations.

Federal Radiation Protection Guides fer the general population limit whole body doses to 500 seem for identifiable individuals and 170 nrem 18

l b

t per year to exposed groups where only the average dose is known. Although thesa guides do not apply to naturally-occurring radioactivity, they do l

provide some perspective on the relative risk from large radou exposures. The j

lifetime risk of fatal cancer associated with 170 arem per year (whole body-lifetime exposure) are estimated as 1.2 I 10-3 to 8 x 10-3, using

[

1972 BEIR Emport risk coefficients and absolute and relative risk models, i

respectively (:!A 72, EP 78). For comparison a lifetime exposure to 0.02 WL l

yields, using the range of estimates in Table II-2, a lifetime risk of f

4 I 10-3 to 3 I 10-2 An exposure level of 0.02 WL is five times what is

/4 E

thought to be the average annual value in U.S. homes; a quantity admittedly not well known. From Table III-1, described in Section III below, it appears that in at least some localities, an appreciable fraction of the population is exposed to esdon progeny levels that exceed 0.02 WL.

l l

III. Status of Federal Programs 1.

Status of Federal programs to measure radon in homes In recent years, a number of Government agencies h.tve conducted field j

l) measurements of indoor radon. Most of these have been conducted in areas i

where radium concsmination problems were believed to exist. Interest in indoor radon was first aroused more than 10 years ago when the use of uranium mill tailings in structures in Grand Junction, Colorado, came to national attention. More recently, EPA has studied indoor radon on phosphate lands having elevated radium concentrations. In the past few years, with an emphasis on energy conservation and " tight" building envelopes, indoor rados i

1 19

1 1

ha's become a subject of scrutiny for structures even where the only sources i

are common soils and building materials. Below is a sumusery of the major activities:

Grand Junction, Colorado: Since 1970, under a Federally-sponsored program, the Colorado Department of Health has measured indoor radon decay product levels in many hundreds of hesses containing uranium mill callings. As part of an effort to determine background levels, a number of homes in the Grand j

Junction area (which did not contain mill tailings). were also selected and measured for indoor radon decay products.

Florida: In 1975, the U.S. IPA began a study to assess the

^

radiation impact on people living in structures built on j

phosphate land. This study ves carried out in conjunction with The Florida Department of Health and Rehabilitative Services (DERS) and the Polk County Health Department. EPA

~

sessured the indoor rados decay product levels in homes built on reclaimed phosphate land and in background homes built on unmineralized soils. Florida's DERS and the University of Florida have conducted independent work of a similar nature.

New York City region: In 1978 the Environmental Measurements Laboratory of DOE, in an effort to determine normal environ-mental levels of indoor raden, conducted a program to measure indoor radon levels in a number of homes in the N.T.C. area.

l Simultaneous measurements of radon decay product levels were also made. Measurements were taken in the basement and on the main floor.

3 l

Alabana: In 1978, under the guidance of State Health Departments and the U.S. EPA, the Tennessee Valley Authority measured raden decay product levels in a number of homes in Northern Alabama and neighboring states where phosphate slag was used in the house construction. A control group of houses was also measured.

San Francisco region: Racently, the Lawrence 3erkeley Laboratory (L3L) began simultaneously measuring indoor radon levels and the infiltration rates of houses. The work has been done in support of DOE's house weatherization programs and energy performance standards for new buildings. In addition to houses in the San Francisco region, L3L has done similar measursments in a number of energy efficient homes throughout the country.

10

l 1,..

Montana: Two years ago, IPA and the Montana Department of Health and Environmental Sciences (MDEES) began taking indoor radiation measurements in the Butta and Anaconda areas because of the intensive local use of phosphate slag aggregate in con-crate block. Very high levels of indoor radon decay levsis j

were detected in homes with and without phosphate block. The area is highly mineralized and sits above thousands of -iles of underground mine shaft. One or both of these latter factors J

is probably chiefly responsible for the generally elevated i

radon levels in this regson.

i Other Studies: On an ad hoc basis, numerous measurements of indoor radca levels have been performed by researchers in national laboratories and universities and by personnel.in l

State health o,apartmaats. Results of a few of these ara l

summerised in Table III-1.

I 1 Ongoing Work: IPA has begun a study to monitor the radon f

levels of 1000 homes in Butte, Montana. A major goal of the l

study is to field validate track-etch monitors as a radon j

measuring device. Truk-etch devices give time averaged I

reading of radon exposure, are inexpensive, and completely l

passive. If the validation of track-etch for field use is accomplished, large scale house surveys will be made possible.

l In another area, as part of an ongoing analysis to study the radiation impact of the phosphate slag in houses, T7A is l

completing the final design of a study which will measure i

radon decay products in 100 slag houses and 100 control houses.

l Data available from these and other studies are given in Table III-1.

It is important to bear in mind that a variety of measurement protocols

'../

and techniques were used in these studies so that direct comparisons are i

not necessarily valid. Some protocols attempt to measure the yearly l

average radon levels under typical living conditions, others involve j

single or multiple measurements over only a short period of time f

(generally less than a day), usually after the windows and doors have been f

closed for a time. The yearly average measurement is normally simulated l

g by four or more integrated measurements over approxi:nately one week in i

i each of the four seasons. Even within these two categories of Il

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i measurement protocols, there are important differences in the measurement I

l

~

process. In short, there is a great need to standardize measurement protocols and techniques to facilitate comparison of the results of future field studies. In developing these protocols and techniques, it will be l

important to evaluate the performance of existing measurement devices and l

to develop new cues where required (see following section).

1 2.

Current status and needs for coordination of Federal research Messarement progress, insertament development, and the development of control technology and its application are the main components of a l'

comprehensive research program on indoor pollutants in general, and radon

\\

in particular. Although there is much work with respect to radon now 1

underway in each of these categories, there has been a fragmentation of l

effort among the various agencies with somewhat differing (and sometimes unclesr) responsibilities. This has been the understandable result of the fact that each agency has responded independently to problems related to its mission as they have arisen. This situation clearly points to the j

l s

(

need for, among other things, a comprehensive interagency research program j

whose scale and organization are consistent with the magnitude and l

l complexity of the potential problems and whose components are responsive j

to the various agency requirements. The information dereloped as a consequence of such a progran will be an essential ingredient to basic Federal policy decisions concerning indoor rados problems.

The data that have been obtained in recent years on radon and radon progeny levels in inhabited structures are sufficiently extensive to permit a gross assessment of the possible health riska associated with l

i l

{

I' current and possible future population exposures. However, as indicated in the previous section, most of this information has beea developed in response to unusual exposure situations; for azample, contaminated indus -

trial sites, the r W istribution of uranium mill tailings, and construction on reclaimed phosphate land. Very little is known about the frequency I

distribution of individual exposures in " normal" settings and there is l

little quanticative understanding of how the various types of radon i

sources, radon transport properties, censtruction practices, building heating and ventilation methods, environmental parameters, and human m

/ !

{

activities affect the magnitude of the long-term exposure to radon and its decay products. A much more extensive information base needs to be

[

l developed before optimal control and regulatory strategies can be realized.

[

This is a fundamental problem that say seriously impede policy development.

f l

This problem should be urgently addressed through the following types of j

[

(

research programs.

I A measurement progran designed to characterise the indoor radon f

exposure of a large population necessarily involves both large-scale 3

1I

) [-

j, surveys and detailed investigations of individual structures. The latter t

studies provide basic information on the various factors that influenca j

r radon exposure; information that is essential to the interpretation of the less detailed data obtained in the surveys.

It will also allow forecasting j

l of national radon exposure levels as trends towards reduced ventilation continue. The survey results define the range of normal indoor radon l

exposures and provide a screening mechanism for arens and/or structures f

t deserving of further study.

i 5

24 m

'E.

• ~ " " " " " '

'~

._,,_,_,_m,__m_, _ _,, _ _, _ _ _ _ _

j' 4

Those two types of measurement programs require different types of

~

instrumentation. For surveys, it is desirable to have a large number of low cost and simply operated detectors that can both be handled and deployed by relatively inexperienced personnel and yield reliable data on long-term radon or raden progeny exposure. yor detailed studies, an array l

of more sophisticated instruments is needed to accurately determine the l

key parameters, which sight include not only radionuclide concentrations but also particle size distribution, condensation nuclei concentration, unattached fractions, air exchange rate, radon exhalation rate, f

tamperature, pressure, humidity, etc.

It appears that various techniques q.

now in use or being developed may be at least minimally adequate for these programs, but there is need for further evaluations and improved '

methods. There is also a need for formal mechanisms of quality control in the measurement programs conducted by the various laboratories through the conduct of intercomparisons and intercalibrations as well as the development of ccameon measurement protocols.

In addition to the field studies described in the previous section, a

/

number of radon and decay product control methods have been studied.

j Where uranium mill tailings have been used, the primary control method is j

i removel. Ecuever, in less estraordinary situations, sealants, ventilation j

l and indoor particulate removal systems have been implemented with varying degrees of success. A new approach is the use of air-to-air heat exchangers on mechanical ventilation systems. This may result in improved energy conservation without the necessity for substantial reductions in air exchange races. All of these methods are presently being investigated.

Increased research en such control techniques vill play an important role 25

i)[,

in'the identification of appropriate (cost-effective) remedial actions that may have to be integrated into the application of energy conservation measures in inhabited structures on a large scale.

An important first step in the development of a coordinated national i

'research plan on radon and other indoor pollutants has been taken by an ad hoc interagency task force sponsored by the Environmental Protection Agency i

and the Department of Energy. Bis group's preliminary draft report I

addresses the overall indoor pollution problem and the many relevant issues in sufficient detail to provide a useful starting point for the 7-s i

i sore formal efforts recommended here. It also emphasizes the need for a coherent national plan for the investigation of all pollutants of potential public heelch significance. De rados problem should not be l

considered in isolation, particularly considering the difficulties associated with carrying out large-scale field studies and the opportunities presented by such studies for uniti-pollutant asasurements.

B is developing plan is likely to include elements of direct interest to l

the Council including the collection of information on existing and anticipated Federal programs and the collection and assessment of available data on pollution exposure.

Another aspect of research coordination is the interaction of Federal agencias and laboratories with the State and local agencies that say be I

closely involved in the extensive field studies. An important potential avenue for such interaction is the Conference of Radiation control Program Directors, which has already taken an interest in technologically enhanced natural radiation exposure. Ois avenue should be explored further.

26 l

l

5 1

3.

Current status of epidemiological studies At first sight, the stanber of investigations of the health status of underground miners and others exposed to radon progeny is impressive.

Appendix I lists 7 U.S. studies and 10 in Canada and Europe. However, I

while data collection has been extensive for most of the reported studies, i

i only rather preliminary results are available and for some none at alle

?

In view of the long latent period before lung cancer appears, particularly l

l for the case.of non-smokers, long-term follow-up is essential.

i The Japanese A-bomb survivor data indicate that for those exposed at

(%

age 50 or more, the increase in lung cancer fatalities due to radiation is q

not only much higher than those not exposed but also shows the same rapid l

l increase with aging. If this same pattern holds for those exposed when they were young adults, the cancer mortality in exposed uranium miners i

vill be much greater than has been observed to date. Therefore, lifetime i

follow-up of miner populations is essential. A sustained effort by the U.S. and other governments is needed to insure that all possible informa-tion is obtained from exposed groups, including those not occupationaly I

exposed. As yet very little effort has been directed at the latter.

t 4

Current tegulatory authorities There is currently no Federal legislation which might be invoked as j

I the statutory basis for a generalized program of regulation with respect i

1 l

to radon exposure levels in inhabited structures.

Initially, we reviewed l

Section 112 of the Clean Air Act, 42 U.S.C. Sec. 7412, in view of the J

recent EPA action in listing radionuclides as hazardous air pollutants 27

- - - - - - - ~ - - -

i I i !i i

I 2

i pu'suant to 42 U.S.C. Sec. 7412(b). See, IPA Federal Register Notice at r

44 F.R. 76,730, et see. (December 27, 1979). However, the thrust of Clean i

Air Act regulation is toward prevention of atmospheric pollution and the l

i maintenance of sabient d r quality. Neither of these terms has been treated as providing coverage of emissions into the internal air of buildings. On the contrary, the regulations implementing the Clean Air l.

Act specifica11y define the term "sabient air" as "... that portion of the I !

l atmosphere, external to buildings, to which the general public has access." 40 C.F.1. Sec. 50.1(e), (Emphasis supplied).

.m

}

There does exist a basis for the regulation of indoor radon exposurs levels in certain limited circumstances under current Federal logislation. Specifically, certain vaste materials, known to be radon l

sources, are subject to regulation under the Atomic Energy Act (uranium mill tailings) and the Resource Conservation and Recovery Act (e.g.,

vastes from uranitsa or phosphate mining). Typically, the use of such vastes as fill material, or the use of sites containing deposits of such vastes as building sites in the absence of appropriate disposal /

_T racismation techniques, will result in elevated radon levels within the d

structures involved.

l In the case of uranitse mill tailings, regulation by the Nuclear Regr.latory Commission is now specifically mandated, pursuant to an amendment to the definition of the term " byproduct material" (42 U.S.C.

Sec. 2014(e)) in the Atomic Energy Act accomplished by the Uranium Mill Tailings Radiation Control Act of 1978. Based on this explicit smandment the NRC is authorized, by virtue of the licensing powers granted pursuant to 42 U.S.C. Sec. 2111, to regulate the distribution or transfer of 28 l

S e

uranium mill tailings and to establish safety standards for the protection of health. The regulatory authority thus granted is all-inclusive since the possession of any "by;toduct sacerial" (defined to explicitly include uranium mill tailings) is forbidden except to the excent authorized by l

license.

Similarly, radon-emitting wastes from uranium or phosphate mining activity are subject to regulation as hasardous wastes pursuant to the Resource Conservation and Recovery Act of 1976 (RCRA), 42 U.S.C. Sec. 6921, et seq., pursuant to the authority to list such waste and to regulate its

((

storage and disposition so as to protect human health and the environment.

As of this writing, however, EPA has deferred listing radioactive wastes under 42 U.S.C. Sec. 6921 in light of the pendency befare Congrssa of an amendment to RCRA to temporarily suspend EPA authority to regulate radio-active was'tes except as necessary to avoid unreasonable risks to human health, and the limitation of the health hazard posed by such vastes to the half dozen States in which they are generated.

See, generally, Sup-pienentary Information, Part III.A.3., IPA Notice of final Rule, Interim f

j Final Rule and Request for Comments Re Hazardous Weste Management System:

Identification and Listing of Hazardous Weste, 45 F.R. 33,086-33,087 (May 19, 1980).

Regulation of radon in inhabited structures under either the Atomic Energy Act or the Resource Conservation and Recovery Act is limited to situations involving the utilization of asterial which emics radon, and otherwise meets the respective statutery definitions of " byproduct sacerial" or " hazardous waste".

A slightly more generalized regulatory 29

l c t, a a j

/

t ba' sis may be found under the Toxic Substances control Act of 1976 (TSCA),

15 U.S.C. Sec. 2601 - Sec. 2629. As is the case with the other statutory I

authorities referred to, however, regulation of raden under this statura i

[

would result from the regulation of chemical substances or mixtures which l'

are rados emitters, e.g., raditan. Moreover, it is clear the principal thrust of the TSCA regulatory scheme is aimed at chemical substances or mixtures subsequent to manufacturing or processing activity, an emphasis i

which limits its utility in regulating naturally-occurring radon. In addition, TSCA authorizes regulation to prevent an "...unreasonst". risk

.s l

of injury to health....",15 U.S.C. Sec. 2605(a). This standmed "::

triggering statutory coverage is arguably more stringent than that involved in the case of the other statutes discussed above, 'and may well require more vigorous evidence of adverse health effects than is currently possible. & Industrial Union Dent. v. American Petroleum Institute, (S. Ct. Docket No.78-911, decided July 2,1980).

Under the Safe Drinking Water Act (42 U.S.C. Sec. 300f through Sec.

300j-10), IPA has authority to establish Faw&num Contaminant I,avel (MCL)

,w for radioactive pollutants in the finished drinking water furnished by community water systems to their customers. Private wells are unregulated (EP 76). No MCL for radon has been promulgated, although the Agency is actively considering the problem. The Agency believes that, under the authority cited above, an MCL for drinking water could be based on the rados concentration in water or the consequent indoor air concentration due to radon entrained in drinking water.

In addition to the so-called " environmental" statutes discussed above, the Depart:nent of Housing and Urban Development has authority to issue 30 nwmmem wwwor

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._ regulations to implessnt the national housing policy goal of, inter alia,,

"...a decent home and suitable living environment for every American family...." 42 U.S.C. Sec. 1441. The Department takes the view that, under this authority, it could promulgate regulations which, on a prospective basis (e.g., applicable to mortgages refinanced or entered 1

after the effective date of suda regulations), could establish radon exposure limits with respect to public housing and private housing financed in whole or in part with Federal financial assistance. With respect to farm housing, the Secretary of Agriculture is statutorily (q

suthorized to approve all building plans and specifications for new buildings and repairs for which financial assistance is authorized under 42 U.S.C. Sec. 1471, ej g. See 42 U.S.C. Sec. 1476. Despite the more specific statutory authority available to the Secretary of Agriculture, however, it is fairly certain that the regulation of radon exposure levels

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pursuant to 42 U.S.C. Sec. 1476 would be possible only on a prospective basis. Accordingly, while there is apparent authority, pursuant to existing legislation administered by the Secretaries of Agriculture and

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)

Housing and Urban Development, for the development of regulations concerning radon exposure levels in inhabited structures, no regulatory scheme is presently in place. Moreover, the direct impact of such regulations would be limited to Federally financed or assisted housing, a limitation which, together with prospective applicatien, would ensure that such regulations would reach only a relatively small percentage or residential housing units and few, if any, comunarcial and industrial structures.

31

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In summary, and based on the above survey, no current legislation j-provides any particularly useful guidance with respect to a workable 1

j approach to new legislation concerning the regulation of raden in 1

)

inhabited structures. Moreover, existing limits on scientific knowledge and measurement technology may well preclude a definitive legislative l

l resolution at this time. If this is the situation, any legislation il recommended should only attempt to focus attention on the problem and seek I

to ensure a structured application of resources looking to future

^

development of more definitive solutions. An example of such " bridge"

. )

l 1egislation may be found in the Earthquake Hazards Reduction Act of 1977, codified as Chapter 86, Title 42, United States Code, 42 U.S.C. Sec. 7701-Sec. 7706, reproduced in Appendix II and discussed further in Section 7.

IV.

$nnume y of Issues The Task Force identified four major questions in its consideration of an appropriate policy for radon control:

1.

Is there adequate information to justify Council consideration of the problems arising from radon in inhabited structures?

2.

Is there adequate information for starting a national program leading to the control of radon in inhabited structures?

3.

Is there regulatery authority at local, State, and Federal levels to control radon exposures if necessary?

4.

Is there adequata coordination of State and Federal investigations of radon exposure pathways and exposure levels?

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4 Issue 1

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Heretofore, consideration of the problem of radon in structures has been on an ad hoc basis arising from specific situations where high radon j

levels were identified more or less by chance. To the best of the Task Force's knowledge, it is the first governmental group to appraise the i

national indoor radon problem as a whole. Although this appraisal is

~

t necessarilypreliminary,webeidevethenumberofsituationsthathave been identified are indicative of a larger national problem. " Unduly large exposures to radon in inhabited structures" are not only associated

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with contaminating events or other sources under man's control, but also j

i found with considerable frequency in natural surroundings. A national survey in Canada has indicated that about 10% of their housing units may have raden progeny levels exceeding 0.02 WI..

Limited studies in the U.S.

suggest similar exposure patterns may exist in portions of the United Srrtes, Table III-1. Moreover, by most reckonings, the health risk due to high indoor radon levels (>0.02 WI.) is considerably larger than that due to naturally-occurring gsumes radiation or medical x-rays.

It may also i

I exceed the risk associated with the 170 mren/y Federal Radiation Protection Guide for groups exposed *o man-made radiation sources (See Section II-3).

Because of the possible prevalence of relatively large eroosures, the likelihood of a trend toward higher exsosures due to improved enerry efficionev in inhabited structures, the risk free such ernosures, and the poteacial total pooulation at risk. which may be very large, ths *ask Force believes Council attention to this problem should not be defer ed.

33

_ _ ~ _ _ _ _

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There is a need for a delineation of overall Federal and individual agency responsibilities in the development and conduct of a national action program on a continuing basis.

I Issue 2 The second issue, whether or not current information is adequate for

{

a national program, is less easily addressed. Federal control actions are being taken now on an ad hoc basis and the number of these programs is

'm likely to increase. However, none of these actions have a potential for j

addressing adequately the nationwide problem. The Task Force believes that a generic study of the frequency distribution of radon eznoeure in structures should be made a necessary first step before Federal control actions on more than a local, problem-oriented level are contemolated.

i The Radiation Policy Council should provide leadership for such a State and Federal program (see Section 7, below).

Even though it is clear that indoor radon exposure is likely to be a T

national problem, we do not believe there is sufficient information on the f

V number and location of structures having extraordinary radon progeny l

1evels and en the causes of such levels to==W regulatory decisions. The limited sampling of structures fee radon levels to date does not allow definitive generalizations concerning radon exposure. Moreover, the dynamics of radon levels in structures must be understood since it is likely that a long term trend towards higher radon levels may be in l

l progress due to energy conser ration practices. The Task Force agrees that it is likely that further investigations will show that only a sustained series of Federal and local actions can address the problem in a way that 1

34 i

i k

i

..voe, - ww==w.

. + * - - - -

will lead to the appropriate suolioration of high rados exposure in inhabited structures. Developing a national program for regulatory control without more appreciation of its eventual scope :ould delay effective resolution. Such control is likely to havs significant socie-economic implications that must be carefully considered pr,ior to any action. Moreover, our present knowledge of indoor radon levels is based mainly,' but not exclusively, en a biased selection of those structures most likely to be contaminated. It is possible that further study will 1

l 1ead to a conclusion that only a limited progra of radon control is warranted. Finally, any national program involving government-sandated control of indoor raden will set a precedent for the treatment of all indoor pollutants to which the general popolation is exposed.

Issee 3 dhile the Task Force recognizes that only a nortion of high raden etuosure could be addressed by current regulations. it is not convinced that enforceable Federal or local standards for indoor air cualiev are desirable at this time. The Task Force's review of the current regulater-r I

framework indicates that seversi avenues af regulation are onen to oublic officials. Current Federal authorities relate mostly to contaminating events due to industrial prograns. Containation due to natural geological occurrences undoubtedly occur also, and in some cases, indirt.ct control such as through HUD housing policies, see Section L.I-4, ray be l

indicated. Moreover, Federal energy conservation progens and other public and private actions to save energy are likely to increase the current trend towards reduced indoor ventilation.

"'ha potential 35

g a

d i

consequences of such programs cannot be ignored if their ultimate effect is'to unduly increase radon exposures. However, the Task Force believes additional Federal regulatory authority should not be requested until the technical basis for determining radon levels and reducing them when necessary has been more firmly established.

Furthermore, any large scale regulator-program would require the

}

full support of State end local officials. A long-term program, with local participation, will be needed to educate these officials and their commanities on the nature of the rados problem and how it can be n

}

controlled. Again the current information base is not adequate to more than begin such an educational effort.

Issue 4

]

The final major issue considered by the Task Force is whether there has or has not been sufficient coordination of Federal programs concerning radon exposures. The-Task Force agrees that, as good as coordination is now, it is mainly bilateral, between a single agency and a State or between two federal agencies. As more Federal asencies and States become involved, a more formal system of coordination will have to be developed.

The main deficiency in coordinating current programs is due to their ad hoc nature. They are for the most part tied into studies of specific localities. Although local and State officials usually have a role in a particular investigation, there is no national program for helping all the States share information and solutions. Moreover, at the Federal level, incaragency cooperation has been developed nostly at the field laboratory level and less in national planning and budgetary actions that take place 36

i in Washington. We do not believe all the Federal agencies a'e sure of r

what their role is or should be in defining the extent of, and partici-pation in, a national program. While we believe regulatory legislation is not appropriate at present at either a State or Federal level, it is possible that non-regulatory legislation that establishes the role of lead l

agencies wonid be helpful. The Radiation Policy Council is well placed to coordinate a Federsi progr a and to consider the desirability of legislative approaches. In Section 7, specific recommendations and options for IPC consideration are indicated.

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7.

Rec h ation No. 1: The Radiation Policy Council should take responsibility for the overall develocuent of Federal research and pollev related to the assessment and control of indoor radon exoosure.

The Task Force agrees that a mechanism must be developed that will

~

allow better budgetary and policy coordination of all Federal actions that touch on the indoor radon problem, and that the RPC is ideally constituted to carry out this function. It could be performed on a day-to-day basis by t

l

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)

members of the working group representing agencies having a substantive J

interest in radon control. Alternately there could be a public and govern-mental rados policy panel composed of persons having substantial experience on radiation control philosophy who conid serve on a long-term basis.

Reports and rec - ndations would be made to the Council on a periodic basis.

37

f i

1 There are a number of policy questions concerning radon control that are beyond the scope of decision making by scientists. For example:

h e is the appropriate balance in Federal spending for radon o

control compared to other public health measures?

he is the proper balance between energy conservation and public o

besich considerations?

4 l

o How esa Federal budgeting for rados be coordinated so that large 1

information gaps do not occur due to funding prioritizations based ou each agency's inmediate needs?

o How should information on radon levels in particular residential structures, on the associated risk, and on possible remedial actions be distributed to local officials, residents and the media?

The Task Force does not believe that it is an adeqtate source of advice on how such questions should be handled. It is of the opinion that the Council will have a continuing need for information and advice, and it believes the Working Group should make recomunendations to the Council on T

the best sechanism.

Recomumendation Nn. 2: The Radiation Poliev Council should sponsor an expert coenittee to evaluate and provide ruidance on Federal scientific programs related to radon exposure and control. The expert scientific committee should consist of Federal, State, academic and industrial scientists, to be appointed by the Council, having established reputations 1

in raden research. This ecummittee should have the time and scientific resources veli beyond those available to the Task Force to be able to 38

. a-address effectively the following tasks:

1.

the collection and critical evaluation of existing data on indoor i

radon exposures; i

2.

the identification of relevant ongoing and anticipated research and development programs; 3.

the assessment of the present state-of-the-art in measurement methodologies 4.

the assessment of the present status of control technology f

development;

[

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l s.

5.

the development of an interagency research plan (and/or the evaluation of existing plans), based on the results of tasks 1-4, that includes specific recommendations on needed research in the conceze of clearly-defined goals, and defines opportunities and possible mechanisms for coordination among the various agencies.

The Coenittee's basic mission would be to orovide the Council with authoritative technical evaluations and reecessendations fer research.

It could reoort to the Council throueh the Working Groun, where the policy

(

(

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)

isolications of the Comunittee recommendations on research could be i

considered. Specific proposals for Council action.would be orepared by r

the Working Group.

An important aspect of the committee's work would be the identifi-cation of the scientific resources presently available for radon research.

Government laboratories such as the DOE Environmental Measurements Laboratory, the IPA Eastern Invironmental Radiation Facility and the EPA Las Vegas Facility have gained considerable experience in radon studies, and the same is true of research grcups at DCE national laboratories and 29

j t

8 l

at several universities and private concerns. The expertise of the National Bureau of Standards in the standardization of measurement methodologies would also be an important resource. This multi-laboratory expertise shonid be utilized in the critical scientific investigations, including the detailed studies of the dynamics of rados and rados progeny 1

in individus1 structures, development of new experimental and analytical methods, and the establishment of asperimental protocols for large-scale d

studies. Such activities will provide necessary support and guidance for the survey efforts. Advantage should also be taken of the considerable v..

experience and espertise that have been gained in other countries, notably Germany (FRG), Sweden, 3ritain, and Canada. Close contact should be i

established with the appropeists agencies and laboratories in these countries, where very similar probisms are being studied and governmental action undertaken.

Alternative approaches to the development of a coordinated research n program are possible, including reliance on the program plan now being developed for all indoor pollutants by the Ad Hoc Interagency Committee on T

l

..)

Indoor Air Pollution. However, the Task Force believes that there is a

)

compelling need for expert technical advice from the scientific comununity on the rados problem that can be most effectively derived through the mechanism of an Expert Committee sponsored by and reporting to the Radiation Policy Council. This Committee's activities should be closely coordinated with other Federal.,Jforts to address. indoor pollution problems.

40 -

Recommendation No. 3: The Radiation Policy Council should encourage the acquisition and analysis of epidemiological data by Federal atencies on a timely basis. Moreover, the Council should reonest Federal agencies to sake the data obtained in evidemiological studies of eroosed miners and other groupe available to as seny analysty as possible. Although the l

Federal Gover==mae has put considerable resources into data acquisition, considerably less effort has been expended on data analysis. Both Federal funding and professional expertise in this area have been in short supply. The resources needed for an improved effort are modest. Council

(

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leadership in this area could be most effective.

Initiatives by the Council to encourage international cooperation in the research area are also desirable. Extensive data has been collected internationally that could contribute to the understanding of risks due to rados progeny at low doses.

The Radiation Policy Council should point out to the Interagency Radiation Research Codetee that research on the potential harm from environmental radon should be encouraged and that epidemiological case

(

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control studies of non-occupationally exposed persons could be particularly useful.

Rac M ation No. 4: The Radiation Policy Council should defer considering a Federal Radiation Protection Guide for indoor radon exposure. Given the serious shortcomings in our current understanding of the problem, such action would be premature. We believe that a period of several years is a acre appropriate time frame for the gradual development of regulatory actions having a large potential impact at the local level.

Even though Federal Radiation Protectica Guides are only " advice" at the al

Se' ate levels, the impact of any guide would be large since all Federal actions would have to take such a Presidectial directive into account.

We think the precedents for national radon levels set by the Canadian and Swedish Governments should be carefully considered by the IPC. In Canada, government actions have been preceded by a national sampling pecgran to determine the frequency at which high radon levels occur in j

I 4

both coni:aninated and uncontaminated areas. Subsequent remedial actions t

l end guides are applied only to radon esposures due to industrial processes. In Sweden, the area of contapplaced control is wider and the m

plan for eventual implementation calls for a long term and phased remedial program. As currently planned, this will eventually include building l

meterials, sites for new construction, remedial measures in existing i

houses, and building specifications for new homes. The Swedish government l

is veil aware of the impact regulations will have at the local level and i

choir program is largely advisory at its present stage. It warrants l

careful study by the Working Group and Council.

I t

Even though we do not recr=manad a radiation protection guide, the 3

consequences of not having a guida for indoor radon should be appreciated by the Council. In the absence of a Federal Guide, there is a chance that the Federal agencies now advising States and other governmental agencies will give conflicting advice. In addition, some States may taka

?

L independent action. We believe the Radiation Policy Council should i

f monitor and coordinata such State and Federal activities so that if a Radiation Protection Guide for Radon is eventually developed, it will not i

have to be implemented on top of a set of inconsistent control levels based on ad hoc considerations. Interim guidance of a purely advisory i

i i

i

. _ _ _ _ _ ~

nature could lessen the chance,of this occurring. ne. practical advantage of interim guidance as opposed to its liability against future actions has I

not been considered by the Task Force. It should be addressed by a body l

siving policy advice to the Council, as called for in the first recommendation.

..___B.ecommendation No. 5: While the Task Force believes new regulatory

_ authority at this time would be premature, the Radiation Policy Council ___

should consider two possible legislative items that are not dependent on furthee study of the indoor radon problem.

i

/

2e appropriate division of regulatory responsibilities between the various Federal agencies for radon and other indoor air pollutants is not

(

i clear and may be a subject the Congress wisnes to consider in the near l

future. 3ere are many technical as well as policy questions involved in I

such decisions and it is likely that an agreed position by tha Council on j

i this 'would be helpful to the Congress. Alternately, the various agencies i

l' can request legislative authority based on agency mandates; but it seems to us that such an approach circumvents the potencia117 very efficient

('

mechanism for interagency coordination and cooperation implicit in the establishment of the Radiation Policy Council.

Secondly, the Ca m il should consider the possibility of recommending

{

i legislation patterned after the Earthquake Hazards Reduction Act of 1977.

l i

nis legislation does not establish Federal authority for the ameliori-l l

zation of earthquake hasards. However, it does lay out a study program of j

i these hazards under congressional mandate and provides for an adequately funded progran based on Federal, State, local and private research and

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43 i

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I p1'anning that would reduce risks. Further, it assigns various aspects of the program to specific Federal agencies, along with goals, priorities and target dates for implementation of the prsgram. A similar legislative approach wonid be adaptable to the radon problem and we have included the l

text of the " Earthquake Essards Reduction Act" as an appendix to this position paper. We believe it deservearserions study by both the Working Group and the Counci1.

VI.

Summary of Public Comments

,A

)

The Task Force received six letters containing comments on our Work Plan published in the Federal Register on June 27, 1980. In addition, Mr.

Anthony Nero of the Lawrence Berkeley Laboratory, University of California, commented extensively on the plan at the Council public meeting in San Francisco, July 31, 1980. We have included his written presentation as part of the public comments. One or more members of the Task Force were present at each of the public hearings and briefed the U

Task Force on public coments pertaining to radon at our meetink on 3

August 7, 1980.

All of the written comments received by the Task Force are reproduced in Appendix III. Albert Hazel of The Colorado Department of Health suggested that the Task Force include radon transport by drinking water in its deliberations and Gerald L. Schroeder, Arthur D. Little, Inc.,

suggests that source-pathway analyses would be more fruitful than direct measurements in determining concentrations oIf rados progeny in homes. The other comeectors were more general. James Spahn, writing for the NRCP, 1

14 l

wr,,,,~,,,-e

provided the risk analysis by Earley and Pasternack referred to in Section l

l II-3 and cautions that only annual average working level determinations provided a suitable basis for action.

l Mehmeed E1,-Ashry comenenting for T7A pointed out non-residential structures were erroneously included in Table 1 of the Federal Register Notice, p. 43510, (this error is correct in Table III-1), and made other j

suggestions on data presentation. He also printed out the need for a slow, carefully considered national approach, a point of view also stated l

by Dr. Eersloff, Williant Geiger, and Anthony Nero in some detail.

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Unfortunately, Dr. Nero's comuments were received too late to be fully l

considered by the Taak Force in the development of this position paper.

However, his comments warrant careful consideration by the Working Group i

and Council.

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REPERZ5CES l

AE 79 Archer, V.E., " Factors in exposure response relationships of rsdon daughter injury," Proceedings of the Mine Safety and Health j

Administration, Workshop on Lung Cancer Epidemiology and Industrial Applications of Sputuut Cytology, November 14-16, 1978, Colorado School of Mines Press, Golden, CO.

1 BA 76 Bair, W.J. and J. M. Thomas, " Predictions of the health effects I

of inhaled transeranitan elements froma experimental W==1s" in Transuranium Nuclides in the Environment, IAEA, Vienna.

BE 78 Beebe, G.W., E. Esto and C.E. I.and, Mortality Experience of Atomic-Bomb Survivors, 1950-1974, I,1fe Span Study Report No. 8.

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Eadiation Effects Research Poundation, T1 l'77, National Academy of Sciences, Washington, DC.

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EP 75 Environmental Protection Agency, Radioactivity Distribution In Phosphate Products, 3 -Products, Effluents, and Wastes.

l 7

Technical Note ORP/CSD-75-3. USEFA, Office of Radiation I

Programs, Washington, DC.

I EP 76 Environmental Protection Agency, National Interim Primarv Drinking Water Regulations, EPA-570/9-76-003. USEPA, Office of l

Water Supply, Washington, DC.

l t

EP 78 Environmental Protection Agency, Indoor Radiation Ernosure Due to Radium-225 in Florida Phosphate I. ands. EPA 520/4-78-013, USEPA,

[

office of Radiation Programs, Washington, DC.

GE 80 George, A.C. and A. J. Breslin, " Distribution of ambient raden

[

and radon daughters in New York and New Jersey residences,"

w l Proceedings of Natural Radiation Environment III, g

April 23-28, 1978. In press, University of Texas, Houston, TZ.

GES 80 Gesell, T. and H.M. Prichard, "The contribution cf radon in cap water to indoor redon concentration," Proceedings of Natural

[

Radiation Environment III, April 23-28, 1978.

In press, i

University of Texas, Houston, TZ.

HI 79

Hewitt, D., "3iostatistical studies on Canadian uranium miners,"

Proceedings of the Mine Safety and Health Administration.

Workshoe on Lung Cancer Epidemiology and Industrial Acplications of Soutum Cytology, November 14-16, 1978, Colorado School of

{

Mines Press, Golden, CO.

JES 79 Hess, C.T., S.A. Norten, et. al., Raden-222 in Portable Water Supplies in Maine: The GeoloE Hydrology, Physics. and Health j

Effects, Land and Water Resources cancer, Universit7 of Maine, Orno, ME.

kd i

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i IP 66 International C= mission on Radiological Protection, Task Group l

on Lung Dynamics, " Deposition and retention models for internal j

dosimetry of the human respirat ry tract," Health Physics M:173 IP 77 International Commission on Radiological Protection, l

Recommendations of the International Commission on Radiological Proceetion, ICRP Publication 26.

Pergemon Press, New York, NT.

i i

LU 79 Lundin P.Y., Archer, and J. Wagoner, "An exposure-time response model for lung cancer mortality in uranium miners-effects of radiation exposure, age, and cigarette smoking," Energy and

[

Health. Proceedings of the Second Alta Conference, Society for

~ ~ ~ " ~ ~

- ~

Industrial and Applied Mathematics, Philadelphia, PA.

t l

~

MA 78 Mays, C.W., H. Spissa, and A. Gerspach, " Skeletal effects following 224 a injections into humans," Health Physics,35,:83 R

5

('

MU 78 Maller, W.A., W. Gossner, O. Hug, and A. Luz, " Late effects after k.

incorporation of the short-lived emitters 224Ra and 227 h in i

T mice," Health Physics 35:33 i

NA 72 National Academy of Sciences, National Research Council, The l

Effects on Populations of Exposure to Low Levels of Ionisins Radiation. Report of the Advisory Committee on the Biological Effects of Ionizing Radiations, National Technical Information Service, P.3. 239 735/AS, Springfield, VA.

NA 76

' National Academy of Science, National Research Council, Health l

' Effects of Alpha-Emitting Particles in the Resoiratorv Tract, EPA 520/4-76-013, USEPA, Office of Radiation Progenas, l

Wahington, DC.

j I

NA 80 National Academy of Sciences, National Research Council, f]

The Effects on Populations of Exposure to Lew Levels of Ionizing I

n, Radiation. Report or the Advisory Committee on the Biological Effects of Ionizing Radiations, Typescript Edition NAS, l

July 29, 1980, Washington, DC.

I NC 80 National Council on Radiation Protection and Measurements, l

Report No. 6As Influence of dose and its distribution in time on dose ersosure relationsnips for low LZT radiations. NCRP, Bethesda, MD.

NR 79 U.S. Nuclear Regulatory Commeission, Draft Generic Invironmental Imoset Statement on Uranita Milling, Volume II, NURIG-0511, N10, Washington, DC, 1979.

UN 77 United Nations, Sources and Effeer.s of Ionizing Radiation.

Report of the United Nations Scientific Comunittee on the Effects of Atomic-Radiation, 1977 Report of the General Assembly, United Nations Publicatien E.77.12.I.

U.N. Publications, NT.

47

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[

APPENDIZ I EFIDEMIOLOGICAL STUDIZ3 0F PERSONS EXPOSED TO RADON propered by Neal Nelson, D.7.M., Ph.D.

Office of Radiation Prograss, U.S. EPA Epidemiological studies of the effects of radon exposure have been carried out in a staber of countries. Although several of these studies.

are now inactive, data analyses can be resumed at any time. They are all ongoing in the sense that substantial fractions of the populations at risk are still alive. Radon progeny esposure levels are listed as high,

- moderate, or low depending on whether-the estimated ananal exposure exceeded 12 WLM; was more than 3 WLM but less than 12 WLM; or was less than 3 WLM.

Studies in the United States a.

Uranium miners - the NIOg8 laboratory in Cincinnati currently has custody of the records. After duplication of the records, part will be retained in the NIOSE Cincinnati laboratory, parr will be sent to the NIOSE Morgantown laboratory.

i 1.

Main study group, i.e., miners isodically examined in 1950-196Q; high level radon exposure. The NIOSE Cincinnati laboratory is I

updating the records and reviewing the epidemiology and effects data.

Most recent publicaciones I

Archer, Y.E., Radford, E.P., and Axelson, O.

" Radon daughter i

cancer in man: factors in exposure-response relationships at low levels," in Conference /Workshow on Lung Can er Epidemiolosv and i

Industrial Aeolications of Soutum Cytology, Colorado School of Mines Press, 1979.

4 Ludin, T.E., Archer, Y.E., and Wagoner, J.E.

"An exposure-time-response model for lung cancer mortality in uranitas miners -

effects of radiation exposure, age and cigarette sacking," in f

Energy and Health, N.E. 3reslow and A.S. Whittemore, editors.

Society for Industrial and Applied Mathematics, 1979.

2.

Secondary study group, i.e., miners in the sputum cytology census of 1957-1968; moderate to low level raden exposure. When records are forwarded frea Cincinnati, the NIOSH Morgantown laboratory plans to update these' and review epidemiology and effects.

(No analyses have been published.)

48

i I

b.

Hardrock metal miners; low level radon exposure. De NIOSH Morgantown laboratorv has a review of mortality in the draft stage. De review will cover misers studied earlier (see below). De primary thrust l

of the review is on tespiratory diseases, with lictie coverage of raden problems. However, a health physicist has started to review the radon measurement data so caden-related problems may be included in the final report.

l Most recent publicatient 4

Wagoner, J.E., Miller, R.W., Lundin, F.E., Fraumeni, J.F., and Hay, M.E.

" Unusual cancer mortality mong a group of underground metal miners," N.E.J.Med. 23 :284-289, 1963.

c.

New Mexico miners; intermediate to high level radon exposure.

Se University of New Mexico has started a long term mortality study of New Mexico uranium miners. De study is supported by the State and by j

mining companies. Only mine operator exposure data will be used in evaluating exposure levels (No publications as yet).

d.

Environmental redon exposures - Colorado; low level radon exposure. A pilot study has been started to determine if there is a difference in sputtui cytology or peripheral lymphocyte cytogenetics between persons living in low versus those in high levels of background raden. M e Colorado State Department of Health is conducting the study for EPA..

e.

" Evaluation of low level radiation effects adjacent to a uranium

~

tailings site in Cannonsburg, PA; low level radon exposure. A pilot study investigating effects of radon and gamena radiation including peripheral lymphocyta cytogenetics, thyroid abnormalities, and lung cancer is being started by the Cancer for Environmental Epidemiology, University of Pittsburg; the sark is being supported by EPA.

%,,)

f.

PHS Indian miner study; high level radon exposure. Study of the Indian miners frees the main study group in Colorado, Utah, and Arizona, and free Shiprock in New Mexico.. Results of the study of Navajo miners at Shiprock are to be published in 1980.

Most recent publications Wagoner, J.K., Archer, 7.E.,

and Gillam, J.D.

" Mortality of American Indian uranium miners," in Proceedinss II International Cancer Congress. Vol. 3.

P. Bucalossi, U. 7eronesi, and N. Cascine11i, editors. Excerpea Medica. Amsterdam, 1973.

3 Radon in water; low level raden exposure.

1.

A study of the carcinogenic impact of raden in water supplies has been started as a pilot study to identify U.S. populatica 49

~

m..___...__.

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groupe with relatively high exposures from radon in water. If such r

population groups are identified, they can be studied further.

Water sources are being screened on the following basist the sample must be from a caemunity water supply in a ecommunity with a population of 5,000 or more and it must be an established connuunity, i.e., with a stable populat2.on.

The study is being done by the School of Public Health,

{

f University of Texas, Houston, with NIH funding.

Most recent publication:

Gesell, T.F., Prichard, E.M., and Hess, C.T.

" Epidemiological l

implications of radon in public water supplies," Specialiac Meeting on the Assessment of Radon and Daughter Exposure and Related Biological Effects, Rome,1980 Uroceedings to be l

g published).

L 1

2.

Maine studies - water exposures. Studies In Mains have been made correlating estimated radon concentrations in water (as a surrogate i

for h man exposure) with cancer mortality races by county to reported by l

NCI. Bis effort is not Federally-supported, but there is new some collaboration between the Maine investigators and the study at the l

Unversity of Texas mentioned above.

l Most recent publications r

Hess, C.T., e_e,ah, Raden-222 in Potable Water Supolies in t

Mainst the Geology. Hydrologv. Physics and Health Effects,

)

Project A-045-ME, Contract A-272-A, Land and Water Resources l

Center, University of Maine at Orono, 1979.

j Studies outside the U.S.

(

)

1

/

Canada I

a.

Fluorspar Miners - radon exposure may have been at high levels.

Minas are now closed. Followup of miners is scheduled to continue.

j Most recent publication:

Wright, E.S. and Couvers, C.M.

" Radiation-induced carcinoma of i

the lung - the St. Lawrence tragedy,"

J. Thorac. Cardiovasc.

i Surg.73,495-498, 1977.

I b.

Ontario uranium miners; low radon level exposure. The inicial i

study is by Dr. David Hewitt (U. of Toronto). This study has been taken i

over by the Ministry of Labor and placed under Dr. Jan Muller. The study is to be updated and expanded.

50 l

-. ~ - - -. -

. _ i __.

f ?..

Most recent publication:

l Hewitt, D.

"31ostatistical studies en Canadian uranium miners,"

in Conference /Workshoo on Lung Cancer Epidemiology and Industrial Ar@lications of Sputum Cytology, Colorado School of Mines Press, 1979.

c.

Other; low redon level exposure. Pilot studies have been started on miners from Elliot Lake and Bancroft and employees of Denison Mines, Ltd. and Rio Algos, Ltd. So far only exposure histories have been i

collected. It appears that in most mines 90% of the radon exposure is at less than 120 cuanlative WLM. No epidemiological data is available yet.

Most recent publication:

~~

McCulloustr,1.5., Stocker, E., and Makepeace, C.E.

" Pilot study on rados daughter exposures in Canada," in Conference /Workshoo A

on Lung Cancer Eoidemiolory and Industrial Apolications of

. )

Sputum Cytology, Colorado School of Mines Press, 1979.

l England a.

Iron miners; relativaly low radon level exposure.

Most recent publication:

Boyd, J.T., Doll, R., Faulds, J.S., and Leiper, J.

" Cancer of the lung in iron ore (haematite) miners," Brit. J. Indust.

Med. E:97-105, 1970.

b.

Other - The National Radiological Protection 3 card is reported to be doing a good review cf radon levels in mines, particularly Cornish 3

tin mines. There is no report of epidemiological followup being planned.

Sweden a.

Kiruna iron miners - low radon level exposures. No follow-up l

reported.

Most recent publication:

Jorgensen, H.S.

"A study of sortality from lung cancer smong ziners in Kiruna, 1950-1970," Work Environa. Hith. 10:126-133, 1973.

b.

Malmberget iron miners; low radon level exposure. Mines described as having no asbestos and a gamma radiation level of 100 3r/yr. Analysis of data from miners born between 1880 and 1919 is being completed by ladford and Renard. No further follo n g is reported.

51 n

.. ~ -

(

i Most recent publication:

Radford, E.P. and Renard, K.G. St. Clair. " Lung cancer in Swedish iron miners exposed to low concentrations of radon daughters," in Abstracts of Paners for the 28th Annual Meeting of the Radiation Research Sociacy, 1980.

c.

Zinkgruvan lead-sine miners - relatively iter radon level exposarse. No follow-up reported.

Most recent publication Azelson, 0. and Sundell, L.'

" Mining, lung cancer and smoking,"

Scand. J. Work Inviroom. Elth 4:46-52, 1978.

d.

Other; background radon exposure. A study was made of lung cancer as related to estimated residential radon exposure. Lung cancer I

rates per WJi were estimated to be similar for these residential exposures and for sine expoenras. No follow-up or expansion of the study has been reported.

Xost recent publications:

Azelson, O. and Edling, C.

" Health hazards from radon daughters in dwellings in Sweden," Park City Environmental Health Conference, 1979 (Proceedings in Press).

Axelson, 0., Edling, C., and Kling, H.

" Lung cancer and residency." A case-reference study on the possible impact of exposure to radon and its daughters in dwellings," Scand. J.

Work Envires. and Health 5:10-15, 1979.

Czechoslovakia Uranium miners; high radon level exposure. Studies on effects a.

i of radon exposure are continuing; however, it is not possible to check on basic data. The only material available is that which has been published.

Most recent publication:

Kuns, E., Seve, J.,

and Placek, 7.

" Lung cancer nortality in uranium miners (methodological aspects)." Health Physics M:579-530, 1978.

e 52

Auarria a.

Spa workers and others; high and low level exposures. Studies have been made of lyurphocyte cytogenetics in spa workers and townspeople at Badgastein. A dose risponse curve was developed but no cancer epidemiologic studies have been done yet.

Most recent publications

~

Pohl-Raling, J. and Pischer, P.

" Epidemiological study on chromoscoe aberrations in a rados spa," Specialist Meeting on the Assessment of Rados and Daughter Ernosure and Related Biological Effects, Rome, 1980 (Proceedingr to be published).

A G

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I APPENDII II i

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(

CHAPTER 84-LutTHQUAKE HAZARDS REDUCHON CfD'l I

(

Sea Sea ffst.

asetase, dietten, and esser.

M sensemens et per ames ed aveslesentry 7"E Db non sesseems eartaeanne mennede redee-m anna and sepaied re.

tsee preerna, sessen for eesssue er (al Esentaleesese, asterades-- et erumas t

(33 Destes = the Promed,eos

dem, p --

(d) Rosensoa eessmesse.Podesta parecipaslee.

p temesses of eact for ee=

vesseenese et paast seemet.

(et

=a staa t rear.

i tad et penas to esseres.

(f) Imr. rear targetes messet I ase ese=

.or. se F.es. rese:Feeeral.

isemos = sier = es.

a ees i

vesepamot tea implemeest.

c1Pe preetseese fewert to

)

tsaa et program esopera.

-_ eal commattees:

ties and eeerstaattee wtth.

ee'etamasses of ressees for see aesteename to severe aentaastasses et contene.

menta4 estassee of the pistas er avocesos see.

i

% ama program meest.

esas settee.

t oe.

(el Staes sometases (ep Otp at the presTesa.

th) Neo Feeerst perttef petien t tal Eartagemas rennetaat program Staa review: re.

cesstratusea.

Port to Cessteuer evalsa.

(2) Eartagemas ties et asa.Tederan sad t3) Meese coems. prediet$se.

Federna pseetettee ocuvs.

443 Eastmemaae.eetased ta=

t:ee.

ti sese: understaadlee 77!5, Assaal report to CoacTesseoeal (3) Edsenstes et tae put esemattese.

',I lat.

1"lE Aatsertences et apprepriatigte.

(m

)

(S) EemmeP"k Peepert1ES (48 t'M aethemat148 f3r the

+

matlanties et earta.

proerest.

l 4 ease besarda, the (b) Gemeessems Server.

~

varied c--_-.

. tel Nasseana senses Feesdassee, et

% emas pee 5 TTOL Caesressament t:ndtnse The Coastees flads and declares the followtag:

(1) All 50 States are ruinerable to the hasards of earthquakes..

and at least 27 of them are subject to a major and moderate sessmic j

31 2 i

l i

l 54

I ll--

~

~. _...

,_.m.

\\

1 -

i !

4

i t

l renue anALTa Axn wztrAnz 42 57701 risk. tactedias Alaska. Canforsta. Eawall. Illinois, wa===ahusetts, Misseart. Montana. Netwta. New Jeresy. New Yort. South Carottaa.

Utah, sad Washlastos. A large porties of the populaties of the f

United States Hves la areas vulnershle te earthquake hasards.

)

(2) Earthesakee have enamed, and saa enase la the future emers>

ees toes of ute. Islsry, destreetles of property, and esosemia sad l

l sosial disrupties. With respect to future earthesaken, such loss, i!

I desernettaa, and disruptsee saa be substantia!!y reduced threesh the l'

\\

developeaset and implemestaties of earthquake hasards redaation uneasures. lasindlas (A) taproved deessa and constreetion methods

ll and praatjaos. (3). land-eme oostrels and redevelopment. (C) prodle-ties teskaitses and early.waratag erstems. (D) esordtasted emer-l!

I sener preparedaeas pleas, and (B) pehtte edseaties and tavelve-I meat programe.

i I

(3) An esportly staffed and adessately fissased earthquake has.

l l arts reduettes preersa. based se Federal. State. Ioan!. and private resenrek, piraalas, da=8=8a===leins and aestribstions would redese j

the riait of seek teos, destruettes, and disruptios la seismie arene 3

i l

by as ansest far greater than the east of seek program.

j (4) A well-funded seismolesteal research program la earthquake

,/

l !

l l

prodleties could provide data adesease for the deessa, of as oper>

f tiemal system that assid prediet asserstely the time, pisee, masaltade.

and physsent effects of earthquakes la seissted areas of the United States.

j (5) As operatieaal earthquake prodleties system can predoes magniffa==t sosial, eseammis legal, and peut $aal esasoquemeen.

j (6) Therte la a setentifle tests for hypotheetstag that major earth-quakes may be modersted. la at least some setsette areas, by appeler time of the Medfaspe of earthquake control and satamelossent research.

(7) The implementation of earthquake hassede redsettos messeres f.

weeld, as na added besefit, alas redsee the rted of loss, destruettoa.

and disruption from other asters! hasards and mammade hasards.

taeindlag hurriesses, tornadoes, aseidents, esplosions. Isadst! des, be11 ding and strostural cave.tas. and fires.

l (8) Reduetten of lees, destruction, and dlarupties from earth.

quakes will deseed on the nations of ladividuala, and orgaatsstions

- 3

! i la the private soster and governmental ualts at Federal. State, and local levels. The currest capability to trsaster knowledge and la-

!l forssation to these sectore is inssiftetest. Improved mechaatsas

'N l j are needed to traastate esisting laformation and researets !!adings I

late rsessaable and usable speciftesticos, artteria, sad practices so l

that Ladividuals ersaatsstions and seversmestal units may make informed destaions and take appropriate actions.

l j

l (9) Severe earthquakes are a worldwide problems. Staes damasias earthquakes asest tatroqueatly la any ese nation. laternattosal co-opersstoa !s riestrable for tautuallearatas from Llatted espertences.

(10) An effective Federal program la earthquake hasards redue.

t!os vtu require taput from and rettew by perseas outande the l'oder 1 Government esport la the setences of earthquate hasards reduction and la the practient application of earthquake hasards reduction measures.

Pua.L.95-124. 3 2. 0et. 7.1977. 915 tat.109 8.

saare Titte. Sorties 1 et 1*Skl. 93=1t6 Asseer, see esetless 1 104 see 4.:o4 of pren ese Thas rate act (seerttee thte Es. ore.No. 12:48. Jetr ll0. Irfe. to F.s. -

casetert tear he ettee se tae Sartagesse ea:3. ses ses as e sue usvier esertoe kisserte Asseetles Act or 1s77*.*

al31 of Title M. Appeedts. War ese.Ma.

the F*esedoes uses sorta e k

a For testeett e,te s.eeense me.ea :rrr e,e.sse.e.is.e m ee, see,e,steeeet.eems oc y u sa m..ive te se tremaferred. se reasossees to rae Direeter toff C.3.Csee Case. est Ada 4ews p.

of tas Feeerse Emersemer *==&

3s.

i, 313 55

W i

i I

42 57702 PUBLIC BEALTH AND WEIJARE

$ 7708. Ceegreeneseal====- of purpose It is the purpose of the Congrees la this chapter to reduce the riske of 11te and property from future earthquakes la the Ustted States threagh the establishment and malatemaaes of as effective earthquake hasards j

redsstica program.

Put.I.94-124. I 3. Oct. 7.1977. 91 Stat.1099.

l Le sheer. sier teessamene torr t!Acade case, med Adm 4ews,p.

f l

nameser and peromme et ren.I. as.4:n. som 2MI.

1 l

(

l e from, neassesses i

l As used La this chapter, salese the esatset otherwise requires:

g (1) The term "taelados" and vartaats thereof should be read as If the phrase "but is met 11 salted to" were alas set forth.

f I

(2) The term " program

• mesas tha earthquake hasards redeettea program estattished mader sostica 7704 of this title.

(3) The term "selemle and vartaats thereof mens havtag to de l

d with, or sansed by earthesahee.

i (4) The torna " State" means aesh of the States of the United States, the Distrtet of Calambia. the Commonwealth of Puerto 1180.

l l

{

the V1rsta Islands. Casa. American Samoa, the Commonwealth of i

k the 3fartaan Isla&ds, and say other terrttery or possessies of the

{

United States.

(5) The term " United States" mesas, when used la a geographleal l

semee, all of the States as deftmed la paragraph (4) of this seettee.

I Pah.I.95-124.14. Oct. 7.1977. 31 Stat.1999.

I' tesanas roe le terr t;Acoes coes, med Adeutown, p.

a== r sese ma.n.ner.a ree.. m.eienne.s,e.

es p es o..

se.

$ 7704. 2feedonal earttaquake hameds r=d===*== progreen g

asemassammene (a) The Freendent shall establish and malatala. la asserdas.ee with the provianaam and petic7 of this chapter, a coordinated earthquake has.

ards redustian progrsa, which shall-(1) be deeltsed and adeninistered to achieve the objectives set l

forth la subsectica (e) of this acetion:

(*) lavolve, where appropriate, each of the associes listed la sub.

eastles (d) of this soettos; and (3) taelsee each of the elements desertbed in subsection (e) of this seettoa. the laptementation plan d6ecribed la subsection (f) of

[

this section, and the asetetases to the States specified la subsectios (v]

I (g) of this secties.

l l

on.s.eee a.ree. me ee..e

.e..evt.e m

e.,e-.

ed e and smeasummenenen se eseewmem. - _ _ _ _.a mee.n.t.ser to meets 4 et e se te somsmessemos and nesen.

l

[

tsee ween see -

to s-.

eessesse et see sessen. ame seeWWom W (b) The Preeldest shall-l (1) withia 30 dare after Osteter 7.1977. destssate the Federal l

i department, agener or entity responsible for the devoteement of the implementatica plaa desertbed la subsectica (f) of this section:

(:) withia 210 days after October 7.1977, submit to the appro.

rtate authertstag committees of the Coasrees the implementatica plan deerrtbed la subsectica (f) of this sections and (3) byrule, within 300 days after October 7.1977-(A) doettaate the Federsi department, assacy. or laterasenev 3up which slasil have primary toeponsibilf ty for the develop.

meat and implementattom of the earthquake hasards reductica I

orogram:

i (B) assiga sad spectfy the role and reopensibility of each appropriate Tetersi depart:sent. agency, and entity with roepect I

to esca oblect And element of the program:

314 56

4 1

e PUBUC HEALTH AND WUJARE 42 57704 l

(C) establish goals. prterttles, and target dates for taple.

maatados of the program; l

(D) provide a mothed for oneperstles and esordtaation with, and samletaaes (to the estaat of available resentees) to, later=

ested goversnaantal entitles la all States, parties! arty these oos.

ta&olag areas of high or moderate solamle riskt and (El provide for (senfled stafflag for the program and its es=posesta, ensemeeves et the senemmen (e) The objectives of the earthquake hasards todacties program shall Laelude--

P seateemos ownesvenesen (1) the development of teokselegten!!y and esomenleaHy fanathie destga and construe 1em methods and pmesdares te make new and esisting streettres, la areas of seinante riot, earthquake resistaat, giftag priority to the development of such 1:ethods and procedures for suetear power generating plaats, dams hweitala, schools, public m

utilttles pabus safety structures. high ossegaae7 baudlaga, and other

)

structures whlek are especially needed la time of dianatert N seedeessen (3) the implementation la all arene of high or a:oderste estamia risk, of a sveten (taatsding peresesel. testaelogy, and procedures) for prediettag d===per earthquakes and for identifytag, evaluaciar.

and acesrately sharasteristag setania hammeds; seest seden (3) the development. publienties, and pramoties. la conlanettes with State and toen1 offlatals and professional orgendweetaas. of model codes and other laeans to esordiante tatsraattos about seismie risk with land use pouer destasons and building activity; amemas.eeeeees seemsse undessessenes

( 4) the development. la arena of sedamite risk of improved under-standlag of and capabiHty with respect to. earthquake-related lasues.

laciudlag methods of controillag the riska from earthquakes. planning to provost such risks. disseminating warnings of earthquakes. orgaa-1 star emergeasy servlees, and planalag for rescastruettaa and rode-velopment after sa earthquake!

3 meneestem of the sea 48e

' s]

(5) the ednestics of the pobuc. laslading State and local off!cials.

as to earthquake phenomena the identificattom of loestions and struc-tures whiek are espesiaHy susceptible to earthquake damage, wars to reduce the adverse comesquesees of as earthquake, and rotated m attereI sammenen senseesses nedetsmesse er semeseemas henseen. the vuesee

-,g,,,,amessser

_ -_E

~ "*

• 8

• a (8) the development of researea on--

l (A) ways to taeresse the use of existtag setentific and engt.

neertag knowledge to mitigate earthquake hamords I

(B) the a maal, econonne legal. and poutical consequences of earthquake predict 10s and (C) ways to assare the avadability of earthquake Insurance or some functional esbetitutet and amaas med seeasse seneseen see emmenes e, eseevessee 4 enesmas sammenene

(*) the dovetepuest of basse and appued research leading to a better understant.ing of the control or siterstica of seismic phe.

[

nomena.

l 315 i

. 57

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42 57704 renue azar rH AND WEE. FARE l

i ree ma.e.< -

(d) ra amassing th. r.i. and respeasantuty of r.<8eral d.part eais.

assasles, and eauties under sebesettee (b)(3)(B) of this asetica, the President shall, where aberspriate taatade the Uasted States Geelestent Servey, the Mattoman Sesesse roandausa, the Deperiment of Defense, the Department of Reasing and Uttaa Development, the National Asressatica j

r and Space Ad=8=8=*masa, the Natieaal Oceania and Atmospherte Ad-alaistrattaa, the Naalesal Barons of Standards, the Emersy Researek and Deveispetent Ada:aistraties, the Neelear Basalatory e===ta=w and the Mattomal Fire Provoetles and centrol Ade=1ststraties.

l i

(e) The resserek elements of the presrass shau Laetaden -

(1) researsk late the heele causes sad maaha=1-of earthquakes (3) dovetepeest of methods te prodlet the time, place. and mag.

attade of future earthenakes:

(3) development of as understanding et the aireamstaneen la Thiek earthquakes might be artsfleisur ladueed by the talostles of flaide la daep wolle, by the impeandment of reservotra, or by other means:

[

(4) ovaluaties of==*hada that stay lead to the deve6epeest of a espabulty to modify or costret earthquakes to certala regieas:

N_

(5) developeest of taformanian and guideltaes for smalas land La light of seismie rtet la all parts of the United States and prepara-l'

• 1em of seismic risk analyses usefal for emerseasy planalag sad anmeneemity pygg; (e) development of teshalaiues for the dellaestica and evaluaties of the peuusal effects of earthquakes. and their appuenties es a i

restenal bands:

(7) developeest of methods for planalas. design esastreettoa.

l rehahultauen, and utilisation of stammade verts as as to effsettvely resist the hasards imposed by earthenskes:

(8) esploration of possible social and economie adjustments that seald be made to redese eartheuske vulnerabtuty and to esplett effeetively estating and developtag earthquake mitisattoa teshaiques:

and (S) sendles of foreign espertence with an aspects of earthquakes.

tenseemessesses s mme vo e rene seeeeems Pedsens med see redesea ressee a

eeessemamena uma etees

• 8"888

, mere,es g- -_-

g (f) The. President shall develop, throesh the Federal asemer, depart-meat, or entity destsnated under suh== 8a= (b)(1) of this sostion, as

[

laplemeamusa plaa which shan set year'by-year targets thressh at least j

j 1980, and stan speetfy the roles for Federal agencies, and resemmended r

appropriate roles for State aed local units of severnment. Lad 17tdaals.

j f

and prtvase ors==8maata== La cartylag out the implementasies plaa. The

~

plas shall provide for-(1) the deveiepenest of measures to be takes with respect to pre-partas for earthquakes, evaluaties of predisues teshalques and setual prodletions of earthquakes, varates the residents of as tres that as earthquake may oseur, and ensurtag that a eseprehensive ruepease is made to the oceurrence of an earthquake;

(*) the development of ways for State. county. looni, and restesal l

severseestal units to use esisdag and developing taewtedse shoot the restosal and !acal vartstions of soiante risk ta maalag their I

!aad use desistons; (3) the development and promalsation of specifiestless, building standards, doetsa ertteria. and construction practices to achieve sp-propriate earthquate resistance for new and existing stru,tures:

i (4) sa examicsuca of alternstave provisions and requirements for reducing earthquake hasards throush Federal and federany i'

finaaeed construct!as. Ioans losa guarantees, and '1 ceases i

316 53

\\

l I

t

~

t 42 57706 PUBLIC HEALTH.WD WELFARE anthertsations so. forth fa subasedoes (b) and (e) of thte aesties), set to esseed 31.000.000 for the flesal year endlag September 30,1978, set to l

esseed 82.000.000 for the flesal ywr endtag September 30,1373, and sat to exeoed 33.000.000 er the flessl year endlag September 30,1980.

assemesmes sawwer (b) There are anthertsed to be appropriated to the Seerstary of the Interter for ;Mrposes for carrytag est through the Direeter of the Calted States Geolent$eal Survey, the responetbtlities that may be amongaed to the i

Direeter under this chapter not to esseed 887.500.000 for the flamal year andtag Septeether 40.19753 set to esseed 835.000.000 for the fleeni rear endtag September 30.19793 and set to asesed 840.000.000 for the flesel year endist Soptember 30,1880.

l messess sesamme rammenesen (e) Te esaWe the Fasadattaa to entry est respeasibilities that may to aestgaed to it a.sder tale chapter there are authertsed to be appropriates'.

I

^

to the Foundact.sa set to esseed 837.800.000 for the f! seal year ending l

l September 30. It?3; not to esesed 833.000.000 for the flesal year endiss' September 30, 1273; and set te onesed $40,000.000 for the flesal year endlag September 30,1380.

Puh.L. 35-13 4. I 7, Oct. 7.1977. 31 Stat.1103.

Imessasses, assemer. For seessiacave terr C.3. cede case. sad Adm. News p.

hiseery and perpose on' Pud 95-124. ose It38.

4 f

l i

v l

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s 318 59

i i

1 i

resuc axALTH MD WE. FARE 42 5 7706 m ao determinades of me appropria. roi. for ins.rasse. :.a.

pro rama, sad p.bue ud privu. reuet.tform ta med.ruas a.

impaat of earthquakeet and

( 4) 4'a=a a f saria= os s timely beata. ot-(A) lastrument. derived data of interest to other researsherst l

(3) dentsa tad malysts data and procedures of tatorest to I

the destsa professions and to the construedes tadastry: nad j

(C) other taformadas and knowledge et laterest to the publie to redese velaarshiEty to earthesake haanrda.

{

When the tanple==*='*-a plan developed by the Pressdest under this i

seedes esatemplates or proceses speettle naties to be takes by any Federal j

aseesy, deoartament, or entity, and, at the end et the 3p-day period be.

steef ag on the date the Pr=dd=e submits seek plas to the appropriate I

}

anthertstag

==h at the Coasress any seek aedes has set been

!astiated, the Pressdent shan file with seek sesamittees a report esplala=

!as la desaH. the reasons why seek aedes has act boss,1mittated.

I scene samassesse (3) Is making anoistaaes available to the States ander the Dtaaster 1

BeHat Ast of 1974. the President may make eseh assistmase available l

.{

to further the purposes of this etapter taaladtag maklag sta11able to the.

States the results of researth and other settvities conducted under this b

f etapter.

I sen-Fedeses sesenesemessee seassess same seeeswa ressee = cesseeme.

]

es see>Fedeses ese Feessed seedsesses sourysesse i

(h) In carrytag ont the provtatoes of this seettoa. the Proeident shall j

provide an opportaatty for participation by the appropriate representa.

tives ct State and losa! governments, and by the pubtle, lacInding repre.

saatatives of bustsees and ladustry. the deelsa profeestema, and the re-search community, la the forsaulattes and implementados of the programs.

Saak mes. Federal participation shall tactade periodle rettew of the i

progress plaa, esasidered la its entirety, by as assembled and adequately j

staffed aroup of such representatives. Any comments os the program

• uDea which such group agrees shall be reported to the Coasroes.

j Messeres developed pursuaat to subesettaa (f)(1) of this seettos for the evaluattom of prediction techalques and actual prodlettons of earth-j quahee shan provide for adequate sos.yederal partietpatloa. To the j

extent that such :aensures Lasiude evaluscos by Federal employees of

)

non-Federsi prediction settvtties, seen measures shall also taelude evalua-time by perseas not ta full-tisse Pederal employssent of Toderal prodlettoa j

activities.

j P'ab.L.35-124. I S. Oct. 7.1977. 31 Stat.109 9.

(

,j 1

Emsessasses nameer, yer 'eenessesse :sPr U.1 Cede Cass. and um iews, p.

)

a:asary ame purpose et Psa.L EG6, ses :TER.

4 8 7705.

As===8 report to Ceassesseanal c===**===

l The President shan, withis alaecy days atter the eed of ensk fiscal i

Fear, seemit as saamal report to the appropriate authoristag committees ta the Coasress doesrthias the status of the program, and deserthtag and i

i ovateatlag presroes achieved during the presedlag fiscal year la reduetag the rtake of earthquahe haantda. F.aeh such report shan laelude any r=aa= = =d = rtase for legislative and other nettom the Proeident deems necessary and approgra.ata, j

Pub.L.35-124. l 6. Det. 7,1977. 31 Stat.1102, f

Zaetniasswo Niseast.

FtW teetmangtve 1ert U.S. Code Caeg. and Adm. News,p.

1 hasserr ame purpose ed yua.L was, sus ::5.

3 7tos. Aashortmeessaof appropriassene commses a "em toe tae seeesems (a) There are authortsed to be appropriated to the Presidest to carry-out the provisions of sectione 7704 and 7705 of this title (in addition to l

any authorisations for sta11ar purposes faciudad !a other Acts and the l

317 l

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APPENDII III EtDILIC NS (i

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61 j

4 b

b ACORN PARK. CAM 8RICGE.MA e2t40-(617} 864 5770 TELEX 9214 July 2,1980 W4114== E. E11aet, PhD-Task Porca mm4-man Office of Badiation Programs ANR-460

?

U.S. IPA Washington, DC 20460

Dear Dr. E11stt:

4212 P,

1

._ J

+

In response to the request for coimaants on issues posed by the work l

plan for rados control in inhabited structures, I submit the fol-l i

loving.

i There is a basic need to develop a system of measurements which, in j

a reasonably short period of time (perhaps one day's effort), will l

characterize the raden-radon daughter prcduct (WL) " hazard potential" l'

of an existing dwelling, a planned construction sita, or of larger geegraphically similar regions. Knowing this potential would enable r==dd =1 seasured or special construction enc 5miquas (e.g., incorpo-rating vapor barriers Luco construction materials at sites of high l

radon flux; avoiding passing cables through subgrade walls) to be applied in order to reduce the potential raden-related radiation hazard to an acceptabla level.

I i

.x Measuring radon or WL a few timac within a dwelling is probably in-Q{

adequate for such charactarintion. Pract;itation, changing baro-matric pressura, wind magnicude and direction, current depth of tha l

water table all can affect the flux of radon into a dwelling. These variations are compounded by' phenomena within the dwelling itself, such as aerosol distribution, ventilation race and water usage.

j t

3ased on experience which ny colleagues and I have had over the past i

20 years in parallel fields of environmental radon-WL nessurenant

{

and control, I believe that it is possible to characterize the potan-tial radon burden of a planned or existing dweims by quantitative 17 l

identifying the sources of radon at the site and the pathways W_a

)

which the radon can nove, by diffusion and/or convection, from the source into the dwelling. This can be done by quantifying; radon concentrations and radon concentration gradients within the surface j

f

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0

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i q

q cuecos.wsaoussrTs l

l ATHENS amussaLs LCNoCN, WCRo P445 mo of.;meno Sm 88A.csco SIo Pauo TtMYC TCRCNTo WASW4GTCN AEN

ArthurDLitthInc t

July 2, 1980 Willian *d.

E11ste, PhD i

Office of Radiation Progras j

l t

two meters of soil or rock at tha sica; supported and unsupported I

radon concentrations in water (and possibly cooking gas) used in i

the d= m a-; the general radon characteristics (emanating 226,

3 content, permeability) of the construction material, especially basement construction; general construction plan, especially sp-proximate planned ventilation rate and whether the basement has j

drainage sumps or cables and pipes passing through subgrade walls-if forced hot air is used for heating, whether there is an air in-take in the bas eant. These data do not require integrating resnits.

climatological and occupant-induced conditions, as is required if

_l over icos periods of time in order to experience a vida range of 1

1 radon characterization is to be based on in-ther-dwelling radon and

[.

WL measurements. Rather, by concentrating the effort on quantify-N ing the sources and oathways of radon, the potential burden can be estimated in a relatively short period *.

The many years of hands-on experience that we have had at Arthur D.

Little, Inc., in development and evaluation of instrumentation sys-l cams to monitor radon and WL and design of systems to control and j

remove radon and/or radon daughter products fron confined atans-j phares makes us confident that the above approach has merit.

J I lould be happy to meet sith you to discuss the above.

t Sincerely, t

y T

0%

(' '

Gerald L. Schroeder GTJ:rhw Enc.

l

!f July 9, 1980 Dr. wi114== E. Ellett Task Force ^=4===

Office of Madiation % -

ABR-460 U.S. Enviremmental Psotection Agency Washington, D.C. 20460

Dear Dr. E11stt:

I do not believe that a national prcgram to control radon

~mj exposures f=en naturany h-41=g high --trations of r.aditan and a

~

governmental Task Ferce to study such levels warrant the tangayers' anney. For 1a gov =mmental agency to set up such a. Task Force only adds to the irresponsible sensa h =' - surrounding exaggerated radiation risks. Win such controls and with radon gas or will there be sub-sequent " Task Forces" to investigate and set li:mits on the number of air hours a person spends traveling, the elevation at which people live, or the stamber of hours a person watches color television? An increase in all of these will result in increased radiation exposure.

As may be implied by reference to reduced ventilatica rates, the reduction in raden gas in inhabited st m.s win rely on decreased insulation :ssulting in higher energy costs. With rising costs of heat-ing, the people with the least social or political means wi n be the hardest hit. Fina H y, with a program to control radon exposures in

'N hemes, there will be an additional cost either directly by the censumer of new horts or by owners of tnose homes requiring remedial action or V

l through increased taxes.

It was stated in the Notice of Inquiry that "-there is apparent-ly no Federal authority for mandatory standards for indoor po Hutants ".

I say thank God for that, especially when the so caned " indoor pollutant" is an intagral part of God's earth!

Sincerely, b,

WO Dr. Lyda W. Hersloff Radioecologist f0 h dol 2

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TD4NESSEE VALLEY AUTHORITY j

Nonnte. TEMmessas s78a8 l'

JUL 171980 i

1 i

4 Dr. W4 " ' *= E. Ellect Task Forca Chairman i

Offica of Radiation Prograr.t. AN1-460 l

U.S. Enviremental Protection Agency j

Washington, D.C.

20460

}

l Daar Dr. Ellect:

i j

We are pleased to provida the enclosed comments on the Work Plan of tha Task Forca established by the Esdiation Policy Ce=*ad' to consider the j

('

issue of radon in inhabited structures as published in the June 27, 1980, Federal Resister (45 71 43508-43512). It is currently phnned j

that T7A representativas will actand the regional public meeting scheduled i

for August 5, 1980, in Arianen, Georgia, as also published in the June 27 j

1980, 7ederg g itter (45 F1 43512). T7A will not present oral state-1 monts at the anating regarding the control of radon in inhabited struc-Cures.

i T7A is interested in this issue because it concerns some of our program unas (i.e., energy conservation for housing).

If we can offer any i

l Caehad ~ 1 assistance to the PmMation Policy Council Task Force or in

{

any way participate in consideration of this issue, please let us know.

j In any event, va desire to be kept informed of any futura developments and results of the stadian which the Task Force will undertaka.

1 l

Sincerely, l

i 3,L gjs&Es W W--

t Mohamed T.J -Ashry, ?h.D.

El l

j 6irector of Enviremental Qualit:y i

I Enclosura i

il 4

1 1,

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4 ao sra...e onnermnitv Emotover

i menTS ON RADIATION POLICT COUNCIL TASE ICRCE I

WORE FIAN REGARDING CONTROL OF RADON l.

IN INEABITED STRUCTUEZS (45 FR 43508-43512) i 1.

The Task Force states that "the average level of radon in U.S.

(

homes and the distribution of values abcut this average are very l

oorly 'snown" (Page 435n, column 3, paragraph 3). This implies the existence of a meaningful average background level of radon.

The ussge of such corsa as "anomalously high," "'= ===117 high," and "high" in the Summary of Background Information section of the Work Plan regarding observed levels of radon, also implies that 4 discrete average level exists to make a comparison and subsequent determination. This implication may not be true. 3acisiv e radiation from non-radon related sources varies significantly in the United Scaces. It can be anticipated that the same vill be true for radon; that is, further studies may show that designation c

of a nacional back.4we value is not --Wful.

Extreme caution should be used in designating or even suggescing the possibility of national standards or guides until more data are available regarding background distributions applicable to many specific geographical

[,j areas. Such data should be gathered for both conventional and A

enargy-efficient homes. Further, setting permissible gross (i.e.,

including background) levels on radon and its progeny in specific geographical areas without full consideration of the impacts of setting a similar level to be applicable nationwide does not appear to be justified.

2.

It is presumed that health effect estimates will be cade by extrapo-14 ting available data on cancer incidence among miners. Cumulative doses and dose races among members of the general public win be different from those doses and dose rates among niners and are received under different conditions. These differences should be explored by the Task Force in their deliberations on the identified options. This consideration is especially important because of the potential high costs which may be incurred by various groups and individuals to meet any radon standards or guides which may be O

adopted. We believe that the number of instances of financial V

hardship could be large.

3.

Pase 43510. Alabama and Neighboring States T7A - The 11 " homes" noted in column 2 for first floors were actuany 5 residences and 6 commercial and/or educational structures. Also, the 73 and 36 percent values listed in the sixth and seventh columns, respectively, are for an (phosphate slag and control) basements. This fact is not obvious from the table.

4.

Pase 43510. last two table columns - To aid in the identification of significant radon and radon decay product levels, it is recommended that the Task Force's position paper include detailed information l

regarding the distribution and range of measured woraing levels (WL) rather than present percentage values above specific working i

levels, such as the percentages above 0.01 and 0.02 WL given in the cable.

i 5.

page 43511. column 2, third eararraph - It is stated that the third

)

part of the Task Force's position paper will discuss "a survey of current Federal Programs." The Task Force should also address programs being carried on or planned by non-Federal groups.

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t.

1 1

@l C R P National Council on Radiation Protection and Measurements me wooomorr avesus. suna tote, wasumnon. c. c. :osta aman caos (zu est.assa r

wannes K. SNC'.AM. headme i

svusn i. mace.: u.o vise henswa

w. accan May.zassuow airosar July 17, 1980

~

William L Iliset, Ph.3.

Office of ladiation Programs AME-440 U.S. Environmental ? otection Agency Washing 1;on, D.C.

20460 Daar Dr. Ellect; 31s is in response to the request for c:mments that appeared in the Federal legister, Triday, June 27, 1980 on tha subject of radon in inhabi:ed struc=ures.

i i

The NCIP has undertaken a study of a closely related subject and, as a resul: of that study, the NC2P would lika c: offer the at. ached comments. I: is unfort.:nate that, due to :he tne constraints placed upon the work of your task forte, we are not a51e to offer a wra refined and scre complace set of comments but ! 5elieve : hat :hese commen:s say l

prove helpful in your work.

t 7ec: of the whole problan of radon in

[

There is one rery 1:q.

inhab1:ed st::crures that needs

. eat deal of emphasis. The results of l

('I our studies emphasize che fact : hat great care onzst 5e exercised in deter-l aining radon concentrations in dwellings :o avoid hasty and imprudent action on the Basis of other than annual average 7erki=g I.avel dece d -

acions. I: is essential that results 5e obtained on :he basis of average annual levels. Tour Federal Register notice implies. hat this will be the casa.

f If there are questions or if you need more i= formation plus contact us.

Thank you for this cpportuni:7 to c mment.

l Sincer y yours,

_i v

(

am s A. Spahn Staff Assistant l

i enclosure I

JAS/kak

] Ib 1

t l

O L

3CIP Basponse to Federal 3agister of 6/27/80 Raquest for Public Caumeent en Baden in Inhabited Structures 1.

Introduction It is important to use the icnowledge gained through the uranium mining experience to predict lung cancar risk which could arise through a particular env1.mtal practica. Since radca daughters are ubiquitous and slavated exposuras of individuals or relatively large groups are possibia, it is desirabia to also quanticate the risk.

Elevated rados daughtar azgosures are now reported in association with a variat7 of ordinary cirouestances as well as unusual or occupational settings. Some of chase are: homas that are poorly ventilated (especially single family dwellings where living spaca is close to the soil); basammar=; crawl spaces with no concreta foundation; areas adjacent to or homas built upon uranium zill tailings; homas that ara supplied with raden-rich watar; and homas naar phosphaca-rich areas kl or naar phosphate taili tss pilas, to name but a few. As more measurements of natural radioaccirity are performed, it will be necessary to establish whether specific situaticus are colarshia with regard to lung cancar risk. The following model has been developed so that individual azposures may be assessed.

2.

predictive Model 3ronchogenic lung cancar induced by long exposure to alavated levels (a few hundrad working level months or more) of radon daughtars in underground mines is voll established (T.andin el g.,1971; Snihs,1973; Save Ac, A.,1976; Kuns and Seve,1978; Azalson and Sundell,1973; t

Archer g g.,1979; Iuns g g.,1979). 3ased upon tha. exposures described in the Federal Register notica, normal environmental azgosures s

could be near 0.2 EX per year resulting in lifetiza exposure of 85 x 0.2 =

17 ' JIM. Snihs (1973) considers that the icwast underground exposure V

which :ssulted in an apparant increase in lung cancer deaths is about if WCf. Sons argue that lung cancer mortality in minars at these icw levels of azposure is not significantly diff arant from azpactad (Stavart,-

1979) and that a threshold for radon daughter-induced lung cancer azists.

Archer a_c, g. (1979) conclude from their analysis of 18 different

• g populations in different countries dat, if a threshold axis s, it is below the range from 20 to 30 WI2.

hs, the possibility exists that environmental or slightly elevacad radca daughter levels do not induca lung cancar.

he data feca the higher sina expcsures might be used to estimata possibla lung cancer ratas at low radon daughtar levels, but many d_ mas the temporal eceditions for mining versus envircumancal azgosura (duration and age at first exposure) naka it difficult to relata the two directly.

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In spite of the difficulties, this approach has been taken here and by others (Stranden,1980; Cohen and Cohen,1980). Spontaneous lung cancer mortality (nonsmoking related) offers some guidance since the model should not produce a lung cancer incidence that is greater than observed for ordinary background levels of radon daughtera, na present model is relatively simpia and yields results that are consistant with the &.se d mining experience. Me andal is based upon the information about lung cancer enumerated below dich appears reasonably certain. ne confounding effect of smoking is censidered later.

A.

ne highest reported rate of appearance of lung cancer attributable to radon daughters appears to occur at low

~

exposure rates (< 0.01 ET.) and is 50 x 104 per year per W12f. At higher exposure ratas (% 1 WT.) the d etdance is

[.

less than one-balf this. One average value of this risk L'

coefficient (10 x 10** per year per WIX) was obrai"*rf by estimating lung cancers in a group of uraniun ninors without regard to exposure rate or age at start of 4

exposure (Iuss el A., 1979). ne average value of 10 x 10 per year 9er *JI2 is recommended at this cima.

3.

na rata of appearance of lung cancer after a single external radiation exposure seems reasonably uniform with time. Supporr for this c=mes from the Japanese A-bomb data (3eebe g g.,1973).

C.

ne appearance race for a singis azgosura is highest when age at exposure is highest (3eebe e,e, g., 1973). 21s is also seen in t

the C:echoslovakian mining data folloving azgosure ce radon daughtars over an extended period (Seve el g.,1976).

D.

ne incidence of lun s cancar before he age of 40 is very

~(. !

low (Saccomano 3 g.,1974; Israel and Chach4nian, 1976).

E.

ne median age associated with lung cancar appearance in miners is about 60 in nonsmokers and 50+ in smokers regardless of the age at first start of mining (Ar=har g g.,1979).

7.

Rados daughtar-induced lung cancer rarely, if ever, appears at less than. 7 years after exposure (Archer g al.,1979).

G.

na time for e.nnor growth from bizarre esils cc frank appearance is about 5 years (Sacc=mano g g., 1974).

1

i

~

-3 Raissland et d. (1976) orded*=t ty proposed a model specifically t

for the appearance ** 1eukemia in a population occupational 17 exposed to chronic external r=d4=*f =. h annual appearance ste of tumors attributable to a single esposure was assumed constant and casamenced after a constant latent interval. h modal for lung cancer developed here is based on this idea, but diffars in two ways: one, the incidence does noe sanifest itself until age 40 regardless of the age at exposure, and after age 40 a minimum single value for the latent interval of 5 years applies; two, the tumor rate is not uniform with tima but is corrected from the cima of exposure by an exponencial factor with an effective half-life of 20 years. h ananal appearanca rates following a 31agia exposure, first at age 20 and then at age 45, are shown schematically in figure 1.

S e uncorrected races are shown in Curves (a) and (b) and the corrected rates by Carves (c) and (d).

^

l, i/

w-h exponential factor is justified by assuming that a repair or loss half-ttoa esists for stem calls that ars =ansformed by alpha j

radiation (Earlay and pasternack, 198C). By using this approach, and l

correcting the attributable =1sk for each yesr subsequent to exposure wi.h a 20 year half-life, the a=t aat =ced lifettaa riska agree well with those observed in the uranium mining studies, including the fact that miners first exposed at age 40 have a higher lifacima lung cancer risk than those first exposed at age 20. De lifacima risk of lung cancer calculated here is also corrected by an appropriate life table value to account for the slight reduc.1on in lung cancers due to death frem other causes.

It is not strica.17 possible to check the performance of tha =odel with natural background exposures to radan daughtars. na model sculd proj ect, however, that about 20 percent of the spontaneous (nonsmo'aing) l lung cancer incidence could be at=1buted to natural radon daughter

'NY l

exposure.

l 3.

Lifstime Lunt Cancer Risks frys Medal predictions h e basic data from the underground ~4ad*g epidemiological studies cannot be applied directly to env1:ccmental situations. Be common factor, however, should exist in the risk per rad for bronchial dose, ne lifetias lung cancer at=ibutable to an absorbed dose of 1 rad, using the conversion factor of 0.5 rad /W121 estimated for siners, as well as lifetime risk for chronic exposure to 1 rad per year, have been calculated. *abia 1 shows the results of these calculations for exposures

4 1,. -, -.

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I TARI.E I l.IFETlHE 5.44W3 CABN WR RISK PER NAll PER VEAR FRiti IRAll0N DAUCHTER EIr0sultE. I.IFETIHit RISK AS A Futti:TidWi t, HF At:E AND BHillATION OF EXFHSINtE.

l.4forjaa 1. sung Cancer Niek I4nsa Cagcars de lgroxiira_._

Ana== rar c x seaa r=

a rar..iassai

[

herat lose i

10 20 30 40 50 60 70.

of 105 rarmosis"

,1

l I Year 9.2 x 18-5 1.3 x 10-4 1.8 m 10-4 2.'6 m 10-4 3.0 m 10-% 2.4 x 30-% 1.8 m 30-% 5.0 m 10-4 IS i

5 Yeese m 4. 8 x 10-4 7.2 x 50-4 9.8 x 10-% l.4 x In-3 1.5 x 10-1 1.2 x 10-3 7.8 x 10-4 4.0 m 10-%

94 i

~3

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-3

-3

-3

~3 in vunre B.8 m 10 1.6 x In 2.2 x 10 3.0 x 10 2.8 m.34 2.0 m 10-3 1.3 x 10 5.4 m IS i ISO

~

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-3

-3

~3 10 Vaas a 4. 8 x in 6.8 x 10 7.8 x 10 7.8 m 30 6.0 x 10 3.6 x 10 1.8 x 10 5.4 x to %

540

-3

-2

-2

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-3

.l f e I..'l x lie-1.3 x 10 1.1 x 30 g,3, yg 6.4 m 10~3'3.8 m (0 1.8 x 10 5.4 x 40 I 804 I

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'For a populat lou ulati age clearact erlatica espsal to tisat les alia ideala finite.I States in 1915 l

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beginning at ages 1, 10, 20, 30, 40, 50, 60, and 70 years for durations of 1, 5, 10, 20, and total to age 85 years. Sinci..he ages vi-4d* an i

i exposed group vary, it is also of interest to k=ow the lifstima risk for a population with age charactaristics lika chose of the United States.

his is shown in the last columet of Table 1 using he 1975 age distribution for the U.S. GiEO,1978).

Bronchial dose has only recently been estimated in envi.otnaantal exposures, herefore, two other 11dettaa risk tables are derived from Tabla 1 that relate to the measured enviroinnental quanticias, W13 and 222 n/m3 E

radon concentration in pCi na average environmental dose conversion factors for the adult male, femels, ten-year old child, and infant are 0.71, 0.64, 1.2, and 0.64 I

rad /%U respectively. D e differences refleer primarily reduced l

breathing ratas under normal environmental conditions, different lung l

morphometry, and the increased percentage of unattached RaA in ord1=ary atmospheres. nus, an environmental exposure is expected to be somewhat more produe:17e of c.smars than an occupational exposure where tha factor 1s 0.5 rad /ku. De rystem can be simplified considerably if we accept l

the environmental dose couversion factor of 0.7 rad /ku. ne lifectas j

risk estimated for venen or that which includes ha aff act of.he higher i

dose conversion factor in childhood is within 10 percent of that adopetsg l

the factor for adult mains at all ages. De lifetima risks per environmental

• u per year are shown in Table 2 for the conditions given with Tabla 1.

a r

For the case of exposure measured as rados concentration and ti=a, the average annual bronchial dose to adult sales from the daughters associated l

2222n/n3 can be calculated as follows:

1 vich 1 pCi i

y, d** #***

") = 0.0005(hours eer day acche) + 0.0002(

)

i

('i Dese(#*

per 3

24 24 i

voar r

a Assuming 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per day are active and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per day are spent resting, rad oci 222,o j

0.00027 3

i.

Dose

=

year l

l

l t

' Art.E 2 f.IFETillE I.titWi CANCliN RICK lillDER DeVillDHilEntrAl. COHillTIDHS PER WJi Fell YEAR. 1.lFETillt RISK AS A FileN:TI(Ni nF r ale Allll IMINATIIMI HF EXPOSilNE l.lfet ama I.usig Cancer Risk laing Cancers in i-1

sporure Age at Faret Eugesure a Populatton e

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'la 40 50 60 70 of lo

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1.1 x in 1.5 x 10 2.1 x 10 2.0 x 10 3 4 x 10 9.1 x 10 "

3.8 m IO "

l'80

~

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in Yazia 3.4 x 10

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4.2 x 10 2.5 x 10 1.3 x 10 3.8 x 10 "

380

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.l f e 9.4 x 10 9.8 x 10 7.7 x 10 7.7 a 10 4.5 x 10 2.7 x 10 1.3 x 10 3.8 x In "

560

~

For Ex.lon.Innalia era meaanreil uniler environamentet rather alian unilargroenut mining conditions.'

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'For a populat Ion ulti ago characteristica esgual to that in the whole finiteel States la 1975.

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As with the 'au calculacions, the values for women or including the effec:

1 of the different dose conversion fac:or for 1Manca and children are vi:*

10 percent of the valus calculated by using the factor for adult salas C n/n5 3

for Table 3 shows the lifacine risks for annual exposures to 1 pC1 the condicicas given with Table 1.

]

4.

Guidelines for Populacion size for Ezvesure in Soecial Situacious The reciprocals of the lifacima risks in Tables 2 and 3 are esc 1macas i

of the 12e o( che population which can be exposed to atther 1 W7.2 or

~

A PC1 ad per year for the various environmental exposues incarvals to produce ona ~t eat = cad lung cancar facality. These populacion stas esetascas are shown in Table 4 1

1K.

Tor a specific exposure, the population size is calculated from ha j

i j

11. facias risks cabulated using 1

i Population Sisa

=

M j

D 4

j vhers (L2)3 Lifetiza risk for the appropriate exposure duracion, D,

=

under consideration. 11f ac1:na risk is obtained from Tables 2 and 3 and degZ n) pon exposura uni:

ends u chosen a

R

('au per year or ci 3

I Exposure from a given environmental practica, Eider E =

3

'au per year or pC1 ~3n/a, whichever is available.

4

(;

l The conserrative

==vd population size calculated here should allow aan l

only a small risk of including the one lung cancar.

i Tables 1 to 3 have been developed w1:hout regard to differences becueen i

smokers act,consmokars. Azalson and Sundell ().968) repor: that, for a l

small number of lung cancer cases developing in sinc-lasd siners in Sweden, j

j

he lifacine risk for nonsmokers actually appears to be higher than for smokars.

• he average eine of appearance of :he tumors in smakars, havever, 1s about 9 years earlier.han in nonsmokars. This possible procac:1ve affect of smoking is now supported by dogs exposed :o radon daughcars vi h j

and vi:hout cigare::a sacka. Azalson sud Sunda11 (1968) cen=ac17ely ascribed his to the procsetive affect of a chickened nucus bar-d ar in :he airways, buc suggescad hac, ones ini:1acad, the promotional effect of i

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tobacco smoke causes :nnors to appear fastar. Archer el g. (1979) indicate that this effect may also be evident in the U.S. data, but at present the results are not clearcut. The modal could be adapted on this basis to allow for a longer c:nnor growth tima for nonsmokars than 5 years and a slightly lower risk coefficians chan 10 x 10-4 per year per WLM for smokars, but not enough data are available J model with any certainty. Cat 11 mora data become available, the predictive model applied hers should provida a conservative estimata applicable to smokars and nonsmokars.

3.

' Summary The model developed hare is intended to utiliza che lung cancar

,e experience obtained in epidemiological studies of underground miners

.")

e at high levels of raden daughter exposure to extrapolata to environmental levels. It is not known if this approach is valid, but it does allow an upper limit estimata of lung cancar production. The cricazion for the modal is that it should fit the existing underground mining lung cancer data well. A modal that expresses' lung cancer risk triiformly with tima after exposure (with the restriction that t nnors do not occur either hafore a 5-year latent incarval or age 40) and corrected from year of exposure by an exponential factor which accounts for c=""i-repair and an appropriaca life table value to account for competing risks of death, satisfias this criterion. Lifetime lung cancar risks per rad, per WT.M/ year, and per pCi C an/m3 are then readily cabulated for diffarant exposure incarvals and are given in Tablas 1, 2, and 3.

The "M== population size that should be exposed to a particular raden daughter level resulting fren a specific practica whila allowing cely a small risk of producing a lung cancar is shown in Table 4 V

l i

i

.=

I I

s

^

leferances 1

i Archer, -T.E., Radford, Z.?., and Azalson, O. (1979).

"ladon daughter cancer in =an: Factors in exposure responsa relacionship," page 324 in Conference Workshco en I.ung Cancer Emidemioloev and *ndus:-tal Acelica:icas of Sout :s Cvtalosv (Colorado School of F.ines Press, Golden, Colorado).

Axelson, O and Sundell, L. (1978). "P.ining lung cancer and smoking," Scand. J.

Work Environ and Health 4, 46.

i 3eebe, G.W., Kato, E., and Land, C.E. (1978). " Studies of the mortali:7 of Ar-bomb survivors.

6. Sfortality and radiation dose, 1950-1974," 1mM ac.

l Res. 75,138.

f f'

Cohen, A.F. and Cohen, 3.L. (1980). " Tests of the linearity assumpticu i= -J:s dose-effect relationship for radiation-induced cancer," Health Phys. 38, 53 Harley, N.E. and ?asternack, 3.S. (1980). "A model for predicting lung cancer risks induced by environmental levels of rados daughters," Esal:h Phys. (in press) i Graal, 1. and Chachinian, A.?. (1976). lung Cancer, Naeural Eistorv, Precosts and *heraer (Acadenic Press, New York).

Lm2, E., Seve, J.,

Placek, 7.,

and Ecracek, J. (1979).

"'.ung cancar in uan in i

relacion :o differe=c :1=a distribution of radiaciet exposure," Heal:h ?hys. 36,699

(

Kunz, E., and Seve, J., (1978). " Lung cancer mortali:7 in uranium n1=ars (nethodological aspects)," Heal:h Phys. 35, 579.

Lundin, R.E., Jr., Wagoner, J.K., and Archer, 7.2. (1971). Radon Daughter Excesure and Resotratorv Cancer Quanticactre and Tammeral Ascacts, National 1

haticute for Cc:upacional Safety and Heal:h, National haci:uce of hvtren= ental Esalth Science, Joint F.onograph No.1 Ciacional Technical hfor=ation Servi:n, 5pringf121d, 71rginia).

Reissland, J. A., Kay, ?., and Dolphin. G,*J. (,1976). " ~he cbse:-ration and ans.1 sit 1 cancer deschs amcus citssified radiaci:n workers," ?h s. F.ed. 31:1.

7 21, 903

I i

t 1

Saccomanno, G., Archer, 7.E., Auerback, 0., Saunders,1.F., and 3rennan, L.M.

G974). "Sevelopment of carcinoma of the lung as reflected in exfoliated enlis,"

Cancer 33, 256.

Seve, J., Kunz, E., and Placek, 7. (1976). " lung cancer in uran 1=n niners and long term exposure to radon daughter products," Esalth Phys. 30, 433.

Snihs, J.0. (1973). "The significance of radon and its progeny as natural radiation sources in Sweden," page 115 Noble Gases, Stanley, R.E. and

.Moghissi, A. A., Eds. Nacional Invirenzental Rasaarch Center Report C::NF-730915 (National Environmental Research Cancer, Las Vegas, Nevada).

Stewart, C.G. (1979) verk in progress.

m r

s Stranden E. (1980). " Radon in dwellings and lung cancer. A discussion," Health Phys. 38, 301.

WHO (1978). '4crid Health Organ 1=ation. Egrid Heal:h Stactseics Annual, Geneva.

j l

l 1

l

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'O IW2 CCLCAACC DEPARTMENT OF HEALTH Ricaard O. Lamm bW[

Frank A. Traylor. MO.

1 Governor J87O Executive Cirecter l

1

., ]

July 21, 1980 i

W1114 mm H. Ellatt, Ph.D.

i

'~

Task Force t'h=4 -

Office of Radiation Programa ANR-460 U.S. Environmental Protection Agency Washington, D.C.

20460

Dear Dr. E11att:

I am vriting to you in reference to the Federal Register notice Friday,

. Tune 27, 1980,.regarding the Rmdiscion Pelicy Council Task Force which you chair.

My comment to you tagarding the topic char you are to address is that the impact of radon in drinking water on concentrations

• sit"" struc-

[

)

tures should be included in your afforts if you have not already done so.

Best personal regards.

Sincerely, G

/

%.c. C A %

M.Alberr J. Hazle,, Director I-

' Radiation and Hazardous Wastes Control Division M'd:bjv cc: Hall 3ch11nger, Louisiana N

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4210 EAST 11TH AVENUE CENVER.COLORACO 80220 PHONE (303) 320--8333

i ENERGY CONSERYM10N k CONyROL e

SYSTEMS, INC.

i William S. Geiger Joyce P. Geiger July 21, 1980 71111am H. Ellett, PhD.

Task Force Chairman Office of Radiation Programs, ANH-MO U. S. Environmental Protection Agency W==M wton, D. C. 20MO

Dear Sir:

I support the Radiation Policy Council decision to prepare a position paper on radon control.

This information is urgently needed because of the inconsistent federal actions and public misconceptions involving radon and low level radiation exposures.

%..)

The actions undertaken to reduce radon exposures from uranium mill tam afs and the EPA recommendations to the Governor of Florida are not only very expensive, but also have added to the media and public misunderstanding of the effects of low level radiation and the significance of the " action levels".

On the other hand, the Federal Weather 12ation Program - Invironmental Assessment acknowledged potential adverse effects from increased radon,and other pollutants, but they were not quantified and were ignored is the conclusion and recommendations even though the potential risks from radon exposure, based on the EPA model, appear to be much greater for these conservation programs than the cases requiring corrective actions!

The proposed position paper sheuld help alleviate such inconsistent approac=es by various agencies in the government.

n, The use of the " Working Level" unit as a primary exposure guide-v line should be discontinued.

It could continue to be used as a derived control level, for example as an alternate to "Maximus Permissible Concentration" values for each isotope for radon and its daughters in air.

The consistent use of radiation exposure units (Rem) would help alleviate-public and media misconceptions and provide for improved perspective by permitting direct com-l parisons with other exposures including such items as the con-troversy over venting of krypton gases from the Three Mile Island Plant.

More specific comments on the Federal Register are as follows:

Tack-4 cal crobl=es

'"he notice discunses techad cal problems including azisting

- '\\ '/

instrumentation, average levels, the distribution of values,

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741 Wecei!! onve Lakeland. Florido 338c3 _

Phone 813/e" "5?

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and the fact that raden levels in a hcme "varr considerably depending on a host of factors".

The existing data have not addressed these other variables except in very general terms.

For example, the Federal Regf. ster of June 2!+,1976 used "high ventilation area", and this notice uses " energy efficient hcuses" and " doors and windows closed".

Additional sampling of this nature would be of little or no value even with " perfect instru-l mentation" because of the increases being incurred by the current energy conservation weatherization measures.

The existing

" average values" and data on the effects of ventilation rates is adequate to determine the average exposure and potential risk from radon exposures for a range of scenarios.

1 Research should concentrate on controlled experiments rather than massive sampling of homes.

In this way, the effects of the significant parsmeters including source terms and ventilation rates can be quantified and measurement techniques standardized.

C~

Data such as the following wculd provide valuable information for evaluating alternative methda of controlling raden expensures:

rose Medain radon and progeny by isotope dust particle size free ion fraction verking level conversicus

. adult parameters cM'd parameters m sk Assessment dose vs. risk model comparisons and perspective

( 'l historical concer incidence and variations s

sacking historical household risks falls fire and explosion drowning electrical location (transportation requirements) floods, tornados, lightning, etc.

poisons space heating crise and violence Seu-e e mens soil rados emissions rates scil type / area radius concentratt.cn external gn=na radiation correlatiens

i 1

3 Material radon emission rates Structural materials phosphate slag aggregates fly ash gypsum board phosphate by-product Decorative tiles rock, brick, etc. (firep3s:o) jgeial-volitical Paoblims The Federal actions in Grand Junction and the recommenda-tions to the State of Florida have only added to the confusion and misunderstandings of the public and have provided material

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for sensationalism by the media.

Editorials and comments in the Florida newspapers questioned the difference in action levels from the Surgeon Generalk recommendations and ask for a deter-misation of the " safe level".

The IPA public seeting in Eartow, Florida was a dissappointment.

Members of the public, whose homes were involved in the surveys, stood in line to get i

"the number" for their home and compare it with their neighboni8r and the proposed IPA action levels while wating for,an IPA cfficial from Washington to arrive to make a presentation.

After apprcximately two hours, it was announced that the official would not be able to make the trementation at the =eeting.

Then, several tec5md cal presentations were made that dealt with radiation and the home surveys.

Ebwever, sost of the public and sedia had left the meeting, having given j

up on the official's attendance.

The " technical presentations" for the few re==d-d"g ;eople appeared to only add to the already G existing confusion.

v The establishment of mandatory action levels based on workding levels, fails to recog=1:e.that the risk estimates are based on the " linear hypothesis" and that no " threshold effect" has bee:

found for icw level radiation exposures.

Further= ore, consddering the host of factors affecting the "workd ng level" or risk in any home, the current practice of just seasurt g the wor'ed g level is totally inadequate, unenforceable and could centribute to the j

victd'd:ation of hcme owners.

The expenditure of vast suns of federal soney, or privata =aney if =andated by rsgulation, to reduce the seasured working level to comply with an arbritary Id"dt for the pur;cse of reduc 1=g the cancer risk is incong: lous with the facts that about 25% of the would have 1: sis =petulatics U .ficant reductions in this rate. There is =uch d

get cancer and that such efforts greater potential benefit for -=-ted,d by spending the =ccey c:

cancer research.

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i Since the " life style" of the occupants of a house has such a great effect on the WL, practices of withholding mortgages, as sectioned in the notice, based on WL measurements alene, i

should be stopped.

Seearate measurement of source terms, venti -

l 1stion L rates, etc. would provide sore useful information and a better comparison of buildings.

l Recommendations j

Federal actions concere.1sg indoor radon exposure should be of an advisory nature without mandatory action levels.

Guidance should be developed on the relation of,the source terms, i

ventilation, and other parameters on the radon and progeny concentrations or '#L.

Dose and ris!.models and risks assessments of other household hazards should be presented for comparison and to support any roccamended levels or guidelines.

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In this manner, alter =atives for obtaining acceptable risks can be evaluated in a logical manner and decisions concerning additional conservation seasures or corrective actions can be made on a rational basis.

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Respectfully submitted, b

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F 17 d am S. Geiger

?!SG: 3g Copies to:

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- 'j Govern;;or Robert Graham, Tm17 mhamsee, F1.

Congressnan.Andy Irelanc, Lakeland, F1.

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U.S. Radiation Policy Council os-J7 Executive office of the President u==h4atton, D.C.

20500 Statement of: Anthony V. Nero, Jr., San. Fr=ne4 = o, July 31,1980

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address:

Yentilationand Indoor Air Quality Program I

h4lding 90, Boom 3058 Lawrence 3erkaley Laboratory 4

Berkeley, CA 94720 The Ememetan Policy Council has an important and difficult charge'.

in its responsibility to help the United States rationalize its h=ad14a!

of radiacion exposure questions. Existing or potential radiation exposures arise in a variety of contexts. It is important that the regulatory struc-l ture be designed to handle this variety of situations in a consistent manner, N}

that corresponding =d=4n4errative responsibilities be given to the appro-priate anchorities, and that the underlying program of research to elucidate actual or potential effects of radiation be effectively coordinated. In addition, the Radiation Policy Carmeil should consider carefully the role it might play in education of the public on the nature and extent of radia-tion-related risks. This will certainly be difficult, since for essentially no risk can it be'said that public information is adequate, so that it has been exceptionally difficult to establish a context for public consideration of radiation-related risks.

These remarks apply for the most parr to the full scope of the Radiation Policy Council. They apply in particular to the area being con-sidered by the task force on indoor radon, to whihh I will devote the rest n

of my comments. The verk of this task force is extremely important since

- it now appears that the most significant portionof natural radiation ex-m posures may occur from this one source, i.e., from exposures of the general 1

V public to radon daughters in their own homes. However, effective control of chase exposures is made difficult by the lack of a regulatory philosophy fci.

indoor air quality and by limited information both on the radon levels that oow exist and on the methods that eruld control these levels. Furthermore, the limited data available on the effects of rather large integrated expo-l sures to rados daughters on 3%ers, i.e.,

some associated risk of lung con-car, does not land itself very directly to estimation of the effects of~

long-term exposures of the general population to typical indoor levels.

However, it is important to note that there is mouncing evidence to suggest that a significant portion of the population receives lifetime doses that are more typically associated with uranium miners than wi-$- background expo-sures of the general public. Whatever percentage of the population receives doses in the occupational range, whether 1% or 5%, these people deserve special attention. Further, it appears that the bulk of the population ex-f posure to radon, including that at high levels, occurs in ordinary houses, i

not cues associated with special industrial activities, not houses that have exceptionally lov air exchange races.

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That the bulk of the exposure should occur in ordinary situations poses a regulatory problem of a different kind than has been dealt with be-fare, either for radioactivity or for other conen=4nants. The fact that we are sepaking of the interior of private d==114=s, rather than of air I

basins, poses a different kind of question than has been f aced in the formn-lation of outdoor, so-ca ned ambient, air quality senad=eds.

Generany

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i speaking, the latter standards are designed to set limits on population ex-posures, i.e., those in an air basin, but - except for limitation of occupa-tional exposures at relatively high levels - standards have not been designed to limit the risk of asch individual. A fundamental difficulty with limiting individual risks per se, is that they will depend on the habits of the indi-l l

I vidual.

l Furthermore, standards per*=4adas to radiation in particular have generany evolved in a rather different context chan that to be considered j

i for indoor radon. Much of the structure for developing and imp 1===nedng standards has been designed for the case where r=d4.=_-14 des are made by i

humans or are encountered in occupational contexts, where the exposure arises l

from some industrial acitvity,and - usuany - where the risks and corres-

. rending control costs are relatively sea n compared with the value of the activity. Because of the comparatively sean risks, it is often possible to j

adope-a relatively conservative attitude about the level of acceptable risk j

or, to put it in another way, about the costs that ought to be incurred to l

avert the presumed risk.

Most of these faterable circumstances are absent in the case at hand.

l The radiation of concern is not only natural, it. occurs in every home, yor

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most cases, the source is not an unusual industrial activity, but the soil

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under the house or the materials of which it is constructed. And, for the higher levels encountered, the apparent risk is substantial, so that control

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measures might be considered even at great cost. But even for the typical case, tha risk may be high enough that a " conservative" regulatory approach j

is probably not appropriate. Rather, realistic appraisals must be made of I

the radon risk and of other costs and benafits, some of which win inevitably not be quantifiable.

l Having anuded to " typical" and " higher" concentr=Na, it is un-fortunately difficult to be much more specific about the levels to which l

the U.S. public is exposed, or in fact about the corresponding health effects.

It can be said that typical houses have daughter concentrations of 0.001 to 0.02 WL.

However, many appear to have concentrations considerably above this range, perhaps even in the vicinity of 0.1 WL or greater, pressing the occu-pational dose limit. It can be sai.1 that long-term exposures at the occupa-tional dose limit yield increased rates of lung cancer. Whether the same is true at more typical levels is highly uncertain, although a linear res-pense to low levels is typicany presumed for regulatory applications where a conservative stance is appropriate. But too little is known to make firmer statements.

For this reason, a vigorous research program is required to more fu ny characterize existing concentratiocs, including their range and distribution, to better understand the dependence of health eff acts on, both levels and the i

i lj exposed population, and to determina the effect of possible control measures.

A number of efforts have been addressing apsects of these questions, in some i

l cases for many years. However, although many efforts are proceeding at uni-versities, EPA laboratories, and DOE laboratories, this diverse effort requires i

good comunication, willing cooperating, and careful coordination. I an j

heartened at the commmmication and cooperation among the researchers on in-l l

door raden. But, the Radiation Policy Council should

=*==4'= carefully how affective coordination of existing efforts can be ensured and how work on j

j key areas not adequately covered can begin, presumably Wma= on eziscing i

capabilities. The resources for performing the important work on this question are rare, in terms of both people and laboratories. Duplication should be i

avoided and, I should add, a proper balance maintained between large field j

survey work, snell field tests, instrumancation development, and - at the

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base - laboratory research' to understand what is being measured and how con-l trol techniques work, i

Effective design and implementation.of the necessary research pro-p j

gram, with both short-cara:and long-term objectives, requires at a =4n4== a f'

tachnical advisory group, as has been suggested, I believe in the task group 4

3 on radon. Consistent diligence will be required for any coordination mech-an4== to meet imediate, and seemingly urgent, needs while maint=4afat ade-quate emphasis on investigation of basic questions that require, not only of-fort, but time. It may be appropriate to consider an indoor Indon institute that would carry out part of the needed work, but would have an added respon-l sibility for integration and coordination. This would help to keep the lous-term goals in view, while =4 4*4*ing duplication and time. As for the seem-l ingly urgene goals, I am confident that - with the pressures under which the j

f ederal agencies work - sufficient emphasis will be placed on "immediate" i

l needs.

One of the apparent immediate needs is to identify that portion of the population living in tha higher livels, i.e., those getting the "occu-pational" doses to which I referred. Improving their situation will require w

a standard that limits the exposures of individuals.

On the other hand, the population as a whole requires some level of protection, so that the average risk ought to be controlled, possibly to an order to magnitude lower level j

than the individual risk limit. I am, frankly, very uncomfortable, for con-captusland practical reasons, with the tendency to set limits in the vicinity of 0.01 - 0.02 WL that are supposed to apply to every individual. On the l

other hand, designing programs that assure that average exposures are at this level or lower appear practical. In particular, they would not depend on minor variations in construction practica and on lifestyle of'the occupant, and they could rationally be area dependent, whereas a standard to control individual exposures cannot.

In looking at the proposal work of the indoor radon task force, I i

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vas disappointed to find that the fundamental question of regulatory approach, j

i.e.., developing a conceptual or philosophic basis for indoor air quality standards, was nowhere mentioned. In particular, the question of individual l

versus population-average limits has to be examined. This notion is fam4 H ar in radiation protection, but not in the sense neant here, where it is difficult i

to set a low-level standard that pertains to every individual simply because 50 nillion environments are involved and because a standard that is set with one occupant of a structure say not be net when a different occupant novas in.

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A specific possib47dty that needs to be consideredi's that mentioned o

above, 4..a., adoption of a high-level individual id=4t, icwor than the occu-pacional dose limit, coupled with a program to control population exposures j

to an even lower level on an average basis.

An. operational trigger level for remedial action would be chosen to be some. fraction of the individual limit consideting vai-4 =h41dty from house to house, measurement uncertainties, and so I suggest this approach be considered by the task force in its position on.

paper, by the EmA4meion Policy Co mc11, and sitimately by those who recommend indoor air quality standards.

The question arises who =ha=1A actually be charged with the respensi-bility for fo 1=e4rg any standard on indoor raden.

It is clear that the Na-3a** ~ = 1 Ce- -41 on '-84=edr= Protection and Measurements, with its long his-tory of such work, should be a kay participant in the process. However, if the ECIP is given the main responsibility for r--

- 44ag a standard for adoption, it should be reminded of the differsacas between the case of indoor radon and the cases where industrial operations azpose the public to san-esde radia-a14Acc

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st-levels that are relatively easily controlled. Moreover, the structure of

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any standard should be consistant with the developing approach to indoor air quality standards in general.

I an afraid that I have suggested a difficu*. requirement for the task force on radon and, in turn, for the full Council, i.e., before we go about settius standards, we deedda what they are supposed to do.

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OCT 6 1980 Honorable Maz 3aucus United States Senate Washington, D.C. 20510 l

Dear Senator 3ancus I

One of your staff investigators, Mr. Nare Smolensky, has raised a number of goeotions regarding the signifiaanse of rades exposures of the U.S. population in a recent assigned ammersedum directed to the " Office of Indiation Programs Staf,f.'

k, As Chief of the Sranch responsible, among other charges, for the planning and coordination of.CIF activities for evaluating and coutrol-ling indoor exposures of the U.S. population to radon, I offer the following in response to his questions:

1.

What is the risk to the U.S. population fr a indoor radsaf Dr. Ellett, who is our principal authority on radiation bionifacts, has responded to yee seperstely on this aseter. These risk estimates are not news they have been used 'in our regulatory program for several years and have been sehjestal to careful review by the Agency's carcinogen Assessment Group. Specifically, the IPA Administ=stor's guidance to the Goverzer of Florida for protection of inhabitants of

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houses on reclaimed phosphate land (4A F.1. 38664, July 2. 1979) and the t

Agemey's interim final standards for cleanup of uranium mill tailings under the Uranium Mill Tailings Radiation Control Act of 1978 (UMTICA)

(45 F.1. 17366, April 22, 1980) were each based on the same risk coeffi-cients for rados that were used to generate our estimate for the U.S.

populacios due to indoor rados. The latter estimate has provided the basis for our comearn and ongoing discussion vita the Department of Energy en the Residential Conserwtion Prorran (RCS) (see the enclosed letter fr a David Hawkins to h h a Savitz, December 19, 1979). DCE comeurs with this concern and we are making good progrees in jointly developing appropriata safegeseda in the ICS program to avoid exacerbating indoor rados exposure.

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Is rados exposure a national emergency?

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Is CEF saving lives by rapidly initiating a program os rados esposure & controls?

These are matters of definition and judgment. Se estimated size of the current and potential future annual impact of indoor rados espesure has been addressed by Dr. Ellett's letter and I cousar with those estimatas. Congress expressed its concern for one source of radon esposure (uranium mill tailings) by passing UMTICA in 1978..In additica, DOE regulations to implement the RC3 program were close to i

final premalgation when the CEP program effort wee launched, and thus i

required a rapid response from us in order to be influensed in a timely l

way. I hava supported the decision to rapidly initiata a comprehensive program on radom because I believe exposure to rados is a radiation v

protection problem of major and national significance, and that both the

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b ongoing and potential future om,nat impact of radon on the U.S.

population would be reduced by timely action on our part.

4.

Is CIF using the best possible contrastors to study rados?

CIP has, en the best of my knowledge, consistently sought and l

used the best qualified innstigators and instientions knees to us for each of the various subjact areas in which we have sponsored work on t

rados. That is not to say that other qualified investigators and institutions do not exist. "3ent possible" is an elusive concept and it is always possibis to second pse such judgments.

5.

How does rados get into the savi m e?

Rados is a radioactive gas produced by tie decay of radium, an el===ne that is present in maall quantities in out soils and geological formations. It is also found in significantly elevated cencentrations in some cres, such as uranitus, thorius, and phosphate cree. 1sdon gas migratas from underlying soil (and from some building satorials) into houses, where it builds up to significant levels. In a few sections of the country rados in tap water (principe117 from deep' wells in granitic formations) can be an additional searca of indoor radon. Levels of rados in almost all indoor environments can be expected to be higher than normal outdoor levels. Our kacwledge base for indoor levels is summarised in the recent Task Force. aport to the Radiation Policy Council enclosed in Dr.111stt's latter to you. The buildup of indoor rados is mitigated by normal lankage of outside air into housest hence our concern for not sealing up houses to an extreme degree for energy conservatica purposes. In the out-of-doors, rados levela are generally low because of stzing into the large 'rolume of air in the atmosphere and the prevailing movement of air masses scross the continent and out to sea, where redon decays harmlassly.

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In summary, I believe that it is reasonable to ass es that the i

i current impact of indoor rados espesare on the U.S. populatica is l

significant, that it could become considerabIy worsened by inappro1miste energy conservation measures, and that protection of the public health from this hasard serits our urgent attention.

I hope the above comments and emelosures are helpful.

• If yes or l

your staff have further questions, I can be reached by phone at (703) i 557-4927.

Sincerely yours,

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( f's Allas C.3. Richardson, Chief I

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General Radiation Standards 3 ranch

,critaria & Standards Division (AM.~MC) office of Radiation Progr es

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3 Inslosuree

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ces Mr. Stevens, Office of Legislative Affairs, IPA i

Mr. Smolossiry l

,Dr,Reseabana (B R-458) 1 i

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