Comments on: Discussion Topic 4, Updated dose/risk factors and scenarios for assessing radiological and non-radiological risk.

By: bcourter

bcourter — Mon, 25 Oct 2010 11:29:27 +0000

Your detailed thoughts on these matters are particularly useful, especially with respect to dose and risk assessment, scenarios, toxic impacts of the metals and other daughter products, updates in radiation protection science, and implementation aspects of the regulations. Recycling of radioactively contaminated materials from mills was an especially important issue when Congress wrote UMTRCA and we appreciate the comment on piping.

We are reviewing changes in regulatory approaches and policy for regulatory agency implementation concerning the direct measurement of concentrations in addition to dose/risk levels, and appreciate your concern.

By: Phil Egidi

Phil Egidi — Thu, 23 Sep 2010 05:25:01 +0000

UMTRA and the implementing regulations were promulgated at a time of 500 mrem/y public dose limits. The 1983 EPA EIS estimated about 130 mrad/y at 5 pCi/g Ra-226 using default occupancy, etc. One has to really tweak the models to get 5 pCi/g Ra-226 under 100 mrem/y in a residential scenario (the West Valley memo rings a bell). Considering that the EPA limit on release of other rad sites is 15 mrem/y > background, it would appear that 5 pCi/g > background is no longer protective. The 15 pCi/g subsurface limit should be dumped because it is not health-based.

The radon limit also should be revisited based on BEIR VI and other more recent work.

EPA should consider BEIR VI, VII and FGR-13, and ICRP 103 in its review. Cancer morbidity as well as mortality, age-adjusted DCFs, etc found in FGR 13 point the way for EPA to update the UMTRA

UMTRA does not have surface activity limits, which is difficult for those of us who work in the field. Not all contamination is in bulk soil or groundwater, contaminated piping from the old mills is still found often in CO, and we have to adopt other standards e.g., ANSI N13.12 to control surface contaminated residual radioactive material.

There are no supplemental standards for Title II, which is a deficiency. If one can get an ACL for groundwater, why can’t we get them for soil that can’t be effectively remediated?
If an area cannot meet the concentration-based limit, but can meet today’s dose- or risk-based limits, that should be protective.

A concentration-based criteria should be derived (again) based on residential risk, and retained as the primary standard. Since that value will be near background for radium-226, EPA must also consider what can be measured at a reasonable cost. 3 pCi/g > background may be a starting point for discussion.

Ingestion of Po-210 should be revisited since the fsub1 value changed so much in ICRP60 et seq.

Since site-specific risk-based limits are derived based on scenario, the possibility exists (and has come to pass) that the site goes from recreational (very low residence time and high residual radioactivity) to occupational or residential use. The site is no longer protective under the new scenario, and it may go undetected. This can pose a real problem that can be avoided by applying a generic concentration-based standard under all scenarios. It will keep things simple, and not place such a reliance on institutional controls, which are not always durable.

Endpoints other than cancer should be reviewed, including cardio-vascular insults. There has also been a recent paper describing elevated radon progeny levels in the brains of Parkinson’s and Alzheimer’s patients.

By: bcourter

bcourter — Thu, 29 Jul 2010 16:37:06 +0000

Thank you for your input. EPA has not yet decided to propose a revised regulation. We are at an early stage of the process and are still reviewing the existing regulations to determine if changes are necessary. If this review determines that the Agency should go forward with draft revisions to the regulations, we will prepare a detailed cost-benefit analysis that will examine the issues you raised. This cost-benefit analysis would be made available to the public for review and comment. If you have any additional information and references you might wish to provide to us on the economic topic you have brought up, we encourage you to send us an e-mail at UraniumReview@EPA.gov. Thanks again for participating in our review.

By: bcourter

bcourter — Thu, 29 Jul 2010 13:56:31 +0000

Thanks for your recommendation! We have added the National Academy’s report, as well as EPA response to it, to the Library of Documents.

By: David Miller

David Miller — Wed, 28 Jul 2010 17:26:55 +0000

Please include an economic analysis of your proposed action. Increasing regulations will result in a lower standard of living for all people, including children, in the affected area. Does the lower standard of living result in a more harmful health effects to the population than allowing the uranium processing facility? and the resulting higher standard of living because of the high paying employment offered?

By: Stanley J. Waligora Jr., CHP

Stanley J. Waligora Jr., CHP — Thu, 22 Jul 2010 16:45:50 +0000

Another important report to consider is the EVALUATION OF GUIDELINES FOR EXPOSURES TO TECHNOLOGICALLY ENHANCED NATURALLY OCCURRING RADIOACTIVE MATERIALS, Board on Radiation Effects Research, National Research Council, National Academy of Sciences, 1999.