4900

                                                             54019874
                 U.S.  ENVIRONMENTAL  PROTECTION  AGENCY
          REPORT TO  CONGRESS ON INDOOR AIR POLLUTION AND RADON
                                 UNDER
                                TITLE IV
          SUPEMUND  AMENDMENTS AND REAUTHORIZATION ACT  OF 1986
                    X
                               April 1987
                                        U.S. Envlreftffi&fital ProtettfcW
                                        Region V, Library
                                        230 South  Dearborn
                                                Illinois  60604

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                                INTRODUCTION
     The purpose of this document is to fulfill the requirement set forth
in Title IV, Section 403(d) of the Superfund Amendments and Reauthorization
Act of 1986 (SARA), that the Administrator or the United States Environmental
Protection Agency (EPA) submit to Congress a plan for implementing indoor
air and radon research programs within the Agency.  In light of the Agency's
current schedule for reviewing research needs and developing a long-term
research program in indoor air, this document does not present a final
implementation plan for indoor air.  Rather, EPA is responding to the
90-day statutory deadline by providing Congress with the following infor-
mation:

     1-1 Background information on the Agency's involvement in indoor air
       quality problems and EPA's current policy for addressing the overall
       problem of indoor air pollution (Chapter 1);

     0 The activities, both programmatic and research, underway to formu-
       late a long-range indoor air program (Chapter 2); and

     0 The Agency's indoor radon program, which includes a detailed des-
       cription of EPA's research and programmatic activities (Chapter 3).
                                       r
     A detailed plan for implementing an Agency-wide program on indoor air,
including a description of the multi-year research program which will
support the Agency's indoor air efforts, will be forthcoming in the near
future.

     Regarding the Title IV requirement that the research programs in
indoor air and radon be reviewed by the Agency's Science Advisory Board (SAB),
a brief discussion follows.  The radon research program recently has been
submitted to the SAB.  The Agency's indoor air research program will  be
submitted for further review by the SAB at the time it is reported to
Congress.  This program was reviewed by the Indoor Air Quality Research
Review Panel of the SAB in September, 1986.  At that time the panel was
presented with ongoing EPA research in indoor air and a plan for conducting
a review of the current state of knowledge in the field.  The panel was
asked to assess the relevance of current projects and to comment on the
adequacy of EPA's proposed "research needs assessment" (RNA).  Panel  members
concluded that the indoor air research program being conducted by EPA was
of high quality and had contributed significantly to the overall understand-
ing of indoor air pollution.1  They recommended that the Agency move forward
with its plans to develop an RNA and that the scope of the study be expanded
to include areas of research not traditionally associated with EPA such as
1 A copy of the SAB report can be found in Appendix A.  EPA's detailed
  response to the SAB report can be found in Appendix B.

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the effects of microbial  pollutants indoors.  Moreover, the panel  urged
strongly that the Agency  develop an indoor air policy, and clearly  define
its program and objectives.  This report to Congress is a major step forward
in articulating the Agency's position on indoor air.

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                           CHAPTER I:  BACKGROUND


A. HISTORICAL CONTEXT

     When the Clean Air Act was amended in 1970, the air pollution problems
of greatest concern to the nation were out-of-doors.  The "mounting dangers
to the public health and welfare," as described by Congress in Title I,
were perceived to be caused by "urbanization, industrial development, and
the increasing use of motor vehicles...."  Consequently, the law that was
intended to protect and enhance the quality of the nation's air resources
gave EPA authority to control a wide variety of air emissions sources and
air pollutants that contributed to the degradation ot ambient air.  EPA
interpreted the term "ambient" to apply to outdoor air only.

     The quality ot the indoor air was not mentioned in the law.  At that
time, except for studies of specialized environments like submarines, space
capsules, and the industrial workplace, virtually no scientific research
had been done on indoor air quality.

     However, in the early 1970s, indoor air pollution received increasing
public attention when the Government instituted energy conservation meas-
ures. During this time, formaldehyde was identified as the cause of acute
irritant reactions, primarily eye and nose irritation and respiratory
distress, in individuals living in homes insulated with urea-formaldehyde
foam insulation and in mobile homes constructed with large quantities of
particleboard and plywood.  This led to additional research to assess the
types and quantities of air pollutants found in various indoor environments,
all of which came to the same conclusion: pollutant concentrations were often
much higher indoors than they were outdoors.  Furthermore, when high exposure
levels were coupled with the fact that most people spend more of their time
indoors than outdoors, the risk to human health from indoor air pollution
was shown to be potentially greater than the risk posed outdoors.

     As the general problem or indoor air pollution was drawing more and
more public attention as a potential health hazard nationwide, a particular
type of indoor air poilution--radon—was causing immediate concern in
particular parts of the country.  Epidemiological studies of underground
miners had established a link between exposure to elevated levels of radon
and the development of lung cancer.  In the late 1960s and early 1970s, EPA
had investigated homes in Grand Junction, Colorado, contaminated by uranium
mill  tailings, a byproduct of uranium mining.  The elevated radon levels
found in those homes led to the issuance ot the Surgeon General's guide-
lines regarding remedial action in houses built on or with uranium mill
tailings.

     During the 1970s,  EPA also investigated instances of elevated radon
levels in houses built  on reclaimed phosphate mines in central Florida.  In
1979, EPA issued guidelines to the State of Florida for remedial action in

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existing homes and for new home construction.  In 1983, the Agency began to
clean up, under the Superfund program, a number of homes in New Jersey that
were built on industrial radium waste sites.

     National attention was focused on the problem of indoor radon in 1984
when a worker at a nuclear powerplant in Pennsylvania was found to be liv-
ing in a house that was contaminated by extremely high levels of radon.  In
that case, the radon was being emitted by the natural soil  on which the
house was built.  Subsequent investigations revealed that thousands of
homes in the Reading Prong, a geological formation that runs from Pennsyl-
vania through New Jersey and into New York, were contaminated by naturally-
occurring radon.  Public concern over the potential  health  effects of radon
exposure, and the realization that such exposures could be  occurring over
wide areas, led to the establishment of EPA's Radon Action  Program directed
specifically at the indoor air pollution problem caused by  radon.
B.  RESOURCES

     In fiscal years 1982 and 1983, Congress appropriated S500K each year
specifically to EPA for research on indoor air quality.  Eventually, a
total of approximately W million was appropriated -- including roughly $2
«ni hon per year in FY 1984, FY 1985, and FY 1986.2  Of the monies spent in
FY 1984 and FY 1985, approximately $400,UOO was spent to conduct research
on mitigation technologies for radon.  In FY 1986, $1.6 million, in addition
to the $2 million for research on indoor air pollution, was appropriated
for radon mitigation research.  The resources set aside for radon research
were supplemented by $200,000 in FY 1984, $310,000 in FY 1985, and $2.4
million in FY 1986 for programmatic activities associated with radon. A
detailed list of resources is provided for fiscal years 1984-1986 in
Appendix C.


C.  CURRENT EPA POLICY

     The Agency's policy with respect to indoor air pollution does not
differ from that for pollutants found outdoors—that is, to protect human
health from undue risk of exposure to environmental pollutants.  The goals
of EPA's programs in indoor air pollution and radon are to:

     0 Identify the nature and magnitude of the health and welfare prob-
       lems posed by indoor air pollution; and

     0 Reduce the-risk to human health and productivity from exposure to
       indoor air pollutants.
2 The projects funded with these monies are described in the "Indoor Air
  Quality Research Plan" prepared by the Interagency Committee on Indoor
  Air Quality (CIAQ), and submitted to Congress in August 1986.

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     The strategy for implementing these goals employs the following four
approaches: (1) emphasizing non-regulatory actions to address the problem;
(2) encouraging State and local governments to play an active role in all
aspects of goal achievement; (3) coordinating and encouraging the efforts
or ot'ier Federal agencies which have responsibility and authority with
respect to indoor air; and (4) coordinating Agency activities with the
private sector.

     While the Agency's program in controlling exposure to indoor radon
gas is already well underway (see Chapter 3), we are just now in the process
of designing a program which will address those aspects of the indoor air
problem which are not directly related to radDn and will be the subject of
a subsequent report.


D.  CURRENT EPA MANAGEMENT STRUCTURE

     The Office of Air and Radiation (OAR) and the Office of Research and
Development (URO) share the responsibility within EPA for developing and
implementing the indoor air and radon programs.  During the SAB review of
the Agency's indoor air research program in September (which excluded the
radon program) concern was expressed over the need for strong leadership
and a clear internal management structure.  In partial response to this
concern, a subcommittee on indoor air has been established within the
Agency's Air and Radiation Research Committee to coordinate future research
efforts with the Agency's policy goals.  The subcommittee is co-chaired by
representatives from ORD and OAR and reports to the parent committee.

     OAR and ORD also have established internal management structures to
respond to the SAB concerns.  OAR has primary responsibility for developing
the Agency policy on indoor air quality and managing the programmatic
activities in this area.  Within OAR, programmatic responsibility for the
overall problem of indoor air pollution has been delegated to the Office of
Program Development (OPD).

   From one perspective, it would be reasonable to assume that a program
specifically targeted to radon would be administered as a subset of an
overall indoor air quality program, since many of the issues (e.g., building
ventilation rates and exposure times) and much of the research are applic-
able to both.  In fact, EPA considered administering its radon program as a
subset of its indoor air quality program, but concluded for the following
reasons that there was considerable merit in managing them independently.
First, indoor radon is more easily characterized than the more general
indoor air pollutton problem, and second, the magnitude of the health
problems caused by radon have demanded an immediate and ongoing EPA re-
sponse to reduce exposure.

    Because of the unique nature of the radon problem, OAR has assigned
internal responsibility for administering the radon program to the Office
of Radiation Programs (ORP), which had already developed the technical
expertise in this area. The Agency is currently establishing a new division

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in URP specifically to address tms problem.  Since both tne indoor air and
radon programs are managed within OAR, the information and experience
gained from the radon program has been and will  continue to be valuable in
guiding the indoor air program as it matures.

     URD has the responsibility for developing the scientific data base to
support OAR's programs and to advance the state of knowledge on indoor air
pollution, including radon.  ORD's research program on indoor air is a
multidisciplinary effort spanning several ORO laboratories.  To facilitate
internal ORO coordination ot this program, an individual within the Office
of Health and Environmental Assessment has been placed in charge of the
program.  He reports directly to the Assistant Administrator for Research
and Development on this issue.  His primary responsibilities include:
(1) developing the peer-reviewed RNA; (2) developing a long-range research
program which incorporates prior SAB recommendations and the findings of
the RNA, and which responds to the policy guidance being developed by OAR;
(3) co-chairing the ORD/OAR subcommittee on indoor air; and (4) serving as
the principal contact on interagency activities.  Support for these tasks
is provided through a management structure that includes both laboratory
and headquarters personnel.

     The radon mitigation research program originally was considered to be
a subset ot the overall indoor air research program, but is now managed
separately by the Office of Environmental Engineering and Technology far
many ot the scientific and programmatic reasons discussed previously.
E.  CURRENT COORDINATION EFFORTS

     Within EPA, offices other than OAR and ORO have responsibilities
related to indoor air quality.  For example, the Otfice of Policy, Planning,
and Evaluation (OPPE) has the general  responsibility of reviewing and evalu-
ating policy developed in the' program offices.  The Otfice of Pesticides
and Toxic Substances (OPTS) has the responsibility of regulating pesticides
and toxic substances, some ot which are used indoors and thus may contribute
to indoor air pollution.  Because of the involvement of several  EPA offices,
an intra-agency ad hoc task force has  been established to help develop EPA
policy and program strategy, and ensure that Agency-wide policy  related to
indoor air quality is consistent.

     To provide a mechanism for internal coordination for its Radon Action
Program, the Agency has established the Radon '^ork Group and the Radon
Management Committee, which are comprised of staff-level and senior-level
management officia-ls, respectively, from the various headquarters and
regional offices within EPA.  These groups provide advice and guidance to
the program and the Administrator on various aspects of EPA's radon program.

     Federal  coordination is provided  through the Committee on Indoor Air
Quality.  This interagency committee:  (1) coordinates research on indoor
air quality:  (2) provides for liaison  and the exchange of information on
inaoor air quality among Federal agencies and with State and local govern-
ments, the private sector, the general  public, and the research  community;
and (3) develops Federal responses to  indoor air quality issues.  It is

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comprised of fifteen Federal  agencies,  with EPA,  the Department  of  Energy,
the Department of Health and Human Services and the Consumer Product  Safety
Commission as the co-chairs.   It is subdivided into nine workgroups,  one  of
which focuses on radon.

     The SAB provides a peer review function for EPA research activities
related to indoor air quality.   The SAB has a separate Radiation Advisory
Committee which reviews radiation-related activities, including  certain
projects within the Radon Action Program.

     Finally, Title IV of SARA requires the Administrator to establish  two
advisory groups.  The first is  to be comprised ot individuals representing
Federal agencies concerned with various aspects of indoor air quality.
It would appear that the CIAQ satisfies these requirements of Title IV.   The
second is to be comprised of individuals representing the States,  the
scientific community, industry, and public interest organizations  to  assist
the Administrator in carrying out the indoor air quality research  program.
EPA is now considering how best to constitute such an advisory group.

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                     CHAPTER  II:   INDOOR AIR POLLUTION


A.  GOALS

     The goals of EPA's indoor air quality program are to:

     IJ  Identify the nature and magnitude of the health and welrare
        problems posed by indoor air pollution; and

     0  Reduce the risk to human health and productivity from exposure
        to indoor air pollution.

8.  STRATEGY

     EPA's program to achieve these goals will be geared toward the
identification of significant indoor air quality problems and appropriate
mitigation strategies.  In those instances where significant indoor air
pollution problems are identified, the Agency will select from the following
mitigation tools, as appropriate, for reducing human health risks:

     0  regulation under existing statutory authorities (e.g., TSCA, FlhRA,
and SWOA) in appropriate circumstances.

     0  non-regulatory programs of information dissemination, technical
assistance, guidance and training; and

     u  building state and local  government and private sector capability to
address indoor air quality problems.

     Due to the complexity of the issue, EPA is beginning to adopt a dual
approach for achieving these goals.  Efforts will  focus both on the in-
dividual pollutants and products found indoors, and on the various types of
buildings in which they are found.  Indoor air pollution can be prevented
or mitigated by reductions in levels of specific pollutants emitted by
specific products.  Traditionally, improvements in environmental  quality
have been achieved by controlling these specific pollutants or sources of
pollutants.  However, there is another facet to indoor air quality.  Indoor
air pollution also is a function of the ways in which buildings are designed,
operated, and used.  Thus, a second way to reduce  indoor air pollution is
to approach it as a "buildings"  problem and to change the ways in which
buildings function.  EPA's indoor air quality program will attempt to
address the problem from both perspectives.

C.  HIGHLIGHTS OF ONGOING INDOOR AIR RESEARCH

     The following is a summary  of the indoor air  research program for
FY 1987 grouped by the categories enumerated in Title IV of the Superfund
Amendments and Reauthorization Act.

Identification

     The major activity in this  area has been to conduct a comprehensive
review and analysis of the indoor air pollution literature.  This assessment
includes the collection of exposure data that will be used to model human

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exposure to indoor air pollutants.  An additional product or this review is
the compilation of an exhaustive bibliography of the indoor air literature
with approximately 1200 citations to date.  The assessment recognizes the
multidisciplinary nature of the indoor problem.  With the integration of
exposure and health effects data, priontization ot indoor air problems may
be established.  Integration of engineering, monitoring and health research
activities can then provide a research strategy to address specific
concerns.  Thus, the assessment will guide ORO in developing its long-term
indoor air researJi strategy and plan.  Foremost is the need to characterize
the nature of indoor air quality problems.  Particularly important are
(1) the health consequences ot existing indoor air quality and (2) the
extent to which these problems exist nationwide.  The assessment will
identity those questions, which, when answered by research results, will
allow the Agency to better inform the public about sources of indoor air
contamination, the relative hazard that indoor pollution may present and
the available options for managing indoor air quality.

     An important function ot the assessment is the identification of
research needs to be addressed by EPA.  Additionally, the assessment will
point out those research needs that fall more appropriately to other
Federal agencies to meet, rather than to EPA.  This aspect will enable
the Agency to fulfill its responsibility in coordinating indoor air
research among the several agencies with concerns in this area.

Source Characterization

     Characterization of sources of indoor air pollution provides informa-
tion on pollutant emission rates and the factors influencing them.  Such
information is useful in guiding health and monitoring studies and even-
tually in the control ot indoor air quality by source modification.  For
FY 1937 emphasis is continuing on developing procedures for measurement
material sources.  Additionally, emission factors and emission models
will be developed for organic pollutants from these sources.  Both chamber
study's a.  1 f tast louse will be utilized in these activities.  Among
other purposes, the test house will be used to validate the indoor air
emission models that are based on the chamber studies of combustion and
material sources.  Development of an indoor source emissions data base is
continuing.  This activity is to organize and standardize in a computerized
file the data from research studies of emissions from sources of indoor
air pollutants.  This effort will  make such information readily available
to the user communities of both the public and private sectors.

Monitoring

     The primary focus of research efforts in the area of monitoring is
the development of "tools" to better assess indoor air situations and to
define the magnitude of the indoor air problem in relation to human
health.  Hence, research projects will result in improved sampling meth-
odology and other support for studies in residences as well  as in office
buildings.  Several projects involve sampling devices for indoor air:
evaluation of a sampler for semivolatile organic components, field evalua-
tion ot a sampler for particulates, development of an N02 detector for
personal exposure monitoring, and development of a total indoor air quality
sampling package for VOC's and particles.  In support of surveys of  indoor

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air quality, research will be conducted on screening and source use ques-
tionnaires, while other work will assess the effectiveness of available
screening techniques tor indoor pollutants.  Other efforts include the
completion of a model to evaluate the cost effectiveness of various
mitigation strategies.  We are investigating the feasibility of a joint
study with Canada to develop and demonstrate the methodology for investi-
gating high-risk non-industrial building types ("sick buildings").

Human Health Effects

     Sufficient evidence of human exposure to indoor air pollutants is
available to demonstrate the need for studies to determine human dose and
health effects.  Incomplete combustion products such as polycylic aromatic
hydrocarbons and many volatile organics from both combustion emissions and
building materials are recognized as human or animal carcinogens.  Conse-
quently, human exposure to these compounds both individually and in mixtures
in indoor air is of great concern.  The major combustion emissions of
concern are environmental tobacco smoke (hIS) and emissions from com-
bustion appliances (unvented heaters, wood and coal  stoves, gas stoves
and cooking).  In particular, our studies and others have suggested that
ETS is the major source of mutagens in indoor air.

     FY 1987 studies will continue to characterize the genotoxicity of these
combustion emissions and to develop biochemical or biological markers to
assess the exposure and dosimetry for indoor organic pollutants.  Combus-
tion sources being evaluated include kerosene heaters, gas stoves and ETS.
The mutagemcity of the emissions from these sources will be evaluated in
laboratory chambers, model homes and pilot field studies.  Biochemical
and chemical marker methodologies will be developed for the mutagenicity
of combustion emissions (e.g., kerosene heaters).  Biological markers
will be developed for hTS, one- such being the physiological excretion of
cotinine, a metabolite of nicotine.  Neurotoxicology studies include an
important replicate experiment to confirm or not confirm the results of a
study of Danish homes that found health effects in humans exposed to
volatile organic compounds in indoor living environments.  In the area of
respiratory toxicology, one study is looking for evidence that children
and adults exposed to concentrations of N0£ and tobacco smoke which are
similar to those experienced in the home might be associated with acute
or chronic disease processes.

Control Technologies, Other Mitigation Measures

     Mitigation efforts have involved the characterization of particles
regarding their physical  and chemical characteristics so that the optimum
design of filters and electrostatic devices can be evaluated and tested
for their cost-effectiveness for indoor air situations.  Alternative
designs to increase removal  efficiency of respirable particles will be
explored, developed and tested.  Options to be investigated include:
new/improved filter materials, pretreatment particle conditioning, and
advanced ESP and fabric filter designs.  A similar approach is underway for
adsorption devices for the removal  of organic vapors from indoor air.  The
research on adsorption will  be followed by evaluations of catalytic oxida-
tion and absorption.

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Demonstration Methods

     With the restructuring of its indoor air research program and the
mandate provided by Congress through Title IV, SARA, ORO is developing a
long-term strategy and plan for indoor air research.  As evidenced by the
foregoing summaries of research activities, the resulting program is con-
sistent with the intent of Congress.  Because of the nature of the FY 1987
program, to better understand the nature and extent of the problem of
indoor air pollution, it is too early to conduct demonstration methods for
reducing or eliminating indoor air pollution.  Such programs will certainly
follow as a consequence of the mitigation efforts described above.

     However, a major project is planned for FY 1987 to demonstrate monitoring
techniques in preparation for a larger study of the distribution of exposures
to indoor air pollutants.  This study is the result of the reassessment by
ORD of a proposed limited field survey to characterize indoor air quality
in the United States.  In agreement with the review by the Science Advisory
Board, ORO will not conduct the previously proposed survey and has, instead,
planned this "demonstration" project.  The study will  test indoor air
quality measurement methodologies and will relate exposure and microenvi-
ronmental measurements to those of outdoor fixed sites.  The study will be
conducted in phases, beginning with a test home, then progressing to a field
study or selected homes (less than 10) and then to a larger selection of
residences.  The results from the study would assess the exposure aspects
ot indoor air quality, especially addressing the measurements of exposure
distributions as related to specific sources.

0.  IMPLEMENTATION PLAN

     A draft of Volume I of the Research Needs Assessment, the compilation
of current knowledge on indoor air, underwent review by a group ot some 40
experts assembled at a workshop at Harvard University in January.  A final
document incorporating their comments and recommendations will be available
for review by Congress and the SAB in the near future.

     Volume II ot the Research Needs Assessment, an identification of
information gaps as a result of assessing the current state-of-the-art in
indoor air, will provide the guidance for a longer-term research implementa-
tion plan.  We expect to be able to deliver a preliminary version of this
plan to Congress shortly.  However, we expect to review these research
needs more broadly, sharing them with the other members of CIAQ, the
technical/scientific community, and representatives of interested private
and public sector groups.

     The Office of Air and Radiation is now planning a program to develop
and disseminate information and guidance to State and local governments,
private sector organizations, and the public.  The subsequent report to
Congress will  include a more detailed discription ot activities envisioned
for the indoor air program.

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                         CHAPTER III.  INDOOR RADON
     Radon is a radioactive gas produced by the radioactive decay ot radium-
226, which occurs naturally in almost all  soils and rocks.   Radon is present
in the atmosphere everywhere due to its release from radium decaying in the
ground.  Outdoor radon levels generally are low.   Typical  indoor levels are
usually about five times higher than average outdoor levels, but can be
over ten thousand times higher.  Exposure to such elevated  levels may
greatly increase an individual's risk of developing lung cancer.  Further,
since everyone is exposed to radon in buildings,  it is believed that radon
substantially contributes to the incidence of lung cancer in the United
States.  The Environmental Protection Agency and  other scientific groups
estimate that from about 5,000 to about 20,000 lung cancer  deaths a year in
the United States may be attributed to radon.  (The American Cancer Society
expects that about 130,000 people will have died  of lung cancer in 1986.  The
Surgaon General attributes around 85 percent ot all lung cancer deaths to
smoking.)

     While the Reading Prong area of Pennsylvania, New Jersey, and New York
is the best known high-radon area in the United States at this time, indoor
radon is potentially a widespread problem.  Elevated radon  levels have been
found in houses in many States—not only where suspected geological factors
or the presence of uranium deposits suggest that  radon might be a problem.
Preliminary data indicate that perhaps more than  10 percent ot the approxi-
mately 85 million homes in the U.S. may have radon levels reaching or exceed-
ing four picoCuries per litar—the level recommended by EPA as a target tor
corrective action.  This level was based on both  health considerations and
on the limitations ot current technology in reducing radon  levels below
this target level.
A.  GOALS

     In response to growing concern about elevated indoor radon concen-
trations in houses situated on the Reading Prong and those located else-
where, the EPA Administrator established the Radon Action Program in
September 1985.  The goals of EPA's Radon Action Program are to:

     0  Determine the extent of the problem.  Information is needed not
        only on the "hot spots" in the United States, but also on the
        distribution of radon levels in homes throughout the country.

     0  Reduce exposure to radon in existing homes.  The development
        and demonstration of cost-effective mitigation techniques will, it
        is hoped, eventually enable homeowners to correct a radon problem
        as easily as they might correct a water or electrical  problem in
        their home.

     7  Prevent radon problems in new housing.  By addressing the problem
        in new construction .is well as in existing houses, the potential
        risk to people who live in new homes can be reduced and consequently,
        the national average concentration ot radon in houses can be lowered.

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B.  STRATEGY

     EPA lacks clear statutory authority to prescribe what homeowners should
do about radon.  Moreover, it does not appear that a regulatory approach is
suitable to deal with this naturally-occurring health hazard.  Consequently,
the Agency is pursuing its objectives, not by the usual regulatory means
(except that it has recently proposed standards for radon in drinking water
under the Safe Drinking Water Act3), but rather by trying to ensure that
the needed technical knowledge exists and that homeowners, contractors, and
State and local officials have access to it.

     Indoor radon levels can vary greatly not only from community to commun-
ity, but also from house to house.  In addition, the problem areas are
widely dispersed throughout most of the country.  Therefore, the Agency
believes that the primary line of response to the problem should be the
State and local governments and the private sector.  These groups are in the
best position to provide homeowners with the day-to-day support necessary
to understand the problem and reduce the risks.

     However, EPA and other parts of the Federal government have unique
capabilities and expertise to offer the State and local governments and the
private sector.  Thus, EPA has developed a program that provides for .both
information development and information delivery.  The Agency is developing
and disseminating technical knowledge to encourage, support, and facilitate
the development of State programs and private sector capabilities in the
areas of radon assessment and mitigation.  It is acting as a catalyst to
bring together the appropriate expertise and responsibilities of Federal
agencies, the State and local governments, and the private sector.

     The Radon Management Committee (RMC), which is comprised of senior
management officials from the various headquarters and regional offices
within EPA, was established to provide broad policy advice and guidance to
EPA's Radon Action Program and the Administrator.  The RMC identified
priorities for the FY 1987 radon program, and developed the following
consensus ranking of the inost important tasks:

     1.  Identify cost-effective mitigation technology for existing
         houses.

     2.  Assist States in developing programs to help citizens under-
         stand radon-related health risks and take action to assess
         and, if necessary, reduce their exposure.

     3.  Develop information materials that States and private sector
         groups can use to help citizens and homeowners.
3 Volatile radon can be transported to indoor air by drinking water that
  is derived fron some groundwater sources.  The mechanisms for the release
  of radon from drinking water to indoor air include:  showers, baths,
  clothes washers, dishwashers, cooking, and flushing toilets.  The average
  contribution from the drinking water source to indoor air radon levels is
  in the range of one to seven percent.

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     4.  Promote good practices in radon measurement  (e.g.,  use  of
         recognized methods, proficiency in making measurements).

     5.  Develop training courses and materials  useful  for govern-
         mental  and private sector personnel.

     6.  Assist  States in designing and conducting surveys to identify
         high-radon areas.

     7.  Conduct a national survey to determine  the distribution of
         indoor  radon levels and identify the  factors that influence
         such levels.

     8.  Share with States and the private sector all available  tech-
         nical knowledge about radon measurement, mitigation, preven-
         tion, and other key topics, and help  tham learn how to  use
         that knowledge.

     9.  Identify cost-effective prevention technology for new housing.

    10.  Reaffirm or revise the Agency's estimates of the health risks
         associated with radon exposure.

In establishing  this ranking, the Management Committee agreed that  all ten
areas are important in achieving the Agency's  goals and should be supported
to the extent possible.

     The Management Committee also recognized  the importance of  the contri-
butions of other Federal agencies to the overall  goals of EPA's  Radon
Action Program.   Consequently, they recommended  that  a portion of the
Agency's efforts be devoted to working with Federal agencies such  as the
Department of Energy, the Department of Housing  and Urban Development, and
the U.S. Geological Survey.
C.  IMPLEMENTATION PLAN

     To provide a better focus to its  efforts,  the Agency's  radon  program
consists of five major elements and objectives:

     0  Radon exposure and health risk:   To identify areas  with  high
        levels of radon in houses and  to determine the national  dis-
        tribution of radon levels and  the associated risks.

     u  Mitigation and prevention:   To identify  cost-effective
        methods to reduce radon levels in existing structures  and
        to prevent elevated radon levels in new  construction.

     3  Capability development:  To stimulate the development  of
        State and private ^ctor capabilities to assess radon
        problems in homes and to help  people mitigate such  problems.

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                                     -15-
      u   Public  information:   To work with  States to provide informa-
         tion  to homeowners  on  radon, its risks, and what can be done
         about it.

      u   hederal  coordination:  To  take advantage of the expertise,  re-
         sponsibilities  and "resources in this Agency, the Department of
         Energy  (DOE), and throughout the Federal government in addressing
         the  radon  issue and  to coordinate  the  activities of each Agency to
         maximize the effectiveness of the  overall Federal effort.

      The following  discussion describes the tasks necessary to meet the
 objectives of the Agency's  indoor  radon program.  Included in this  discus-
 sion  is  a brief outline of  the progress made to date on each of the activi-
 ties  and a projection of what  remains to be done.  A crosswalk between the
 requirements  of Title IV and the activities of EPA's Radon Action Program
 is  provided  in  Appendix 0.

      1.   RADON  EXPOSURE AND  HEALTH RISK

         (a) Conduct a National Assessment  of Representative Structure
            Types and Geographical Locations

      The Agency  plans to conduct a national assessment to better define the
 distribution  of  radon levels in houses across the country and to determine
 the national  average.   Existing information on indoor radon levels  is
 fragmented and  is very  likely to be skewed because a disproportionate
 number of measurements  have  been made in known problem areas, such  as the
 Reading  Prong.   A determination of the distribution of radon levels through-
 out the  United  States is essential in determining the risk to the general
 population from  indoor  radon.

      A design for the national assessment was submitted to the Radiation
 Advisory  Committee of EPA's  SAB in September 1986.  They offered the Agency
 some  initial  recommendations, and EPA is revising the design accordingly.
 The SAB's final   review  is expected to be completed by mid-1987, at which
 time  EPA  will make the  SAB's final report,  along with any Agency comments,
 available to  Congress.

      The  national assessment is likely to involve 3,000 to 5,000 structures
 randomly  distributed throughout the United States.  In its initial  recom-
 mendations,  the SAB stressed the importance of obtaining a high rate of
 participant return to maximize the value of the survey results.  In addition,
 the cost  of the assessment has been estimated to range from $300 to $500
 per dwelling.  The"se two factors have been  influential  in determining the
 number of houses that will  be included in the survey.   While the sample
size planned will yield   a good picture ot the distribution of radon levels
 across the United States, it will  be minimally useful  in assessing the
factors which influence   those levels, such  as geology  and house character-
istics.

     EPA expects to begin deployment of measurement  devices  in  FY 1988.
Devices will, be  placed in houses for a  one  year period to obtain the annual

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                                    -16-


average radon concentration in each structure.  The survey and the associated
data analyses will take approximately two to three years to complete.

     Another important feature in determining public exposure to indoor
radon is the concentrations found in schools, office buildings, and other
non-residential structures.  The Agency's national assessment is devoted to
private residences, because they are usually the major sources of exposure.
However, EPA plans to look at what data exist for other types of structures
and to conduct a feasibility study of what needs to be done to provide an
indication of the levels in non-residential buildings.  The results of this
study will be provided to Congress in October 1987, in the Agency's report
to Congress mandated by Section I18(k)(l) of SARA.

        (b) Provide Technical Assistance to State Survey Efforts

     While it is important to determine the national distribution ot radon
levels, it is also important to locate areas of particular concern.  The
Agency considered including this objective in the national assessment, but
realized that it would be too resource intensive, and the information would
not be available soon enough to meet the demand to identify high-risk areas.
Therefore, the Agency designed a program to provide assistance to States in
conducting their own surveys.  The objectives of EPA's State Survey Program
are to: (1) find areas of high indoor radon levels; (2) implement consistent
survey methods to assure comparable results; and (3) determine how geology
can be used to predict nigh indoor radon levels.  Assistance offered by EPA
depends on an individual State's needs, but may include survey design,
measurement devices (charcoal canisters), laboratory analysis, etc.

     Ten States (Alabama, Colorado, Connecticut, Kansas, Kentucky, Michigan,
Rhode Island, Tennessee, Wisconsin, and Wyoming) are participating in the
survey program this winter.  These ten states were selected, from a total
of 21 requestors, primarily on the basis of their ability to deploy measure-
ment devices during the 1986-1987 heating season.  Ten is the maximum number
of States that EPA can provide assistance to at one time.  The Agency
expects to eventually provid-i ds>i
-------
                                    -17-


        (c) Develop Models to Predict the Potential  for Structures
            Built on Certain Land Types to Have Elevated Indoor Radon
            Concentrations

     An important adjunct to the survey efforts to identify high-risk areas
is the ability to predict the occurrence of elevated indoor radon levels
based on models.  One can think of this task as a ladder, with the lowest
rung being the ability to predict whether large blocks of land, such as the
northwestern portion of a given State, might cause high indoor radon levels,
The middle part of the ladder would be the ability to predict whether
smaller areas of land, such as individual counties,  might have an indoor
radon problem.  Finally, at the top of the ladder would be the ability to
predict whether an individual parcel of land might cause high radon levels
in a house built on it.  This latter piece ot information is the most
useful, but also the most difficult to obtain.

     The Agency presently has a modest effort underway to identify those
geological factors and characteristics which are most useful as indicators
ot high radon levels.  EPA also is conducting some preliminary work on the
use of soil gas measurements to predict the radon potential for individual
parcels of land.  This technique appears promising,  but is a long way from
being a reliable and accurate predictor of high radon levels.  Ultimately,
work in the area ot hazardous land evaluation should yield a model that can
predict, on both a macro and a micro level, the potential for a particular
area to cause high indoor radon levels.

        (d) Develop Measurement Protocols

     Since many radon measurements are now done by commercial firms, it is
critical that these measurements be comparable and that the public has some
assurance that they are being done accurately.  To meet this need, the
Agency published standardized measurement protocols  in February 1986, for
seven of the most commonly-used measurement methods.  This document was
followed by a protocols applications document in September 1986, which
outlines the procedures for determining where measurements should be made
in a house and under what conditions.  DOE is also pursuing improved
measurement protocols.

     Protocols are needed to ensure that the new devices being developed to
measure radon indoors are used correctly.  In addition, further protocol
applications are needed for specific circumstances,  such as epidemiological
studies and radon diagnosis for remedial action.  Limited work is beginning
in these areas.

        (e) Conduct Epidemiological and Other Health Studies
            to Determine the Link Between Lung Cancer and Radon
            Exposure in Houses

     There are many unanswered questions concerning  the health effects of
radon.  Current risk estimates are based on underground miners; however,
there is a strong need to establish a link between increased risk of lung
cancer and exposure to radon in a residential setting.  In addition, there
are questions about the risk to children and the potential synergistic
effects between radon and smoking.

-------
                                    -18-


     Several epidemiological studies are planned to address these questions.
Two ot the larger studies, sponsored by DOE and the Mew Jersey Department
of Health, are just beginning and will  be conducted in Pennsylvania and New
Jersey, respectively.  It is important  to note that preliminary results
from these studies will not be available for several years because of the
latency period associated with lung cancer.  Preliminary results from the
eastern Pennsylvania study, conducted by Argonne National  Laboratory, will
be available in 3-5 years.

     The Agency is tracking the epidemiological studies now underway, and
is identifying study populations and additional epidemiological research
opportunities to assess the exposure of the general population to indoor
radon.  In addition, EPA and the Nuclear Regulatory Commission are sponsor-
ing a study by the National Academy of  Sciences to review all existing
available data on health risks from radon.  The study report is expected to
be published in the spring of 1987.

     ?..  MITIGATION AND PREVENTION

        (a) Develop and Demonstrate Cost-effective Mitigation Methods
            to Reduce Radon Levels in Houses

     There are four ways to reduce radon levels in a structure:  (1) prevent
radon from entering a house; (2) ventilate the air containing radon and its
decay products from the house; (3) remove radon and/or its decay products
from indoor air; and (4) remove the source of the radon.  The Agency is
conducting a program to demonstrate these various mitigation techniques.

     The results to date have been very promising.  Our experience, thus
far, indicates that the use of techniques that prevent radon entry by
ventilating the radon-laden soil gas from under or around the foundations
Dr from within basement block walls is  effective.  This approach can reduce
radon levels by more than 95 percent, even in houses with very high initial
radon levels (greater than 1000 picoCuries per liter).  The costs of these
techniques are expected to range from $100 to 55,000 per home, with an
average of approximately $1 ,000 per home.  The costs of radon reduction
methods are expected to decrease as more qualified mitigation contractors
enter the market.  Thus, indoor radon levels can be reduced substantially
at a relatively low cost.  Our experience also indicates that the mitigation
schemes are very house-specific, and more than one mitigation method may
have to be used to reduce radon to an acceptable level in a given house.
Finally, methods to prevent radon from  entering a house are most effective
in reducing extremely elevated levels.

     The information gained through research on 18 homes in Pennsylvania
contributed to two Agency publications  in August 1986: "Radon Reduction
Methods: A Homeowner's Guide," and "Radon Reduction Techniques for Detached
Houses: Technical  Guidance."  These publications will be revised in FY 1987
based on additional research in Pennsylvania, New Jersey, and New York.

     For the next several years, EPA plans to continue the demonstration
program in existing homes in the Reading Prong, and begin demonstrations in
States outside ot the Reading Prong to  gain experience in a wider variety
of housing types.   In FY 1987, the Agency plans to conduct demonstrations

-------
                                    -19-
in up to 110 homes in Pennsylvania, New Jersey, New York, and up to three
other States.

     Thus far, the demonstration program has focused on active soil' ven-
tilation techniques.  Most of the houses involved have had high radon
levels (greater than 100 picoCuries per liter).  In addition, some research
has been done on heat recovery ventilators and methods for reducing radon
in household water supplies.  Research on these techniques will continue,
and studies on passive soil ventilation techniques will be initiated.
Future work will be directed towards houses with lower concentrations—
levels in the 4 to 100 picoCuries per liter range--the range in which most
affected houses fall.

     To approach the demonstration program in a systematic manner, EPA has
developed two matrices that enable the Agency to maximize the use ot its
resources and ensure that all the key variables in housing and mitigation
technology are tested adequately.  One matrix has been developed for exist-
ing houses and another for new houses.  These matrices have been reviewed
by the Agency's SAB, which supports their use.  Each matrix includes various
radon reduction techniques, initial radon levels, house substructure types,
important house design features, soil characteristics, and other relevant
factors.  The cells in the matrix need to be filled with a minimum of five
replicates each to achieve the confidence levels that homeowners are likely
to want before they install a mitigation measure in their homes.  EPA's
current estimate is that at least 600 existing homes and 125 new houses
will have to be tested to fulfill this objective.

     EPA is developing and validating diagnostic protocols that researchers,
States, and private contractors can use to determine mitigation approaches
in houses.  The protocols will also help EPA and others to collect comparable
data from those who install and test the effectiveness of radon reduction
techniques in houses.
        (b) Apply and Evaluate Mitigation Methods
     Once mitigation methods have been developed and demonstrated under
 research conditions in a selected number of houses, they must be more widely
 applied and evaluated in a large number of varied housing types under
 conditions likely to be faced by the average homeowner.  To meet this need,
 the Agency has initiated a House Evaluation Program with three objectives:
 (1) to evaluate the cost and effectiveness of mitigation methods in the
 private sector; (2) to train State and private sector personnel in diagnos-
 ing and mitigating radon in houses; and (3) to provide feedback to the
 Agency's mitigation demonstration program.

     In carrying out the objectives of this program, State personnel, in
cooperation with EPA, diagnose a house with elevated radon levels and offer
 the homeowner several alternative mitigation schemes.  In exchange for this
 service, the homeowner permits the State and EPA to obtain data on radon
 levels in the homes after the installation of control techniques.  Thus,
valuable information is gained on the cost-etfectiveness ot the installed
techniques.  An important facet of this program is the homeowner chooses
whether to undertake the mitigation work, and is responsible for selecting
the contractor.  This is a significant difference between the house evalua-
 tion program and the Agency's demonstration program.

-------
                                    -20-


     An additional beneMi: of this project is that it provides "hands-on"
training in radon diagnosis and mitigation to State-and local  governments,
and to private sector personnel, and promotes the use of local contractors
to conduct mitigation work, thus expanding the cadre of experienced mitiga-
tion professionals.  It is also expected that many homeowners  will  attempt
mitigation on their own.  The results of these efforts *ill provide informa-
tion on the feasibility of radon mitigation being conducted by the homeowner,
and will serve to better focus public information materials.

     The Agency has already evaluated approximately 80 homes in Pennsylvania.
During the remainder of FY 1987, EPA plans to evaluate up to another 150
homes in Pennsylvania, New Jersey, New York, and in States that may have
identified problem areas through their survey efforts.

        (c) Develop and Demonstrate Techniques to Prevent Radon Entry in
            New Construction

     A critical element in reducing the health risk from radon exposure is
to prevent radon antry in new construction.  This can be accomplished by
using specific building techniques.  Some research has been conducted in
this area by groups outside of EPA.  The evidence clearly indicates that it
is easier to prevent a radon problem before a house is built than it is to
correct it afterwards.  Thus, the Agency is designing a program for FY 1987
to conduct demonstrations in up to 25 new houses in New York and other
States.  The Agency is trying to situate the demonstrations on land that
has the potential for causing radon problems and where the developer is
willing to build preventive techniques into some of the houses while keeping
others of the same design as controls.  Generally, EPA will build in passive
control measures, but will  make it easy for the homeowner to use active
soil ventilation techniques should they prove necessary.

     The Agency is working closely with the housing industry,  particularly
the National Association of Home Builders (NAHB), to encourage their interest
in this area.  As part of a cooperative agreement, EPA and NAHB are putting
together a pamphlet on preventive construction methods.  This  will  be even-
tually followed-up with a technical manual describing in detail various
construction practices to prevent radon entry.

        (d) Develop Model Building Codes

     The only way to ultimately ensure that prevention/mitigation techniques
are incorporated into new construction practices is through modifications
to local building codes.  Florida has already passed legislation requiring
the use of certain construction practices in houses built in certain areas
of the State.  Other States and localities are considering similar action.
The Agency is working with the Council of American Building Officials and
the three model code organizations to ensure that Agency efforts in the
area of radon prevention are reflected in local building codes.

        (e) Study Fundamentals and Devices

     To assist the field demonstration on radon reduction in new and exist-
ing homes, certain aspects of radon mitigation require laboratory research.

-------
                                    -21-
The Agency is developing methods to evaluate the effectiveness of certain
types of air cleaning systems.  This work will have applicability to indoor
air pollutants in general, as well as to radon decay products.  Additional
research needs include tests of sealants and coatings, and the development
of standardized specifications for mitigation schemes, such as subslab
ventilation systems.  These needs, once met, will greatly enhance the
development of private sector mitigation capabilities.

     3- CAPABILITY DEVELOPMENT

        (a) Provide Technical Assistance to the States

     The objective of EPA's State assistance program is to encourage self-
sufficiency within States as they address radon problems.  The approach the
Agency has taken is to transfer technical knowledge to State personnel and
help them learn how to use it.  EPA will show the States how to do the
work, but will not do it for them.  Similarly, EPA will provide them with
technical support services, but will not offer long-term financial assistance,
This effort has headquarters, laboratory, and regional components.

     The types of assistance EPA provides to States may include:

     0  Designing and conducting State surveys;
     0  Hands-on experience in diagnostic evaluation;
     0  Consultation on development of State programs;
     0  Analytical services;
     "  Training courses and informational  materials;
     0  Communications with affected communities; and
     0  Advice and technical information on radon mitigation.

Many States will require some or all of these types of assistance.

     Table I indicates a typical workload for developing capabilities in a
State.  The tasks range from survey design  to implementing a low-interest
loan program if a State chooses this option to provide financial assistance
to homeowners.  Once a State discovers a radon problem, it must develop, in
somewhat of a step progression, many of the capabilities described in Table 1,
The Agency's experience with Pennsylvania,  New Jersey, and New York indicates
that States will need EPA assistance for two to five years.  EPA currently
is targeting resources to develop the types of capabilities indicated in
Table I in the States affected by the Reading Prong, but is now beginning
to move to States outside that area.  It is likely that EPA will be required
to provide State assistance over the next five to seven years.

        (b) Conduct State Training Programs on Measurement Techniques,
            Risk Evaluation, and Remedial Methods

     There is a great need for training both State and private sector
organizations about various aspects of the radon problem.  The Agency has
developed a "Radon Diagnostician" training  course which has been given
approximately 20 times to State personnel and their private contractors.
The course, which runs 3 days, presents the basics on the physical

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-------
                                    -22-
characteristies of radon, the available measurement techniques and mitigation
methods, and risk evaluation.  The Agency is encouraging the States and the
private sector to take over this facet of the program.  EPA plans to video-
tape large portions of the course to facilitate its delivery by the States
and other appropriate groups, such as universities.

     The diagnostician training course has been well-received and has
highlighted the need for additional types of training.  Since new develop-
ments are occurring almost daily in the radon mitigation field, there is a
need for a one-day follow-up session to update participants on new mitiga-
tion techniques.  In addition, there is a need for a longer course (perhaps
a week) which would focus on actual "hands-on" mitigation experiences.  The
target audience primarily would be construction contractors interested in
conducting radon mitigation work.  There is currently a very limited cadre
of qualified mitigation contractors, and demand for their services far out-
strips the supply.  By designing training courses to be eventually adopted
by the States and the private sector, EPA can increase the number of mitiga-
tion professionals available to provide remedial  services to homeowners.

        (c) Implement a Quality Assurance Program for Radon Measurement

     To reassure the public that radon measurements being made by commer-
cial firms are accurate, the Agency established the Radon Measurement
Proficiency (RMP) program to allow measurement companies to voluntarily
demonstrate their ability to measure radon and its decay products.  To
assist in this effort, DUE shared with EPA its quality assurance facilities
at its Environmental  Measurement Laboratory in New York.  EPA has recently
developed the necessary capabilities at its Eastern Environmental Radiation
Facility to conduct this program in-house.  The RMP program has been quite
successful, and several States are considering using it as part of their
certification programs.

     The RMP program is likely to continue to expand over the next year,
with more vendors entering the market.  The number of companies entering
the market has almost tripled since the inception of the program in February
1986, and it is expected to increase over the next year or two.  Therefore,
EPA has increased the amount of resources committed to this program.
However, at the same time, to conserve these resources, the number of
rounds of the program offered have been reduced from four to two because of
the large number of participating companies.  Although the number of firms
may eventually taper off, the need for the RMP program will continue well
into the future.  The Agency is evaluating whether there are other feasible
funding options.

        (d) Issue Technical Guidance

     Many Agency activities generate technical information that is extremely
useful  to the States and the private sector.  This information must be
packaged and distributed in a timely fashion for these groups to benefit
from it.  In August,  the Agency published its "Radon Reduction Techniques
for Detached Houses:  Technical Guidance." This manual will  be revised and

-------
                                    -23-


updated in FY 1987.  In addition, the Agency is preparing technical  guidance
for new home construction in cooperation with the NAHB.  There will  be a
continuing need for these types or technical documents as new strides are
made in the field.


        (e) Establish a Federal Clearinghouse for Information on
            Assessing and Mitigating Exposure to Indoor Radon

     A recent report issued by the U.S. General Accounting Office indicated
the need for a Federal clearinghouse on radon.4  Such a clearinghouse would
collect and distribute information and research produced by the public,
private, and academic sectors on radon.  Because of the increasing volume
of data, there is a growing need for a central collection point for informa-
tion related to health effects, measurement data, radon prevention and
mitigation techniques, etc.  While the Agency recognizes this need as well,
it has had to place a higher priority on first generating and disseminating
information to assist the States and the public.

     4. PUBLIC INFORMATION

     There is a continuing need to work with the States to provide home-
owners the information necessary to help them understand and evaluate the
radon problem.  An effective public information program is an essential
component of EPA's approach to indoor radon.  Last August, the Agency
published two brochures, "A Citizen's Guide to Radon: What It Is and What
to Do About It," and "Radon Reduction Methods: A Homeowner's Guide."  Both
are aimed at helping the general public understand indoor radon.  These
brochures have been adopted by a number of States and private sector organi-
zations.  Similar types of brochures directed at specific audiences or at
other aspects of the radon problem are needed to supplement existing mater-
ials.  The Agency is also working with private groups to develop educational
materials or workshops for their members.   In addition to these activities,
the Agency expects to participate in various symposia, workshops, and
public meetings.

     5. FEDERAL COORDINATION

     There is an active Interest on the part of other Federal agencies to
evaluate the problem of elevated radon concentrations in homes.  The Depart-
ment of Energy and the Department of Housing and Urban Development (HUD)
have particular interest in the effects of  radon on the indoor environment.
DOE's energy conservation activities are balanced with efforts to assess
an.1  i«i, ijii-; the eTfect of conservation on  indoor radon levels.  Further,
DOE plans to enhance its radon basic research efforts in 1988 and is devoting
an additional $10 million in the areas of health and biological effects and
geological studies;  EPA and DOE have cooperated in a research project on
4 Indoor Radon Air Pollution, Government Accounting Office. GAO-RDED-86-170,
  June  1986.

-------
                                    -24-


radon mitigation diagnostics.  A copy of DOE's Radon Research Program Plan
is attached as Appendix E.  A draft memorandum of understanding between
EPA and DUE on radon research and related technological  activities is
in its final  form.  HUD is mandated by statute to ensure that all  HUD-
assisted projects are located in sate and healthful  environments.   In this
context, HUD is interested in developing inexpensive and effective mitiga-
tion techniques for new and existing houses.

     These different agency concerns have led to the formation of  several
forums for the discussion of the indoor radon problem by interested Federal
agencies.  The CIAQ has a special workgroup to develop a coordinated Federal
response to the radon problem.  EPA and DUE co-chair this group, which has
prepared a document which outlines the indoor radon  issue, assesses current
Federal research efforts, and identifies priority information needs.  These
priority tasks are consistent with those identified  in this implementation
plan.

     In addition, the Committee on Interagency Radiation Research  and
Policy Coordination (CIRRPC), under the Office of Science and Technology
Policy (OSTP), is examining the radon issue through  its  Radon Subpanel,
which has reviewed the Federal government's activities on radon.  The
results of its findings are contained in "Radon Protection and Health
Effects" published in August 1986.  CIRRPC consists  of representatives from
18 Federal agencies and a subcabinet level representative from OSTP.  It is
responsible for coordinating radiation matters among Federal  agencies,
evaluating radiation research, and providing OSTP with advice on issues of
radiation policy.                   -

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                          APPENDIX A
    \          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
     5
    *                        WASHINGTON, O C. 2^0460
 November 5, 1986

The Honorable Lee M. Thorns
Administrator
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC   20460

Dear Mr. Thonas:

     The Science Advisory Beard's Indoor Air Quality Research Review
Panel prepared this report in response to the request to undertake a
review of the Office of Research and Development's (ORD) plan to assess
indoor air  research needs.  This bread based review focused en research
plans, design of a limited field study, and ongoing research.

     Although the Agency was net specifically charged with responsibility
for indoor air quality under the Clean Air Act Amendments of 1977, it
is the Federal agency whose -nission clearly relates to this issue.
This mission is supported by the recent passage of the Radon Gas and
Indoor Air Quality- Research Act of 1986, as well as language in the
House of Representatives appropriations bills for fiscal years 1984 and
1985.   Through its research activities in support of the regulatory
work in the Office of Air and Radiation, the Agency has made substantial
contributions to the knowledge of the factors determining indoor air
quality, and of  its effsct on human health.  Nevertheless, the Panel
concludea that while the indoor air research being conducted was of
high quality, the research taken as a whole did not constitute a "program"
in indoor air quality.

     Our major reccmrnendaticns include: 1) development and adoption of
a clear policy statement t/at indoor air quality is an inportant and
essential ccrrponent of the responsibility of the Agency, 2) assigning
responsibility for the indoor air quality program to an individual of
appropriate scientific stature with specific experience in this area,
3) the proposed limited field survey should not be carried out as
presented since the resources that it would demand are not commensurate
with the scientific information and insights which would be derived, 4)
preparation of a relative risk assessment for the more important pollutants
(including asbestos, biological contaminants, criteria air pjollutants,
and toxic chemicals) in crcer to develop a framework for deslsion making,
and 5) eight general occlusions and recommendations concerning current
research on indoor air --ality.

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                                  -2-
     In researching and preparing this report, the Panel was pleased
with the cooperation and candor of Agency staff in conducting briefings
and answering questions.

     Thank you for the opportunity to present our evaluation of this
program.  We look forward to the Agency's response to our report.
                                     Sincecely
                                     Jar; Atj. Stolwijk, Chairman
                                     Indoor Air Quality Research
                                        Review Panel
                                     Science Advisory Board
                                        V
,1
                                     Norton Nelson, Chairman
                                     Executive Corcnittee
                                     Science Advisory Board
cc:  A. Janes Barnes
     Vaun Newill
     Craig Potter
     Terr/ F. Ycsie

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                                                        SAB-EC-37-::
REVIEW OF THE OFFICE OF RESEARCH AND DEVELOPMENT'S

  PLAN FOR ASSESSING INDOOR AIR RESEARCH NEEDS
                 A REPORT OF THE

     INDCCR AIR C'-'ALITY RESEARCH REVIEW PANEL

          C" THE SCIEN'CE ADVISORY BOARD
                 October 24, 1986
       U.S.  L.-virormental Protection Agency
              Science Advisory Board
                 '.•.'ashir.gton, D.C.

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                                  NOTICE
     This report has been written as part of the activities of the
Environmental Protection Agency's Congressionally established Science
Advisory Board, a public group providing extramural advice on scientific
issues.  The Board is structured to provide a balanced, independent,
expert assessment of scientific issues it reviews, and hence, the
contents of this report do not necessarily represent the views and
policies of the Environmental Protection Agency nor of other agencies
in the Executive Branca of the Federal Government.

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                   U.S. Environmental Protection Agency
                          Science Advisory Board
                             Washington,  D.C.
                 Indoor Air Quality Research Review Panel
Chairman
Dr. Jan A.J. Stclwijk, Department of Epidemiology and Public Health,
     Yale University School of Medicine,  New Haven,  Connecticut
Panel Members


Dr. Irvin K. Billic'-'.,  G=s Research Institute,  Chicago,  Illinois

Dr. Naihua Duan, Statistician,  Rand Corporation,  Santa  Monica, California

Dr. David Grirerud,  Lawrence Berkeley Laboratory,  University of
     California, Berkeley, California

Dr. Thcrss J. Kulle, Research Associate Professor of  Medicine, University
     of Maryland School of Medicine,  Baltimore,- Maryland

Dr. Janes Melius, National Institute for Occupational Safety and Health,
     Cincinnati, Ohio

Dr. James Ware, Associate Professor,  Department of Biostatistics, Harvard
     School of Public Health, Boston, Massachusetts

Dr. Jerry Wesolowski,  Air and Industrial Hygiene  Lab, California Department
     of Health, Berkeley, California

Dr. Jarres E. Woods,  Honeywell Energy Products  Center, Golden Valley,
     Minnesota

Dr. Cary Young, Electric Power Research Institute, Palo Alto,  California


Executive Secretsrv
Mr. Robert Flaak, r- : rcmental Scientist,  Science Advisory Board,  U.S.
     Enviror.7«nt2L "- r . :-2ct:cn Agency/ Washington, D.C. 20460

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                       TABLE OF CONTENTS




1.  EXECUTIVE SUMMARY	•	•	1



2.  INTRODUCTION	3
3.  NEED FOR AN EPA  POLICY STATEMENT ON INDOOR
        AIR QUALITY   	  .....  3

4.  REVIEW OF ORD'S  PLAN'  FOR DETERMINING FUTURE
        RESEARCH NEEDS ON INDOOR AIR POLLUTION 	  4
5.  REVIEW OF PRELL'-'.IIJARY PROPOSAL FOR A FIELD SURVEY   ....  5
6.  REVIEW CF c::coir>3 RESEARCH  PROJECTS RELATED
        TO INDCCR AIR QUALITY	7
7.  PROGRAM M-::-.G£.'-'£:rr


8.  APFETDICEi
    1.  Memorancjr. from  Dr.  Scott Bciker to the Panel dated
            Aug-JSt 15, 1986

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1.   EXECUTIVE SUMMARY


     As part of a continuing process for reviewing U.S. Environmental
Protection Agency (EPA) research programs, the Science Advisory Board's
(SAB) Indoor Air Quality Research Review Panel evaluated, on September
3-4, 1986, the Office of Research and Development's (ORD) indoor air
research program.  This broad based review focused on research plans,
design of a limited field study and a review of ongoing projects (see
Appendix A for further details on the Charge to the Panel).  The Panel
was also free to identify other program needs.

     The Panel's major conclusions and recommendations are as follows:

     •  The EPA should develop and adopt a clear policy statement that
        indoor air quality is an important and essential component of its
        responsibility.  This policy statement should state the broad
        objectives that are of the highest priority to EPA.  Such an
        indoor air policy statement and program would serve the Office
        of Air and Radiation in providing the total exposure perspective
        to the mandated responsibility to assure clean air to the U.S.
        peculation.  It would also more clearly define the policy and
        program coals toward which the research is directed.

     •  An effective Indoor Air Quality Program must be multi-disciplinary
        and thus needs to build on a framework which is common to all  -
        participants, with clearly recognizable goals.  In view of the
        widespread interest in indoor air quality, and the wide range of
        clients, it is important tha". this framework for decision making
        be understandable and clearly relevant.  The most effective
        ccmon reference point would be a relative risk assessment for
        the more important pollutants (including asbestos, biological
        contaminants, criteria air pollutants, and toxic chemicals).

     •  The Panel unanimously concluded that the proposed limited field
        survey should not be carried out as presented.  The resources  it
        would demand are not commensurate with the scientific information
        and insight which would be derived.  The relevance of the goals
        was not discussed and presented; the connection with other surveys
        of various types, completed or currently ongoing, was not established;
        and the design seemed to be based more on available methodologies
        than on a clearly perceived goal of the utility which the results
        would be likely to achieve.  A more clearly defined set of objectives
        might be achievable at a much reduced level of effort.  The
        statistical design, the measurement methodology,  the quality
        assurance were all considered scientifically adequate.  As an
        alternative to the proposed field study, a small  field trial of
        nine residences in the Research Triangle Park  (RTP) area of North
        Carolina, arc c: nine residences at a remote location, would
        present a cost effective opportunity  to test  the  feasibility,
        cf such a s_.-.•;•/, as well as some of  the variance to be expected.
                                   -1-

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The Panel reviewed current indoor air quality projects,  limiting
itself to the relevance and balance of the projects.  The Panel
reached the following general conclusions and recommendations:

    - Existing work is biased heavily toward residential
     ••(single family) environments.  The EPA should focus a
      reasonable amount of attention on occupants of
      commercial and public sector/public access buildings.

    - Responsibility for indoor air quality implies that areas
      that are not traditionally addressed in ambient air quality
      programs, such as radon, asbestos, and microbials, should
      be covered by coordinated research, intra-tnurally or extra-
      murally.

    - The EPA should more carefully articulate hew it plans to
      integrate work carried out by other public agencies and
      private organizations into its own research program.

    - Building assign, construction and operation are essential
      factors in indoor air quality.  The EPA should develop scne
      in-house competency in these areas which complements that
      present in other agencies.

    - The EPA should state what efforts are being undertaken.
      to follow up on the approach based on a single  unconfirmed
      study (by Molhave) on the effects of mixtures of large
      numbers of volatile organic chemicals (VCC) in very low
      concentrations.

    - Monitoring research which does not have immediate policy
      relevant results should be regarded as less policy relevant
      than research aimed at source characterization and control,
      or research aimed at measuring health effects of exposures.

     The Panel has confidence in the investigators and the EPA staff,
and concludes that in the presence of clearly stated Agency policies
and a suitable administrative structure, they will produce an
excellent program.

Responsibility for the indoor air quality program should be assicned
to an individual of strong, proven leadership who has appropriate
scientific stature and specific experience in this area, who would
devote full time attention to the program and to the implementation
of a research needs assessment.  The leadership of the program and
the administrative structure should promote multi-disciplinary
cooperation, in the conception,  initiation, and execution of projects
and' to the dissemination of the information obtained.
                           -2-

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 2.    INTRODUCTION
     The U.S. Environmental Protection Agency has, for a number of years
and on a limited basis, supported and carried out research on factors
affecting  indoor air quality.  Much of the  initial efforts addressed
criteria air pollutants and how  indoor concentrations related to outdoor
concentrations.  A number of events, observations and insights have
served to  make air quality in the indoor environment a more salient
public health issue.  Time budget studies conclude that a very large
part of the twenty four hour day is spent in indoor environments. Other
studies showed that there are many important sources of air pollutants
inside buildings, and the rise in the price of energy in the decade
of the 1970's changed the way buildings are constructed and operated.
Studies in Western Europe, Canada and the U.S. demonstrated that for
many pollutants and in many locations the major fraction of the total
population exposure to air pollutants may occur indoors, and for many of
these pollutants, such as environmental tobacco smoke, nitrogen dioxide,
volatile organic chemicals and radon, the concentration indoors is often
much higher than outdoors.  These, and other developments, have led to
a greatly  increased public awareness of indoor air quality issues.

     The EPA was not specifically charged with responsibility for indoor
air quality uncer the Clean Air Act Amendments of 1977, but it is the
Federal agency for which indoor air quality is closest to its central
mission.   Congress considers EPA as the lead" agency for indoor air quality..
Other Federal agencies which have programs ana responsibilities in this
area, such as the Department of Energy (DDE), the Consumer Product Safety
Conr.issicn (CPSC), and the Department of Health and Human Services (DHHS),
are represented in the interagency Committee on Indoor Air Quality (CIAQ),
and they recognize the central position of EPA.  It iinportant that the
ongoing coordination between these agencies continue.

     Through its research activities in support of the regulatory work  in
the Office of Air and Radiation, EPA has made substantial contributions
to our understanding of the factors determining indoor air quality, and
of its effect on human health.  More recently, research activities have
included projects specifically supported by Congressional appropriations
for indoor air quality research.  The Agency has a number of capable and
proven investigators who also have experience in managing and administerinc
extramural research efforts.  The CPSC, DOE and DHHS also conduct, support"
and administer research work of high quality on special aspects of indoor
air quality.


3.   NEED.FOR AN EPA POLICY STATEMENT ON INDOOR AIR QUALITY


     It is understandable that EPA has moved slowly toward defining its
role in improving incocr air quality for the nation.  At  the time of the
formation  of the A-or-.cy, the relative importance of indoor air quality
was not yet recc-~ :r.:-c.  The realization of the  importance of indoor air
quality in protect:-.- and advancing public  health and welfare developed
op.ly gradually, =r- -_-.e Panel believes this realization  is still growing.
                                   -3-

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     Another reason for the slow development of an indoor air quality
policy stems from the clear difference in strategy for the control of  .
ambient  (or outdoor) air pollutants compared to indoor pollutants.  For
ambient air, the most effective strategy is regulatory, while for indoor
air quality a very different strategy may be required.  One possible
strategy for indoor air pollution control is to increase understanding
through well-coordinated and designed research, followed by dissemination
of this information to individual householders, architects, building
managers and organizations that have an interest in or responsibility for
the quality of indoor air in residences and public access buildings.
Since neither individuals nor such organizations can effectively do all
the research required to develop guidelines and control methodologies,
this type of information and guidance would help to reduce risks to
public health from indoor air quality by helping them make appropriate
and well informed choices.

     The EPA will continue to experience difficulty in establishing a
viable and stable basis for assessing research needs and arriving at
efficient decisions en research priorities,  schedules and resource
allocations, in the absence of a clear definition of the indoor air
quality program arc its objectives.  To iirprove their effectiveness, E?A
researchers must knew what specific EPA policies and objectives their
research is designed to acdress.

     Although it is understandable that EPA policy on indoor air quality
was not easily forr.ulated nor quickly adopted in the past, the Panel_
recormends that EPA develop such a policy and state its high priority
for the nation.   Supporting this need is the continuing Congressional
direction provided in House of Representatives appropriation bills for
fiscal years 19S4 and 19:5, and the Radon and Indoor Air Quality Research
Act of 1986 which is specific to EPA's role and responsibility for indoor
air quality and radcn research.  Such a policy statement can provide
integration to EPA's researcii and other program activities by ensuring
that the research program and policy goals are jointly planned.


4.   REVIEW OF ORD'S PLAN FOR DETERMINING FUTURE RESEARCH NEEDS
       ON IN30CR AIR PCLL^TICN


     In assessing OPD's plan for future research needs the Panel considered
the documents submitted, and presentations by EPA staff.

     A scientifically effective indoor air quality research program must be
a multidisciplinary one that builds on a framework which  is common to all
participants, with clearly recognizable goals.  In view of the widespread
interest in the area c: indoor air quality, and the wide range of clients,
it is important tr.ai this framework for decision makinq be understandable
and clearly relev=rt.  The most effective common reference point would  be
a relative risk a.-..--.^i-tnt for the'more important pollutants  (including
asbestos, biclc-;:.-.. •"-tiT.inants, criteria air pollutants and toxic
                                   -4-

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chemicals).  An example of the output of such an effort would be a table
which in one column would list the factors in the indoor atacsphere that
are considered important.  The next column would list for each of the
pollutants the 10, 50 and 90 percentile concentrations as encountered in
indoor measurements, and the corresponding outdoor concentrations, with
time-weighted exposures.  The next column would contain the best estimate
of the adverse health effects associated with the observed exposures for
each pollutant.  The final column would give, again for each pollutant,
the total estimate of the incidence of these adverse health effects in
the whole U.S. population associated with the exposures derived from
previously described columns.

     The EPA has not made such estimates in the past, but it should recognize
that they will indicate a number of uncertainties and areas of inadequate
knowledge.  The construction of such a table will require coordinated
input from all the disciplines now involved, and should be refined and
updated as new infonration emerges.  This table can also clarify which
factors' are least known or understood, and allow for comparisons of the
relative impact on public health and the level of effort necessary.  The
Panel recommends that EPA staff directly undertake this assessment and
not assign it to cuts ice ccntractors,  in order that internal competence
improve and that the experience gained will be of maximum direct benefit
to the program.

     Over the years, such a table should also represent the clearest
demonstration of progress that occurs in research and development and in
the dissemination of this progress.  The Panel knows that efforts have
already begun to ccrstract such a table which would also serve to present
the best estimate of the current state of knowledge.  It would also be
useful to incorporate estimates of that fraction of tht- total population
exposure which sterrs from the outdoor environment.  Somewhat similar
exercises have derived from the European Regional Office of the World
Health Organization, EURO Reports and Studies 103 (1986): "Indoor Air
Quality Research".

     Finally, the construction of a table which constitutes the generally
accepted state of knowledge and its formal dissemination as a basis for
research policy decisions will assist in the more effective integration
of interagency programs.  It will also help to attract extramural
investigator-initiated research proposals which match with Federal program
needs.  It will clarify  to Congressional committees the status of current
and future research activities.


5.   REVIEW OF PRELIMIXARY PROPOSAL FOR A FIELD SURVEY


     The Agency presented the Panel with a preliminary design  for  a field
study that is  inte" >. : as a pilot  for a much  larger study  in  the  future.  The
proposal recommenc.; -.r-.2in.ing a large number  of observations  in  residential
environments thrc--r  •,.s:cal ronitdring and  through questionnaire responses
frcn the occupant.-.   :-•? announced objective  is  to  test  the hypothesis  that
                                   -5-

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the concentration of indoor air pollutants does not significantly vary in
residential environments in different regions or seasons.  The proposal
specifically states that the study will
"...
          address the magnitude of possible factors affecting the
      distribution of selected indoor pollutants in U.S. residences.
      This study will emphasize measurements for Volatile Organic
      Chemicals (VTX's), Semi-Volatile Organic Chemicals (SVOC's),
      .and combustion products including particles (mass and
      chemical composition) and N02«  The resulting data will be
      used by EPA in designing future Indoor Air Quality Surveys."


     The overall design incorporated two phases.  In Phase I, EPA would study
nine homes near Research Triangle Park, N.C. with a similar cluster of nine
homes studied in or near Gaithersburg, MD.  The main purpose of Phase I is to
test monitoring and survey instruments.  In Phase II / EPA would select two
cities.  Current planning focuses on Baltimore, MD and Chattanooga, TN.  In
each of the two cities, EPA would monitor during each of four seasons, in
four different ten hcne neighborhood clusters, for a total of2x4x4xlO
residences.  The neighborhood clusters will be chosen randomly from the four
quartiles of census derived housing values or from census derived income
levels.  Within a neighborhood cluster 10 homes would be chosen randomly.  The
measurement program presented concentrated on VCC's and SVCC's,  particulates,
NC2< formaldehyde, water v«.por, temperature, air exchangs rate and nicotine by
passive sampling.   In addition, EPA plans to carry out screening interviews,
baseline interviews and occupant diaries to capture building characteristics
and occupant behavior.

     The Panel did not possess sufficient information at the time of the
review to conduct a detailed evaluation of the technical details of the
design, although the Panel commends the Agency for its continuing efforts to
use sound statistical practices in the design of surveys.  It is evident that
the instrumentation is close to, or at, the state of the art level and that
EPA will require field validation for some of the methodology.

     The major weakness of the proposal is not in the technical design, or  in
the ability to carry out the design, but in the scientific justification for
planning and carrying out a study of this size and cost without demonstrating,
or discussing the justification for, its need and how the results would be
used.  The Panel also found that the number and detail of secondary objectives
were overstated and that these objectives could not be met.  The Panel noted
that EPA has obtained data of a somewhat similar nature  in the Total Exposure
Assessment Methodology (TEAM) studies.  The methodology appears to derive in
considerable part from the experience gained in TEAM studies.  The TEAM
results were not used in any observable way to 'anticipate the results  in the
proposed new survey or to assess the qualitative and quantitative variance
which could be expect-;-:!.  An analysis and interpretation of the TEAM results
along the lines of th-? planned survey was not evident and would be most
instructive.
                                     -6-

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     The Panel unanimously agrees that the field survey proposal should
not be carried out as currently presented.  -The justification presented
was not commensurate with the information and insight that EPA would
obtain.  The relevance of the goals was not discussed and presented; the
connection with other surveys of various types, coupleted or currently
ongoing was not established; and the design seemed to be based more on
available methodologies than on a clearly perceived goal on the utility
which the results would be likely to achieve.  A more clearly defined set
of objectives might be achievable at a much reduced level of effort.

     The Panel concludes that a small field trial of nine residences in
the Research Triangle Park area, and of nine residences at a remote location
would present the opportunity to test the feasibility, as well as some of
the variance expected.  It also believes that such an effort would contribute
to the building of confidence and competence, especially if EPA staff took
an active part in the undertaking.
6.   REVIEW CF ONGOING RESEARCH PROJECTS RELATED TO INDOOR AIR QUALITY
     The Panel reviewed ongoing research projects in the areas of monitoring
source characterization and control, and health effects.  The charge to the
Panel did not include a detailed evaluation of all of the projects but, rathe
to comment on the balance, coherence and objectives of the overall program.

     In each research area the Panel found that projects are designed and
executed with competence and dedication.  The scientific and technical
soundness, however, is not matched by coherence, clarity or the relative
importance of the overall goals.  The investigators -culd not be expected
to produce spontaneous coordination, or to develop coordinated objectives
without clear policy guidance.

   .  The existing research program currently consists of a collection of
projects with few linkages between them.  In reviewing this ongoing program,
the Panel reached the following conclusions:


     •  The balance of concern is still biased heavily toward residential
        (single family) environments.  The EPA should focus a reasonable
        amount of attention on occupants of commercial and public sector/pus
        access buildings.  A large number of Americans spend about equal
        amounts of time in these two environments.

     •  Responsibility for indoor air quality implies that areas  that  are
        not traditionally addressed in ambient air quality programs, such
        as radon, asi>3=tos, and microbials, should be covered by  coordinate;:
        research,  ir.tra-^.urally or. extra-murally.
                                    -7-

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     •  The EPA should more carefully articulate how it plans to integrate
        work carried out by other public agencies and private organizations
        into its own research program.  Even-studies done within EPA by
        another laboratory other than those located at RTP do not appear to
        be integrated into new plans.  There appears to be a tendency to
        start de_ novo projects, rather than building on what is already known

     •  Building design, construction and operation are essential factors
        in indoor air quality.  Although these areas of expertise exist in
        several other Federal agencies, the EPA should develop some in-house
        competency in these areas which complements that present in other
        agencies.  This is supported by the recent Radon Gas and Indoor Air
        Quality Research Act of 1986.

     •  The EPA should state what efforts are being undertaken to follow
        up on the approach based on a single unconfirmed study (by Mclhave)
        on the effects of mixtures of large numbers of volatile organic
        chemicals (VOC) in very low concentrations.  The Agency should also
        state what efforts, if any, are being considered to replicate or
        otherwise corf irn this work.

     •  Monitoring research which does not have immediate policy relevant
        results should be regarded as less policy relevant than research
        aired at source characterization and control, or research aimed at
        measuring health effects of exposures.  Both of the latter can produc
        results that are immediately usable, and the Panel finds that"the
        flow of resources -does not correspond to that relevance.  Having
        clearly stated policies and objectives is likely to bring about
        char.;es in these patterns.

     The Panel has confidence in the investigators and the EPA staff,  and
concludes that Li the presence of clearly stated Agency policies and a
suitable administrative structure, they will produce an excellent program.


7.   PROGRAM MANAGEMENT
     There is a need for a management structure which can both provide the
leadership and be held accountable for the clear definition and implementatk
of research objectives, and a manager who can nurture, guide, and coordinate
the clearly very capable human resources and material support dedicated
to the indoor air quality program.

     Responsibility for the indoor air quality program should be assigned
to an individual of strong, proven leadership who has appropriate scientific
stature and specific experience in this area, who would devote full time
attention to the prccran and to the implementation of a continuing research
needs assessment.  T'r.e administrative structure, and  the leadership of the
program should prc-cto multi-disciplinary cooperation in the conception,
initiation, and e:-o:jt:cn of projects, through to the dissemination of the
information otts:.-•;•:.
                                    -8-

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                                 APPENDIX 1

\       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 I                        WASHINGTON. D.C. 20460
                                         1  5 1985              orr.ce or
                                         I  w >w>^»
                                                       RESEARCH AND
 SUBJECT:   SAB Review of GRQ's  Plan- for  Assessing  Indoor  Air  Research Neens
                                      .  : ^    /
 FROM:      Scott R.  8a"*«r^li>>**   W«W TT I I I  JIHIMIVUIICtUUjt
                                 to obtain  selected data that  will'more clear"
carry out a
i 11 u.ninate major
                                    A-l

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             '  "-                    -2-

   This direction for EPA's indoor air research program has the support  of  the
interagency Committee on Indoor Air Quality,  EPA- program and policy  offices,  and
Congressional staff.  However, all parties agree that before ORO commits its  re-
sources fully to this approach, it should see* the advice of scientific  experts
1n the field, including that of the SAB.  At  the same time, it will  be useful
for ORO to receive scientific advice from the SA3 on the utility of  research
projects currently underway (or planned at EPA) that might be expected to
contribute significantly to the foundation of CRO's future researcn  plan.

Scope of the SA8 Peview

     (1)  Scientific advice on the plan for conducting a research needs
          assess~e*t - C:I will' present "to tr*e SAS Panel a rraneworx qescrioinq
          how it mce^s to carry out its assessment and will specify the data
          bases that will  be examined.  We would like the SA3 Panel  to offer
          its asvice c". Me proposed approach to assessing tne gaps  in scientific
          knowledge, including tne adequacy,  individually and as a whole, of
          the data bas^s that will be used in the assessment of research needs,
          In our r:es'> = to csnqjct a thorough- assessment, we are particularly
          concerned abc-t balance:  whether or not we have identified for
          incljsic* i- t~e assessment all appropriate issues; and whether or  not
          we have pr::-;-ly framed the issues  to be considered.  In this  context.
          it is i1-::"".*-: tuat the SA3 advise us on the appropriateness  of  (1)
          incluCTnc fe roi lowing issues in our assessment, individual ly anq
          on tne wo^ ? . (2^ inclucinq any additional issues, and (3) our ration'
          for cna^acte"': :' nc eac." issue as we nave done, recognizing tnaT      ~"
          certain eie~en:s wqre qeliDerately  included or exciu^elT  We are  not
          d~s
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                            -3-

o  Health research

   o  Balance of attention to products  of combustion,  side-stream
      cigarette smoke, volatile organic compounds  (individually  and
      In complex mixtures)

   o  Appropriate health-related endpoints to consider in  an  indoor
      air research program, including cancer, respiratory  effects
      neurotoxicological  effects, and other unknown  classes of
      effects

   o  Aparopriata expTS'jre scenarios,  including chambers,  test
      houses, and field/epidemiology studies.

o 'Source char;cteri ration
   o  Aporomate netnocs to einance  understanding of sources,  ,
      ircljding cna.-ibers  and field-level  test houses

   o  Kc-v to det5riine t"e role of  source characterization  in con-
      c-j:t:rg nealtn ris* assessments  on  indoor air pollutants

   o  Alternative apprcacr.es for ranking  sources for  testing.

o  Corfc1  tecw-o1ocy

   o  nets'— ini-g cost-effective nethods  for ensuring good  indoor a:
   "  qua 1 i ty .

o  Overall
   o  Balance between hazar:  assessment, exposure assessment,  source
      characterization, and risk mitigation strategies  to  ensure
      a proper interrelation  between risk assessment and  risk
      management

   o  The narkets to which the outputs of the future program should
      be oriented, including  consumers (for public decision-making),
      states ana municipalities, regulatory programs, and  private-
      sector manufacturers.

      The Office of Air and Radiation (OAR) has recently  initiated a
   policy coordination and development process for indoor  air  within
   EPA.  This process involves extensive participation  by  ORD  and
   the policy and program offices within the Agency.  As  part  of  this
   process, C-2 will soon undertake a problem characterization study
   on indoor air.  This study is being designed to provide an  overview
   of the c"::'e"i and to formulate issues around which  policy  options
   car be c:r:'-!/ defined.. OAR is now developing the central  questic-
   that wi:: ':'- tne basis^of this overview study, and will circulate
   the- *•:-•- :-
-------
                                .4-
(2)
       gs.c.  arov:--c an

      Review  of  oncoing and planned studies
                  '.-M  hav  spanned the r.aage
         understanding of indoor air pollution.


                                           on the relevance of these  studis
                                            researcn  neessJIn keeping wit
                                    of tasearcn in Progress, we would value
          t	^hetheTwe^arPdoing the right research"  in contrast  t<
          'doing  the  research right."

To assist you in  preparing  for the meeting, we have attached  three document
I wUl  U t?e oasis for  presentation and discussion:

  ,  %  .   „  .   -anrtf.f  rtf nan's  indoor  air  research program.   Please consid
  U)  ll"eclo      source characterization. Mnlt.r1n, methods developn
       fllld studies, a'd health as  background  informal.on for the discuss.
       of ongoing studies;
(2)   A document
     assessneit
                  C 'j 11 i n i
   (3)  A  descriptici o
ng the proposed  approach  to  the  research needs


he prelininary design for a  limited  field  survey.
                                   A-4

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    As is customary, the Panel may_choose ta consider Additional issues for
   :ussion.  'We look"forward to~engag~ing in a productive dialogue with the
   el.  We would be pleased to discuss our three requests with any Panel
   Ders prior to the meeting.  Thank you for assisting us in this activity,
Attachments

cc: Gerald G. Akl*nd (MO-56)
    Donald J. Ehreth (RO-672)
    Elissa Feldnan (Rn-672)
    Robert A. Flaa* (A-101F)
    Juditi A. Hranan (V.D-51)
    David Mace (MD-5o)
    Courtney Rioraai (?0-5£0)
    Charles .Rnies  (uC-55)
    Will ian G. Tljc
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                               APPENDIX P.

           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

 '••iww*                       WASHINGTON, D.C.  20460
DRAFT
                                                       THE ADMINISTRATOR


Dr. Jan A.J. Stolwijk,  Chairman
Indoor Air Quality .Research Review Panel
Science Advisory Board
U.S. Environmental  Protection Agency
Washington, D.C. 20460

Dear Dr. Stolwijk:

     Thank you for  your letter of November 5, 1986, containing the Indoor  Air
Quality Research Review Panel's review of the Agency's plan to assess  indoor
air research needs.   We appreciate the timely manner in which this Panel of  ths
Science Advisory Board  (SAB) undertook this review and submitted its  report.
You succinctly summarize in your letter the substantive conclusions and
recommendations  of  the  report, some of which we have already implemented.

     We recognize that  an  Agency policy statement on indoor air is needed, both
to establish a purpose  and direction for its indoor air program and to guide
the Agency's research in support of this program.  We believe that Title -IV  -
Radon Gas and Indoor  Air Quality Research contained in the recently passed
Superfund Amendments  and Reauthorizatlon Act of 1986 clarifies our Congres-
sional mandate to conduct  indoor air research and to establich an indoor ai"
program.  This combined action will make clear that our mission includes
assessing the potential  harm to the public from indoor air pollution.   In
addition, the Agency's  studies now show the important contributicn of  indoor
exposure to total human exposure to air pollution.

     Within the Agency's air research program over the past few years, we  have
investigated the potential effects from indoor exposure to certain air pollu-
tants.  These have  included carbon monoxide, oxides of nitrogen, and dust
(especially dust containing lead particles).  While these efforts have but-
tressed our major research supporting regulatory activities, they have emerged
as a major research area in themselves.  As the results of this enlarged
research activity become evident, we will begin to factor in the contribution
of indoor air pollution to total human exposure when we develop our strategies
for outdoor air regulations and for regulations 1n other areas for which we
have statutory authority.  To adequately fulfill its mission of protecting and
enhancing the Nation's  air quality, the Agency must address the potential
benefits of reducing  exposure to indoor air pollution.

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                                      -2-


     The EPA indoor air program will  focus on sharpening the  public's awareness
of indoor air problems.  At the center of this effort will  be an Agency-directed
research program to provide the information necessary to help us communicate  to
the public a basic understanding of potential  indoor air problems and possible
solutions.  Private sector and other public sector institutions  can  be  expected
to play essential  roles in developing and distributing the  information  neces-
sary to improve and protect Indoor air quality.  I have delegated to the  Office
of Air and Radiation (OAR) the responsibility for developing  the Agency's
policy on indoor air quality.   OAR will develop and implement the specifics of
the policy while the Office of Research and Development (ORO) will provide
support with a research program attuned to the needs of the policy.

     A key recommendation in your letter suggests that an effective  indoor air
quality program must be multidisciplinary and should build  on a  framework-
common to all participants. Even before the SAB review, the  Agency  had begun
an effort to assess tne available information on indoor air.  As a result of
your recommendation, that assessment  will be expanded to ensure that it ident-
ifies the multidisciplinary nature of the indoor air issue.  The Research Needs
Assessment (RNA) that 0?0 plans to produce for the Agency's indoor air  program
will consist of two .volumes: the first will compile and synthesize the  informa-
tion on indoor air Quality; the second will describe the research plan  that the
Agency will  implement to address tne issues raised in the first  volume.

     The primary value of performing  a multidisciplinary needs assessment'wil1
be to enable integration of effort among the engineering, monitoring, and
health laboratories, to address specific concerns that have been identified,
and reconcile any explicative  research activities.

     Foremost in our  planning  at this time is the need to characterize  the
nature of indoor air quality problems.- Particularly important are:  1) the
health consequences o< existing indoor air quality; and 2)  the extent to  which
these problems exist nationwide.  A strategy for accomplishing this  characteri-
zation is emerging from our assessment.  One approach under consideration is
one that is health-based; i.e., to investigate the sources  of those  pollutants
causing health effects.  Once  potential sources of unhealthy  indoor  pollutant
levels are identified, a comprehensive program can be developed  for  determining
the origins of indoor air pollution problems and for correcting  these problems
with effective control techniques.

     Using a health-based approach that focuses on sources  has several
attributes.   Identifying sources of concern allows for quick  implementation  of
mitigation measures.  This approach also allows for prioritization by source
category within budgeted resources.  However, such an approach calls for  a
multid1sc1pl1nary effort that  is not easily accomplished within  the  highly
specialized scientific co"nunity we have today.

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                                      -3-


     Through our current assessment activities,  we are striving to  identify
those questions which, when answered by research results,  will  allow the  Agency
to better educate the public about available options .regarding  indoor air qual°
1ty.  Individual homeowners (as well as designers, builders, manufacturers and
maintenance professionals)  will be made aware of the sources of contamination,
and the relative hazard that indoor pollution may present, e.g., that associ-
ated with Improper usage and storage of chemicals.  We have already produced a
report aimed at this audience,  Guidelines for Monitoring Indoor Air quality.
which summarizes current monitoring methods.  Other benefits of this report
include new methods of assessing problems,  the refinement  and rethinking  of
monitoring techniques, the  definition of health  parameters affected, and  the
identification of specific  populations at risk.   Means to  avoid or  mitigate
potential problems can te described, so that affected  persons can make intelli-
gent choices regarding how  to minimize the level of contamination to which they
are exposed.

     A very definite conclusion of your review is that our proposed limited
field survey should not be  carried out as presented.  We agree, after consider-
ing your advice, that the proposed limited field survey should- not  be conducted
addressing the states objectives.   With the emergence  of EPA's  program fo-r.
improving indoor air quality, a more effective effort will include, among other
actions, directing monitoring resources toward developing  the "tools" to  better
define the magnitude of tne indoor air problem in relation to human health.  An
integrated research effort  to replace the reviewed survey  is under  discussion
by the laboratories at Research Triangle Park.  As suggested, it would be
designed primarily to test  the adequacy of the methodology.  This would be an
in-house activity as much as pos~ible to minimize cost, build staff confidence
and experience, and provide for real-time corrective measures.

     Your recommendations concerning our current indoor air quality projects
are also helpful.  We concur that we should focus our indoor research on  those
settings which provide the greatest degree of exposure to the public.
Commercial- and public-access building microenvironments are second only  to
residences  in this regara.   In our 1982-83 indoor air program, we studied 10
such buildings, including schools, hospitals, homes for the elderly, and  office
buildings.  In our planning for indoor air research (for FY-87 and  beyond) we
are increasing attention to nonresidential settings.  Of course, our studies  on
measurement methods, material source characterization, and indoor air quality
control are applicable to both residential and non-residential situations.   Our
clinical studies of health responses to VOCs were triggered by the "sick
building syndrome," a phenomenon most often connected with office buildings.

     Also regarding our current indoor air activities, you recommend that our
research program shoul: c:/er areas not. traditionally addressed in ambient  air
quality programs, such as  radon, asbestos, and  "microbials." The specific areas
of radon and asbestos a-e effectively managed by separate  programs within EPA0
We have previously net  ^-nlignted these areas within the  indoor air program
because of the distnc.:-c- of program resources.  We will make a more con-
certed effort to factor :hese  pollutants into the program, in  concert with
existing programs.  Tna -cency has only  limited expertise  in addressing

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                                      -4-


"microblals" but recognizes that this area must be included  in  future  planning,,
We can utilize existing expertise in other Federal agencies, such as CDC  and
NIOSH, where work in this area has been ongoing.

     Another recommendation of the SAB is that the Agency carefully articulate
how it plans to integrate work carried out by other public agencies and private
organizations into its own research program.   As  described earlier we  are
drafting an assessment of the current knowledge of Indoor air pollution.   Using
this document, EPA will develop a long range  research program to provide  needed
information identified in the assessment.  Upon review of this  assessment  and
the resulting research plan by both the SAB and the public,  it  will be apparent
that EPA has reviewed and considered the research efforts of other Federal
agencies and the cc~~jnity at large.  Such review will be an ongoing effort and
we will continue to integrate our research plans  with the indoor air research
activities of otner institutions.  We will also be more explicit in our
planning documents regarding the integration  of research by  other groups.

     A further recc~-endation of the SAB is that  the Agency  develop in-house
conpetency in the areas of building design, construction, and operation.   Whilt
we rely heavily on the expertise of others (most  notably the American  Society
of Heating, Refrigeraring and Air Conditioning Engineers and the Department of
Energy), we realize the need for in-house competency 1n this area. Our padon
mitigation research progran is developing staff knowledge in residential
design, construction, and indoor pollutant dynamics.  As our experience grows
in indoor air source characterization, pollutant  modeling, public building
investigation, and pollutant control, we will acquire the kind  of expertise
that you recormend.

     One recommendation dealing particularly  with our health effects research
suggests that the Agency describe its follow-up of the 'approach based  on  the
Mjilhave study concept.  Mjtthave and his colleagues have explored the
effects of controlled exposure of humans to complex mixtures of volatile
organic compounds (VOCs).  Results of this study have been published in the
peer-reviewed literature and suggest that low level VOC exposure in amounts
comparable to concentrations found in new construction Danish homes produced
memory impairment and sensory irritation in subjects known to be sensitive to
VOCs—i.e., persons identified by questionnaire as having "sick building
syndrome."  These findings are provocative because the available literature  on
individual compounds contained in the VOC mixture would not Indicate any
adverse effects at such low levels.  The literature concerning  the health
effects of complex VOC mixtures is negligible.

     The Mjilhave study did contain some questionable areas in experimental
concept and design, ra-'.inj it difficult for EPA to interpret the study and use
it for quantitative r::^ assessment.  -This presents a significant problem to
EPA since the study results are plausible in  light of anecdotal reports related
to sick building syncrc~e.  >Je are sufficiently aware of M01have's work to
believe that effects are cjite conceivable, and there is no opposing  informa-
tion using the Mtflhave i^roacn  in the published  literature.  Thus,  there is
reason to conduct a ,~:c-f-=^ replicate experiment to independently confirm or

-------
                                      -5-


not confirm effects observed in humans.   If EPA (or another  organization)  does
not replicate M(Hhave's work and publish the results in the  peer-reviewed
literature, there will  forever be a question.   Since the question  is  related  to
a human clinical study, the need is even more pressing.

     Under the circumstances,  we,'along  with an extramural group of experts,
are currently designing a protocol  which is a modified replication of the
Mtflhave study.  Minor in scope, the study is expected to utilize approxi-
mately S100K of the FY-87 indoor air resources.  At its conclusion, the  results
will determine the necessity for an expanded follow-up program.

     A specific recommendation concerning our current research  is  that
monitoring research aimed at measuring health effects of exposures or at source
characterization and control should be pursued with a higher priority.  The
development of an Agency policy for indoor air quality has focussed our  atten-
tion on integrating monitoring research  with other  programs.   In the
development of our research plan, we are closely examining the  required  balance
between monitoring, health, and engineering.

     The final major recommendation of the SAB is that the responsibility  for
the Agency's indoor air quality program  be assigned to an individual  of  proven
leadership and specific experience in this area.  You further point out  the.
need for a management structure which can both provide the leadership and  be
held accountable for the clear definition and Implementation of  research
objectives.

     We appreciate your concern for our management  structure and tilent  within
EPA.  However, prior to the receipt of your report, I made management assign-
ments for the inooor air'program.  These assignments, as discussed abo/e,  ars
those given to OAR for policy development and to ORO regarding  a long-term
research plan.  Foremost is the goal of assuring public awareness  of  indoor air
problems.  OAR will design and subsequently Implement the specifics of the
program; ORO will coordinate all research on indoor air in support of this
policy.  The Assistant Administrator for ORO has appointed a Program  Manager
with full authority for coordinating all activities in ORO  relating to indoor
air.  Responsibilities include:  development of the ORD RNA, the design  of the
research program, negotiations on budget and funding and program implementation,
In carrying out these tasks, the Program Manager has developed  a management
structure that includes both laboratory personnel who are directing research  on
indoor air and Headquarters personnel to ensure that the scientific questions
of most importance to policy are being addressed.  For this  assignment,  the
Program Manager reports directly to the Deputy Assistant Administrator for
ORO and is the principal 030 contact with other Agency offices concerning
indoor air matters.  As s^cn, he serves  as Co-chairman of the Indoor  Air
Quality Subcommittee of fe ORD/OAR Air Research Committee.

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                                      -6-


     The quality of our indoor air is of increasing interest  to  the  general
public as well as to the Agency.   This timely review will  contribute to the
development and implementation of our research program for indoor air.   Please
accept my thanks and appreciation to you, as Chairman, and to the members  of
the Panel for your assistance.

                                      Sincerely,
                                      Lee M.  Thomas
cc:   Mr.  A.  James  Barnes  (A-101)
     Dr.  Terry Yosie (A-101)
     Dr.  Vaun Newill  (RO-572)
     Or.  Peter Preuss  (RD-639)
     Mr.  Craig Potter  (A.NR-443)
     Or.  Lester Grant  (MO-52)

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                                 APPENDIX C

                              RESOURCE HISTORY
                            INDOOR AIR AND RADON
INDOOR AIR:
MONITORING

HEALTH EFFECTS

ENGINEERING
TOTAL
RADON:
RADON EXPOSURE AND HEALTH RISK

  National assessment/state surveys
  Hazardous land evaluation
  Measurement protocols
  Health effects analysis

MITIGATION AND PREVENTION

  Mitigation demonstration program
  Develop radon chamber
  House evaluation program
  New houses
  Study of fundamentals and devices

CAPABILITY DEVELOPMENT

  Training program
  Quality assurance program
  Support of State radon task force

PUBLIC INFORMATION

GENERAL SUPPORT
FY 1984 FY 1985
Total $(K) Total $(K)
1465 1450
125 100
462 550
2052 2100
FY 1984 FY 1985
Total $(K) Total $(K)
20
200 293
135 265
FY 1986
Total $(K)
1410
250
578
2238
FY 1986
Total $(K)
600
200
140
20
1500
200
410
100
50
340
250
20
30
90
TOTAL
335
578
3950

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                           APPENDIX  D

              CROSSWALK  BETWEEN  TITLE  IV  REQUIREMENTS  AND
                      EPA'S INDOOR  RADON PROGRAM
Title IV Requirements
                                                 EPA Program
Sec. 403(b)(l)

Research and development concerning
the identification, characterization,
and monitoring of the sources and
levels of...radon, which includes
research and developr.ent relating to
(A) the measureaenc of. ..[radon] con-
centrations and its strengths and
sources
(B) high-risk building  types
(C) instrurer. cs
collection
                for
                       radon! data
Sec .
           (2)
Research .-elating to the effects of
...radon on hucan health
                                                  .Conduct a national
                                                  assessment
                                                  .Provide technical
                                                  assistance to  State
                                                  survey efforts
                                                  .Develop measurement:
                                                  protocols
                                                  .Conduct  epidemic-
                                                  logical  studies  eo
                                                  determine  the  link
                                                  betveen  lung cance:
                                                  and radon  exposure
                                                  in house s
Sec .  4C3(b) (3)

Research and development relating to
control technologies or other mitiga-
tion measures to prevent or abate...
[radon] (including the development,
evaluation, and testing of individual
and generic control devices and systems)

Sec.  403(b)(4)

Demonstration of methods for reducing or
eliminating ... radon , including sealing,
venting, and other methods that the Admin-
istrator determines to be effective
                                                  .Develop  and  demon-
                                                   strate cost-effect!
                                                   mitigation methods
                                                   reduce radon  levels
                                                   in  houses
                                                  .Apply and evaluate
                                                   mitigation methods
                                                  .Study fundamentals
                                                   and devices
                                                  .Issue technical
                                                   guidance

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Sec.  403(b)(5)

Research, to be carried out in conjunction
with  the Secretary of Housing and Urban
Development,  for the purpose of developing
(A) methods for assessing  the potential  for
radon contamination  of  new construction,
including  (but not  limited to) consideration
of the  moisture content  of soil,  porosity  of
soil, and  radon content  of soil
(B)  Design measures  to  avoid...[radon]
                                                 .Develop models to
                                                 predict the potent
                                                 for structures bui
                                                 on certain land  ey
                                                 to have elevated  ii
                                                 door  radon concent
                                                 tions
                                                 .Develop and demon=
                                                 strate  techniques
                                                 prevent radon enfr
                                                  in  new  construceio
                                                 .Develop model
                                                  building  codes
                                                 .Conduct  cooperativ
                                                  radon prevention p
                                                  Jects with HUT)
1;
p <
 Sec .
            (6)
The d i s ses i na t io r. of information to assure
public availability of the findings of the
activities under this section
                                             the    .Provide  technical
                                                    assistance  to  the
                                                    States
                                                   •Conduct  State
                                                    training prograas
                                                   .Implement a qualit
                                                    assurance prograc
                                                    radon measurement
                                                   .Establish a Federa
                                                    clearinghouse for
                                                    radon information
                                                   .Implement an effee
                                                    tive public infor-
                                                    mation  program

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                APPENDIX E
OFFICE OF HEALTH AND ENVIRONMENTAL RESEARCH
  RADON RESEARCH PROGRAM PLAN
                           FEBRUARY 1987

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The Office  of  Health and Environmental  Research has




developed this  following plan  to address  its radon




research  needs and goals.   This plan broadly defines the




four goals which will provide  the overall basis   for the




OHER  current  and  future radon  related activities.




More  detailed  information can  be obtained from the




individual program areas.

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the European Communities, la cht near term, cht expanded OHCT radoa program




vill provide Information needed  by  state and local health departments, the




building induacry and eh* public.  In the longer term, computer baaed




analytical risk assessment capabilities using  the database generated by




this research program will be developed for the private sector, and state




and local governments use.




Pregraa Rationale



     Public concern about Indoor radon exposure is focussed on two questions:




     •  what health risk is associated with the exposures incurred in homes?




        if this risk is  unacceptably high,  what can be done to reduce it in a




        cost-effective manner?




There is also a third question,  one that Is currently less visible but of com-




parable importance:




     -  what can be done to avoid undue risks  in future housing?




A closely related question of special concern  to the Department of Energy, and




to CHER in particular, is the following:




     -  what Is the public health risk associated with possible future trends



        in radon exposures related to the application of advanced energy



        conservation technology in new housing?




     To address these questions  properly, a comprehensive research program la




needed which includes many  disciplines,  e.g.,  health physics,  fundamental




radiation physics,  chemistry, and biology,  geology,  soil science, aeroaol




physics, atmospheric physics and chemistry, epidemiology, structural




engineering, snd risk analysis.   The magnitude of the effort required is




suggested by the effort  required to understand the analogous phenomena




outdoors.  It  is likely  that  the  risk associated  with environmental radon




exposure will not be adequately defined until  models  of lung cancer induction

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              DOE/ER Plan for Radon Research Program






 Prograaaatle Goal




     Tht go4l of the program  is  Co develop  the quantitative data and




 principles that will allow accurati assessment of radon exposure and




 associated lung cancer  risk under -environmental  conditions.




 Adalnlstratlve Rationale and Coordination




     The Office of Health and Environaental Research (OHER) has been a major




 sponsor of radon-related research for several decades*   Under  its  auspices,




 considerable information has been generated froa  laboratory aniaal  studies,




 studies of radon transport and diffusion into and within structures, and basic




 but related studies of  internally deposited alpha emitters.  In addition, OHER




 has augaented earlier Public Health Service studies  on  uranium  miners with




 recent research on miners in New  Mexico where  exposure data are more  accurate.




 Nevertheless,  our  knowledge is still neither general enough to yield




 predictive principles,  nor quantitative enough  to allow the accurate risk




 analysis on which rational policy decisions must  rest.




     Because of increasing societal concerns over radon health effects, OHER




 is planning a  substantial  expansion of its radon  research program beginning in




 rt 1987.   The  program will be highly integrated:   the OHEA subprograms,




 carried out at  geographically  separated sites  will be coordinated ac




 Headquarters with one another and with  related programs sponsored by the




Office of Conservation and Renewable Energy (CI).  Tht  DOC  program  as a whole




will be coordinated with programs  of other agencies principally through the



 Federal Committee on Indoor Air Quality, whose  radon work group is  co-chaired




 by DOE and EPA,  and with programs of other nations through  the  Commission of

-------
                                   - 3 -






     Recent research results providt « useful framework,  for  the design of such




a program.  Radon la the soil git around the foundation has b««a Identified 41




the doainant  eource of  Indoor radon  in most  structural,  at Itast in tht United




States.  Mortovar, tha flow of thia aoll gas acroaa tha building anvalopa




appears to be mostly driven by pressure differentials acroaa tha foundation




produced by thermal gradients and wind effects.   An important goal of tha




proposed research program  Is the development of a detailed model of radon




availability  in the soil and transport into structures.   Such a model could




then be applied to the evaluation of mitigation techniques that focus on the




reduction of  the entry rate into structures, and would provide a reaaonable




basis for estimating the probability that high  indoor radon levels would be




found in particularly areas.   A better understanding of  the complex




relationship  between pressure differentials and ventilation rate would also be




relevant to determining the radon risk from  energy  conservation.




     A second research goal is to improve our capability for determining radon




exposure and  dose to the critical cells of the respiratory tract.   Hew and im-



proved a«asureaent methodologies are currently  being  developed and evaluated,




and this effort  along  with  appropriate quality assurance  programs should be




maintained.  Environmental influences on radon decay produce propertiea, par-




ticularly concentrations,  charge, and particle size, need to be better




understood.  Models  of  these  phenomena can be applied to the evaluation of air*




cleaning •itigation techniques and allow the inference of long-term exposure




from short-term measurements.  Finally, a much better understanding of




particle deposition patterna  and  removal  mechanisms and particle/critical call



geometry in tha respiratory tract is needed so  that tha  radiation doses to the




target cells can be  quantitatively estimated under various conditiona of

-------
                                   - 4 -






expoeure.   This  capability  it eapecially important la tht interpretation of




data froa controlled «niaal  experiments in  teraa  of human health effects.




     A third goal  of  thia program ia to conduct  appropriata  epldeaiological




•tudiaa to quantify any ralatioa btcwetn lung cancer incidenca and




environoental radon axpoaura.  Such atudies ara  unlikaly to  dafina doae-




reaponaa ralationahipa ovar the antira range of  human exposures,  but Bay




provide reasonable estimates of risk at high exposure levels and  suggest




possible relationships between radon exposure and sacking ia the induction of




lung cancer.



     The fourth and laat goal is probably the aoat important one in the long




run, namely, the development of a fundamental underatanding  of tha role of




radon in the induction of lung cancer.   A detailed model of  the proceaa of




lung carcinogenesia,  even  if  highly phenoaenological,  would  be extremely




valuable in providing a fira basis  for  inferring  the dose-response curve and




determining the interaction between radon and soaking in lung cancer



induction.   Because  of  its  immediate and practical importance, this goal




deserves the full attention of the scientific community.




     In the reaainder of thia document,  each of the above goala vill ba




discussed ia detail*




Program Description




Coal t\:  Model Development for Radon Availability and Transport




     A detailed model ia needed that relates radon concentrationa indoors  to tha




key factors that influence radon availability ia  tha ground and the efficiency




of aoil gaa transport through the  soil and acroaa tha building envelope.   Such



a aodel can be used to evaluate  the potential for high  exposures ia existing




and future atructurea and to interpret  field atudiaa of tht effectivenesa  of

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     Rcetnt rtsearch haa identified many of tht relevant factors tad



proctsats, and It may b« said that wt  havi a qualitaclvt undtratanding of what




ia |oln| on.   Kadiua content of tht toil, toil porosity, .grata  size,




ptratabllity, vattr  conttnt, pressure  differentials,  and diffusion  all play a




role*  Details of  building  construction design  art always iaportane, a face




which places  a fundamental  limitation  oa tht applicability of any aodel  to




individual structures.   A more  realistic goal for a aodel is the identifica-




tion of areas where high indoor radon  exposures are more likely to  be  found.




     Aoong the key elements of  a research program directed  at this model




development are tht following:



     (1)   Laboratory  and field  investigations of radoa availability in      •  -




reasonably homogeneous geological formations and media so that  quantitative




relationships may be found between soil  gss  radon  and the key physical




variables, e.g., soil radium, emanation fraction,  porosity,  water,  etc.




     (2)   Studies  of  radon  transport ia the ground under natural conditions in




the absence of structures,  e.g.,  the  effects  of  soil porosity,   permeability,



and water content, and barometric pressure variations on diffusive and




corrective flow through homogenous and fractured media and across the air-




ground interface.




     (3)   "Research-house"  investigation*  involving detailed correlations of




radon entry rate* with measurements  of relevant  physical variables,  e.g., soil




gas radon pressure differential across the foundation, indoor and outdoor




temperatures, outdoor wind  speed and direction, soil moisture,  ventilation



rate, tte.

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                                   - 6 -


     (4)  Investigation of eh* applicability of exiating geological and radio-

•tcrie  data, ••!•»  uraniua geology,  aoil maps,  airborne gamma surveys,

regional radon aurvcyi, to the development and validation of models of radon

availability and tranaport.

     In the conduct of thlt work, we will  continue  to  coordinate our efforta

with OOC/CE, EPA, USCS and the CEC.prograa, all of whoa are conducting related

researchi

Goal 92:  Accurate Determination of Radon Exposure and Doae to Che Critical
          Cells of the Respiratory Tract

     The doses to the critical cells are strongly dependent on the deposition

pattern of the inhaled radioactive particulatet,  which, la turn depends on

particle size and charge aa well as many factors associated with the

individual breathing pattern and respiratory tract morphology.  The inference

of long-term doses to  these cells requires a full understanding of how

environaental factora affect oat only the concentrations of radon decay

products in the ambiest air but also the rate of neutralization of the initial

positive ions of polonium-213,  their rate of  attachment to atmospheric

particulars, and the rate of  particle  growth.  A  model of these processes that

takea into account realistic air circulation patterns, ion, molecular cluster,

and particle mobilities, chemical reactions, and deposition on surface* la

needed  to interpret the limited available data on radioaetiv* particle

concentratlona and size distributions and their changes with time.  This

model would find an important application in the  assessment of the

effectiveness of various  air cleaning techniques for  doae  reduction.

     New «nd improved methods for radon, radon decay product* tod airborne

particulate measurement are continually  being developed in the DOE research

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                                   - 7 -






 program and tlstwhtrt.  Tht DOE Environment*! Measurements laboratory  (EXL)




 has btcomt tht jit facto national priatry  reference laboratory for tnviroo-




 •total radon mtssurement,  and hat beta actively involved in the evaluation of




 various measurement  techniques  and  in  the conduct of research laboratory




 intercomparisona.  It is working closely with EPA and tht states ia tht




 development of a national  quality assurance  program.  These efforts to develop




 and test measurement methodologies will be maintained, as a means to assure




 that state-of-the-art technology is available to the private sector and the




 general public for the assessment of radon exposures.




     Tht contribution of thoron decay products to total radon exposure and tht




 consequent dost to the lungs needs to be bttter defined.   Tht limited  data on




 thoron now available indicate that this contribution can be significant ia




 some situations.   Moreover, the presence of  thoron decay products can




 soaetiaes cause iaportant  errors in soae  types of radon measurements.  Thoron




 itself may be of  interest  since, because  of its  short  lifetiae,  it might be




 used as an indicator of tht rapidity of transport of soil gas into a




 structure.   Thus,  attention should be paid to thoron in future research



 studies,  where possible.




     Methods for inferring long-term exposure to radon decay products from




biological indicators need to be pursued  further.   One approach deserving




further invtstigatioa is the use of lead-210 ia the skeleton ss such an




indicator.  Measurements of lead-210 accumulations ia  former mint and mill




workers with substantial past exposures while  they art still alivt is  likely




 Co bt important in testing the  utility of this approach*  Ia addition, highly



stnsitivt lastr analysis techniques have been developed Cor obtaining  data on




 human exposure to uranium.  These could  bt  applied  to bioassay measurements of




appropriate radionuclides  to infer recent exposures to radon decay products.

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                                   - 8 -






     Although txpoeure la units of working  level month  (VLM) h*a been found to




b« • rtaaonably adequate eurrogate for dott la epidemiologlcal studies, a




detailed understanding of tht lung cancer risk from radon expoaurt (end tht




tranalatioo of Cht results of snimsl studies co human riak) requiree a




quantitative aaataamtnt of doata to tht critical ctlla  of tht reapiratory




tract.   Improved aodela of tht luog art nttded that tak* account of biological




variability*  The processes  of particle deposition,  tranaport,  and  removal




must be thoroughly investigated, and uncertaintiea in tht identity  and




location of the. target cells resolved.   Research that  addresses  these problems




will have a high priority in an expanded ER prograa.  It should alao be kept in




mind that it  is unlikely that absorbed dose in tht region of tht critical




cells is the relevant physical quantity in terms of risk.  However, once the




source-target geooetry in the lung is adequately defined, microdosimetry,




fundaoental radiation physics and chemistry can be applied to the development




of modela of  lung  cancer  induction (see  Goal  14).




Gjal <3:  Assessaest  of .Health Sisk by Appropriate Epidersiologieal  Studiea




     Current estimates of lung cancer risk due to exposure to radon and ita




progeny are  derived froa  epidemiological studies of uranium miners  in



Colorado,  Czechoslovakia,  Sweden,  and Canada.  Ongoing OHER research is




limited to caae control atudiea of  uranium miners in New Mexico,  where




dosimetrlc,  aediral,  and  lifestyle are superior to previous miner studies, and




t rtctntly initiattd  study of feaalt lung cancer cases  in Pennsylvania.  These




studies vill provide more reliable data on  lung cancer  riak fro* exposure to




radon in Cht mine environment.




     While estimates of risk from  domestic radon exposure may bt extrapolated




froa tht miner studies, they are inherently inaceuract  for several reasons.



The studies vert conducted on men  of a limited age rangt la ta occupational

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                                   - 9 -


tioas havt • high ptretatagt  of  smokers,  non-aalignant respiratory ditcate 1;


highly prevaleat aaong ainers, and aintrs ptrfora htavy manual labor.  la tht


dusty aint tnvlronmtat, a high ptrctntagt of radon daughctrt art "attachtd" to


particlts.  Sioca tht  attached  fraction  ia  lower ia  other  environmental ex-


poeurea, ic haa been suggested  chat  tht  latter  may  reault  ia draoatically ia-


ereaatd delivered dost froa a particular txpoaurt level*  Also,  iaforaatioa oo


radoo doses and oo potentially  confounding  factora  auch aa cigartttt emoking


is incomplete, and  ita validity sonewhat queatioaable.  Becauae  the airier


population ia atypical,  additional carefully planned  epideaiologteal studies


will be carried  out to provide inforaatioa  on  confounding factora,


particularly smokiag,  and  to  provide inforaatioa that will be applicable to


residential communities.


Coal 04;. ... Quantitative Model  ^p.f_..Lung Cancer Induction Due to Radon Exposure


     A major eaphasia  of the  OHER radiation research prograa haa beta tht


investigation of the basic physical,  chemical,  and  biological mechanisms of


cancer induction following radiation exposure.   An understanding of these


mechanisms  ia  required for the determination of dose-response relationships


over the range of exposures normally tncounttred ia  tht environment and in tht


workplace.


     This general atatement ctrtaialy applies  to possible environmental radoa

                                          L
exposures, which range ovtr a factor of  10  • To aoat extent, tht current


radoa risk tstiaatts dtrivtd froa tht exposure  of aintra  havt to bt


txtrapolattd to higher exposures to cover tht full rangt.   Thus,- thtrt is a


compelling nttd  to  targtt aoac of tht txiating  tffort on fundamental radiatioo


physics, cheaistry and biology  within tht OHER  program on tht particular


endpoiat of lung cancer.   Different  aodels  of cancer  iaductioa aay bt needed

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                                   -  10 -






 for the various eancera, and it ia appropriate to concentrate OB Choi* faw



 whara  the  affaet of radiatioa  axpoaura  1»  clearly  important.  Aa lacreaaed



 ovarall effort will ba inatltuted to davalop a fundaaental underatandiag of



 tha machaniama  of  lunj  cancar  induction and tha  respective rolaa of radon and



 smoking la thia procaaa.  Thia  afforc will  iocluda tha aaarch for Barkers aad



 oncogenaa aa wall  as modern  cytogenetlc atudiaa. To determine calla at riak



 for tunor davelopaeac, kinetic atudiea  of  tissue repair proceaaea leading to



 metaplasia and  neoplasia will  be used,  aa will electron microscopy and



 chemical markers.  The axpreaaion of oncogenea in  the proliferating tissues



 will help  characterize  the progression  of  cellular eventa leading to



 neoplasia, and identify repair  enzymea  that may  modify  tha diaaaaa  proceaa.



 Connection of these phenomena  to the  initial physico-chemical changes at tha



 cellular and subcellular level due to the  action of the incident alpha



 particlea will  be  an essential feature  of  the ultimate  model*



     Experimental  animal studies will ba an important element of tha expanded



 CHER program.  Direct estimates of human  riak may be  derivable  if tha physical



 and biological differencea between apeciaa can be  properly accounted  for.



 Possible interacciona between  radon  and amoking  la lung cancar  induction caa



 be iaveatigated by varying tha aequence of  expoaure to tha tvo  pollutants.



 Some cxiating evidence appaara to imply that radoa decay products primarly



 initiate tha carcinogtnetic process  while amoking  promotes the  caacar growth.



Thia la a very significant distinction  that may  atrongly  affect radon riak



 aatlaatea.  Finally,  animal studies are necessary  to understand particla


                   i
 depoaitioa, tranaport,  and clearance  proceaaea ia  tha respiratory tract (aaa



 Goal f2).

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