United States      Science Advisory       EPA-SAS-OWC-33-015
      Environmental      Board (A-101)           -uly 1993
      Proteclion Agency                    	
v>EPA AN SAB REPORT:
     [REVIEW OF ISSUES
      RELATED TO THE COST
      OF MITIGATING INDOOR
      RADON RESULTING
      FROM DRINKING
      WATER
      REVIEW OF THE OFFICE OF
      GROUNDWATER AND DRINKING
      WATER APPROACH TO THE COSTS
      OF RADON CONTROL OR
      MITIGATION EXPERIENCED BY
      HOUSEHOLDS OR COMMUNITIES

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              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            WASHINGTON, D.C. 20460
                                                              OFFICE OF THE ADMINISTRATOR
July 29, 1993                                                   SC.ENCE ADVISORY BOARD

EPA-SAB-DWC-93-015

Honorable Carol M. Browner
Administrator
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC  20460

      Subject:     Review of issues related to the cost of mitigating indoor radon
                  resulting from drinking water.

Dear Ms.  Browner:

      The Science Advisory Board (SAB) has completed its review of the Agency's
approach  to ascertaining the costs of radon control or mitigation experienced by
households or communities in  response to Public Law 102-398, Section 519 (106
STAT  16(18) pertaining to implementation of the Safe Drinking Water Act
(SDWA).  This report is part ..fa larger study by the SAB of regulating drinking
water radon levels, cost, uncer.i.nty of risk, and overarching issues.

      On February 8 and 9. '.'j'-M. the Radon Engineering Cost Subcommittee
(RECS) of the SAB's Drinking Water  Committee (DWC) conducted a review
focused on the following charge  :<> determine whether EPA offices are employing
a reasonable approach for estimating the costs of mitigating indoor radon from
drinking water in residences, and  whether the technologies that have been judged
by EPA as being Best Available Technology (BAT) for central or well-head
treatment for each size water  treatment-facility category are appropriate, and
whether the design, operation, installation and maintenance of these technologies
are reasonably estimated.  Additionally, the SAB was asked to address the relative
cost-effectiveness of controlling radon  exposure from drinking water in comparison
to controlling other sources of indoor  radon.  "Effective," in this context, means
the extent to which radon exposure is reduced by the treatment applied to produce
significant reductions in adverse health effects.  These results can be normalized

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using assumed dose-effect values.  The  findings and conclusions of the
Subcommittee follow.

1. Exposure Issues

      a)     The Subcommittee determined that the EPA offices are employing a
            reasonable framework for estimating the cost-effectiveness of
            mitigating airborne indoor radon from soil and water sources in
            residences.  The cost factors for testing and mitigation of soil gases
            are based on a substantial body of data from actual practice and
            represent the consensus of a group of industry experts.

      b)     Based on one national sampling survey, the  average concentration of
            radon in potentially regulated U.S. water supplies at point of use (not
            well head) is approximately 300 pCi/Lwater in groundwater systems
            (100 pCi/L when considering a population-weighted average of ground
            and surface  water systems); certain state and regional survey data
            were not included.  EPA estimates that a  300 pCifLw&ier standard
            would reduce total risk from radon by approximately 2.5%.  However,
            assuming an equilibrium ratio of 10,000 to 1, water to household  air,
            the average  contribution  to airborne radon from waterborne radon is
            estimated to be 0.01 pCi/L^^. This contrasts with an average
            indoor airborne radon concentration of between 1 and 1.5 pCi/L^ for
            all sources of airborne radon. Regulation  of waterborne radon then
            will reduce the total airborne radon risk (all sources of radon
            considered) by less than 1%. This contribution to the total reduction
            of risk (1%)  is lessened by the fact that a  regulatory limit on
            waterborne radon would reduce, not remove  radon from all water
            supplies. Current estimates are that a regulatory limit of 300
            pCi/Lwater would reduce the average U.S. concentration of waterborne
            radon to approximately 50% of the present value,  indicating that
            regulation of waterborne  radon at 300 pCi/Lvr&ter would reduce the
            total risk of airborne radon by less than 0.5% from the currently
            existing  risk. By whatever route one arrives at the calculation of
            total risk from radon, that is whether it is 0.5% or 2.5%, it most
            assuredly is  a small risk level compared to soil gas radon.

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      c)     The  wide discrepancy between the cost-effectiveness of mitigating
            water-borne radon versus soil gas radon underscores the minor role
            that waterborne radon plays in the overall indoor health hazard.  The
            EPA estimates that approximately 80 deaths (range 81-89) could be
            avoided per year by reducing all groundwater-based public systems to
            300 pCi/Lwater with the  maximum individual lifetime risk of fatal
            cancer reduced to 2 x 10" .

            The most recent cost estimates are about $400M per year, or about
            $5M per life saved. On the other hand, the primary source of radon
            in indoor air is soil gas  which  produces an ambient outdoor air
            concentration of about 0.4 pCi/L^, and an average indoor
            concentration of about 1.3 pCi/L^.  EPA estimates that if all homes
            with concentrations above 4 pCi/L^  were mitigated with present
            technology, then about 3,000 of the 13,600 yearly deaths (range 6740
            to 30,600 lung cancer deaths) attributed to indoor radon could be
            eliminated, and under this scenario, the cost per life saved would be
            about $700,000 and the  maximum individual lifetime lung cancer risk
                         o
            reduced to 10  .

2. Cost and Engineering Issues:

      a),    The Office of Ground water and Drinking Water (OGW&DW) has
            approached the development of the unit costs for the removal of
            radon from drinking water by the Packed Tower Aeration (PTA)
            method using a reasonable framework. Problems do arise in
            calculating the total unit costs, however, because of the assumptions
            made on the individual items that make up the total unit costs.
            Other water treatment authorities have made their own estimates,
            using nearly the same approach as OGW&DW, and have estimated
            different total costs.

      b)     With regard to consideration of alternative aeration technologies (that
            is, "engineered" versus  modular systems) with systems of different
            sizes: EPA's estimates are based on the use of a PTA for all system
            sizes.  Operation and Maintenance (O&M) costs are also based on  a

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            uniform approach for all sizes.  Actual costs and practice will vary
            with the size of the system installing the treatment.  Very small
            systems are likely to experiment with  a variety of their own informal
            designs as well as a variety of packaged systems and their  style of
            operation and interactions with the public and with regulatory
            agencies are likely to be more informal as well. Larger systems are
            likely to impose a more formal design, bid, and construction practice
            and engender closer regulatory review and greater public input.  If
            EPA's purpose  is to produce an estimate reflecting the most likely
            cost, then these estimates should better reflect the impact of system
            size on design practice.

      c)    Certainly PTA  is an effective technique for removing radon from
            groundwater and qualifies as Best Available Treatment (BAT) for
            central treatment.  However, there may also be a perceived problem
            in using PTA in certain localities because of off-gas dispersal.
            Granular Activated Carbon (GAC) was also discussed as a possible
            BAT.   EPA cited long contact times required and difficulties in
            disposing of waste GAC as reasons for rejecting this technology.  Yet.
            it seems that GAC has been demonstrated to remove radon, and  chat
            problems of waste disposal may be manageable where influent radon
         ,   levels are modest.  Additionally,  GAC may be a particularly  well
            suited technology for the smallest systems, since it could be  installed
            as an in-line pressure vessel not requiring repumping.

      d)    The cost of disinfection resulting from  radon PTA treatment is a
            significant factor in the cost of radon mitigation and should be
            explicitly stated for different size systems.  Groundwater can be
            distributed without disinfection only if the system has appropriate
            barriers to contamination by micro-organisms.  Also, the cancer r:.-lw
            associated with  exposures to disinfection by-products were not
            discussed.

3.  Recommendations:

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a)    We are pleased that the OGW&DW has recalculated their unit costs
      for Packed Tower Aeration (PTA) in response to the comments
      already received and recommend that they continue this iterative
      process with the commenters and work cooperatively with other
      responsible interested parties. We consider this necessary because we
      find merit in some  of the non-EPA data.

b)    We recommend that EPA review its choices for BAT and more
      carefully state the reasons for choices made reducing the cost of the
      GAG process.

c)    Since EPA's purpose is to produce an estimate reflecting the most
      likely cost of units, these estimates should more accurately reflect the
      impact of system size on design practice.

d)    The Subcommittee suggests that summary tables be included in the
      report that compare and contrast the  impact of several levels of radon
      exposure (e.g.  300 pCi/L^^ versus 1000 pCi/Lwater and 3000
      pCi/Lwater) on system and national costs including cancer deaths
      avoided at various confidence levels.  This would be most helpful to
      highlight the impact of various remediation efforts to members of
      Congress, the  states, various water treatment authorities and the
      interested public.

e)    The EPA analysis shows that mitigating radon from water as
      required by the SDWA, is  10 times more expensive than mitigating
      radon  from  soil gas. This regulatory requirement (policy) however,
      should not negate logical and practical considerations related to
      determining U.S. cost burdens, compared and contrasted to potential
      health benefits.

f)    One important part of the OGW&DWS cost calculations on which the
      SAB does want to comment specifically is  that of the Interest rate
      assumptions used.  Interest rate assumptions markedly impact  the
      annualized capital costs for radon removal from drinking water.  The
      operation and maintenance (O&M) costs are insensitive to interest

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            rates.  The SAB recommends that an Interest rate higher than the
            3% currently employed by the Agency be used.

      g)    The cost of disinfection resulting from radon treatment apparently
            has not been explicitly itemized In the cost of radon control and the
            SAB recommends that this oversight be  corrected.

      h)    The Subcommittee was provided with two thoughtful and detailed
            analyses by the American Water Works Association (AWWA) and the
            Association of California Water Agencies (ACWA).  This commentary
            was appreciated by the Subcommittee and provided insights and a
            greater diversity of opinion that was useful in our deliberations and
            should be considered by EPA in their reevaluation of the radon
            issues.

      i)     The SAB recommends that the OGW&DW participate in the
            upcoming "Radon Removal by Packed Tower Stripping" research
            project of the AWWA so that they can have their impact on  project
            design and data collection.

      j)     Finally, the SAB realizes that it has recommended considerable work
         i   to be done to make EPA's cost studies more creditable and therefore
            recommends that the EPA, if necessary, request  from the Courts and
            the Congress sufficient time to do the work.

      Subsequent to the February meeting of the Subcommittee and prior to the
publication of this SAB report, the OGW&DW provided  revised cost estimates to
the Subcommittee.  These estimates were  not available at the time of the public
meeting, and have not been given  the usual public scrutiny and discussion that is
such an integral part of all SAB meetings. Therefore, we have not addressed
them in this report.  However, we do recognize that the issues contained  in  the
revised estimates are of great interest and warrant further public and SAB
interaction in the future.

      The SAB has offered a number of broad-ranging, as well as specific findings
and recommendations on the Agency's  radon  engineering cost and treatment

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technology issues.  We are pleased to have had the opportunity to be of service to
the Agency.  We trust that these comments will help in your guidance of this
important program, and look forward to your response.

                             Sincerely,
               L. Ltohs
Dr. Raymond C. Loehr, Chair              Dr. Verne A. Ray, Cl
Executive Committee                      Drinking Water Committee
Science Advisory Board                    Science Advisory  Board

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                                  NOTICE

      This report has been written as a part of the activities of the Science
Advisory Board, a public advisory group providing extramural scientific
information and advice to the Administrator and other officials  of the
Environmental Protection Agency.  The Board is structured to provide a balanced,
expert assessment of scientific matters related to problems facing the Agency.
This report has not been reviewed  for approval by the Agency; hence,  the
comments of this report do not necessarily represent the views and policies of the
Environmental Protection Agency or of other federal agencies.  Any mention of
trade names or commercial products does not constitute endorsement or
recommendation for use.

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                                 ABSTRACT

      The Radon Engineering Cost Subcommittee (REGS) of the Drinking Water
Committee (DWC) of the EPA Science Advisory Board (SAB) has reviewed the
Agency's approach to the costs of radon control or mitigation experienced by
households or communities. On February 8 and 9, 1993, the Radon Engineering
Cost Subcommittee (REGS) of the  SAB's Drinking Water Committee (DWC)
conducted a focused review of the  cost issues.

      As part of its charge REGS  evaluated EPA's approach for estimating the
costs of mitigating indoor radon from drinking water in residences, assessed  EPA's
judgement on Best Available Technology (BAT) for central or well-head treatment
for each size water treatment-facility category are appropriate, and reviewed  cost
estimates  for design, operation, installation and maintenance of these technologies.
The SAB  also compared the cost-effectiveness of controlling radon exposure from
drinking water with the costs  of controlling other sources of indoor radon.
"Effective," in this context, means the extent to which radon exposure is reduced
by the treatment applied to produce significant improvements in health.  These
results can be normalized using calculated dose-effect values.

      The Subcommittee determined that the EPA offices are employing a
reasonable framework for estimating the cost-effectiveness of mitigating airborne
indoor raldon in residences. The approach for soil gases embodies standard Agency
and industry methodology, and the cost  data for testing and mitigation are based
on a substantial body of data from actual practice and represent the consensus of
industry experts.

      The Subcommittee recommends that  EPA invite more direct interaction with
various water industry commenters regarding radon removal from drinking water
in order to obtain better data  on actual  construction, operation, and cost
estimating practice before making  its independent judgements.  Of particular
concern were the representativeness of the  data base on occurrence of radon  in
groundwater, the elements used to calculate costs  of treatment unit operations, the
effect of system size on unit costs, and the  incidence and cost of disinfection  after
air stripping.
                                      11

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Kev Words:  Radon, Radon Engineering Cost, Radon Treatment
                                    111

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                            Science Advisory Board
                     Radon Engineering Cost Subcommittee
                          Drinking Water Committee
Dr. Verne A. Ray, Medical Research Laboratory, Pfizer, Inc.; Groton, Connecticut

  embes
Dr. Judy A. Bean, University of Miami, Department of Epidemiology, Miami,
Florida

Mr. Keith E. Cams, Cams, Perkins, Associates, Pinole, California

Mr. Richard A. Conway, Union Carbide Corporation, South Charleston, West
Virginia

Dr. Ben B. Ewing, Lu'mmi Island, Washington

Dr. James H. Johnson, Department of Civil Engineering, Howard University,
      Washington, DC

Mr. David W. Saum, Infiltec. Ir.c . Falls Church, Virginia

Dr. James M. Symons, Department of Civil and Environmental Engineering,
      University of Houston. Houston, Texas
        i
Dr. Vernon L. Snoeyink, Department of Civil Engineering, University of Illinois,
      Urbana, Illinois

Dr. Rhodes Trussell, James M  Montgomery Consulting Engineers, Inc., Pasadena,
      California

Dr. James EL Watson, Department of Environmental Sciences and Engineering,
      University of North Car..; ma. Chapel Hill, North Carolina

Invited T
Dr. Douglas Crawford Brown, University of North Carolina, Department of
      Environmental Sciences and Engineering, Chapel Hill, North Carolina

Science Advisory Board Staff:

Dr. K. Jack Kooyoomjian, Designated Federal Official, U.S. EPA, Science Advisory
      Board (A-101F), 401 M Street, SW, Washington, DC 20460

                                     iv

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Mrs. Diana L. Pozun, Staff Secretary, U.S. EPA, Science Advisory Board

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                      TABLE OF CONTENTS


1. EXECUTIVE SUMMARY	  1
     1.1  Overview	  1
     1.2  Occurrence and Risk Estimates	  2
     1.3  Reasonableness of Cost Estimates For Mitigating Radon  	  4
     1.4   The Technologies  for Central or Well-Head Treatment and
          Judgements on Best Available Technology  	  5
     1.5   The Cost Estimates of Design, Operation Installation and
          Maintenance of These Technologies for Each Size Range	  5

2. INTRODUCTION	  8

3. REGULATORY RATIONALE 	   10

4. OCCURRENCE AND RISK ESTIMATES	   12

5. RESPONSES TO THE CHARGE  	   16
     5.1  Response to Charge Question 1	   16
     5.2  Response to Charge Question 2	   17
          5.2.1 BAT Judgements  	   18
          5.2.2 Appropriate Technologies For Each Size Range	   18
     5.3  Response to Charge Question 3	    21

APPENDIX A REVIEW, BRIEFING AND BACKGROUND MATERIALS   .   A-l

APPENDIX B - LITERATURE  CITED   	   B-i

APPENDDC C - COST ESTIMATES AND UNCERTAINTY MEASURES ...   C-l

APPENDIX D - GLOSSARY OF TERMS AND ACRONYMS  	  D-l
                                VI

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                        1. EXECUTIVE SUMMARY
      This report presents the Science Advisory Board's (SAB) review of the
Agency's approach to the costs of radon  control or mitigation experienced by
households or communities.  Our findings and recommendations are aimed at
improving the Agency's overall approach.

1.1 Overview

      Radon in drinking water is  a two-fold concern in environmental health.  It
is a drinking water contaminant which can impact health through the ingestion
route as can many other contaminants regulated under the 1988 SDWA.  It also
can contribute to indoor air radon concentrations which expose  occupants through
inhalation.  Both concerns need to be addressed by the Agency,  but  it should not
ignore the issue of whether a regulatory  focus on waterborne radon  will
significantly reduce the health risk posed by radon in comparison with other viable
approaches.
       i
      It is recognized that current statutes mandate  that EPA regulate radon in
drinking water to reduce exposure to radon in homes, even though the
contribution of drinking water :o indoor  air radon concentration is quite small
compared with radon from soil emission.  But it is also recognized that radon
from water may yield potentially greater  health impacts through the combined
inhalation and ingestion routes than other water contaminants which are
regulated by EPA.

      The primary source of radon in indoor air is soil gas which produces  .m
ambient outdoor air concentration  of about 0.4 pCi/L^ ,  and an  average indoor
concentration of abbut 1.3 pCi/L,^. EPA estimates that if all homes with
concentrations above 4 pCi/L^ were mitigated with present technology, th«in .\'.»• .t

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3,000 of the 13,500 yearly deaths attributed to indoor radon could be eliminated.
Under this scenario, the cost per life saved would be about  $700,000.

      The contribution of waterborne indoor radon is much smaller, and it is
estimated by EPA that there is a ratio of about 10,000 to 1 (one) between the
water concentration and the increase in the indoor air concentration, with typical
household water use.  Therefore, 300 pCi/L in water contributes approximately
0.03 pCi/L^ to the indoor air concentration.  The EPA estimates that from 81 to
89 deaths (depending on the model) could be avoided per year by reducing all
ground-based public water systems  to 300 pCi/Lwater. The most recent cost
estimates are about $400M ($400,000,000) per year, or about $3.2M per life saved.

      This wide discrepancy between the cost-effectiveness of mitigating water-
borne radon versus soil gas radon  underscores the minor role that waterborne
radon plays in the overall indoor health hazard.  Still, its regulation is required
under the Safe Drinking Water Act (SDWA).

      The question addressed is: To what degree will regulation of radon in water
          i
bring about a reduction in exposure, and risk, to airborne radon in homes, and has
the U.S. EPA shown that a focus on waterborne radon is reasonable and cost-
effective in light of this goal?   The inclusion of non-inhalation pathways of
exposure, especially direct ingestion, does not significantly alter the conclusions
here. (NOTE: Estimates of exposure from direct ingestion were included in EPA's
analysis.)
 1.2  Occurrence and' Risk Estimates

      The occurrence data employed by the U.S. EPA in estimating exposures to
 airborne radon are both the best available and a reasonable basis for making such
 estimates-.  The affected population was determined based on a properly random

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national survey of indoor radon in U.S. homes.  The measurement technique
employed was alpha track detectors placed into homes for an entire year.  While
new data continue to be produced, it is unlikely that these data will significantly
change the existing estimates of the distribution of airborne radon concentrations
in U.S. homes.

      The contribution of waterborne radon to indoor air concentrations is less
well established.  Current estimates are that a regulatory limit  of 300 pCi/Lwater
would reduce the average U.S. concentration of waterborne radon to  approximately
50% of the present value, indicating that regulation of waterborne radon at 300
pCi/Lwate would  reduce the total risk of airborne radon by less than 0.5%  from
the currently existing risk.

      It  should be noted that homes with very high concentrations of waterborne
radon may contain a higher contribution of airborne radon from water.  A
waterborne radon concentration of 10,000 pCi/Lwater would yield an average
contribution of 1  pCi/L^, which is significant relative to  the national average.
Homes utilizing water with high radon concentrations, however tend  also to have
high airborne concentrations from subsoil sources.  The U.S. EPA should develop
estimates of the distribution of airborne radon contributions from waterborne
radon both in  the presence and in the absence of potential regulatory limits on
waterborne radon.

      The airborne risk estimates used by EPA are based on recommendations  of
the National Academy of Sciences's (NAS) Committee on  the Biological Effects of
Ionizing Radiation (BEIR).  These estimates are extrapolated from data obtained
from uranium  miners, and a modifying factor has been added to account for
differences between exposure conditions and physiological properties of individuals
in mines and homes.  Both the BEIR Committee and EPA have noted the
uncertainty in  these estimates.  The SAB's Radiation Advisory Committee (RAO
has reviewed this in the past and concurred with the EPA's risk estimates.   These

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uncertainties  in the risk estimates are reflected in the EPA's range of values for
the cost per life saved.

1.3 Reasonableness of Cost Estimates For Mitigating Radon

      The Subcommittee determined that the EPA offices are employing a
reasonable framework for estimating the cost and cost-effectiveness of mitigating
airborne indoor radon in residences. The approach embodies standard Agency and
industry methodology, focuses on existing homes, considers inhalation as the only
exposure pathway and does not differentiate by radon source (i.e., soil versus
water).  This approach includes the determination of the affected population,
determination of the cost for testing and mitigation, analysis of the risk reduction
from mitigation and calculation of the cost per life saved. The cost data for
testing of air and mitigation of subsoil sources are based on a substantial body of
data from actual practice and  represent the consensus of a group of industry
experts.

      In summary the Subcommittee considers the  approach to be  reasonable, and
the availability of the data from a national survey of indoor radon  and actual cost
data strengthen the final result.  The Subcommittee considers EPA's calculations
of cost per life saved to be based upon reasonable occurrence estimates, risk
estimates and cost  estimates.

      The Office of Groundwater and Drinking Water (OGW&DW) has
approached the development of the unit costs for the removal of radon from
drinking water by Packed Tower Stripping (PTS) in a reasonable manner.
Problems do arise in calculating the total unit costs, however, because of the
assumptions made on the individual items that make up the total unit costs.
Other water treatment authorities have made their own estimates,  using  nearly
the same approach as OGW&DW, and have estimated different total costs.  The
SAB does not wish to comment on which is the "correct" assumption for each

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component of the total, but does recommend that OGW&DW meet with these
other groups and their consultants to understand and resolve these differences.
The impact of significant differences can be severe in terms of national costs to
implement a radon rule.

1.4   The Technologies for Central or Well-Head Treatment and Judgements on
      Best Available Technology

      Certainly aeration is an effective technique  for removing radon from
groundwater and qualifies as BAT for central treatment.  However, there may be a
piecemeal problem in using Packed Tower Aeration (PTA) in certain localities
because of off-gas dispersal.  Granular Activated Carbon (GAG) was also discussed
as a possible BAT. EPA cited long contact times required and difficulties in
disposing of waste GAG as reasons for rejecting this technology. Yet, it seems
that GAG has been demonstrated to remove radon, .and that problems of waste
disposal may be manageable where influent radon levels are modest. Additionally,
GAC may be a particularly well-suited technology  for small systems, since it could
be installed as an in-line pres.su rp vessel not  requiring repumping.    We
recommend that EPA review its choices for BAT, more carefully state the reasons
for its choices made and estimate the likely number of systems using GAC and  the
attendant costs.
1.5   The Cost Estimates of IVsign, Operation Installation and Maintenance of
      These Technologies for Kach Size Range

      The basic approach the KPA is taking reflects a standard framework to cost
estimation: compiling and analyzing data on occurrence, determining the likely
technology to be used, and estimating the cost of technology implementation as a
function, of the water quality and system size.  However, there are three concerns
that the SAB has  about these estimates: a) the basic objective of the cost

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estimation process,  b)  the consideration of the relationship of system size, style
of design and operation, and c) whether the costs are appropriately estimated?

      It is unclear whether EPA's purpose is to estimate the costs industry will
most likely incur  as a  result of the radon regulations or to estimate the lowest
possible cost industry could incur.  There was extensive discussion on this point by
the Subcommittee at its review meeting of February 8, 1993.  In either case, EPA
would do well to invite more direct interaction with various commenters  to obtain
better data on actual construction, operation, and cost estimating practice before
making its independent judgements.

      With regard to consideration of alternative  aeration technologies at different
sizes: EPA's estimates are based on the use of a PTA for all system sizes.
Operation and Maintenance (O&M) costs are also based on a uniform approach for
all sizes. Actual practice is likely to vary with the size of the system installing the
treatment.  Some experience might be gained from the volatile organic carbon
(VOC)  rule here.  Very small systems  are likely to experiment with a variety of
their own informal designs as well as  a variety of packaged systems and  their
style of operation and interface with the public and with regulatory agencies is
likely to be more informal as well. Larger systems are likely to impose a more
formal  design, bid, and construction practice and experience closer regulatory
review  and greater public input.  If EPA's purpose is to produce an estimate
reflecting the most likely cost, then these estimates should better reflect the
impact of system size on design practice.

         Interest rate assumptions markedly impact the annualized capital costs for
radon removal from drinking water.  O&M costs are insensitive to interest  rates.
Capital improvements for many small  systems require interest rates of 10% or
higher.  Annual costs for radon removal by PTA were based on a three percent
interest rate. The impact of a 10 percent interest was also evaluated, but the
emphasis was on a three percent interest rate.  The SAB recommends that  an

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 interest rate higher than the 3% currently employed by the Agency be used.  The
 cost of disinfection resulting from  radon PTA treatment  is a significant factor in
 the cost of radon mitigation and should be explicitly stated for different size
 systems.  Groundwater can be distributed without disinfection only if the system
 has appropriate barriers to contamination by micro-organisms.  Also, the cancer
 risks associated with exposures to  disinfection by-products  were not discussed.

       It would be most helpful to  members of Congress,  the states, various water
 treatment authorities and the interested public to have the Agency's presentation
 and summary of data, as well as the Agency's recommendations succinctly
 presented in the report to Congress in a few  well-planned and clearly labeled
 summary tables, histograms  or charts.  This will serve to focus the many issues
 onto the key recommendations of the Agency, and to obtain a summary of the
- trade-offs involved with this issue.

       Finally, the SAB recommends that the  OGW&DW participate in the
 upcoming "Radon Removal by Packed Tower Stripping" American Water Works
 Association (AWWA) research project so that  they can have their input on project
 design and data collection.  This will make the output of  this important study as
 useful to OGW&DW as possible.

       In summary, the SAB  is pleased  that the OGW&DW  has recalculated their
 unit costs for PTA in response to the comments already received and the SAB
 recommends that they continue this iterative  process with the commenters and
 work cooperatively with other responsible interested parties.

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                           2. INTRODUCTION
      At the request of the Office of Drinking Water (ORD), the Radon
Engineering Cost Subcommittee (REGS) of the Science Advisory Board's (SAB)
Drinking Water Committee (DWC) met on February 8 and 9, 1993 to review
background reports and documents related to the cost of mitigating indoor radon.
(See Appendix A - References 1-6, 10-13, and 15). The Subcommittee was made
up of members of the DWC, the Radiation Advisory Committee (RAG), and the
Environmental Engineering Committee (EEC).  Presentations by EPA staff (J.W.
Conlon, F. Marcinowski, M.J. Parrotta, M. Cummins, JA Auerbach, and others.
See Appendix A - Reference 11.) were also heard by the Subcommittee.

       The statement of charge to the Subcommittee, as accepted by the
Subcommittee, was as follows:

      a)    To determine whether the EPA is employing a reasonable approach
            for estimating the coat of mitigating indoor radon from drinking
            water in residence.

      b)    To assess whether the EPA has made appropriate judgements of Best
            Available Techno!.»y iBAT) for central of well-head treatment of each
            size water treatment facility category, and whether  the cost estimates
            of design, operation installation and maintenance of these
            technologies are accurately estimated; and
                                     8

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      c)    To address the relative cost-effectiveness of controlling radon
            exposure from drinking water in comparison to controlling other
            sources of indoor radon.

Each of the three elements of the charge are addressed below.
 i   ^'Effective" in this context means the extent to which radon exposure is reduced
by the treatment applied to produce significant improvements in health.

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                      3. REGULATORY RATIONALE
      The history of concern over radon in water (See, for instance, Appendix B -
References 1-3, 5, and  7-9) provides the framework within which the following
discussion must be placed. That history is that (a) radon was found to be a source
of risk in mining populations exposed to airborne radon,  (b) airborne radon was
found in indoor air of homes, (c) radon was found in water supplies  in the U.S.,
and (d) radon was found to emanate from water to air in homes.  It was
concluded that waterborne radon might pose a potential risk to human health
through its contribution to the  concentration of airborne  radon in homes (See, for
instance, Appendix B, Reference 5).

       Subsequent risk analyses performed by the U.S. EPA and others indicated
that emanation from water to air is not the only route of exposure to waterborne
radon (See, for instance, Appendix B,  References 7-9), direct ingestion also being of
potential significance based on  calculation, the historical focus  on airborne  radon
remains.  Even if ingestion exposures  are considered, the conclusions of this report
are not altered. This raises the issue of whether a regulatory  focus on waterborne
radon will significantly affect the health risk posed by radon in the general
environment.  The present section examines the three goals of any potential radon
policy.

      The first goal is to  reduce the risk from waterborne pollutants. This goal
requires an answer to the question of whether waterborne radon produces a
significant additive risk and whether a focus on waterborne radon, rather than on
other pollutants, is a reasonable means for reaching a significant reduction in
health risk.  The second goal might be to reduce the risk from environmental
radon.  This" requires an answer to the question of whether environmental  radon
produces a significant risk and   whether a focus on waterborne radon will
reasonably reduce the overall risk  posed by environmental radon.  The  third goal
                                      10

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might be to reduce the overall environmental risk from all sources of risk. The
question to be addressed here is whether a focus on environmental radon will be
the most effective means to reach this goal (See, for instance, Appendix B,
References 4 & 6 pertaining to reducing risk).

      The following discussion focuses only on the second policy goal.  The
question addressed is:  To what degree will regulation of radon in water bring
about a reduction in exposure, and risk,  to airborne radon in homes, and has the
U.S. EPA shown  that a focus on waterborne radon is reasonable and cost-effective
in light of this goal? It is presumed that inclusion of non-inhalation pathways of
exposure, especially direct ingestion, does not significantly alter  the conclusions
here.
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               4. OCCURRENCE AND RISK ESTIMATES
      The occurrence data employed by the U.S. EPA in estimating exposures to
airborne radon are both the best available and a reasonable basis for making such
estimates.  The affected population was determined based on a  random national
survey of indoor radon in U.S. homes.  The measurement technique employed was
alpha track detectors placed into homes for  a year. While new data continue to
be produced,  it is unlikely that these data will significantly change the existing
estimates of the distribution of airborne radon concentrations in U.S. homes.

      The  contribution of waterborne radon to indoor air concentrations is less
well established for two reasons.  First, the occurrence data on waterborne radon
continue to be weakened by considerations of sample size and conflicting sets of
data. Second, the equilibrium ratio between airborne radon concentration (as
produced by only waterborne radon) and the waterborne radon concentration is
not well established. At  present, the estimate of 1 per 10,000 for this ratio as
adopted by the U.S. EPA is  reasonable in light of the existing data  but must be
viewed  as preliminary.  An equilibrium ratio of  1 per 10,000 is assumed in this
discussion.

      The average concentration of radon in potentially  regulated U.S. water
supplies is estimated by EPA to be approximately 300 pCi/Lvrater in groundwater
systems (100 pCi/Lwater when considering a population-weighted average of ground
and surface water systems).   EPA estimates that a 300 pCi/Lwater standard would
reduce total risk from radon by approximately 2.5%  (See Appendix B - references
11 and  12, as well as memo dated 4/20/93 from Douglas  Crawford-Brown,  which
includes relevant citations.)  Assuming an equilibrium ratio of 10,000 to 1, water
to household air, the average contribution to airborne radon from waterborne
radon is estimated to be  0.01 pCi/L^.  This contrasts with an average indoor
airborne radon concentration of between  1 and 1.5 pCi/L  for all sources of
                                      12

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airborne radon. Regulation of waterborne radon then will reduce the total
airborne radon risk (all sources of radon considered)  by less than 1%.  By
whatever route one arrives at the calculation of total risk from radon, that is
whether it is 0.5% or 2.5%, it most assuredly is a small risk level compared to soil
gas radon.

      This contribution to the total reduction of risk (1%) is lessened by the fact
that a regulatory limit on waterborne radon would reduce, not remove radon from
all water supplies. Current estimates are that a regulatory limit of 300 pCi/Lvnter
would reduce the average U.S. concentration of waterborne radon to approximately
50% of the present value, indicating that regulation of waterborne radon at 300
pCi/Lwater would reduce the total risk of airborne radon by less than 0.5% from
the currently existing risk.

      It should be noted that homes with very high concentrations of waterborne
radon may contain a higher contribution of airborne radon from radon emanated
by water. A waterborne  radon concentration of 10,000 pCi/Lwater would yield an
average contribution of 1 pCi/Lair, which is significant relative to the  national
average., Homes utilizing water with high radon concentrations, however tend also
to have high airborne concentrations from other sources. The U.S. EPA should
develop estimates of the distribution of airborne radon contributions from
waterborne radon both in the presence and in the absence of potential regulatory
limits on waterborne radon.

      The risk estimates used by EPA are based on recommendations of the
NAS's Committee on the Biological  Effects  of Ionizing Radiation  (BEIR).  These
estimates are extrapolated from data obtained from uranium miners, and a
modifying factor has been added to  account for differences between exposure
conditions and physiological properties of individuals in mines and homes.   Both
the  BEIR Committee and EPA have noted the uncertainty in these estimates. The
SAB's Radiation Advisory Committee (RAO has reviewed and concurred with the
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EPA's risk estimates.  These uncertainties are in the risk estimates are reflected
in the EPA's range of values for the cost per life saved.

       The Subcommittee notes that two major points related to epidemiology that
were not covered in the meeting.  First, the miner risk data is for exposures
considerably higher than the 4 pCi/L^ action level recommended for homes, and
the linear extrapolation to 4 pCi/L^ has been the subject of controversy in the
past.  In the case of the very small incremental change in radon levels from water
contributions (0.03 from 300 pCi/L^^, there is some question as to its effect if
the initial house levels are also very  low (e.g., house at 0.5 pCi/L^ and water
contribution of 0.03 pCi/L^ results in a net 0.53 pCi/L^p.  The linear
extrapolation becomes even more questionable at the low levels.  Second, the risk
.to non-smokers is at least a factor of 10 lower than the risk to smokers.

       The Subcommittee determined that the EPA offices are employing a
reasonable framework for estimating the cost and cost-effectiveness of mitigating
airborne indoor radon in residences.  The approach embodies standard Agency and
industry methodology, focuses on existing homes, considers inhalation as the only
exposure 'pathway and does not differentiate by radon source (i.e., soil versus
water).  The cost data for testing and mitigation of radon in indoor air are  based
on a substantial body of data from actual practice and represent the consensus of
industry experts.

       The national costs for testing and mitigation are based on an action level of
4 pCi/L^ and a mitigation reduction level of 2 pCi/L^. (The action, level
corresponds to 224 Lung Cancer Deaths (LCDs) per  million). The national  radon
mitigation costs are based on the summed weighted costs for installation, O&M for
various  mitigation methods and foundation types.

       In summary the Subcommittee considers EPA's calculations of cost per life
saved appear to be based upon reasonable occurrence estimates, risk estimates and
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cost estimates; however, much of these data are in a continuing state of evolution
and refinement.
                                     15

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                    5. RESPONSES TO THE CHARGE

5.1 Response to Charge  Question 1

      Charge 1: To determine whether EPA is employing a reasonable approach
      for estimating the  cost of mitigating indoor radon from ambient and
      drinking water sources in residences.

      The Subcommittee determined that the EPA offices are employing a
reasonable approach for estimating the cost-effectiveness of mitigating airborne
indoor radon in residences.  The approach embodies standard Agency and industry
methodology, focuses on existing homes, considers inhalation as the only exposure
pathway and does not differentiate by radon source (i.e., soil versus water) in its
occurrence estimates. This approach includes the determination of the affected
population, determination of the cost for testing and mitigation, analysis of the
risk reduction from mitigation and calculation of the cost per life saved.

      The affected population was determined based on a national  survey of
indoor radon in U.S. homes!  The survey was conducted using alpha track
detectors which were placed in homes for a full year.  Cost data for testing and
mitigation are based on a substantial body of data from actual practice. The risk
estimates used by EPA are based on recommendations of the National Academy  of
Science's Committee on the Biological Effects of Ionizing  Radiation (BEIR).  These
estimates are extrapolated from data obtained from uranium  miners, and a
modifying factor has been added to account for differences between exposure
conditions and physiological properties of individuals in mines and homes.  Both
the BEIR Committee and the EPA have noted the uncertainty of these estimates.
The SAB's Radiation Advisory Committee has reviewed and concurred with the
EPA's risk estimates. In addition to the uncertainty in the risk estimates, there
are other uncertainties that are reflected in the EPA's range of values for the cost
per life saved.  In summary,  the  Subcommittee considers the approach to be
                                      16

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reasonable, and the availability of the data from a national survey of indoor radon
and actual cost data support the Agency's final result.

      The contribution of waterborne radon to indoor air concentrations is less
well established for two reasons. First, the occurrence data on waterborne radon
continue to be weakened by considerations of sample size and  conflicting sets of
data. Second, the equilibrium  ratio between, airborne radon concentration (as
produced by only waterborne radon) and the waterborne radon concentration is
not well established.  At present, the estimate of 1 per 10,000  for this ratio as
adopted by the U.S. EPA is reasonable in light of the existing  data but must be
viewed  as preliminary.  An equilibrium ratio of 1 per 10,000 is assumed in this
discussion.

      The average  concentration of radon in potentially regulated U.S.  water
supplies is approximately  300  pCi/Lwater in groundwater systems (100 pCi/Lwater
when considering a population-weighted average of ground and surface water
systems).  EPA estimates  that a 300 pCi/Lwater standard would reduce total risk
from radon by approximately 2.5%.   (See Appendix B  - references 11 and 12, as
well as  memo  dated 4/20/93 from Douglas Crawford-Brown, which includes
relevant citations.)  Assuming an equilibrium ratio of 10,000 to 1, water to
household air, the average contribution to airborne radon from waterborne radon
is estimated to be 0.01 pCi/L^. This contrasts with an average indoor  airborne
radon concentration of between 1 and  1.5  pCi/L^ for all sources of airborne
radon.  Regulation of waterborne radon then will reduce the total airborne radon
risk (all sources of radon considered) by less than 1%.  By  whatever route one
arrives  at the  calculation of total risk from radon, that is whether ft is 0.5% or
2.5%, it most assuredly is a small risk level compared to soil gas radon.

5.2  Response  to Charge Question 2
                                      17

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      Charge 2: To assess whether the EPA has made appropriate judgements of
      Best Available Technology [BAT] for central or well-head treatment of each
      size water treatment-facility category, and whether the cost estimates of
      design, operation installation and maintenance of these technologies, are
      accurately estimated.

      The  question of BAT will be  discussed in two parts: 1) Are EPA's BAT
Judgments appropriate?, and 2) Are appropriate technologies selected for each size
range?

5.2.1  BAT Judgements

      Certainly aeration is an effective technique for removing radon from
groundwater and qualifies as BAT.  Granular Activated Carbon (GAC) was also
discussed as a possible BAT.  EPA cited long contact times required and
difficulties  in disposing of waste GAC as reasons for rejecting this technology.  Yet
is seems that GAC has been demonstrated to remove radon, and  that problems of
waste disposal may be manageable where influent radon levels are modest.
Moreover, GAC may be a part:c-_:arly important technology for small systems,
because the units would be small, regardless of the longer contact time, and more
importantly, can be applied a*  i pressure vessel not requiring repumping.
Moreover there may also be a pr-jblem in using Packed Tower Aeration (PTA) in
certain localities because of oif m  dispersal and the cost of repumping.
Additional  community aesthetic concerns deal with the unsightly  character of air
towers.   We recommend that EPA reconsider its choices for BAT and more
carefully state the reasons for its  choices made, as well as estimate the likely
number of systems using GAC and  the attendant costs.

5.2.2  Appropriate Technologies For Each Size Range
                                      18

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      There are three concerns that the SAB has about these estimates:  a) the
basic objective of the cost estimation process, b)  the consideration of the
relationship of system size style of design  and operation, and c) are the costs
appropriately estimated?

      a)     Basic objectives; It is unclear  whether EPA's purpose is to estimate
             the costs industry will most likely incur  as  a result of the radon
             regulations or to estimate the lowest possible cost industry could
             incur.  There was extensive discussion on this point by the
             Subcommittee at its review meeting of February 8,  1993.  In either
             case, EPA would do well to invite more direct interaction with
             various commenters to obtain better data on actual construction,
             operation, and cost estimating practice before making its independent
            judgements.

      b)     Consideration of alternative aeration technologies at different sizes:
             EPA's estimates are based on the use of PTA for all system sizes.
             O&M costs are also based on  a uniform approach for all sizes.  Actual
            practice is likely to vary with  the size of the system installing the
            treatment. Some experience might be gained from the VOC rule here.
            Very small systems are likely  to experiment with a variety of their
            own informal designs as well as a variety of packaged systems and
            their style of operation and interface with the public and with
            regulatory agencies is likely to be more informal as  well.  Again, GAG
            may be a particularly well-suited technology for small systems, since
            it could be installed as an in-line pressure vessel not requiring
            repumping.  Larger systems are likely to impose a more formal
            design, bid, and construction practice and experience closer regulatory
            review and greater public input.  Larger  systems  also often have
            wells in residential areas and  are required by local planning boards to
            design the facility  to blend in  with the surrounding  homes.  These
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      requirements significantly increases costs.  If EPA's purpose is to
      produce an estimate reflecting the most likely cost, then these
      estimates should better reflect the impact of system size on design
      practice.

c)     Costs Appropriately Estimated:  The basic approach the EPA is
      taking to cost estimation, that is, compiling and analyzing data on
      occurrence, determining the likely technology to be used, and
      estimating the cost of technology implementation as a function of the
      water quality and system size are appropriate.

d)    Additional Considerations: (Refer to Appendix C - Tables of Cost
      Estimates and Uncertainty Measures.)

      (1) The EPA analysis was of drinking water mitigation, and only
      considered the cost per life saved for an aggregation of all  sizes of
      central water systems, but this data can be used to determine the cost
      per life saved for each system size category.  When this is  done, the
      largest systems show a cost of less than $500,000 per life saved, and
      the smallest systems .show a cost of over $50M per life saved.  This
      disaggregation su^v.sts that central system mitigation mav not be
      economical for th<» smaller systems.  Continuing this line of analysis,
      systems with very high radon concentrations might be analyzed
      separately, and PTA might be shown to be cost-effective (e.g., a small
      system with 30,000 pCi/Lwater rather   than the assumed 300
      pCi/Lwater would have a cost-effectiveness of about $500,000 per life
      saved).. The Subcommittee recommends that the EPA use  this type of
      disaggregated analysis.

      (2) If central water system mitigation is not cost-effective  for some
      systems, then other  non-central radon  mitigation technologies rr.-.ijht
                                20

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             be investigated so that mitigation advice or assistance can be provided
             to the public at risk.  From the EPA analysis of air and water
             mitigation, the effectiveness of installing a standard soil gas radon
             mitigation system in-house with water radon problems can be
             estimated. Assuming a background of 0.4 pCi/L^,  an average house
             level of 1.3 pCi/L^, and a mitigation system  effectiveness of 50%,
             radon levels could be lowered  OA5pCi/L^r for a cost of about $185
             per year.  The cost per life saved is about $1.2M per year.  The
             Subcommittee recommends that the EPA use this type of analysis to
             investigate the cost of standard soil gas  mitigation as an alternative
             to central system treatment.

             (3)  In the small central water systems,  where central radon
             mitigation might not be cost-effective, there may be  very simple non-
             central system mitigation systems that would provide even more  cost-
             effective mitigation than the standard Active Sub-Slab
             Depressurization (ASD) systems (for soil gas  mitigation).  For
             instance, entry from washing clothes or showering might be mitigated
             with exhaust fans, and drinking water might be filtered with a very
             small GAG system  The Subcommittee recommends  that  the EPA
             study new types of low cost mitigation alternatives and perform
             research if necessary.
5.3 Response to Charge Question 3

      Charge 3: To address the relative cost-effectiveness^ of controlling radon
      exposure from drinking water in comparison to controlling other sources of
      indoor radon.
    V ji». ——
      Effective" in this context means the extent to which radon exposure ;s .'•••:
by the treatment applied to produce significant improvements in health.
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      Radon in drinking water is a two-fold concern in environmental health.  It
is a drinking water contaminant which can  impact health through the ingestion
route as can many other contaminants regulated under the 1988 SDWA.  It also
can contribute to indoor air radon concentrations which expose occupants through
inhalation.  Both concerns need to be addressed by the Agency.

      The SAB review of the EPA approach to evaluation of the overall indoor
airborne radon exposure and its mitigation cost-effectiveness has been discussed
above under Charge 1.  The cost-effectiveness  of mitigation of radon in water in
comparison to controlling other sources of indoor radon is discussed here.

      It is recognized that current statutes  mandate that  EPA regulate radon in
drinking water to reduce exposure to radon in homes,  even though the
contribution of drinking water  to indoor air concentration is quite  small compared
with radon from  soil emission.  But it is also recognized that radon from water
yields potentially greater health impacts  through the combined inhalation  and
ingestion  routes than do the concentration of many other  water contaminants
which are regulated by  EPA.

      The primary source of radon in indoor air is soil gas which  produces an
ambient outdoor  air concentration of about 0.4 pCi/L^, and an average indoor
concentration of about 1.3 pCi/L^.  EPA estimates that if all homes with
concentrations above 4 pCi/L^ were mitigated with present technology, then about
3,000 of the 13,500 yearly deaths attributed to indoor radon could  be eliminated.
Under this scenario* the cost per  life saved would be about $700k.

      The contribution of waterborne indoor radon is much smaller, and it is
estimated that there is a ratio of about  10,000 to (1) one between the water
concentration and the increase  in the indoor air concentration, with typical
household water  use. Therefore,  300 pCi/Lwater in water contributes
approximately 0.03 pCi/L^ to the indoor air concentration.  The EPA estimates
                                      22

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that approximately 80 deaths could be avoided per year by reducing all ground-
based public water systems to 300 pCi/Lwater.  The most recent cost estimates are
about  $400M per year, or about $3.2M  per life saved.

      This wide discrepancy between the cost-effectiveness of mitigating
waterborne radon versus soil gas radon  underscores the minor role that
waterborne radon plays in the overall indoor health hazard.  Still, its regulation is
required under the SDWA. This regulatory policy, however,  should not negate the
logic and practical considerations that relate to determining U.S. cost burdens.

      The Office of Groundwater and Drinking Water (OGW&DW) has
approached the development of the unit  costs for the removal of radon from
drinking water by PTS in a reasonable manner.  Problems do arise in calculating
the total unit costs, however, because of the assumptions made on the individual
items that make up the total unit costs.  Other thoughtful  groups have made their
own estimates, using nearly the same approach as OGW&DW, and have estimated
different total costs.
         i
      The SAB does not wish to comment on which is the "correct" assumption
for each component of the total, but does recommend that OGW&DW meet with
these other groups and their consultants to understand these differences.  The
result of these meetings probably will be a range  of costs, the low end being a
"bare bones" system that smaller systems might install, the high end being a
"engineered" system that a larger system might install.  This  result would have
two advantages; one, the assumptions supporting the cost for each system would
be clearly delineated and two, OGW&DW would have a better understanding of
the expected range of costs around their  estimate of "best",  rather than the
assumed 20 percent lower and 30 percent higher that is now  being used.

      One important part of the OGW&DW's calculation on which the SAB
want to comment specifically is that of the interest rate assumptions used.
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Interest rate assumptions markedly impact the annualized capital costs for radon
removal from drinking water.  O&M costs are insensitive to interest rates.
Capital improvements for many small systems require interest rates of 10% or
higher.  Annual costs for radon removal by Packed Tower Aeration (PTA) were
based on a three percent interest rate.  The impact of a 10 percent interest was
also evaluated, but the emphasis was on a three percent interest rate.  The SAB
recommends that an Interest rate  higher than the 3% currently employed by the
Agency be used.

        The cost of disinfection resulting from radon PTA treatment is a
significant factor in radon cost mitigation and should be explicitly stated for
different size systems. Systems that require PTA, which are not now disinfected,
will require disinfection.  Groundwater can be distributed without disinfection only
if the  system has appropriate barriers to contamination by microorganisms.  PTA
introduces the possibility of such contamination, and, thus, disinfection is required.
The cost of such disinfection  has  not been  explicitly itemized in the cost of radon
control, and the  SAB recommends that this oversight be corrected.  The
Subcommittee understands,  based  on  subsequent discussions with OGW&DW staff,
that the 'cost of disinfection varies considerably based on system size.  For
instance, predominantly small systems have costs for disinfection ranging typically
from $100 to $200/year/household, while large systems may only cost a few dollars
per household per year.  It is the Subcommittee's view that costs of disinfection,
especially in small systems,  needs  to be reviewed thoroughly.

       In summary, the SAB is pleased that the OGW&DW has recalculated their
unit costs for PTA in response to  the comments already received and the SAB   ;
recommends that they continue this iterative process with the commenters and
works cooperatively with other responsible interested parties.

       Finally, the SAB recommends that the OGW&DW participate in the
upcoming. "Radon Removal by Packed Tower Stripping" American Water Works
                                      24

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Association research project so that they can have their input on project design
and data collection and consider the new AWWA and ACWA documents in their
future review.  This  will make the output of this important study as useful to
OGW&DW as possible.

      Currently, the EPA has considered PTA as the only feasible BAT.  However,
the Subcommittee.considers that treatment with GAG should be revisited,
especially since it would enable a system to use it as an in-line pressure vessel, not
requiring repumping. It could also eliminate the  need for disinfection.
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                             APPENDIX A

       REVIEW, BRIEFING AND BACKGROUND MATERIALS
1)     Cummins, Michael D., Memorandum to Marc. Parrotta, entitled "Removal
      from Contaminated Ground Water by Packed Column Air Stripping, " U.S.
      EPA, Water Supply Technology Branch, Cincinnati, Ohio, April 26, 1988

2)     Cummins, Michael D., Memorandum to Marc Parrotta entitled "Packed
      Tower Aeration Cost Estimates for Radon Removal,"  U.S. EPA, Office of
      Ground Water and Drinking Water, Technical Support Division, March  11,
      1992

3)     Longtin, Jon (Project Engineer, TSD) and Denning, George (Economist,
      OPD&E), "Draft for Discussion with QAMS of the Data Quality Objectives
      for the National Inorganics and Radionuclides Survey," Technical Support
      Division, Office of Drinking Water, Office of Water, U.S. EPA, Cincinnati,
      Ohio, March 8, 1985

4)     Mills, William R., Stephen K. Hall and Thomas  E. Levy, Letter to Carol M.
      Browner, Raymond C. Loehr, Genevieve Matanoski, and Verne Ray from the
      Alliance  for Radon Reduction, February 2, 1993

5)     Cummins, Michael D. Memorandum to Marc Parrotta entitled "Simplified
      Equations for Estimating Radon Removal Cost via Packed Tower Aeration,"
      U.S. EPA, Office of Ground Water and Drinking Water, Technical Support
      Division, July 16, 1992

6)     Parrotta, Marc, Memorandum to Addressees entitled "Cost Modeling
      Update," U.S. EPA, Office of Water, February 21, 1992

7)     Saum, David, Memorandum to Members of the SAB Radon Engineering
      Cost Subcommittee, dated February 3, 1993

8)     Sullivan, John H., Letter to Carol Browner Pertaining to National Primary
      Drinking Water Regulations: Radionuclides (Radon) [WH-FRL 3956-4], from
      the Government Affairs Office of the American Water Works Association,
      January 26, 1993

9)     U.S. Congressional Record - Senate, S15103, Sec. 591 SAFE DRINKING
      WATER ACT IMPLEMENTATION, September  25, 1992

10)   U.S. EPA, "Addendum to The Occurrence and Exposure Assessments for
      Radon, Radium-226, Radium-228, Uranium and  Gross Alpha Particle
      Activity in Public Drinking Water Supplies, " (Revised Occurrence  Estimates

                                   A-l

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      Based on Comments to the Proposed Radionuclides regulation), A Draft
      Document Prepared by Wade Miller Associates, Inc. under EPA Contract
      No. 68-CO-0069, Work Assignment 1-32, for the Office of Ground Water and
      Drinking Water, September 30, 1992

11)   U.S. EPA, Briefing Materials by Dr. Janet A. Auerbach, Mr. James M.
      Conlon, Mr. Michael Cummins, Mr. Frank Marcinowski,  and Mr.  Marc J.
      Parrotta, February 8, 1993

12)   U.S. EPA, "National Primary Drinking Water Regulations;  Radionuclides;
      Proposed Rule, 40 CFR Parts 141 and 142," Federal Register. Vol. 56, No.
      138, pages 33050 to 33127, July 18, 1991 (Attention to the cost components
      in the Table of Contents, Section V, where the mitigation technologies and
      the  costs are discussed.)

13)   U.S. EPA, "Regulatory Impact Analysis of Proposed National Primary
      Drinking Water Regulations for Radionuclides," Prepared by Wade Miller
      Associates, Inc. under EPA Contract No. 68-CO-0069, Work Assignment No.
      0-1  for the Office of Drinking Water, Washington, D.C., July 17, 1991

14)   U.S. EPA, "Technical Support Document for the 1992  Citizen's Guide to
      Radon," Office of Air and Radiation (ANR-464), EPA 400-R-92-011, May 20,
      1992

15)   U.S. EPA, "Technologies and Costs for the Removal of radionuclides from
      Potable Water Supplies," Prepared by Malcom Pirnie, Inc. for the Drinking
      Water Technology Branch, Office of Ground Water and Drinking Water,
      July 1992 (NOTE: This is the primary review document.)
                                    A-2

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                 APPENDIX B - LITERATURE CITED

1)    Safe Drinking Water Act Amendments of 1986, Public Law 99-339, 100
      STAT 642

2)    Departments of Veterans Affairs and Housing and Urban Development, and
      Independent Agencies Appropriation Act, 1993, PUB.  L. 102-398, Section
      519, 106 STAT 1618 (1992) (This is the citation adopted from the
      Congressional Record (See Reference #3, below) that  requires the EPA
      Study of Radon.)

3)    U.S. Congressional Record - Senate, S15103, Sec. 591  SAFE DRINKING
      WATER ACT IMPLEMENTATION, September 25, 1992

4)    U.S. EPA, "Safeguarding the Future; Credible Science, Credible Decisions,"
      The Report of the Expert Panel on the Role of Science at EPA, [Panel
      members are Raymond C. Loehr, Chairman, Bernard  D. Goldstein, Anil
      Nerode and Paul G.  Risser],  EPA/600/9-91/050, January 8, 1992

5)    U.S. EPA, "Technical Support Document for the 1992  Citizen's Guide to
      Radon," Office of Air and Radiation (ANR-464), EPA 400-R-92-011, May 20,
      1992

6)    U.S. EPA/SAB, "Reducing Risk: Setting Priorities and Strategies for
      Environmental Protection. SAB-EC-90-021, September 25, 1990

7)    U.S. EPA/SAB, "Review of the Office of Drinking Water's Assessment of
      Radionuclides in Drink:r.^ Water and  Four Draft Criteria Documents: Man-
      Made Radionuclide Occurrence, Uranium, Radium, Radon," Prepared by the
      Drinking Water Subcorr.m;::ee of the Radiation Advisory Committee of the
      Science Advisory Board. KPA-SAB-RAC-87-035, July 27, 1987

8)    U.S. EPA/SAB, "Status  .1 Radionuclide Models," Prepared by the Radiation
      Advisory Committee  of the Science  Advisory Board, EPA-SAB-RAC-92-001,
      January 9, 1992

9)    U.S. EPA/SAB, "Revised Radon Risk Estimates and Associated
      Uncertainties," Prepared by the Radiation Advisory Committee of the
      Science Advisory Board. EPA-SAB-RAC-LTR-92-003, January 9, 1992
                                    B-l

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10)   U.S. EPA/SAB, "Review of Draft Criteria Documents for Radionuclides in
      Drinking Water," [Drinking Water Criteria Document for Uranium,
      November 1989; External Review Draft for the Quantification of
      Toxicological Effects Document on Radium, (TR-1242-67), 10 July  1990;
      Quantitative Risk Assessment for radon in Drinking Water, May 1990; and
      Quantitative Risk Assessment for Beta Particle and Gamma Emitters in
      Drinking Water, May 1990], Prepared by the Radionuclides in Drinking
      Water Subcommittee of the Radiation Advisory Committee  of the Science
      Advisory Board, EPA-SAB-RAC-92-009, January 9, 1992

11)    Longtin, Jon "Occurrence of Radionuclides in Drinking Water: A National
      Study," p. 97 Radon. Radium and Uranium in Drinking Water, edited by C.
      Cothern and P. Rebers, Lewis Publishers, Cheslea, Michigan, 1990

12)   Milvy, P. and C. Cothern, "Scientific Background for the  Development of
      regulations for Radionuclides in Drinking Water," p. 1 Radon.  RJadium and
      Uranium in Drinking Water, edited by C. Cothern and P. Rebers, Lewis
      Publishers, Cheslea, Michigan, 1990
                                    B-2

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    APPENDIX C - COST ESTIMATES AND UNCERTAINTY
                            MEASURES
NOTE: The following tables of cost estimates and uncertainty measures, which
  dissaggregate totals to include soil gas mitigation, have been provided by an
SAB/RECS consultant for illustration, comparison and discussion purposes only
         and are not quality-checked or peer-reviewed for accuracy.
                                 C-l

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                          DISTRIBUTION LIST

Deputy Administrator
Assistant Administrators
EPA Regional Administrators
EPA Laboratory Directors
Deputy Assistant Administrator for Office of Research and Development (ORD):
      Director,  Center for Environmental Research Information (CERI)
      Director,  Office of Environmental Engineering and Technology
      Demonstration (OEETD)
      Director,  Office of Environmental Processes and Effects Research (OEPER)
      Director,  Office of Modeling, Monitoring Systems, and Quality Assurance
       (OMMSQA)
      Director,  Office of Technology Transfer and Regulatory Support (OTTRS)
Deputy Assistant Administrator for Water:
      Director,  Office of Ground Water and Drinking Water (OGW&DW)
      Director,  Office of Science and Technology (OST)
      Deputy Director, OST
Deputy Assistant Administrator for Air and Radiation:
      Director,  Office of Radiation and Indoor Air (ORIA)
      Director,  Office of Air Quality Planning and Standards (OAQPS)
      Director,  Office of Radiation Programs (ORP), Las Vegas, Nevada
Deputy Assistant Administrator for Office of Prevention, Pesticides and Toxic
Substances (OPPTS):
      Director,  Office of Pollution prevention and Toxics (OPPT)
Deputy Assistant Administrator for Office of Solid Waste and Emergency Response
(OSWER):
      Director,  Office of Emergency and Remedial Response  (OERR)
Deputy Director, OERR
      Director,  Office of Solid Waste (OSW)
Deputy Director, OSW
      Director, Technology Innovation office (TIO)
EPA Headquarters  Library
EPA Regional Libraries
EPA Laboratory Libraries

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     APPENDIX D - GLOSSARY OF TERMS AND ACRONYMS
ACWA
ASD
AWWA
BAT
BEIR
DWG
EEC
EHC
EPA

GAG
k
NAS
O&M
OGW&DW
ORD
PTA
PTS
L
LCD
M
ASSOCIATION OF CALIFORNIA WATER AGENCIES
ACTIVE SUB-SLAB DEPRESSURIZATION
AMERICAN WATER WORKS ASSOCIATION
BEST AVAILABLE TECHNOLOGY
BIOLOGICAL EFFECTS OF IONIZING RADIATION
DRINKING WATER COMMITTEE (U.S. EPA/SAB)
ENVIRONMENTAL ENGINEERING COMMITTEE (U.S. EPA/SAB)
ENVIRONMENTAL HEALTH COMMITTEE (U.S. EPA/SAB)
U.S. ENVIRONMENTAL PROTECTION AGENCY (U.S. EPA, or
"The  Agency")
GRANULAR ACTIVATED CARBON
THOUSAND (DOLLARS)
NATIONAL ACADEMY OF SCIENCE
OPERATION AND MAINTENANCE
OFFICE OF GROUNDWATER AND DRINKING WATER
OFFICE OF RESEARCH AND DEVELOPMENT, U.S. EPA
PACKED TOWER AERATION
PACKED TOWER STRIPPING
LITER
LUNG CANCER DEATHS
MILLION (DOLLARS)
PICO CURIE
pCi
pCi/Lwater Concentration in water
pCi/L^  Concentration in air
RAG      RADIATION ADVISORY COMMITTEE (U.S. EPA/SAB)
SAB      SCIENCE ADVISORY BOARD (U.S. EPA)
SDWA    SAFE DRINKING WATER ACT OF 1988
U.S.      UNITED STATES
VOC      VOLATILE ORGANIC CARBON
                            D-l

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                          DISTRIBUTION LIST

Deputy Administrator
Assistant Administrators
EPA Regional Administrators
EPA Laboratory Directors
Deputy Assistant Administrator for Office of Research and Development (ORD):
      Director, Center for Environmental Research Information (CERI)
      Director, Office of Environmental Engineering and Technology
      Demonstration (OEETD)
      Director, Office of Environmental Processes  and Effects  Research (OEPER)
      Director, Office of Modeling, Monitoring Systems, and Quality Assurance
        (OMMSQA)
      Director, Office of Technology Transfer and  Regulatory Support (OTTRS)
Deputy Assistant Administrator for Water:
      Director, Office of Ground Water and Drinking Water (OGW&DW)
      Director, Office of Science and Technology (OST)
      Deputy Director, OST
Deputy Assistant Administrator for Air and Radiation:
      Director, Office of Radiation and Indoor Air (ORLA)
      Director, Office of Air Quality Planning and Standards (OAQPS)
      Director, Office of Radiation Programs (ORP), Las Vegas, Nevada
Deputy Assistant Administrator for Office of Prevention,  Pesticides and Toxic
Substances :OPPTS):
      Director, Office of Pollution prevention and Toxics (OPPT)
Deputy Assistant Administrator for Office of Solid  Waste and Emergency Response
(OSWER):
      Director, Office of Emergency and Remedial Response (OERR)
Deputy  Director, OERR
      Director, Office of Solid Waste (OSW)
Deputy  Director, OSW
      Director, Technology Innovation office (TIO)
EPA Headquarters Library
EPA Regional Libraries
EPA Laboratory Libraries

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