Aprils, 1996
EPA-SAB-RAC-ADV-96-003
Honorable Carol M. Browner
Administrator
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Re: Radiation Advisory Committee (RAC) Advisory on
Environmental Radiation Ambient Monitoring System
(ERAMS)
Dear Ms. Browner:
This Advisory was written by the Radiation Advisory Committee (RAC) of the
Science Advisory Board (SAB) in response to a request from the Office of Radiation
and Indoor Air (ORIA) to provide advice on technical issues pertinent to developing a
new vision and re-orienting the Environmental Radiation Ambient Monitoring System
(ERAMS). An SAB Advisory is a peer review of an Agency work-in-progress. Typically,
the Agency asks for an Advisory when it is in the midst of an extensive, complex project
that would benefit from an objective, independent scrutiny of its work to date. The goal
of the Advisory is to provide suggestions for mid-course corrections and/or new thrusts
that will refine the trajectory of the project. The output of the Advisory is similar to that
of a Review; i.e., a written report to the Administrator. Generally, an Advisory would be
followed by an SAB Review of the completed Agency project at some point in the
future. The Board would take steps to insure that the final Review Panel had a
significant presence of new participants so as to insure an independent assessment of
the Agency's work.
The RAC met on July 13 and 14, 1995 at the EPA's National Air and Radiation
Environmental Laboratory (NAREL) in Montgomery, Alabama for presentations and
discussions of the ERAMS. The RAC concluded this advisory on October 24, 1995 in a
teleconference meeting. This Advisory contains brief background information about
ERAMS, the charge presented to the Committee, the Committee's response, and an
additional, overarching recommendation to the effect that the Agency do more to
interpret the data generated from any ERAMS - the present ERAMS, or a reconfigured
ERAMS.
-------
The documents provided to the RAC for the ERAMS advisory included Plans for
the Reconfiguration of the Environmental Radiation Ambient Monitoring System
(ERAMS), June 15, 1995 - Draft. This document noted that the EPA is evaluating the
ERAMS "to determine if current methods of assessing ambient levels of radioactive
pollutants should be modified to better address current and future environmental
monitoring needs," and in particular, to "consider the need to collect additional data to
better assess environmental radiation exposure at the community level." It should be
noted that the RAC was asked to provide advice on reconfiguring EPA's ERAMS
program without any discussion on available funds for ERAMS in future years. Our
advice contained in this advisory is focused on maintaining a technically sound
program, rather than tempering comments based on available EPA funding.
1. Background
The ERAMS was formed on July 1, 1973, when the EPA combined several
existing monitoring systems into a single system. The focus of the previous monitoring
systems was primarily on monitoring radionuclide fallout due to weapons testing. The
focus of ERAMS was shifted toward monitoring in the vicinity of both major population
centers and nuclear facilities. The general objectives identified for ERAMS have been
to provide a means for estimating ambient levels of radionuclides in the environment
and following trends in environmental radioactivity levels. The draft plans provided to
the RAC state that:
The proposed evaluation and redirection of ERAMS are the result of
several initiatives, including internal evaluations by the NAREL-ERAMS
Steering Committee, a national survey of ERAMS users designed and
administered to all regular recipients of ERAMS data, a contractor-
performed comprehensive evaluation of ERAMS, and a wide range of
requests for information and data from system users. The principal
priorities that emerged from these initiatives are the following: (1) to
continue monitoring ambient levels of radionuclides in the environment;
(2) to collect data to assess local exposures associated with nuclear
facilities and sites (to support the Community-Based Environmental
Protection Initiative); (3) to sample and analyze additional media; (4) to
coordinate with other networks; and (5) to update techniques for data
dissemination.
2. Charge to the Committee
Based on the above priorities, the following objectives were proposed by ORIA
for the review and redesign of the existing ERAMS:
a) to provide a continuous, comprehensive, cost-effective national
monitoring network to determine ambient levels in various environmental
-------
media in the United States, and to enhance the system's capability for
estimating ambient levels of radioactivity in the environment on a national
scale;
b) to monitor radioactivity around specific sites to provide data for assessing
concentrations in local communities;
c) to coordinate with local, state, Federal, national, and international
organizations to provide a world-wide network for data on environmental
radiation levels;
d) to develop routine and special sampling programs for ERAMS stations to
ensure that both national and local program objectives are met;
e) to develop data quality objectives based on the requirements of the
program;
f) to make ERAMS data more available on a current basis and at minimum
cost to other users, including the scientific community, local and national
officials, and the public; and
g) to provide support for emergency response activities.
The Charge to the RAC relates to these objectives. The Committee was asked
to respond to the following questions:
h) Are the proposed objectives adequate for developing a new vision,
refinements, and redirection of ERAMS, given the priorities that emerged
from the various efforts to evaluate the program and user needs?
I) Should additional objectives be considered, given these priorities?
j) With specific emphasis on ambient monitoring, site-specific monitoring,
and data dissemination, are the general approaches outlined in the
Agency's submittal on the proposed ERAMS objectives appropriate?
k) Should additional factors be considered in achieving these objectives?
3. Response to the Charge
3.1 Discussion
-------
The RAC commends NAREL on its initiative to evaluate the ERAMS. The RAC
was impressed with the technical expertise, professionalism, and conscientiousness of
NAREL staff, and especially their positive attitude in seeking review and advice on
ERAMS plans. Review materials were provided to the Committee in a timely manner.
Presentations to the Committee were very informative, and these presentations were
complemented by helpful handout materials. Presenters adhered to the schedule and
allowed ample time for discussion.
-------
In the process of conducting this advisory, RAC members and NAREL staff came
to the conclusion that the items stated as objectives for the redesign of ERAMS were
actually a mix of activities, objectives and goals to achieve objectives. The Committee
noted that an ERAMS mission statement is needed, and that objectives should support
this mission. A critical component in determining the objectives is defining the uses for
the ERAMS data.
The RAC recognizes that its charge does not include suggesting a mission
statement for the ERAMS program. However, there was consensus among RAC
members and NAREL staff that the ERAMS mission/goal should include the following
components (order does not indicate priority):
a) to gather baseline data on environmental levels of natural and man-made
radiation and radionuclides. These data should be independent, reliable,
and capable of revealing trends;
b) to gather data that help the assessment of population exposures/doses;
c) to monitor radionuclides released into the environment during radiological
emergencies; and
d) to inform the public, as well as public officials.
3.2 Response to Specific Questions
The RAC offers the following specific advice with regard to the items originally
specified as objectives, now regarded as activities. Responses to the four Charge
questions (items 2.h) - k)) are integrated into the other responses. It is our
understanding that the details of the implementation of ERAMS - such as sampling
locations, media sampled, and sampling frequency - could be the subject of a future
advisory, and we offer only a few general comments on these items at this time.
a) To provide a continuous, comprehensive, cost-effective national
monitoring network to determine ambient levels in various
environmental media in the United States, and to enhance the
system's capability for estimating ambient levels of radioactivity in
the environment on a national scale.
Advice:
(1) Consider monitoring outside the United States, to include Territories
and Trustees of the United States and its Antarctic bases.
(2) Consider monitoring total external gamma radiation as well as
radionuclide-specific activities in environmental media.
-------
(3) Consider (where feasible and beneficial) making the monitoring
network available for sharing samples with other parts of the
Agency and for coordinated monitoring of other substances of
concern to public health. This should be addressed in more detail
in the ERAMS II advisory.
(4) Consider whether routine analysis of precipitation samples is needed.
(5) Consider collection of additional environmental samples such as soil,
additional food items, and biological media.
(6) Continue the present partnership with state and local agencies for
sample collection, and consider the possibility of obtaining additional
assistance from colleges and universities.
(7) Increase personal contacts with state and local government sample
collectors to ensure adequacy of sample collection and to reinforce
among collectors and their agencies the importance of their work.
Consider the possibility of a Newsletter or similar communication to share
with collectors.
b) To monitor radioactivity around specific sites to provide data for
assessing concentrations in local communities.
Advice:
(1) Consider a limited ERAMS monitoring effort in the area of nuclear
facilities (including waste facilities) to provide data on radiation and
radioactivity levels. This will respond to public concerns for corroborating
monitoring performed by ERAMS with that of the NRC/Agreement States
licensees and, DOE and its contractors. The limitations of data generated
from such an effort should be appropriately noted.
(2) To assess the population dose associated with a specific nuclear
facility will require many monitoring stations and a level of effort that is
probably not feasible for ERAMS. However, a limited ERAMS effort could
lead to partnerships with other Agencies, such as NRC and DOE, that
would enhance the capability of ERAMS, as well as provide independent
correlation of a facility's monitoring data with that of ERAMS.
c) To coordinate with local, state, federal, national, and international
organizations to provide a world-wide network for data on
environmental radiation levels.
-------
Advice:
(1) Report data using the international system of units to facilitate
coordination with international organizations.
(2) Information regarding the sampling and measurements performed by
local and state agencies for the monitoring and compliance
measurements required by the Safe Drinking Water Act, the Clean Water
Act, and the Clean Air Act, could be extremely useful if available as part
of the ERAMS Database. This could result in having an almost complete
universe of sites for regulatory evaluation when standards need to be
revised.
(3) The Agency could explore electronic techniques for the integration
and dissemination of the data.
(4) Organize a data collection and reporting system that can process
environmental radiation data from the Department of Energy's (DOE)
Environmental Measurements Laboratory, DOE contractors, nuclear
power stations, and state regulatory agencies.
(5) Consider the opportunity to share ERAMS samples with other EPA
programs so that a database can be extended for contaminants in
addition to radionuclides.
d) To develop routine and special sampling programs for ERAMS
stations to ensure that both national and local program objectives
are met.
Advice:
(1) The intended use of the ERAMS data should dictate the details of the
sampling program, such as sampling locations, media sampled, and
sampling frequency. These details could be the subject of a future
advisory.
e) To develop data quality objectives based on the requirements of the
program.
Advice:
(1) ERAMS reports should include accurate and up-to-date information on
detection and quantification limits.
(2) If most results are below the detection level, effort should be made to
make some measurements at lower detection levels in order to quantify
-------
the levels. This extra effort would not be necessary on a routine basis,
but should be done on limited occasions, as part of an overall quality
assurance program. Specifically, this process would be of a limited
nature, and have the following two objectives: (a) Ascertain the
background level of radionuclides in all monitoring stations, and (b)
Become a part of a Quality Assurance program to ensure that measuring
devices can perform appropriate analyses.
(3) Current detection limits and uncertainties for ERAMS data should be
used with models of nuclide transport, uptake, and dosimetry to determine
whether the system can distinguish significant from insignificant dose
levels. Some EPA programs are interested in annual doses as low as 15
or even 4 mrem (0.15 or 0.004 mSv). If not, more sensitive methods for
some nuclides may be needed.
f) To make ERAMS data more available on a current basis and at
minimum cost to other users, including the scientific community,
local and national officials, and the public.
Advice:
(1) Advertise the availability of Environmental Radiation Data (ERD)
reports. The availability of ERAMS data is not widely known in the
scientific community or by the public. The data produced by ERAMS is
credible and deserves wider distribution.
(2) Publish ERAMS results in peer-reviewed journals on a regular basis
and present results at professional society meetings. Interpretation of the
data by the authors of the reports in terms of radionuclide distribution
patterns and doses to humans will be needed.
g) To provide support for emergency response activities.
Advice:
(1) Incorporate emergency response information in the plan for a future
ERAMS Advisory. Information needed to evaluate emergency response
activities was not presented to the RAC. The role of ERAMS in the
Federal Radiological Emergency Response Plan (FRERP) and the
National Contingency Plan (NCP) should be clearly presented in the
ERAMS plan.
4. Additional Advice/Major Recommendation
A major recommendation of this Advisory is that NAREL increase its emphasis
on interpretation of ERAMS data. It should include discussion and explanation of
8
-------
anomalous data; trend analysis; and dose assessment. The RAC members had
different opinions on whether NAREL's interpretation of ERAMS data should include
risk assessment. The RAC recognizes that these additional tasks must compete with
other tasks for resources. The recommendation to emphasize interpretation of the
ERAMS data would increase the data's usefulness both to the scientific community and
to the public.
The RAC is pleased to have the opportunity to conduct this advisory, and we
hope that you will find our advice useful in reconfiguring the Environmental Radiation
Ambient Monitoring System. We look forward to receiving your reaction to our
comments, and particularly to our comments on the mission of ERAMS and the
interpretation of ERAMS data.
Sincerely,
Dr. Genevieve M. Matanoski, Chair Dr. James E. Watson, Jr. Chair
Executive Committee Radiation Advisory Committee
Science Advisory Board Science Advisory Board
-------
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 reflect 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.
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
SCIENCE ADVISORY BOARD
RADIATION ADVISORY COMMITTEE
Chair
Dr. James E. Watson, Jr., Professor, Department of Environmental Sciences and Engineering,
University of North Carolina at Chapel Hill, NC
Members
Dr. William Bair, (Retired) Director, Battelle Pacific Northwest Laboratory, Richland, WA
Dr. Stephen L. Brown, Director, R2C2 (Risks of Radiation and Chemical Compounds), Oakland,
CA
Dr. June Fabryka-Martin, Staff Scientist, Los Alamos National Laboratory, Los Alamos, NM
Dr. Ricardo Gonzalez-Mendez, Associate Professor, Department of Radiological Sciences,
University of Puerto Rico School of Medicine, San Juan, PR
Dr. David G. Hoel, Chairman and Professor, Department of Biometry & Epidemiology, Medical
University of South Carolina, Charleston, SC
Dr. F. Owen Hoffman, President & Director, SENES Oak Ridge, Inc., Center for Risk Analysis,
Oak Ridge, TN
Dr. Bernd Kahn, Professor, School of Nuclear Engineering and Health Physics, and Director,
Environmental Resources Center, Georgia Institute of Technology, Environmental Resources
Center, Atlanta, GA
Dr. Ellen Mangione, Director, Disease Control and Environmental Epidemiology Division,
Colorado Department of Health, Denver, CO
Dr. Paul J. Merges, Chief, Bureau of Radiation, Hazardous Substance Regulation Division, New
York State Department of Environmental Conservation, Albany, NY
Consultant on ERA MS
Dr. Janet Johnson, Senior Radiation Scientist, Shepherd Miller, Inc., Ft. Collins, CO
Science Advisory Board Staff
Dr. K. Jack Kooyoomjian, Designated Federal Official, U.S. EPA, Science Advisory Board
(1400F), 401 M Street, SW, Washington, DC 20460
Ms. Diana L. Pozun, Staff Secretary, U.S. EPA, Science Advisory Board (1400F), 401 M Street,
SW, Washington, DC 20460
-------
GLOSSARY OF TERMS AND ACRONYMS
EC Executive Committee (U.S. EPA/SAB)
EPA Environmental Protection Agency (U.S. EPA)
ERAMS Environmental Radiation Ambient Monitoring System
ERD Environmental Radiation Data
FRERP Eederal Radiological Emergency Response Plan
NAREL National Air and Radiation Environmental Laboratory (U.S.
EPA/OAR)
NCP National Contingency Plan
NRC Nuclear Regulatory Commission (U.S. NRC)
OAR Office of Air and Radiation (U.S. EPA)
ORIA Office of Radiation and Indoor Air (U.S. EPA)
RAC Radiation Advisory Committee (U.S. EPA/SAB)
SAB Science Advisory Board (U.S. EPA)
-------
DISTRIBUTION LIST
Administrator
Deputy Administrator
Assistant Administrators
Deputy Assistant Administrator for Science, ORD
Director, Office of Science Policy, ORD
Deputy Assistant Administrator for Air and Radiation
Director, Office of Radiation and Indoor Air
EPA Regional Administrators
EPA Laboratory Directors
EPA Headquarters Library
EPA Regional Libraries
EPA Laboratory Libraries
Library of Congress
National Technical Information Service
Congressional Research Service
------- |