UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                              WASHINGTON. O.C. 20460
      30 1QQ3                                                   OFPK^e€1>li ADMINISTRATOR
      «SU» LWO                                                     SCeNqeADVtSORYBQAftO
 EPA-SAB-EC-LTR-93-010

 IJdnorable Carol M. Browner
'Administrator
 U.S. Environmental Protection Agency
 401 M Street, S.W.
 Washington,  D.C. 20460

       Re;   SAB Review of Multimedia Risk and Cost Assessment of Eadon in
             Drinking Water

 Dear Ms, Browner:

       The EPA Science Advisory  Board (SAB) is pleased to comment on the
 multimedia risk of exposure to radon and the cost of mitigation as required by
 Public Law 102-389 (the Chafee-Lautenberg Amendments to EPA's FY 1993
 Appropriation Bill enacted October 6,  1992).  The Chafee-Lautenberg Amendment
 states that "The Science Advisory Board shall review the Agency's study and
 submit its recommendation to the Administrator on its findings,"  The study
 report made available to the SAB is entitled "Multimedia Risk and Cost
 Assessment of Radon in Drinking Water",1 This SAB report on the Agency's
 study, prepared by the  Chafee-Lautenberg Study Review Committee of the SAB,
 complements previous detailed SAB comments transmitted to you on the
 uncertainty analysis of  radon  risks (July 9, 1993) and on costs of mitigation of
 risks from radon in water  (July 30, 1993).

       The issues of major  concern in assessing risks of radon exposure and costs
 of mitigation may  be grouped into four categories:  a) population exposure profiles;
 b) risk estimation  procedures; c) mitigation costs; and d) integration of these for
 regulatory decision mak'."5  The  EPA study considered each of these issues and,
 in turn, they have been addressed by the SAB.
    By way of background, ike SAB early in 1993 began, interactions with SPA, including receipt of background nw*mat on
 thit study Bataeuer, the specific report remewnd by th* Cumnuttee inns not received until Jttfy 9, 1993, and £Au*t tiauttd fun*
 was iwfulabit to review and comment on the rppon fyn'uus« of the July 31, 1993 deadline for submission to Con^mx
 Continuing to the present itudy report, there has irr/i a xtsiuly improvement ui flat quality of the onolytet conducts! trj £PA_

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 A. Population extioawe profiles

       The Agency report estimates that 81 million people use water originating
 from community groundwater supplies with a population-weighted average radon
 activity of 246 picocuries per liter of water (pCi/L^^p.  The Agency report
 estimates that approximately 19 million people are served by water supplies with
 radon concentrations in  excess of 300 pCi/Lwataji> the Maximum Concentration
 Level proposed by the Agency, It is the SAB's impression from information
 provided by public commentera, that the Agency's estimates of population exposure
 to radon in drinking water are rather uncertain and may seriously underestimate
 the number of community water systems impacted by the proposed drinking water
 standard.  This uncertainty in exposure estimates ultimately impacts the costs of
 mitigation.  There is clearly a need for more information and a better presentation
 of available data  on  the  profile of population exposure to radon in drinking water,
 including the distribution of radon in drinking water exposures for communities of
 varying size,

 B. Risk, estimation procedures

      The  risk estimation procedures used by the Agency address both the risks
 from radon inhaled in air and ingested in water.  The risk estimates from airborne
 radon with lung cancer as an endpoint are based on strong epidemiological
 evidence from studies of  uranium miners, augmented by data on other
 underground miners, and supported by data from laboratory animal studies.
 However, there continues to be debate about the extrapolated lung cancer risk at
 lower levels of exposure.   This issue may be clarified during the next several years
when the results  of several major epidemiological studies focusing on exposure to
radon in homes become available.  However, even though there is a  potential  risk
 at low levels of exposure to air borne radon, it must be recognised that the
 populations available for  epidemiological studies are relatively small, the majority
 of residential exposures are not particularly high, and the postulated levels of risk
are sufficiently low that epidemiological  studies might well be unable to identify
any increase in risk  attributed to  residential radon exposure if such a risk is
present.

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       The situation is quite different for estimating the risks of ingested radon in
drinking water.  In this case, there is no direct epidemiologieal or laboratory
animal evidence of cancer being caused by ingestkm of radon in drinking water.
Thus, the approach to estimation of cancer risk from raaon in drinking water is
more indirect than for radon in air.  In the absence of direct evidence, it is not
possible to exclude the possibility of zero risk from ingssted radon.

       The indirect risk estimation approach involves several steps.  First, the dose
to various tissues has been  calculated from models for the distribution of radon in
the body following ingestion of radon.  The model calculation is based, in part, on
organ distribution information from an unpublished study with radio-xenon (as a
surrogate for radon, since both are noble gases) using human subjects. The
meager data base results in uncertainty in estimating tissue doses from ingested
radon in drinking water.  This uncertainty could be reduced through further
research.  In the next step,  the calculated doses havt been used along with organ-
specific risk estimates per unit dose, derived from data on the Japanese atomic
bomb survivors, to calculate cancer risk to various organs.  To a large extent, this
involves an extrapolation from the very acute, high dose rate, gamma (low  Linear
Energy Transfer) exposure of the Atomic Bomb survivors to a very protracted,
very low dose rate, alpha particle (high Linear Energy Transfer) exposure with
ingested radon.  The  SAB is of the opinion that the estimates of risk from
ingested radon have  additional uncertainty due  to possible differences in the
distribution of dose,  and resulting effects, from alpha particles from radon and
progeny. However, it should be noted that even at the upper bound of the
uncertainty analysis  for ingested  radon, for most situations the risk from radon
ingested in drinking water is still much lower than the risk from airborne radon
entering the  house directly from  the soil.  Indeed, for many homes the risk from
the radon in water is even lower than that from radon in the outdoor air.

       The available information on exposure and risk  have been generally
integrated under a scientifically satisfactory framework by the Agency as evidenced
in the Agency's multimedia  risk assessment for  radon (BPA-SAB-RAC-93-OH, July,
1993), However, the uncertainties noted earlier in this report are carried forward
into most of the integrated  analyses. However,  the differences of opinion,
especially with regard to the extent of the exposed population, with interested
parties are not reflected in the Agency report or in the integrated analyses.

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      The risk estimates are illustrated in Figures 1 and 2.  The population risk
estimates for airborne radon indoors are the most certain,  with the nominal
estimate of 13,600 lung cancer deaths per year (range of 6740 to 30,600 lung
                                         rt
cancer deaths) from exposure to indoor air .  Less than one percent of this lung
cancer risk is attributable to radon reaching homes via water.  In contrast,
exposure to radon in outdoor air is estimated to produce 520 lung cancer deaths
                                                 o
per year (range  of 280 to  1500 lung cancer deaths)  . And  finally it is estimated
that ingestion of radon in water is estimated to cause 46 cancers per year (range
of 11 to 212 cancers per year) .  This latter  estimate is  the most uncertain of all
the estimates made.  Airborne radon arising from water is  estimated  to result in
113 lung cancers per year (range of 40  to 408 lung cancers per year)   which are
included in the estimate presented above for indoor residential air. These risk
estimates for radon can be placed in perspective by comparison with an estimate
of approximately 30,000 cancer deaths per year from all exposures to naturally
occurring radiation, including approximately  13,600 deaths  from inhaled radon and
approximately 2,500 cancers estimated for naturally occurring radio-potassium in
the human body,

C. Mitigation costs

      The costs of mitigation of radon  in the water and indoor air are also
uncertain.   Part of the uncertainty for mitigation costs of radon in water relates to
differences of opinion between the Agency staff and interested parties over the
cost of mitigation systems,  For  example,  the Agency staff estimates capital costs
for mitigation of radon in water at less than $2 billion, while interested parties
have  estimates of capital coats in excess of $10 billion.  Similar differences exist
for recurring maintenance and operating costs.  The other  part of the uncertainty
for mitigation costs of radon in water relates to the representativeness of the data
base on the occurrence of radon in groundwater used by the Agency.   These data
       2
       Report to the United StatM Congnw on BadioauelidM In Drinking Water  Multimedia Riik and Cort Aiaexament
of Radon in DrSWriag Wnt*r. Prtpawd for PL 102-389, Offit* of Wat*r. US EwnrQwoantai Protection Agency. Jujy 9, 1993.
3-2,
          , p. 3-3,
       4
       Ibid, Tabte 7-3 beta model estimate*.

           Tabta 7-3.

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are the source for estimates of the number and size of communities that would
require radon mitigation depending on the level of the MCL finally selected for
regulation,  In contrast to ths potential mandated regulation of radon in water,
mitigation of radon in indoor air involves voluntary actions by homeowners.  Total
cost estimates of the  latter are highly uncertain because the extent and cost of
testing for radon in homes and the  extent of voluntary participation in mitigation
action in affected homes are unknown.

      The SAB is of  the opinion that the mitigation cost uncertainties for radon
in drinking water could be reduced by the EPA working with interested parties to
resolve issues related to the occurrence of radon in community systems of various
sizes, the cost of the  various process treatment operations and processes for
various system sizes,  and the frequency of the  need for disinfection after aeration.
This may require reopening the comment period for this rulemaking.  The SAB
recommends that EPA, if necessary, request from the Court and Congress
sufficient time to do this work to reduce uncertainties in the cost estimates and
the cost per cancer avoided.  The public  interest will be served if the Agency
carries out activities over several years which provide a better basis for deciding
how to most effectively mitigate riiks from radon exposure in drinking water.

0. Integration for regulatory decision-making

      Because of uncertainties in both risk estimates and costs of mitigation there
is substantial uncertainty in the cost per cancer death avoided.  This uncertainly
is especially large for mitigation of cancers related to ingestion of water.  However,
even with this uncertainty, it is clear that the cost  per lung cancer avoided from
mitigation of indoor air radon is substantially less than the cost per cancer death
avoided due to mitigation of exposure from radon in drinking water.  This
difference appears to  be at least a factor of 4 ($3,2  million per cancer death
related to drinking water and $0,7 million per cancer death related to airborne
radon) and may be substantially larger. The highest costs may be those associated
with mitigation of risks for radon in water for  the smallest communities.

      In summary, the SAB notes the extent of the uncertainties  in the population
exposure profiles, the risk  estimates for ingested radon in drinking water and the
costs of mitigation.  In view of these large uncertainties for risk estimates for

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 ingested radon in drinking water and knowledge of the substantially greater risks
 associated with airborne radon indoors and outdoors directly from soil, the SAB
 advises that EPA consider various options for mitigating radon ean^r risks. The
 options all include continuing the Agency's efforts to encourage voluntary actions
 to reduce indoor  air radon in view of the cost effectiveness of this approach for
 reducing risks,

      With regard to water, as one option the Agency  could promulgate a
 standard at 300 pCi/Lwater as has been proposed.   However, in doing so it must be
 recognized that this involves selecting a risk reduction  strategy for radon that is
 the most costly in terms of costs per cancer death avoided; i.e., more than four
 tiroes the cost of cancer risk avoidance for airborne radon indoors.  Alternatively,
 as another option a standard might be set at  some higher level such as 1000 to
 3000 pCi/Lwater, to initiate mitigation of the highest potential  risks.  For example,
 setting a water standard at 3000 pCi/Lwater would result in water contributing no
 more radon to  indoor air than is present in outdoor air,  (Keep in mind that the
 radon in outdoor air arises by natural processes from soil gas  and there is no way
 to alter the outdoor radon levels.)  At the same time it would  be appropriate to
 intensify research on radon ingestion and radon mitigation, data gathering on
 radon occurrence for all media, and dialogue with interested parties.  These
 actions would serve to reduce the uncertainties in the risk estimates, the costs of
 mitigation, and, ultimately, the estimates of cost per cancer avoided.  We cannot
 emphasize too strongly the SAB view that a relative risk orientation should be
 applied to the decision making process.  Comparative analysis  of uncertainties on
 the risks of various exposure scenarios and mitigation approaches should be
 developed and provided to  the risk managers.

      The SAB strongly supports the use of a relative risk reduction orientation
as an important consideration in  making risk  reduction decisions on all sources of
 risk, including those attributable  to radon.  Other important considerations include
 legislative authorities, environmental equity, economics, and the like.  In short, the
 relative  risk approach calls For giving the highest priority to  mitigating the largest
sources of risks first* espfially when the cost-effectiveness of risk reduction of
such sources is high.  The SAB recognizes that the large number of laws under
which EPA operates makes it difficult to implement a relative  risk reduction
strategy uniformly across the Agency.  Radon  is an excellent example of the

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problem with radon in drinking water governed under one statute (Safe Drinking
Water Act) while radon in indoor air is not currently subject to regulation under a
specific statute.  The SAB strongly encourages the Agency and the Congress to
work together to consider changes in existing statutes that would permit
implementation of relative risk reduction strategies in a more efficient and
effective manner.

      The SAB appreciates this opportunity to advise you  and the Congress on
this important matter,  and we look forward to receiving a  response on these
suggestions.

                               Sincere

Dr.' Raymond C. Loehr              v~*"-H5p5£ger &!ilcCleua& c
Chair, Executive Committee                Chair, Chafee-Lautenberg Study
Science Advisory Board                   Review Committee

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                 Figure 1. Estimated Annual Cancer Risk From
                   Exposure to Radon (in Cancer Deaths/Year}
              Ration from
              Soil Gas
              Radon from
              Drinking Water
                                fndoorAIr
                            13,600  ^
tia inhalation
                           113
                            vtamhaiation
             *fVs* potential inpacttKf by
                   Water Standard
                                                          Range offfis/c Estimates Shown m Figure:
                          13.6QQ (6740 - 30,600)
DATA SOURCf: "Report to Congmss on fiafffonuctides in Drinking Water:

Mu&media ftis* and Cosl Assess/rteftl of ftedon in Drinking Water

Office of Walor, Juty 9. 1993.
                            113(40-408)*

                             46(11-203)*

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        Figure 2, Estimated Annual Deaths From Exposure
                   to Radon (In Cancer Deaths/Year)
           Estimated Cancer Deaths/Year
     3S.OOQ
     30,000
     25,000
     20,000
     15,000
     10,000
      5,000 -
                            High
                            Met/
                            Low
                                                          13,600
                                       520
                Ingested DW      Inhaled Outdoor Air    Inhaled Indoor Air
                            Sources of Exposure

     ; 'Report to ffig (/,$, Congress on Ract/onuc/lctes in Drinking Water:
Multimedia Risk and Cost Assessment of Radon in Drinking
Office of Water, US EPA Juty 9, W93,

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             U.S. ENVIRONMENTAL PROTECTION AGENCY
                      SCIENCE ADVISORY BOARD
           CHAFEE-LAUTENBERG STUDY REVIEW COMMITTEE
CHAIRMAN

Dr. Roger O. McClellan
President
Chemical Industry Institute of Toxicology
P.O. Bo* 12137
Research Triangle Park, NC  27709

MEMBERS

Mr, Richard Conway
Senior Corporate Fellow
Union Carbide Corporation 770/341
P.O. Box 8361
South Charleston, WV 25303-0361

Dr, Morton Lippmaim
Professor
Institute of Environmental Medicine
New York  University
Long Meadow Road
Tuxedo,  NY  10987

Dr. Genevieve M. Matanoski
Professor of Epidemiology
School of Hygiene and Public Health
The Johns  Hopkins University
601 Wolff Street, Room 6019
Baltimore,  MD  21205

Dr. Verne Ray
Senior Technical Advisor
Medical Research Laboratory
Pfizer Inc,
Groton, CT 06340

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DESIGNATED FEDEHAL OFFICIAL
Dr. Edward S. Bender
Environmental Protection Agency
Science Advisory Board
401 M Street, S.W,» A-101
Washington, DC 20460
STAFF SECRETARY
Mrs, Marcia K. Jolly
Environmental Protection Agency
Science Advisory Board
401 M Street,  S.W., A-101
Washington, DC  20460

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