Table 1. Radon Test Results Showing Polonium-MCL Violations of Safe Drinking Water Act’s Radionuclides Rule of 1976 in NY & Florida (NOTE: Original ETR test reports used to prepare Table 1 @ www.gfxtechnology.com/ETR-6.pdf; Radionuclides Tables & Link to Radon Petition to Gov. Cuomo @ www.gfxtechnology.com/Radon.html) NOTE: These pages from http://www.gfxtechnology.com/BVW.html; pdf version @ http://www.gfxtechnology.com/BVW.pdf with field-test results for 18 homes in North Carolina containing huge amounts of Polonium & Radon hundreds of times those shown above. HOME Alpha Activity (pCi/L) vs Time (minutes) Fig. A. Relative activity in air of a “sealed” bathroom from a 10-minute, 10 LPM shower contaminated with Rn-222, Po-218, Pb-214, Bi-214. NOTE: The curve for Rn-222 indicates the Brinkmans’ bathroom air would level off at about 8.6 pCi/L after 2 consecutive showers, compared to 240 pCi/L in House 17; one of 18 tested in 2008 by Vinson. 1 NOTE: Bi-214 & Po-214 curves overlap, but have different radiation-energy levels as illustrated in Fig. C. (Breathing air 24/7 with only 4 pCi/L of Ra-222 has the same cancer risk as smoking a pack of cigarettes per day.) Fig. B. Calculated Alpha & Gross Alpha particle activity for EPA-regulated decay products of Rn-222 (Po-218 & Po-214) corresponding to 135 pCi/L test result from ETR. 2 NOTE: Gross Alpha activity quickly exceeds its 15 pCi/L MCL, as well as the measured Rn-222 activity of 135 pCi/L. High levels of Po-218 & 214 in the Brinkmans’ tap water after passing through an sophisticated WateRx™ WH5 purification system indicates their water company is in violation of federal law. Dangers of High Levels of Radon Radiation Energy (MEV) vs Time (minutes) Fig. C. Relative Alpha, Beta/Gamma Radiation-Energy (MEV) in water emitted by each atom of Rn-222, Po-218, Pb214, Bi-214 or Po-214 after filling a tank, tub, water heater, pipe, ice maker, pool, filter, toilet…with water & Rn-222. 3 The following cancers & harmful respiratory effects are associated with chronic exposure to Radon-222 and its 7 deadly decay products: Alpha Emitters: Po-218, Po-214, & Po-210 Beta/Photon (Gamma) Emitters: Pb-214, Bi-214, Pb-210, Bi-210: Radon & Polonium in Air* Radon & Polonium in Water** 1. liver cancer 1. lung cancer (typically bronchogenic) 2. bladder cancer 2. squamous cell carcinoma 3. stomach ulcer 3. small cell carcinoma 4. leukemia 4. adenocarcinoma 5. cirrhosis of liver 5. large cell carcinoma 6. cardiovascular diseases 6. emphysema 7. pulmonary fibrosis NOTE: The Surgeon General C. Everett Koop stated that radioactivity, 8. chronic interstitial pneumonia rather than tar, accounts for at least 90% of all smoking-related lung 9. Silicosis cancers. The Center for Disease Control concluded "Americans are 10. respiratory lesions exposed to far more radiation from tobacco smoke than from any other 11. chromosomal aberrations source."** * University of Minnesota Web page: http://enhs.umn.edu/hazards/hazardssite/radon/radonharm.html * * Health effects of polonium @ http://www.lenntech.com/periodic/elements/po.htm NOTE: Fig. A, B & C indicate radiation from Po-218, Pb-214, Bi-214 & Po-214 track the decay of Rn-222, whereas radiation from Po-214’s daughter, (Pb-210) is about 2,100 times weaker (22 yr ½ life) as are its progeny, Bi-210 & Po-210. From Fig. 6; Radon transfer from groundwater used in showers to indoor air, by David S. Vinson, Ted R. Campbell, Avner Vengosh, J. Appl. Geochemistry, June 7, 2008 [http://sites.nicholas.duke.edu/avnervengosh/files/2011/08/Radon_in_air.pdf] Curves in Fig. B & C from equations 20(a) to 21(d) in Algebraic approach to the radioactive decay equations, L. Moral and A. F. Pacheco, Am. J. Phys. 71, July 2003 @ http://users.df.uba.ar/sgil/physics_paper_doc/papers_phys/modern/radiactive_dacay.pdf. 3 Radiation energy levels and other parameters from pages 42 & 78, EVS Human Health Fact Sheet for Radium (Argonne National Laboratory, August 2005) 1 2 NOTE ÍThree years after Table 2 was published, the North Carolina Radon-in-Water Advisory Committee, established by NCDHHS, Div. of Environmental Health and Division of Water Quality and NCDHHS, Division of Public Health recommended the establishment of the following guide lines: Private wells with radon concentrations at or above 10,000 pCi/L: Treatment of water should be considered in conjunction with the treatment of indoor air radon released from soil gas. Private wells with radon concentrations between 4,000 and 10,000 pCi/L: Treatment of water should be considered optional. [3] §These Guidelines ignored the fact that Table 2 indicates refilling a water heater, toilet tank, pool, ice maker, etc. without an “optional” water aeration system may produce over 8,000 to 20,000 pCi/L of Po-218 + Po-214 + Po-210 --- 500 -1300 times the federal MCL of 15 pCi/L for Gross Alpha & § 4,000 to 10, 000 pCi/L of Po-214 will produce about 1.9 to 3.8 pCi/L of Pb-210; above the maximum radiation dose allowed by the EPA for Beta/Photon emitters of 4-mrem/yr - without including the dose from Bi-214 & Bi-210. § Cancer Risk factors for 10,000 pCi/L of Pb-210 is 0.45, compared to 0.94 for its granddaughter, Po-210, compared to 0.000456 for Po-210’s parent: Bi-210. [4] § Pb-210 is the most deadly Beta/Gamma emitter [5] [3] Recommendation for Concentrations of Radon in Private Wells, dated 1/9/13 by W. Lee Cox, III, Chief, Radiation Protection Section. [4] Table 1. “Federal Guidance Report No. 13 Cancer Risk Coefficients, Unit Risk Quantities for Drinking Water Concentrations, and the Concentrations Yielding a 1 in a Million Lifetime Cancer Risk for Environmentally Significant Radionuclides” [5] Table 3. “Cancer Risk at the Gross Beta MCL for Five of the most Carcinogenic Radionuclides Covered by the MCL” @ www.oehha.ca.gov/water/reports/grossbetahealth.pdf North Carolina Departmenr of Healrh and Human Services Division of Health Service Regulation www.ncradon.org/Publications_files/NC%20RPS%20Recommendation%20to% 20Citizens%20with%20Private%20Wells.pdf Pat McCrory Governor AIdona Z. Wos, M.D. Ambassador (Ret.) Secretary OHHS Orexdal Pratt Division Director Recommendation for Concentrations of Radon in Private Wells NOTE (a): Table 2 on the preceding page indicates refilling a water heater, toilet tank, pool, ice maker, etc. without an “optional” water aeration system may produce over 8,000 to 20,000 pCi/L of Po-218 + Po-214 + Po-210 --- 500 -1300 times the federal MCL of 15 pCi/L for Gross Alpha. The N.C. Radiation Protection Section advises homeowners with private wells to follow the recommendations set forth by the North Carolina Radon-in-Water Advisory Committee l . These recommendations, found on page 5 of the final report, are as follows: Private wells with radon concentrations at or above 10,000 pCilL: Treatment of water should be considered in conjunction with the treatment of indoor air radon released from soil gas.. Private wells with radon concentrations between 4,000 and 10,000 pCiIL: Treatment of water should be considered optional. NOTE (b): 4,000 to 10, 000 pCi/L of Po-214 will produce about 1.9 to 3.8 pCi/L of Pb-210; above the maximum radiation dose allowed by the EPA for Beta/Photon emitters of 4-mrem/yr - without including the dose from Bi-214 & Bi-210. This recommendation is made recognizing that the radon concentration in water is used to help determine whether water is a significant contributor to existing indoor air radon levels. Inhalation of radon in air poses: a greater health risk than ingestion of radon through water. The recommendation seeks to address the combined sources of radon from soil gas and radon released from water. The goal is to limit the combined radon exposure in the home to no more than the Environmental Protection Agency (EPA) recommended level of 4 pCi/L. As a general rule, 10,000 pCi/L radon in water will contribute I pCilL radon to the air in the home. Given this ratio, mitigation of air and/or water supply is recommended when the radon in air and equivalent radon in water concentrations combine to exceed 4.0 pCi/L. NOTE (c): Table 2 also shows the following “general rule, 10,000 pCi/L radon in water will contribute 1 pCi/L radon to the air in the home” is wrong; it shows water-to-air transfer coefficients were 3.3 to 88.4 higher; ranging from 0.00033 in House 2 to 0.00884 in House 17, respectively. The risk of radon in drinking water has been estimated by the EPA to cause 168 cancer deaths per year in the United States. The majority of these deaths (about 89%) are caused by breathing in radon that has gassed out of the water while washing dishes or showering, which leads to lung cancer. Overall, lung cancer deaths from airborne radon are estimated to be about 20,000 per year in the U.S. For this reason, it is always recommended that hJmeowners test for airborne radon in their home, as this presents the greater risk. Testing for radon in air or water is easy and affordable. There are a number of radon test kits available online or in your local home improvement store for $20 or less. The NC Radon Program sells radon test kits at a subsidized cost to North Carolina citizens. Visit www.ncradon.org for more information. W. Lee Cox, III Chief, Radiation Protection Section _________________,Oate: 1 "North Carolina RadonMin-Water Advisory Committee Re~ort". Committee established by NCDENR, Div. of Environmental Health and Division of Water Quality and NCDHHS, Division of Public Health. Final report: March 9. 2011. ~ Radiation Protection Section www.ncramation.nct/ Phone: 919-571-4141/ Fax: 919-571-4148 Location: 3825 Barrett Orive, Raleigh, NC 27609 Mailing Address: 1645 Mail Service Center' Raleigh, North Carolina 27699-1645 An Equal Opportunity / Affirmative Action Employer p.c. ,.... f- • transfer coefficient of 1.0 x 10-4; ignoring a 2008 study of 18 homes that showed such transfer NOTICE. Dr. Ikeda cites a 1999 NAS report that used an obsolete water to indoor air coefficients ranged from 3.3 x 10-4 to 88.4 x 10-4 - 3.3 to 88.4 times higher for both Radon-222 & its carcinogenic daughter Polonium-218, which she totally ignored. [1] DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health SeNlee Page 2 - Vasile . Centers for DIsease Control and Prevention (CDC) Atlanta, GA. 30333 September IS, 2014 Cannine F. Vasile, Ph.D. 60 Herbert Circle Patchogue, New Yark I1772 Dear Dr. Vasile: Thank you for reaching out again to the Agency for Toxic Substllnees and Disease Registry (ATSDR) and die CealeD fbr Disease Control and Prevention (CDC) regarding your cont!nuin.!! concerns about radon and other radioisotopes In groundwater near the Brookhaven National Laboratory (BNL) and in drinking Water provided by the Suffolk County Water Authority (SCWA). Sinee 2008, ATSDR IlA'I responded to each ofyour concerns and requests for publio health evaluations ofspecifIC environmental releases and review of sewA regulatory compliance operatiOOll1 procedures. In every c;ase, ATSDR bas evaluated the information you provided along with additiooal information and data we obtained from sewA. the New York State Department of Health (NYSOOH), the New York State Department of Environmental Conservation, and the U.S. Environmental Protection Agency. As a direct result of ODe request, ATSDR developed and reloued the September 2009 Brookhaven LaDdfiU Health CoDsultatiOll. In addition. ATSDR obtained a commitment from NYSOOH to conduct an updated cancer registry review for NlSIIlu and Suffolk Counties, New Yark. ATSDR and CDC are not environmental regulatory agencies and do not review or eval~ environmental regulatory operational procedures of other organiz.ations or agencies. Therefore, we CIlIIDot comment on how or whether SCWA or other organi7ations are in compliance with Safe Drinking Wawr Act or other environmental regulatory requirements. Most ofyour recent concerns bave focused on whether I'Bdon and other l'lIdioilotDpes are in poundwater near BNt and in SCWA driDking water at levels ofpublic health concern. You provided ATSDR with coples of tile SCWA Warer Quality Reports and various other reports shout the Long Isbmd groundwater quality. On each of the copies, you highlighted specific high readings. . The Vlst mlliority of the sampling results indicate that radon and other radioisotopes are not above the laboratory detection levels in groundwater and drinking water. When all of the sewA and New York State data are analyzed. the potentiallong.tenn level of exposures to radon and other radioisotopes are significantly less than the occasional high readings that you highlighted. ~ Therefore, we have concluded that the measured levels of tldOD III1d other radioisotopes in SCWA dr\nlciDg water are not at levels of heslth concern. _1 At your request, we specifically evaluated whether the evaporation of radon out of sewA drinking water could increase the indoor air levels of radon above the national health-based indoor air standard of 4 picocuries per liter of air, Using the recommended methodology in the 1999 NAS report, Risk Assessment ofRadon In Drinking Water (i.e., water to indoor air trsnsrer coefficient of 1.0 x 10-4), we determined that the rsdon found in SCWA drinking WBter would not result in indoor air levels above the national health·based indoor air standard. We are confident that our scientific activities since 2008 have lICCUllItely assessed the risk level of possible exposure to radon and other radioisotopes in SCWA drinking water. Based on our evaluations, we have determined there is no risk to bwnan health from Ingesting, inhaling or having skin contact with SCWA drinking water. In the absence of new infonnation and data for analysis that suggest people are being exposed over a long period oflime to high levels ofradon or other radioisotopes, we are unable to reinstate your petition regarding radon and other radioisotopes in groundwater near the BNL and in drinking water provided by the SCWA. Thank you for your interest and commitment to ensuring safe drinking water for residents of Suffolk County. Sincerely, /iL1V~ Robin M. Ikeda, MD, MPH RADM,USPHS Deputy Director, Office ofNoncommunicable Diseases, Injury and Environmental Health. and Acting Director, National Center for Environmental Health, and Agency for Toxic Substances and Disease Registry Centers for Disease Control and Prevention We have reviewed all of the information you provided to support your !lSSC'rtlon that radon and other tldioisotopos are pmoot in the groundwater and drinking water at levels ofhealth concern. Using methodology established by the risk assessment scientific community, including the National Academy of Sciences (NAS), ATSDR ClValuated the lonS-tenn levels of exposure of someone who might ingest, inhale, or have skin contact with the drinking waler provided by SCWA. ATSDR evaluated possible long-term ex:po9ll1C levels by conducting statistical analyses of aU the SCWA lUId New Yark State available sampling resuhs, including the elevated levels you highlighted. _______________________ [1] “Radon transfer from groundwater used in showers to indoor air”, by David S. Vinson, Ted R. Campbell, Avner Vengosh, J. App. Geochemistry, June 7, 2008 @ http://sites.nicholas. duke.edu/avnervengosh/files/2011/08/Radon_in_air.pdf. Attachment A: List of Man-made and Naturally-Occurring Radionuclides addressed by 15 pCi/L gross alpha particle activity MCL standard4 Nd-144 Sm-147 Sm-148 Po-208 Bi-210 Bi-211 Bi-212 Bi-213 Bi-214 Po-210 Po-212 Po-213 Po-214 Po-215 Po-216 Po-218 At-217 At-218 Tl-217 Ra-219 Ra-223 Ra-224 Ra-226 Rn-220 Fr-221 Fr-223 Ac-225 Ac-227 Th-227 Th-228 Th-229 Th-230 Th-232 U-230 U-232 U-233 U-234 U-235 U-236 U-238 Pa-231 Pu-236 Pu-238 Pu 239 Pu-240 Pu-241 Pu-242 Np-237 Am-241 Cm-242 Cm-244 Cm-245 Cm-248 Bk-248 Cf-250 NOTE: This University of Minnesota Web page http://enhs.umn.edu/ hazards/hazardssite/radon/ radonharm.html lists a host of cancers & harmful respiratory effects associated with chronic exposure to Radon-222 and its 7 deadly decay products, such as: • lung cancer (typically bronchogenic), squamous cell carcinoma, small cell carcinoma, adenocarcinoma, large cell carcinoma & • emphysema, pulmonary fibrosis, chronic interstitial pneumonia, silicosis, respiratory lesions, chromosomal aberrations, etc. EPA-Directive no. 9283.1-14 MEMORANDUM SUBJECT: Use of Uranium Drinking Water Standards under 40 CFR 141 and 40 CFR 192 as Remediation Goals for Groundwater at CERCLA sites FROM: Elaine F. Davies, Acting Director Office of Emergency and Remedial Response (OERR) Office of Solid Waste and Emergency Response Stephen D. Page, Director Office of Radiation and Indoor Air (ORIA) Office of Air and Radiation [Dated November 6, 2001] This list includes only those radionuclides with half lives exceeding 4 days . 4 -8-
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