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t DRAFT DATE: TO: FROM: SUBJECT: June 7, 1990 Any Millman Tom Borelli THE~.FPA' S ETS I3T._ ASSEa, MEMo ( Radon. EPA ) e ON RESEARRC,6 NO'I INCLY3 ED THE TSK INTRODUCTION in 1986, when the NAS ( NRC ) issued its report on ETS, it listed three kinds of scientific information as "missing". The third missing category was described as: "3. The interaction between ETS and radon exposure, which can increase risk of lung cancer, is worth examining further." The NAS and the EPA both concluded that an investigation of a possible combined effect of ETS and radon was warranted. When the EPA designed and contracted out the current Risk Assessment, it did so under a general agreezent with Battelle. The EPA engaged Kenneth E. Brown (a consultant to the SAB) to do the Risk Assessment. Ken Brown sub--contracted' with Douglas Crawford- Brown to do sections on lung cancer and a chapter on the "Interaction of ETS with Radon Progeny" (see attached). No such chapter appears to be part of the current draft. What happened? Their assumptions about ETS and radon appear to have been wrong. Apparently their investigation did not find a negative combined effect. RADON_ P~D CANCER Radon is a naturally occurring gas. it seeps into buildings from the ground. It takes the form of alpha particles. These are free floating radiation particles called radon progeny or radon daughters. In this form they can be inhaled into the lungs. Once in the lungs, these progeny can become attached and remain for an extended period thus increasing the risk of developing cancer. Previous studies have shown two important facts: 1) Radon progeny in a room will attach themselves to walls, ceilings, furniture, etc. The more the progeny become attached to surface.s, the fewer there are left to be inhaled.

DRAFT. 2) When free floating progeny are inhaled, about 90% of them will become attached to the lung. Rz1DOXVETS AN `i'HE RISK ASSESSI~NT In October 2989 a paper was presented in San Francisco at the annual meeting of the Society for Risk Analysa.s. The paper was called 'i'KE ZNF U NCE OF ETS ON THE RISK OF LUNG CANCER FROM RAD_O_U 2,ROGENX IN 'I'HE HOME ._ It was written by Douglas Crawford-Brown and read by his employer, Kenneth G. Brown. These are the same Browns hired by the EPA to prepare the current risk assessment - including the chapter on ETS and children and the missinq chaRter on ETS and radon. In doing the risk assessment work, the Browns did not do any new research. For their conclusions about ETS and lung cancer they didd meta-analysis on 24 existing studies. They did a literature review to come up with the section on children and ETS. They did a mathematical model to calculate ETS and radon exposure in homes. As a result of this study they concluded that: "ETS 3.owe the Dose-Rate. It makes nrogeny Iess_ava~able~" in presenting the paper in San Francisco, Xen Brown reported that, like radon, ETS consists of particles which hang suspended in the air. If radon progeny are in the same air, the progeny attach themselves to the ETS particles. While he did not specifically state it, previous studies had shown that when an individual inhales ETS particles, with or without ~ed attached radon progeny, 851 of wat they inhale will be exh In other words, the radon progeny attached to the ETS particles get exhaled. They do not attach themselves to the lung. They do not remain in the lung for a long time. They do not have the opportunity to cause cancer. CONCLUS_ZUDt Crawf ord-Erown ° s f indings were not what the EPA wanted to hear. And, they certainly were not what they wanted to publish in thoi.r Risk Assessment. Therefore, they simply excluded these findings from the Risk Assessment even though they were bought and paid for. In effect, this action changed the Risk AssessMOnt from aa scientif ic report to a political position paper. UESTIONS 1. Why was this information not included in the Risk Assessment?

DRAFTC, 2. Why have the chapters of the Risk Assessment been changed? 3. When was the chapter claiming respiratory effects added to the Risk Assessment? 4. What was the original contract between Ken Brown and the EPA? 5. Why was Ken Brown, a consultant to the EPA's SAB, chosen to do the Risk Assessment? SUPPORTLNG EVIDENCE FOR THE CRA,WFOR3?-BR'OWrI _REPOR=-jNDIN~S (NPL has a tape of the paper being read.) The following tables, showing the reduced availability of progeny were presented (by slides) during the reading: "Rat 'on Dose-Rate W/ETS to Dose-Rate WO ETS InWal Particle Rati o 1. Goncentr_ation 5,000 0.6 10,000 0.78 50,000 0.85 100,000 0.86 Ratio 1: Includes effect of unattached ions Ratio 2: Excludes effect of the unattached ions" Ratio 2 3.9 2.3 1.2 1.1 (NOTE: This is due to expeximental data in unpublished study by D. L. Swift suggesting removal of unattached progeny in the nasa.l passage) "Summary: 1} Dose-rate in the house wo/ETS 2) Dose-rate w/ETS effect of increased particles in the air 3) Dose-rate with ETS included an assumed 2 fold increase in mucose." 0.0032 rads/mo 0.0023 rads/mo