From Name
Terry Howell

Gary, AllAccording to NAS, "Technologically enhanced naturally occurring radioactive materials are any naturally occurring radioactive materials not subject to regulation under the Atomic Energy Act whose radionuclide concentrations or potential for human exposure have
been increased above levels encountered in the natural state by human activities."
One only has to visit the quarries where the aggregate is mined or the sand pumps where the sand is pumped from the stream beds and watch the processes of how the materials are sieved, and washed for preparation to see that a tremendous amount of "natural" material that is undesirable in the mix is being removed, especially from the sand, and that the end product is therefore "enriched" (E.G. more pCi/g after).
What is more significant is "... or potential for human exposure have
been increased...".
By choosing to ignore the problem and by arbitrarily and capriciously choosing to insert "other than radon" into its guidance to protect the special interest groups, the EPA is, in my opinion, has committed gross and willful negligence, and perpetuates the very environmental injustice on the poor and disadvantaged that it was supposed to be protecting.
Terry E. Howell, President
Radalink, Inc.
thowell@radalink.com
770-457-1944
-----Original Message-----
From: McCahill, Gary [mailto:Gary.McCahill@ct.gov]
Sent: Tuesday, December 14, 2010 10:21 AM
To: Terry Howell; RADONPROFESSIONALS@LIST.UIOWA.EDU
Subject: RE: [RNPROF] Reminder
What technological enhancement of thorium concentration is performed in the production of concrete? While NORM may be present in the sand or aggregate used to make concrete, and may contribute to radon, it is not "enhanced" or concentrated. An example of TENORM might be Magthor, where thorium is added to magnesium to make it harder and more heat resistant (often 4% thorium by weight).
What does TENORM stand for?
Technologically Enhanced Naturally Occurring Radioactive Materials (natural materials in which the concentration of radioactive material is enhanced)
EPA Regulations
EPA and other Federal and State agencies are responsible for regulating public exposures to NORM that are not licensed by NRC. State authority is derived from the Constitution, by which the States have primary responsibility for the health and safety of the public. EPA, State, and NRC programs do not treat the radiological risks from NORM consistently. NRC licensees generally are required to meet more restrictive conditions than are possessors and users of other NORM. There are no significant differences in the radiological risks of these materials, although radon and some discrete radium sources have a higher radiological hazard than uranium and thorium (NRC 1996).
Currently there are no federal regulations specifically controlling TENORM. However, numerous federal laws do regulate parts of the TENORM industry. An example is the NESHAPS for radon emanation from a mill tailings pile.
EPA has authority to protect the public health and environment from adverse affects of exposure to ionizing radiation. The authority to regulate TENORM is derived from several statutes, including the AEA; the Clean Air Act (CAA); UMTRCA (as mentioned before); The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); and the Toxic Substances Control Act (TSCA). The Resource Conservation and Recovery Act (RCRA) and the Solid Waste Disposal Act (SWDA) explicitly exclude source, byproduct, and special nuclear material (by definition), but they do not explicitly exclude NORM/TENORM. TSCA includes a subchapter on Indoor Radon Abatement, which was written with residential NORM (i.e., Rn) in mind (EPA 1993).
________________________________
From: International Web Resource for Radon Professionals [RADONPROFESSIONALS@LIST.UIOWA.EDU] On Behalf Of Terry Howell [thowell@RADALINK.COM]
Sent: Monday, December 13, 2010 3:39 PM
To: RADONPROFESSIONALS@LIST.UIOWA.EDU
Subject: Re: [RNPROF] Reminder
For much of the 90's I was a real proponent for the EPA setting up a "centralized" database of test results that could eliminate the duplication of having to report our data to all the licensing states in a multitude of varying formats (E.G. a different query for every state). At first I did not understand why all the states were against this but in early 2000 a nice lady from one of those states sat and explained the facts of life in government and that if something like this happened jobs would be lost and already slashed budgets would be cut even further. Since that time I have also come to accept that the states probably would not change their requirements anyway, if for no other reason, and rightly so, than because of the cost of modifying their individual records and databases to accommodate what ever format the feds would mandate. I have also seen and experienced first hand what can happen when results are voluntarily passed along to state programs that have no programs and how they can misuse that data because there is no protection given to the businesses that provide it.
For more than a decade the EPA has done little or nothing in furthering anything other than very fundamental awareness of radon. They have ignored requests and even demands from the industry that they exercise their regulatory ability and enforce existing law. They even opposed their own OIG and claimed they had no regulatory power. It has now been more than two years since the collapse of FANNIEMAE and FREDIEMAC and their being absorbed by HUD, yet, the EPA has continued to ignore the very mission it was established to fulfill; enforce the NEPA statutes. What is even more egregious is that they continue to ignore the elevated radon levels in high rise residential properties that are being caused by radon emanation from the concrete and concrete products they are constructed with. By it's own definitions concrete is TENORM and EPA has clear regulatory authority over it and since the monitory loss potential is so great, there is true RISK involved not to mention the environmental injustice to the poor and disadvantaged that must live in these buildings thinking they are safe.
It is my opinion that the EPA should squash this initiative to move into the data collecting business and find better uses for its meager resources for radon. If they can find nothing better to do with the money we taxpayers provide them, go mitigate a school or housing project somewhere. Anywhere! The last thing the radon industry needs in this economy is another US EPA "Don't Test for Radon Here Map".
Terry E. Howell, President
Radalink, Inc.
thowell@radalink.com
770-457-1944
-----Original Message-----
From: International Web Resource for Radon Professionals [mailto:RADONPROFESSIONALS@LIST.UIOWA.EDU] On Behalf Of Field, R W
Sent: Monday, December 13, 2010 11:30 AM
To: RADONPROFESSIONALS@LIST.UIOWA.EDU
Subject: [RNPROF] Reminder
-----REMINDER: Seeking Feedback on a Radon Data Exchange Initiative, Feedback Open Through 12/15/10-----
***Launching a Radon Data Exchange Workgroup***
EPA is launching a partnership effort through RadonLeaders.org to work on better coordination in the collection of radon data, and the aggregation of available data.
An initial meeting to discuss this effort will be held at 1:00PM EST on Friday, December 17, 2010. To learn more, provide feedback on the initiative, and register for the first meeting please visit:
www.radonleaders.org/node/8206. Feedback is open through Wednesday, December 15, 2010.
If you have any questions please contact us at info@radonleaders.org.
________________________________
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