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reprinted without permission from the San Francisco Chronicle, Monday,
September 2, 1991

THE EPA'S "FLIMFLAM" REGULATIONS ON RADON

by Warren T. Brookes

The fiscal plight of state governments has been well documented.  Not so well
reported is one of the principal reasons for this plight: Mandates from
Washington on everything from health care to the environment.

One reason for this is that environmentalism is a "free vote" for congressmen
because the costs are paid by other jurisdictions, public and private, and
usually hidden from view.

Not anymore.  Last month, Columbus, Ohio, said environmental mandates already
in place would cost 1.3 billion to 1.6 billion during the next decade.   With
new mandates coming along, current per-household costs of about $200 will rise
to $856 per year.

The Columbus study makes a powerful point: Too many Washington environmental
mandates are not only far more costly than predicted, but address only
perceived rather than real risks.

For example, last June, the Environmental Protection Agency issued its proposed
rule on radionuclides (mainly radon) in drinking water.  The EPA said the rule
would avoid some 83 cancer cases a year for a total capital cost of 2.4 billion
and an annual cost of $310 million.  If these figures had any basis in reality,
the regulation would be a bargain at 4 million per cancer risk avoided.

But everyone knows those figures are absurd.  The Association of California
Water Agencies, representing about 400 public water providers, says the actual
cost to California alone would be $3 billion in capital and $540 million a
year.

Since California has one of the lowest radon levels in the nation, the actual
cost to all the states would be at least $34 billion in capital and $6 billion
a year.  That's a cost per cancer risk avoided of more than $70 million, 18
times the EPA's projection.

Even that might be acceptable if the estimate of 83 cancer risks avoided bore
any resemblance to reality.  But it doesn't.

This is because the EPA has chosen to regulate radon in water at 300 picocuries
per liter or about half the present water average of 600.  That may sound like
a lot, but as the EPA-proposed rule states, "every 10,000 pCi/l radon in water
contributes about 1 pCi/1 radon to indoor air in the average home."

Since the average residential background level of radon in air is 1.2pCi/l (or
12,000 in water), U.S. water exposure is already 20 times lower than background
air exposure.  Thus, the EPA proposes to lower water to 40 times below residen-
tial "danger level" of 4 pCi/l, which is the equivalent of 40,000 pCi/l in
water.

This would be bad enough on its face were it not for the fact that the EPA
"danger" level in homes is already under attack in the science community as
overkill.  Canada's standard is about 20 pCi/l, which is the equivalent of 200,
000 pCi/l in water.

Canada has found no correlation between raised radon levels and raised lung
cancer death rates.  Pennsylvania, Iowa, Minnesota, Florida and Utah have found
inverse correlations between radon levels and lung cancer death rates: the
higher the average levels of residential radon, the lower the lung cancer death
rate.

The EPA risk model on radon is now under as much fire as its already discredited
models on dioxin, airborne asbestos and pesticides.  Phillip Abelson, the
distinguished senior editor of Science magazine, calls EPA's radon program
"flimflam."

Studies by the National Cancer Institute have repeatedly shown no evidence of
raised lung cancer from raised residential radon exposure, even among Chinese
women exposed to double the U.S. residential average.

Perhaps the most telling point is raised by William Nazaroff of the prestigious
Lawrence Berkeley Indoor Pollution Laboratory, who puts the potential cancer
risk from radon to nonsmokers at only 500 cancers nationwide.

Accepting Nazaroff's figure for a nation exposed to an average background radon
level of the equivalent of 12,000 pCi/l in water implies the actual danger of
radon in water at 600 pCi/l is essentially nonexistent.

Why doesn't the EPA just regulate water at the residential background level of
12,000 pCi/l?  Because at 12,000, there would be almost no need to regulate!

California estimates that only 13 percent of its grond-water systems are above
1,000 pCi/l and less than 3 percent above 5,000.  On the other hand, regulating
at 300 would require 90 percent of California's water systems and to spend
money on radon reduction systems.

The only beneficiaries of such madness are regulators and politicians, who
will reap special interest contributions from those selling the equipment
needed to carry out this mindless Washington mandate.

Warren T. Brookes is a syndicated economics writer based in Washington, D.C.