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Internal SFUND Box Number 35 OF 283 

Initials/Date: LDS / 3-8-2007 
ldaR&'M-a.-/-$*m 

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Department of Energy 

Washington, DC 20585 

August 5, 1987 

Ms. Barbara Hostage 

Response Standards and Criteria Branch 

Emergency Response Division (WH-548B) 

U.S. Environmental Protection Agency 

401 M Street, SW 

Washington, DC 20460 

Dear Barbara: 

At the July 30, 1987, meeting of the workgroup on adjusting, the 

reportable quantities for radionuclides, I expressed some 

concerns about the deposition modeling used to examine ingestion 

pathways other than through drinking water. I agreed to reexamine the supporting technical background documents regarding 

deposition modeling and inform you of my findings and opinions. 

The two documents I re-examined were: "Technical Background 

Document to Support Proposed Rulemaking Pursuant to Section 102 

of the Comprehensive Environmental Response, Compensation, and 

Liability Act: Radionuclides" (draft, October 1986); and, 

"Methods and Results for Calculations of Radionuclide Reportable 

Quantities Under Varying Sets of Conditions" (undated, handed out 

at the July 30, 1987, workgroup meeting). 

The Environmental Protection Agency (EPA) has chosen to develop 

reportable quantities for radionuclides using a modeling-based 

calculational approach. The modeling approach adopted for 

examining the inhalation pathway is very simple and very conservative using these assumptions: a downwind distance of 30 

meters; a ground-level release; Pasquill type "D" (neutral) 

stability; wind speed of 1 meter/second; and, exposure of an 

individual in the plume centerline for 24 hours. The atmospheric 

dispersion model used for this analysis is not considered 

generally applicable for distances less than 100 meters for a 

variety of physical reasons, although calculations can be made by 

extrapolating plume spread parameters from published values at 

100 meters to represent conditions at 30 meters. That calculations can be made does not make these calculations any more 

meaningful in terms cf representing physical dispersion 

processes. Although concerned about the questionable applicability of the atmospheric dispersion model to distances of 30 

meters and the high degree of conservatism in the modeling 

assumptions, members of the working group chose not to make an 

issue of the modeling for the inhalation pathway because the 

calculations are at least straightforward and reproducible, and 

because other considerations not related to modeling (e.g., che 

distance of cordons around a transportation accident involving 

hazardous chemicals) appeared more important. 
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However, as I indicated at the meeting, use of the atmospheric 

dispersion model developed for the inhalation pathway as a 

starting point for calculation of deposition significantly 

increases my level of concern about the modeling approach for 

the vegetable and milk ingestion pathways because of the 

complexities of the physical processes involved. Calculation of 

deposition using the very conservative calculation of air 

concentration along the centerline of the plume substantially 

compounds the degree of conservatism in the analysis because of 

assumptions of maximum distribution over an area, as well as 

assumptions related to plant/cow uptake, amounts of vegetables 

available for human consumption, amounts of grass available for 

grazing by a cow, and availability of someone to drink the milk 

from the cow. The entire analysis becomes reductio ad absurdam. 

Interdiction of milk and foodstuffs would be a response action, 

and I question the need of considering vegetable and milk 

ingestion pathways in the development of reportable quantities, 

which are really triggers for notification. If I interpret 

Exhibit 3 of the second technical reference document correctly, 

the number of reportable quantities based on ingestion other than 

drinking water increases from four in the NPRM to over 200 for 

the next most likely condition (condition #16). I believe this 

increase is unjustifiable given the modeling assumptions 

involved. 

In addition to my concerns about the modeling for the 

determination of the reportable quantitites, I must strenuously 

object to the statement on page 20 of the second technical 

reference document that "EPA has since recognized that ... the 

derivation of the deposition velocity in the Nuclear Regulatory 

Commission model is incorrect." This statement is completely 

unsubstantiated and without basis. First, the reference* to NRC 

Regulatory Guide 1.109 is incorrect. Regulatory Guide 1.111 

presents the bases for deposition of airborne materials for 

routine releases. Regulatory Guide 1.111 has been used by the 

NRC and its licensees for about a decade without modification or 

repudiation. Second, the methodology used in Regulatory Guide 

1.111 does not result in a single deposition velocity considered 

in the determination of amount of material deposited from an 

airborne plume. The use of diffusivity theory (the basis for the 

Regulatory Guide 1.111 approach) in the determination of material 

deposited is probably a better representation of actual atmospheric 

processes than consideration of a single deposition velocity to be 

multiplied with a relative concentration (X/Q) to determine the 

amount of material deposited. Based on my experiences with the 

application of Regulatory Guide 1.111, an "effective" deposition 

velocity can be computed by dividing the relative deposition (,D/Q) 
J 

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by the relative concentration (X/Q), and this "effective" 

deposition velocity is generally less than 1 centimeter/second 

typically assumed (or about 1.2 centimeter/second as assumed in 

the technical reference document). However, the deposition velo~ 

cities determined by the two different approaches are not really 

comparable. EPA should remove the statement disparaging the NRC 

approach from the technical reference document and simply discuss 

the different theoretical approaches and the different results. 

However, I strongly suggest that deposition for pathways other 

than drinking water is not a relevant consideration for reportable 

quantities, and certainly not supported by any technical reference 

documents that I have seen. If deposition fcr these other 

pathways remains a consideration of EPA for the determination of 

reportable quantities, I believe that the entire modeling bases 

for both ingestion and inhalation would have to be re-examined. 

I hope you and your colleagues at EPA find these comments useful 

in the development of reportable quantities for radionuclides. 

Sincerely, 

^/4,rzy> 

X/ James E. Fairobent 

(X Office of Environmental Guidance 

and Compliance 

cc: John Riley, EPA