RE: Environmental modeling position at EPA -Reply

["Karam, Andrew" <Andrew_Karam@URMC.Rochester.edu>]

Dear Gerald,

My concern with this notice is that the position was posted as one that
looked as though it will entail modeling of radioactive releases, asks for
"solid" scientific credentials, but places more emphasis on interactions
with various constituency groups than on direct knowledge of ionizing
radiation.  This suggests to me that EPA is more interested in making policy
and regulations in general than in making sure that their policies and
regulations are well-founded in science.  This comment has been made by many
people in many fields, not just by HPs on Radsafe.

My academic background includes a number of courses, and some practical
experience in hydrogeology and environmental fate and transport modeling.  I
realize that the physical and chemical properties of the contaminants are of
greater importance than their radiological properties when modeling their
behavior in the environment.  However, I also realize that it is kind of
nice to understand the effects of whatever it is that you're modeling in
order to have a "common sense" check as to whether or not your answers are
reasonable.  For example, if you are modeling the NW Plume at Paducah (Tc-99
and TCE) and, when all's said and done, you come up with a dose of several
rem to the maximally exposed individual, unless you have some understanding
of health physics, you will not know if this is good or bad, realistic or
unrealistic.  All you have is a number without any understanding of its
significance.  If you then go on to recommend remedial actions based on
these numbers, still without a real understanding of their validity or
significance, the whole situation is compounded further.

Along a similar line, one person from EPA suggested that, at a
radium-contaminated site I was involved with, cleanup criteria should be 5
pCi/gm until you got within a few meters of any dwelling, at which point
they should go to 4.5 pCi/gm.  The rationale was to reduce radon deaths by
10%.  Nice in theory (LNT considerations aside), but difficult to put into
practice.  In fact, this suggestion was shot down by asking how the EPA
intended to tell the difference.

To me, it makes little sense to advertise a scientific position that will
presumably be dealing with modeling the distribution of radioactive
materials in the environment and then to say that it's not necessary to
really know anything about ionizing radiation as long as you can explain
your results to lawyers, the public, and other regulators.  This seems, in
fact, to be an extension of what Ray Johnson is concerned about, only at a
higher level.  If it's not necessary to know about radiation to do the
modeling that the regs are (and will be) based on, then why should it be
necessary to know about ionizing radiation in order to run a radiation
safety program?  

If, in fact, it is expected that the successful applicant will receive
training to remedy any knowledge deficiencies in this area, then this should
have been clearly stated in the position description.  And, if someone from
EPA who knows about this position states this to be the case, then I will
happily (and with great relief) retract my comments.
Sincerely,

Andy
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