Radon Daughter Exposure Estimation And Its Relation To The Exposure Limit

INTRODUCTION This presentation is concerned with the administrative and technical capability of the Atomic Energy Control Board (AECB) to assure compliance with the individual exposure limit for radon daughters (currently 4 WLM per year). It is not concerned with the epidemiological bases for setting the exposure limit. Moreover, the intent is to show how sophisticated methodologies and advanced technologies, applied to radon daughter concentration measurements in uranium mines, convey the spirit of compliance by providing better estimates than do the historical methods. These better estimates mean that more accurate and more precise estimates of each worker's exposure are determined using these more modern methods and devices. The estimates so derived should provide more convincing evidence to an individual worker that his assigned exposure is a valid indicator of his true exposure. In addition, a perspective on the exposure estimate in relation to the exposure limit is given as further evidence that an exposure limit is not the dividing line between "safe" and "unsafe" exposures. A brief description is given of the compliance aspects of the Atomic Energy Control Regulations and of the limitations of purely statistical non-compliance procedures. Most of the emphasis of the paper will be placed on the uncertainties associated with conventional radon daughter exposure determination and the means being employed (and anticipated) to reduce these uncertainties. NON-COMPLIANCE Under current Atomic Energy Control Regulations (1978), the annual individual exposure limit for radon daughters is given without reference to the possible methods of sampling and calculation of radon daughter exposure and without any reference to possible uncertainties or their magnitudes. This is common in such statutes, the details of sampling, calculation, error analysis, and so on, being left for licence conditions or provided as a specific guideline to the licensee on the matter of compliance with the Regulation. Since the exposure limit is contained in the Regulations, compliance with it is absolute, as with any other law. In Canada, a state of non-compliance with the radon daughter exposure limit exists when an exposure (attributed to an employee) is reported by the licensee to exceed the limit. No uncertainty in the measurements or in the overall determination of exposure is reported nor is any requested. Removal of the worker and the loss of his services are the immediate and direct penalty suffered by the licensee for failure to maintain the exposure at, or below, the limit. A worker may be re-instated to employment for the balance of the reporting period only if the licensee can assure the AECB that further significant exposure to the worker will not ensue. In other jurisdictions, such as the United States, non-compliance is defined on a statistical basis. For example, NIOSH, the National Institute for Occupational Safety and Health presents procedures for calculating the 95% Lower Confidence Limit (LCL) in order to "compare the results of occupational environmental sampling to an occupational health standard and make a decision with a known chance of making an incorrect decision that a state of non-compliance exists" (Leidel and Busch, 1975). (In the nomenclature of this presentation, exposure limit would be used in place of "standard", in the NIOSH sense). Furthermore, it is emphasized in the NIOSH document that such numerical comparisons "are necessary only if the sample mean is greater than the standard". The NIOSH document points out, quite correctly, that the "statistical procedures presented below will not detect and do not allow for analysis of highly inaccurate results, i.e., systematic (non-random) errors or mistakes ... If a systematic error is known to exist in an instrument or analytical procedure then correct the sample mean of the data before analyzing for non-compliance". It is certainly not the purpose of this paper to criticize the sophisticated statistical approach to non-compliance as given in the NIOSH document or in similar approaches used in other jurisdictions. Rather, the purpose is to approach, with some introspection, the question of the determination of exposure by the employer for his employee and especially the employee's understanding of, and confidence in, the accuracy of the exposure determination and its relation to the exposure limit. DETERMINATION OF EXPOSURE Historically, in uranium mines, exposure to radon daughters for an individual miner