INDOOR RADON POLICY AND PROCEDURES LAWLER WOOD HOUSING, LLC

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Tobias Rogers
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INDOOR RADON POLICY AND PROCEDURES LAWLER WOOD HOUSING, LLC Prepared for Lawler-Wood Housing, LLC Riverview Tower, Suite 2000 900 South Gay Street

1 INDOOR RADON POLICY AND PROCEDURES LAWLER WOOD HOUSING, LLC Prepared for Lawler-Wood Housing, LLC Riverview Tower, Suite South Gay Street Knoxville, Tennessee Prepared by ORION Orion Environmental Solutions, Inc Hodges Landing Drive Knoxville, Tennessee September ORION

2 TABLE OF CONTENTS Indoor Radon Policy & Procedures Page Overview 3 Objectives 3 General Information 4 What is Radon? 4 Radon Gas Health Hazards 4 Regulatory Information 5 Radon Testing 6 Retesting 7 Radon Mitigation 7 Training 8 Inspections and Routine Maintenance 8 Resident Notification 8 2 ORION

3 INDOOR RADON POLICY AND PROCEDURES LAWLER WOOD HOUSING, LLC Indoor Radon Policy & Procedures OVERVIEW: This source of information for this guidance is mainly the U.S. Environmental Protection Agency (EPA), U.S. Department of Housing and Urban Development (HUD), National Apartment Association (NAA), and National Multi Housing Council (NMHC). Federal agencies have no regulations regarding indoor radon, but do have recommendations and guidelines. Some state and other federal agencies have programs and guidelines for indoor radon. The guidelines provided here are a framework for indoor radon awareness and control at Lawler Wood Housing (LWH) facilities, in accordance with the regulations, accepted guidelines and industry standard practices. OBJECTIVES: To minimize and control potential sources of indoor radon within LWH facilities for a safe and healthy living and working environment, To assist employees of LWH facilities in establishing procedures for addressing potential indoor radon issues in their multifamily facilities. Achieved by: o Establishing policies and procedures within LWH to ensure adequate communication, information, and practices regarding indoor radon, o Informing personnel involved in maintenance and janitorial activities of the locations and potential health hazards of elevated indoor radon, o Informing all residents of known indoor radon issues, if any, at the facility at resident registration, and o Maintaining documentation and records for all indoor radon activities (e.g., monitoring results, mitigation actions, periodic monitoring results) involving LBP in the respective buildings. This Policy and Procedures covers: Potential LWH target facilities to be inspected for indoor radon, Health hazards associated with elevated indoor radon, Rules and guidelines regarding indoor radon, Effective communication and disclosure with residents, and Maintenance procedures for migration equipment, and Developing and maintaining appropriate indoor radon and mitigation documentation. Employees associated with indoor radon issues in the multi-family units should review these procedures, forms, and documentation contained in this Policy and Procedures document. 3 ORION

4 GENERAL INFORMATION WHAT IS RADON? Radon is a colorless and odorless gas. Radon is not a commercial product. It is a naturally occurring radioactive gas that comes from the natural breakdown (i.e., radioactive decay) of uranium and is usually found in igneous rock and soil. It can also be found in water in some cases. The release of radon from decay of rock is a constant naturally occurring process. RADON HEALTH HAZARDS The primary routes of potential exposure to radon are inhalation and ingestion. The Surgeon General has warned that radon is the second leading cause of lung cancer in the United States, and EPA estimates that 21,000 lung cancer deaths each year due to radon exposure. Only smoking causes more lung cancer deaths annually. Risks of dying from lung cancer caused by radon are much greater for smokers than nonsmokers. Scientific studies of radon exposure have shown that children may be more sensitive to radon because of their higher respiration rate and rapidly dividing cells during growth may make them more vulnerable to radiation damage. Although high concentrations of radon in groundwater may contribute to radon exposure through ingestion, the inhalation of radon released from water (e.g., showers, bathing) is usually more of a health concern. Because of health concerns, U.S. Environmental Protection Agency (EPA) established guidance levels for corrective action or mitigation are 4.0 pci/l (picocuries/liter) or greater of radon for indoor air. Levels of radon outdoors are very small as it is released to the atmosphere. There are no known health hazards for radon outdoors in residential areas or rural areas that are not associated with uranium mining, uranium processing, or uranium disposal. When radon is released indoors or underground (e.g., mines, tunnels, basements), it is not easily dispersed and tends to accumulate to high concentrations that can create a health hazard when inhaled. Concern about health hazards from exposure to radon in homes have been known since the 1980s in the United States. EPA and equivalent state regulatory agencies conducted several surveys for radon in homes in the late 1980s and early 1990s. EPA estimates that 1 in every 15 homes has radon concentrations that exceed the guidance action level of 4.0 pci/l. Exposure to elevated levels of radon is dangerous to people of all ages. Risk increases as an individual is exposed to higher concentrations of radon over a longer period of time. Because people spend so much time in their homes, EPA recommends that all residences be tested. Radon testing should be conducted in the lowest areas of the dwelling where a person would normally spend long periods of time (e.g., basement den, bedroom) or the first floor because this is where radon can accumulate. Radon in soil gas is the main source of radon problems in residences. Pathways for radon to enter a building include cracks in the slabs and walls, expansion joints between floors and walls, open sump pits, crawlspaces, and openings around utility penetrations. 4 ORION

5 REGULATORY INFORMATION EPA has no regulatory authority regarding indoor radon levels in air. However, EPA does have authority for carcinogens in water and since radon is a known carcinogen, EPA has established maximum concentration level for radon in water through the Safe Drinking Water Act. Therefore, the concentration of radon in drinking water from a public well or municipal supply and distribution systems are monitored and controlled. EPA has published and issued several information documents including The Home Buyer s and Seller s Guide to Radon, Citizens Guide to Radon that are available to the public. These and other documents about radon are available at EPA has developed a radon zone map which identifies indoor radon risk by county, with Zone 1 being the highest risk and Zone 3 being the least risk. Zone 1 counties have a predicted average indoor radon screening level greater than 4 pci/l (picocuries per liter) (red zones) Zone 2 counties have a predicted average indoor radon screening level between 2 and 4 pci/l (orange zones) Zone 3 counties have a predicted average indoor radon screening level less than 2 pci/l (yellow zones) Highest Potential Moderate Potential Low Potential The EPA Zone map for Tennessee is provided below: 5 ORION

6 The Indoor Radon Abatement Act and subsequent amendments require U.S. Housing and Urban Development (HUD) to develop an effective policy for dealing with radon using available guidelines and standards to ensure that occupants of housing subsidized by HUD are not exposure to hazardous levels of radon (4.0 pci/l or greater). HUD and EPA jointly prepared a document Radon Measurement in HUD Multifamily Buildings. The document has been updated with the 2012 Protocol of Conducting Radon and Radon Decay Product Measurements In Multifamily Buildings, by American Association of Radon Scientists and Technologists (AARST). HUD standards require radon testing and mitigation to be conducted by a radon professional. Radon professionals must be certified/accredited by the AARST National Radon Proficiency Program (NRPP) or the Nation Radon Safety Board (NRSB). If the state where the multifamily housing is located has its own regulation requirement for radon certification, the radon professional must have that state s certification for testing or mitigation. HUD standards for testing multifamily buildings for radon depends on the Radon Zone (Zone 1 to 3) for background indoor radon levels for the county of the building and the type of HUD funding that the owner is applying for. For some loans, HUD requires indoor radon testing regardless of the Radon Zone. RADON TESTING The purpose of conducting radon measurements is to identify locations that have elevated radon concentrations and to determine if radon mitigation is necessary in order to protect current or future occupants. The purpose of radon testing protocols or standards is to help achieve reliable radon measurements. The standard addresses the needs of building occupants, residence/facility managers, property owners, and radon measurement professionals concerned with radon measurements in multifamily buildings. The National Multi Housing Council and National Apartment Association recommend that facility managers notify residents that the radon testing will be performed. HUD standards require radon testing in multifamily buildings to be conducted by a certified radon measurement professional. HUD radon testing protocols specify at a minimum of 25% of the ground floor units in any one building must be tested and a minimum of 10% of units on each floor of upper floors in any one building. AARST standards for testing are more stringent and require 100% of all ground floor units to be tested. Lawler Wood Housing will use the HUD requirements unless the state of residency requires that the AARST standards be used. 6 ORION

7 HUD requirements follow the testing procedures specified by NRPP and NRSB. Testing must be conducted in the lowest occupied level of the multifamily building. The testing is non-intrusive, but requires placing a passive radon test kit or continuous monitor in residential units for a minimum of 48 hours. HUD requires that testing must be conducted the closed building conditions. This means that 12 hours prior to testing and during the 48 hour testing period that windows and door must be closed, except for normal entry to and exit from the unit. No fans or heating/air conditioning systems should be used to bring in outdoor air during the testing. Fans or heating/air conditioning systems that recirculate indoor air during the testing can be used. The test kits are placed in rooms that are normally occupied, but not in bathrooms or kitchens. Passive test kits or continuous monitors are collected by the radon measurement professional after the test period and sent to a certified radon testing laboratory (test kits) or read in the professional s office (continuous monitor). Test results must be reported to the facility owner and should be reported to the facility manager. HUD has no requirements to report the individual test results to the unit occupant. However, HUD does require that if the results are 4.0 pci/l or higher, the units must be retested to confirm the first test results or radon mitigation must be planned, designed and promptly implemented to reduce radon concentrations. RETESTING Factors can cause indoor radon concentrations to change over time, such as new exterior wall or slab openings, foundation settling, building deterioration, renovation/rehabilitation of the buildings or upgrades to energy and plumbing utilities. Retesting should occur when: Significant changes to slab, footers, or foundation occur, Construction blasting or earthquakes nearby Previously installed radon mitigation system is modified or repaired or A ground contact area that was not previously tested is now occupied or planned for occupation. HUD always requires that retesting be conducted after a mitigation system is installed in order to test the effectiveness of the mitigation. In this case, retesting must be conducted no sooner than 24 hours after the mitigation system is in operation and no more than one month after the system is in operation. Results must be reported to the building owner and facility manager. HUD has no other requirements for retesting multifamily buildings after initial testing or after installation of a radon mitigation system, but HUD s Radon Policy states that retesting should be conducted every few years. AARST recommends retesting each building every five years. RADON MITIGATION HUD requires that radon mitigation systems be installed by a certified and accredited radon mitigation contractor. NRPP and NRSB both offer accreditation to radon professional after passing stringent training and exams. HUD requires that if mitigation is required, the mitigation systems must be designed and installed for an entire multifamily building, not individual apartment units. The mitigation system requires that a sub-slab depressurization system be installed for the building. The basement/bottom level concrete floor must be penetrated to expose the gravel pack beneath, and PVC piping installed and connected to new piping that vents to the outside. A fan is installed on the 7 ORION

8 outdoor piping or attic to allow air beneath the slab to vent to the atmosphere or attic. The fans are very quiet and cannot be heard inside the apartment unit. This sub-slab depressurization system removes air with high radon levels from beneath the slab and vents them to the atmosphere rather than into the apartment unit. A flow meter (manometer) on the fan shows that the fan is operating, and some fan systems have alarms that sound if the fan stops running. Retesting the unit after the mitigation system is installed confirms that the radon mitigation system is working as designed (see Retesting section). HUD policy states that the landlord is responsible for paying the electrical costs of running the mitigation fan. TRAINING Facility management and maintenance should be provided information and awareness training about indoor radon (what is radon, health issues, mitigation, inspections). In addition, facility staff should be informed about whether indoor radon is a health or safety issue at their respective multifamily buildings. This includes the results of previous or planned radon testing at the facility and general results of the testing (less than or exceeding the EPA guidance level (4.0 pci/l) for further action). The staff should also know if radon mitigation systems have been installed, the locations of the mitigation systems and fans, and how to check on the system operation. Each staff member is required to sign the training attendance sheet. Annual training is recommended for staff and each new member is required to attend the training. Facility maintenance staff is not required to obtain training and testing to become radon professionals. INSPECTIONS and ROUTINE MAINTENANCE The fan manometers and radon venting pipes a facility s radon mitigation system will be visually inspected quarterly to ensure that the radon mitigation systems are operating and intact. These visual inspections will coincide with regular facility inspections by LWH staff. Periodic radon testing of building will be conducted by certified radon measurement professionals (see Retesting section). LWH facility staff will conduct annual inspections of radon mitigation systems at their facilities using an inspection checklist. HUD policy states that information needed for operating and maintaining the radon mitigation system should be included in the general operations and maintenance plan (O&M Plan) for the building. RESIDENT NOTIFCATION HUD has no requirements for notifying residents of upcoming radon tests and no requirements to report the individual radon test results to the unit occupant. 8 ORION

REAL ESTATE TRANSACTIONS

REAL ESTATE TRANSACTIONS More often, informed buyers are having radon tests performed when purchasing a home. Discovering elevated radon concentrations doesn t mean you need to walk away from the deal! Testing for and mitigating