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                                                 Regional Center for hmironmcmal Information

                                                      I'S EPA Region III
                                                       1650 Arch St

                                                     Philadelphia PA 1<>101
              REPORT ON  RADON AND  REAL ESTATE PROBLEMS
                       IN EASTERN PENNSYLVANIA

                    PREPARED BY MARY T. BREWSTER

                              APRIL,  1990
                                        U.S. EPA Region III
                                        Regional Center for Environmental
                                         Information
                                        1650 Arch Street (3PM52)
                                        Philadelphia, PA 19103
PREPARED FOR REGION  III AIR,  TOXICS,  AND  RADIATION  MANAGEMENT
DIVISION, SPECIAL PROGRAMS  SECTION, LEWIS K. FELLEISEN, CHIEF
(under  Greater  Leadership  Opportunities  rotational  assignment
January- April,  1990.)

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                          ACKNOWLEDGEMENTS

   This project was made possible with the cooperation of:

The Pennsylvania Association  of  Realtors,  the Boards of Realtors
of Philadelphia,  the Main Line, Harrisburg,  Bethlehem, Reading, and
in Delaware,  Chester,  Bucks, and Montgomery (Eastern/Central/North
Penn)  counties; and the realtors interviewed in those counties.

Thomas Gerusky, Carl  Granlund, and  Don Bowie of the Pennsylvania
Department   of   Environmental  Resources  Bureau   of   Radiation
Protection.

Lew Felleisen  and  Bill Belanger,  EPA, Region  III,  Air Programs
Branch, Air,  Toxics, and Radiation Management Division.

Diane  McCreary,  Librarian,  and  Joyce Baker of  the  Region III
Information Resource Center.

Joseph T.  Piotrowski,  Chief, Permits Enforcement Branch, and Carol
Amend,  Chief,  Program  Management  Section,   Water  Management
Division,  who agreed to a three month rotational  assignment for the
author under the Greater Leadership Opportunities (GLO) program.

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                        Executive Summary

     Under  our mandate  to assist  the State  and  design public
information  projects   the  Region  III  Radon Program   included
realtors in  its  outreach efforts,  and  in January,  1990,  began a
radon outreach project to realtors in eastern Pennsylvania.

     Meetings were held with representatives  from the Pennsylvania
Association  of Realtors  (PAR),  with   county  Board of  Realtors
executives of Philadelphia, the Main Line, Harrisburg,  Bethlehem,
Reading, and in Delaware, Chester,  Bucks,  and Montgomery counties
to find  out  their problems,  and to advise them  of the resources
EPA/DER have available  on  radon.   Individual interviews and five
focus group interviews were also conducted.   Approximately thirty
five real estate agents provided comments in either individual or
group interviews for this project.

     The Pennsylvania Association of Realtors advises its members
to encourage radon testing, and to use its radon disclosure forms.
The PAR recommends that realtors use the Radon Disclosure Addendum
to Exclusive Right to  Sell Agreement, which  the  agent  and seller
sign when the seller lists a property for sale with a real estate
broker,  and  the  Radon Disclosure Addendum to  Agreement  of Sale,
which is used when the  buyer  presents a formal offer to purchase
a property.  These forms are  based on the duty of the  seller and
his agents to disclose defects to the buyer which could influence
the decision to purchase.   Failure to do so  could make the seller
and the  realtor  liable if radon is  found after  settlement  on a
property. Since  the  seller may not  know  that radon is  present,
giving the buyer the opportunity for a radon test gives the buyer
information on a hidden defect which may influence the decision to
purchase a property.

     Realtors identified problems with  short and  long  term tests
in real estate transactions, with seller disclosure of radon, with
sellers being penalized for radon problems,  with  escrow  of funds
for radon repair,  with public education scare tactics,  and with
lack of buyer/seller knowledge about radon.

     The realtors interviewed  seemed receptive to EPA  efforts to
find out about their problems, and interpreted this as a way for
EPA to avoid an adversarial role with realtors.   Generally,  just
about all realtors interviewed had been to at  least one training
seminar  on  radon,   and seemed  knowledgeable  about  radon  and
mitigation.   Many realtors felt that they had been saturated with
training on radon.

     Realtors identified solutions to the problems they encounter.
The public needs more  clear cut guidance  on  radon levels between
4 and 20 pCi/1,  especially  for real estate transactions.  There is

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a need for clear cut guidance  for  real  estate transactions which
takes into account  the  lack of time for long  term  testing.   EPA
should encourage homeowners to test  for radon  before homes go on
the  market.    Realtors  themselves  believed  that  the  National
Association-of Realtors  and EPA should work together more on radon
since it  is  a national  problem,  and guidelines  for dealing with
radon are needed.   Realtors saw a need  for  clear information on
risk and exposure for the  public.  They also thought that a more
consumer-oriented look at types of remediation, and how geography
and construction affect cost, would help the public.  They believed
that EPA/DER education programs on radon for realtors and for the
public should emphasize non-technical,  concise  facts on  how to
solve radon problems.  Realtors, and ultimately  the general public,
need solutions to practical problems.

     This project was an effort to determine how realtors perceive
radon problems, and  to document how the Agency's radon policies are
affecting the public.  Acting on this information is important to
the  success  of  communicating  the risks of radon.    EPA should
continue to pursue opportunities  to look at how the general public
perceives radon  so  that  the  Agency will  accomplish  it  goal of
increasing radon testing.  EPA  has  a  wealth of  radon data but must
recognize how confusing  the information on radon is  to  the non-
scientist.  The Agency must keep  sight of what  the public needs to
know as it continues to  find new  ways to communicate the risks and
implications of radon.

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1.  PURPOSE OF PROJECT

     The Toxic Substances Control Act gives the Agency its mandate
for indoor radon abatement and  sets  the long term goal of having
the air  within buildings in the  United States to be  as  free of
radon as the ambient air outside of buildings.  The Act gives the
Administrator the authority to develop and implement activities to
assist State radon programs.   EPA technical assistance to the
States includes design and implementation of public information and
education programs.  Less than 3% of homes  nationwide have been
tested, and the Agency's  goal  is to  encourage every homeowner to
test for radon. Under its mandate to assist the states with public
information projects, and with the staff resources provided under
the Greater Leadership Opportunities program,  the Region began a
radon  outreach project  to  realtors  in eastern  Pennsylvania  in
January 1990.

     The Region and  the  Pennsylvania Department  of Environmental
Resources have worked since 1985 to educate the public and realtors
on radon, and EPA Headquarters has been working with the National
Association of Realtors.   At the start of the project,  the Region
wanted to find out about  the  impact  of  radon on  residential real
estate  sales  and  prices,   the  frequency  of  cancelled  sales
contracts,  and  the  desirability  of  a  property  after  radon
remediation.

     EPA Region III  wanted to help  realtors  and  the public deal
with  radon.    EPA  wanted to  make sure  that realtors  know what
information is currently available to help them and home buyers and
sellers deal with this issue.  Since realtors  work  closely with the
public and see the daily problems of residential radon testing, the
Region believed there was a need to work at the state/local level
to document these problems and to provide a report to policymakers
working to resolve them.

     This project was not intended as a  formal survey of realtors,
but a first step in determining whether further research is needed.
The Region  will share  its findings  with  Pennsylvania,  the other
states, and with the county Boards  of  Realtors.   This may be  a
basis for a more formal national study of realtors  in the future.


2.  METHODOLOGY

     To begin the Radon Real  Estate  Outreach Project,  Region III
Radon staff met with the Director of Pennsylvania's Radon Program
to refine objectives  and  address State concerns.  The Region chose
eastern Pennsylvania for the  project because there were a variety

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of radon problems in the area,  and  its proximity to the Regional
office in Philadelphia would allow interviews within a short period
of time.

     EPA and  DER staff met with  the Director, Member  and Board
Services of  the Pennsylvania Association  of Realtors  (PAR),  to
introduce the project,  find out about the role of the PAR, and to
get support for the project.  PAR provided names of County Board
officers for interviews.

     Next, during  February and March,  there were  meetings with
Board of Realtors executive officers or presidents in Philadelphia,
the Main  Line,  Harrisburg,  Bethlehem, Reading,  and in Delaware,
Chester,  Bucks,  and   Montgomery  (Eastern/Central/North  Penn)
counties to find out their  problems,  and to advise them of EPA/DER
resources on radon.

     Individual interviews  and five group interviews were conducted
with realtors chosen at random,  or recommended by Board officials
because of their experience with radon.  Many county realtor Board
executives were also realtors who  could discuss the radon problems
encountered in real estate.  Group  discussions on radon problems
resulted at the  initiative of brokers in  charge  who invited the
agents  in their offices  to take part  in discussions.   Groups
contained  a  minimum  of  four  and  a  maximum  of  seven  agents.
Approximately thirty five real estate agents provided comments in
either individual or group interviews for this project.

     The  County  Board  President   or  Executive  Officer,  and
individuals/groups  received a  package of radon  materials which
included a  list of EPA/DER radon publications, names  and phone
numbers  of  EPA/DER radon staff,  copies  of a  Citizen's  Guide to
Radon, Radon  Reduction Methods, Radon Information  (a  fact sheet
prepared by the  Region), Pennsylvania's  Guide to Radon Reduction
Contractor Selection,  and Certified Radon Services Listing, and a
Map of  Percentage  of Radon Readings Above 4  pC  in Pennsylvania
(plotted December 18,  1989).


3.  OVERVIEW OF PENNSYLVANIA REALTORS' EFFORTS:  HOW REALTORS IN
PENNSYLVANIA DEAL WITH RADON

Role of th« Pennsylvania Association of Realtors and County Boards
of Realtor*

     The   Pennsylvania Association  of  Realtors   (PAR)   is  a
professional  real   estate  organization  which has  approximately
29,000 members.   Its  purpose is  to  encourage investment in real
property and  to  maintain a high professional standard of conduct
among its members  in accordance with the National Association of
Realtors' Code of Ethics.   This Code of Ethics exists to improve

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realtor professionalism and protect  the  consumer.   PAR helps its
members increase  their skills and  knowledge of the  real estate
industry  by  providing  real  estate  courses  and standard forms,
publishing a  monthly  newsletter,  the Pennsylvania  Realtor,  and
serving as a resource in legal matters.  PAR also gives advice on
how to run county  Boards, which serve the same purpose  at the local
level.

Explanation of Radon Disclosure Forms

     The Pennsylvania Association of  Realtors has a Standard Forms
Committee.  Both the PAR and realtors in the counties where radon
was first  found recognized the potential radon liability problem
and  believed  that  realtors  had  a  responsibility  to  inform
buyers/sellers about radon based on the duty to disclose property
defects.  Any broker or local  Board can develop forms, and the PAR
requests that local Boards submit these forms for review.

     The Pennsylvania Association of  Realtors advises and strongly
urges  its members  to encourage  radon testing,  and  to  use  the
disclosure forms, but does  not force the use of  the recommended
form.  As  a professional association  with voluntary membership, it
does  not  impose restrictions on  its members.   It would  take  a
government action to make the use of the form mandatory.

     The  PAR  recommends that  realtors use two forms:   the Radon
Disclosure Addendum to the Exclusive Right to  Sell Agreement, which
the agent  and seller sign when the seller lists a property for sale
with  a  real  estate  broker,  and the  Radon Disclosure  Addendum to
Agreement of Sale, which is used when the buyer presents a formal
offer to purchase a property.

     These forms  protect  the  interests of realtors,  buyers,  and
sellers.  Realtors and sellers gain protection from liability with
use of  these  disclosure forms.   The seller,  or his  agents,  must
disclose to the prospective buyer known defects that will adversely
affect the property.   The real estate agent, though  paid by  the
seller, has  a duty to  disclose  material,  latent defects  to  the
buyer. There is the possibility that  a  seller or a broker could be
sued on breach of  warranty, negligence, or failure to disclose, if
radon is  discovered after settlement.   since the seller  may  not
know that radon is  present, giving the buyer the  opportunity  for
a radon test gives the buyer information on a hidden defect which
may influence the decision to purchase a property.

     The Pennsylvania Association of Realtors revised these forms
in  January,   1990.     Realtors  discussed  the  old  form  during
interviews, so it is not possible to assess how the revisions  may
have affected realtors' perceptions of problems.   The realtors
believed that the forms were  helpful in  establishing  a procedure
for  dealing  with   radon  tests  in  residential  real   estate
transactions.

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l. Radon Disclosure Addendum To Exclusive Right To Sell Agreement

     This form includes a "Notice to Sellers Regarding Radon Gas"
which explains what radon is, its origins, and affects.  The form
protects  the seller  and the  real estate  agent  from potential
liability by requiring the  seller  to disclose knowledge  of the
presence of radon on the property, the date and the type of radon
test,  and the  date and  method  of  radon reduction.   The  form
includes a statement that the  seller  does not warrant either the
method or result of the test.

     The revised form requests the seller to provide more details
such as test dates, methods, results,  and radon reduction methods
used.  The revised form also added statements that the seller may
be required to provide details of any testing or radon remediation,
including copies of test reports, and that the  seller agrees to
make property available for testing during the term of the listing
agreement.  The property owner and the agent sign the form.

2.  Radon Disclosure Addendum To Agreement Of Sale

     This  form  gives the  buyer the  right  to have  the property
inspected for radon at his own expense, by a certified inspector,
within a  certain number  of days from  date  of execution  of the
agreement of sale.  The buyer, the seller, and the agent sign the
form.   If the inspection shows  radon greater than  4  pCi/1, the
buyer must  give the seller  a  copy of the test  results,  and the
seller may then  submit  a corrective proposal, in writing,  to the
buyer.  Upon receipt of the corrective proposal, the buyer has five
days to accept the proposal  in writing, which releases the seller
and  his  agents  from  liability,  or  the buyer  can declare the
agreement null and void, and all deposit monies shall be returned
to the buyer.


4.  BACKGROUND SUMMARY OF LITERATURE

     As a first step in understanding  the realtor's point of view,
a  literature review was done  to research the types of problems
radon had caused in real estate transactions.  As of March, 1990,
the literature search revealed articles which described theoretical
concerns about testing accuracy, disclosure and liability problems,
and the need for public education.  These articles were important
in  setting  the context  for the  issues raised  by realtors  in
interviews for this project.

     Articles describe  the  need  for radon  testing to be  done
quickly to complete a real  estate transaction,  while at the same
time, buyers and seller need accurate and reliable results.   The
literature  also identifies  a  need to  calibrate  and standardize
testing procedures so buyers can rely on the results.  Many factors

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influence  radon  concentration  such   as   season,   location  of
detectors, duration  of test,  conditions at  the test  site,  and
seller control of the property during the test.  This variability
may lead  to  the potential legal problem of getting reproducible
results.

     The  real  estate  industry  articles   described  a  need  to
establish  legal  standards to  judge the conduct of  real  estate
brokers and  agents when  dealing with  radon which consider  the
knowledge  and capabilities  of agents  and the  limits  of  their
knowledge. There is a need to protect the home buyer from possible
exposure to radon, and to protect the  seller and the  broker from
liability.   The use of radon  disclosure clauses to  protect  the
buyer and  seller,  and the creation of  escrow accounts  to  cover
potential radon mitigation costs after settlement are suggested.

     The  literature  search  revealed the need for  consumers  and
professionals to improve their  ability to recognize and understand
radon  problems,  and   for   buyers   to  have  enough   definitive
information  on  radon  levels  and   health  risks  to  judge  the
seriousness of a radon problem.  Buyers may  not know what test data
means and expect the real estate agent to interpret.

     While the findings of this outreach project are anecdotal, the
literature review documents  the problems realtors  see with  radon
testing, disclosure,  and public education.   Studies of the affect
of radon on real estate, the  problem of remediation based on short
term tests, or the need for specific real estate guidance,  do not
appear to exist.


5.  FINDINGS

General Realtor  Perceptions  of the Problems  of  Radon Testing in
Real Estate Transactions

     Realtors pointed out that buying  and  selling  a home induces
anxiety in general, and the  discovery  of radon can increase that
anxiety.   Affordability and repairs after the  fact  are general
issues of concern for home buyers.   They are also concerned  about
resale value  and radon,  and this can  be true even if  the  radon
problem haft  been fixed.  Buyers may have  doubts  and experience
"buyers'  remorse" after  signing  an  agreement of  sale.    The
discovery of, any flaw in the property  may  cause  them  to question
their decision.

     The radon disclosure  form  suggests the  option of a radon test
to buyers.  If buyers are uncertain whether to order a test, most
realtors seem  to advise testing.   One realtor  pointed  out that
"emotions run high,  it's better for  buyers to know about radon and
be reassured."

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     In general, buyers and  relocation  ccr.panies  are mere likely
than sellers to test  for radon.  If buyers are from outside a "high
radon area", they seem to have more fear of radon.  Some realtors
believe that many buyers don't test the homes they  already occupy.

     Relocation  companies  appear  to  require  radon  tests  and
remediation even between 4 and 20 pCi/1 based on  a  short term test.
Some buyers test even though the seller  has already tested, but it
is impossible  to say how frequently this happens.   While actual
numbers are difficult to verify, many realtors estimated the number
of buyers who requested radon tests.  One Board executive in a high
radon area  estimated that  90%  of homes  up for  sale have  radon
tests.  Two offices close to New Jersey, with buyers from the New
York-New Jersey  area,  estimate that about  95-98% of buyers want
radon tests.   Another company  estimated that about  50%  of buyers
want a radon test.

     While it  is difficult to quantify, most realtors interviewed
had at  least one transaction cancelled when a  test  showed  radon
greater than 4  pCi/1. Agents at one office estimate about 20% walk
away when a  radon reading higher  than 4 pCi/1  is  discovered.   It
is not  unusual  for  some buyers  to cancel deals on homes with
readings greater than 4pCi/l,  but some  agents  believe  that some
buyers look for reasons to walk away.  There is a  belief that some
buyers are using radon to nullify sales agreements, in part because
of "buyers remorse",  and possibly, because of fear of radon.

     The radon disclosure forms seems  to work well  in laying out
what needs to be done once high readings result.   The radon clause
in the agreement of sale gives  agents  a  procedure  for dealing with
radon tests, repairs, and what will happen  if a high radon  level
is discovered.   The  buyer makes  an offer,  and according to  the
radon clause if the buyer wants to test,  the buyer pays for it. If
corrective action is  needed, the  seller has the option  to repair
or  not,  and  the  buyer  can  accept  the  seller's  proposal  to
remediate, accept the property  "as is"  if the seller  does not want
to remediate, or cancel the agreement.  Less  experienced agents may
have  more  of   a problem  dealing  with  radon  issue  than  more
experienced agents; the agent's radon  knowledge makes it easier to
deal with radon.

     If sellers want to sell, generally they must repair,  because
in many areas,  it was a buyers  market  at the time  of the study. In
a slow  market, buyers have  many  choices, and can make  offers on
houses with no radon problem.

     Generally,  the  sales price  of a  house does  not seem  to be
affected  by the presence of  radon,  according to  the  realtors
interviewed.    In one  office  there  was  an   example  of  "bad"
remediation: a contractor installed an effective unit which was so
unaesthetic, the price of the house dropped by $25,000. This sseems
to  be an  extreme  case.    Some realtors see buyers who use 4+

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readings as a ploy for a price reduction, but it was not possible
to determine how frequently this happens.

     Realtors are viewed as experts by the public and as a result,
many Boards get calls  from the public on radon in general and about
the accuracy of the different types of radon testing in particular.
One realtor commented that "radon should not be all on the agent;
EPA/DER could do more public education."

     Many  realtors had questions  about whether EPA  plans  to
"tighten  the radon limit"  to  2 pCi/1.   Also,  there was  some
question about why EPA uses 4 pCi/1 as the action level, when the
number is higher in other countries.


Specific Problems with Radon Testing in Real Estate Transactions.

1.   Problems  With Short  And  Long  Term  Tests  In  Real  Estate
Transactions

     In The Citizen's  Guide to Radon,  EPA advises the public to do
a short  term screening test,  in the lowest livable area  of the
home, with all doors and windows closed during the test. EPA also
advises that the test  be done during the cooler months of the year.
The  Citizen's  Guide  recommends  follow-up  measurements be  made
before the decision to correct the radon problem.   If the results
of the  short term test  are between  4  and  20  pCi/1, the  Agency
advises long term follow-up measurements for one  year,  or  of one
week duration during each of the four seasons.

     This  advice  can  cause   problems  during  a   real   estate
transaction. Many  sellers do  not test  their homes before  they
decide to sell.   A buyer who looks at the house and decides to make
a formal offer  then has the right to test for  radon.  The buyer can
perform the test or hire a professional.  Some realtors raised the
problems of the "self test", with the possibility of seller/buyer
error in placement, the potential for tampering by the seller, and
the  two  week turn  around time  for results.   One county  Board
official  hears comments  that  some  people  think that  realtors
conspire with testers to profit from radon.   The policy of  Boards
and agents is not to  recommend testers or remediators when asked
by clients but: to give names from the  state certification list for
a client  to make a choice.   This  puts realtors in a  sensitive
position when asked to recommend whether  a client should self test
or use a professional tester which  costs more,  but gives  quicker
results.

     There are problems with tests in summer with low results, and
it is difficult  to keep a house closed up for  the test when the
buyer does not have control over testing conditions.  Realtors also
questioned whether a 4 or 5 pCi/1 reading during  the winter  is a

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cause  for  concern when the  reading is  likely  to be  much lower
during the rest of the year.

     There is  also  the problem of placement of  the  test device:
EPA advises-the lowest living area, possibly a basement, but many
realtors have  enough experience to  know that there is  also the
whole house average,  or a reading on one level  used as a living
area.  Realtors want to know  which  is the most reliable method for
a real estate transaction.

     If the initial screening shows a reading between 4-20 pCi/1,
there is not enough time to consider long term testing.  Further,
the  fact that  EPA brochures do  not advise remedial work on the
basis  of the  charcoal  canister  has led realtors, especially in
areas with many high radon readings, to question the validity and
accuracy of the canisters  themselves. Their perception is that if
the canisters were  accurate, EPA wouldn't tell  people  to do long
term testing with alpha tracks to confirm a radon problem.

     The potential  conflict  of  interest between companies which
both test and remediate is another  concern.  Realtors are aware of
the option to have one firm test  and another to remediate, buy see
a problem because time is needed to get estimates.  Some realtors
have  encountered radon mitigation  firms  which  want   to retest
before doing remediation.

     Realtors  almost  universally reported that  many buyers,  and
many relocation companies require remediation based on short term
test results which show readings of as low as 5 pCi/1.  Generally,
remediation is based on the short term test unless the seller pre-
tests.

2.  Perception of Problems with Disclosure of Radon

     There  is  a  burden on  both the realtor  and the  seller to
disclose defects such as radon and  both  can be liable if they fail
to disclose defects to the buyer.  Realtors work for and are paid
by  the seller  but  at  the  same time must  consider the buyer's
interest in  property  defects.   Where  radon is  concerned,  some
realtors believe the buyer's right to test is not in the seller's
best interest.  A buyer who  makes  a formal  offer tests for radon
and  finds  a  level even  slightly  over 4 pCi/1 may  cancel  the
agreement of sale.   Some  realtors  were  concerned that  the seller
then must  disclose the presence of radon to the  next potential
buyer, possibly making the property  less marketable,  or raising a
red  flag to a buyer who may have otherwise been unconcerned about
radon.
                                8

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3.  Sellers  Are Penalized For Radon Problems  Which They Did Not
cause

     There was  divided opinion among  realtors on  the  merits of
seller testing at the time of listing.  At the listing phase, the
realtor must  find  out  if the seller has knowledge  of radon as a
defect.  There  is  a burden  on both the realtor and the seller to
disclose defects such as radon to  the buyer and both can be liable
if they fail to disclose.  Some realtors encourage sellers to test
for radon  at the  time the  property  is listed  for  sale  with a
broker,  while  others  do  not.     One  realtor  and Board  member
recommends a  radon test  to  sellers at  listing; however, there is
always the  risk that if the agent insists  on a radon  test,  the
seller can go to one who doesn't.

     Some realtors view  the radon test as one more test to deal
with early in the listing process,  which will prevent problems once
a formal offer  is made.   These realtors believe that the listing
phase is a good time for a radon test because  it will help sell the
house.  These agents believe that they can prevent problems if they
advise the seller to test and use the  test report  as a marketing
tool if there is a low reading.  Some agents present  the radon test
to the  seller at  listing as a practice to  make the house more
marketable in the  same way  a termite  certification does,  so that
when a prospective buyer  shows interest  in the house, there will
be one less problem that could threaten an agreement of sale.  Some
real estate  agencies  in one county with a high number of radon
readings greater than 4 pCi/1, have given canisters  to sellers who
have used them to test, but to many buyers,  this does not seem to
be the same as an "official" test which may cost $60 or more.

     There were some realtors interviewed who  view radon testing
as something  which may hinder  a  real  estate transaction.   These
realtors don't see  radon as a seller's problem because radon occurs
naturally and was not caused by the seller.    For these realtors,
radon problems  don't seem to be  in the same category as termite
problems, which the seller did not cause, but must fix.  High radon
levels  are not  generally perceived  as the  seller's burden  to
correct.   The  seller  has lived  in the house with  no  apparent
problem, so why should he/she  fix it?   According  to one agent,
some realtors fearing lawsuits, suggest a radon  test. Other agents
question the emphasis on residential radon testing and mitigation,
when people, don't spend all  their time at home, and want to know
about the risk from radon exposure in offices, schools, and daycare
centers.

     There was concern that radon testing could penalize the
seller in two ways.  First, if there is a reading over 4 pCi/1, the
buyer might  still  cancel the sales  contract  even  if the  seller
fixes the problem.  Second, the seller is vulnerable  if the realtor
recommends a  radon test  because  if radon higher than 4  pCi/1  is

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found, the seller must disclose even  though  he  did not cause the
problem.

     Sellers are concerned about the cost of radon remediation, and
some agents-feel that radon testing poses a financial penalty for
the buyer, especially if a professional tester is involved.  Many
realtors asked  the  question:  is it reasonable  for a  buyer  or a
seller to fix a  radon problem with  a  reading somewhere between 4
and 20 pCi/1  without a long term test?   In one case, the short term
test showed a reading of 11, and the seller paid  $1200 to remediate
on  the basis of the short  term test so the  house  would  sell
quickly.  At another office,  the agents  found  that  sellers  were
usually willing to make  repairs  if radon is found.  They cited one
case  where  the  seller  refused to  make  repairs,  and the buyer
cancelled the agreement of sale.  The seller then took the house
off the market,  and later  put  it back  on the market  at  a higher
price, presumably to recover the cost  of radon repairs.

4.  Escrow Of Funds For One Year Is A  Problem

     Real estate literature suggests that an  escrow account be set
up if a buyer or seller wants a long term test to confirm a radon
problem, or if  there is  a question about the  accuracy of the short
term screening.   Although some realtors say escrow accounts are no
problem,  there  seemed to  be strong  feeling against  their  use.
Realtors  were   concerned  about  who  holds  the  funds,  and  who
determines if the reading is accurate.    Realtors pointed out that
after settlement, the agreement of sale expires, and establishing
escrow accounts  to  allow  for radon mitigation  after  a year  long
test clouds settlement.  They say that the main  issue is that real
estate transactions  must be explicit  about what needs to be  done
and when.    They also  said  that mortgage  companies  don't  want
unresolved  problems, and  require  that  all conditions  of  the
agreement of sale must be met before closing.

     One  realtor cited two  cases where  there  were  high  enough
readings to warrant  long term tests and escrow accounts (one held
by the realtor,  one by the title company).   This did not seem to
be a problem for the buyer or the seller, but it was not a common
event at this office either.  In one case, $1475  was put in escrow,
and the realtor was  waiting for results of the long term test.  The
buyer had forgotten that the year was almost completed until the
realtor called.

     One  agent  commented  that with a more  expensive  house,  the
seller may not  need the cash, but  a seller with a less expensive
home or a cash  flow problem  might  be  more negatively affected by
the temporary loss  of cash for an escrow account.

     Realtors preferred remediation instead  of  escrow between 4
and 20, but  thought that escrow was a better choice if the short
term test was between 4 and 10.

                                10

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5.  Public Information Scare Tactics

     There is  a  view that some radon  information  has scared the
public  unnecessarily.    Some  realtors who  saw  the Ad  Council
television spot which showed  an X ray of a family,  felt that it was
a scare tactic,  and  that  unless EPA could point to actual deaths
caused  by radon,  it  was better   to  give  the public  positive
information on the subject.  These realtors recognized that EPA has
a duty to warn the public of the effects of radon, but questioned
the basis of the lung cancer death statistics.

     It was not unusual for realtors to see panic at radon readings
as low as 5pCi/l.  Realtors  want the public to understand that a
reading over 4pCi/l  is "not the end of the world".  Some realtors
see some buyers who are aware of the potential  risk and don't want
any  radon in  a  house.  There  is  also  a perception, though not
widespread, that radon services companies generate scare ads when
"things quiet down".

6.  Lack Of Buyer And seller Knowledge About Radon

     Realtors see a belief that "everything is ok now, radon is a
Reading Prong problem."  Realtors in counties with a number of high
readings see buyers who are new to the area as more  concerned about
the presence  of  radon and as  more  likely  to  request radon tests
than long time residents who  buy  in  the  same area.   Long  time
residents, whether buyers  or sellers, seem to accept the radon risk
or believe that  if you don't  see radon,  it's not there,  or think
that "radon has  been around  awhile,  I've  lived with  it".   At one
county Board  of  Realtors  meeting,  the Board  President  asked for
radon problems from the twenty members present,  and there were none
to report. This  county is not  considered  a "high" radon area and
a lot  of  buyers  waive their right  to a radon test  and  sign the
release from  liability.   Some  are so casual  that they don't  read
the radon disclosure form and just write  "waived",  which  is not
acceptable to realtors, and defeats the intent of the form.

     Realtors offered many anecdotal  examples  of  fear or lack of
accurate  knowledge  about  radon can cause problems  in  actual  or
potential transactions.

     In one, case, a buyer tested a property and found  a radon level
of 14  pCi/1.   The seller corrected  the  problem,  but  the  buyer
didn't show up at settlement.  Even though the radon  level was
reduced, and  everything done  in accordance with the  agreement of
sale, the  buyer  wanted to cancel the transaction,  and  sued the
seller to get his $11,000  down payment back.  The case was settled
out of court in March, 1990,  with the buyer receiving $7,000, and
the seller, $4,000.


                               11

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     One buyer made a formal offer on a house, had the radon test
which showed a  number between 4 and 20 pCi/1,  and cancelled the
deal.  The same  buyer made another offer on a house, but, according
to the realtor, bought it anyway  when  the radon reading was over
4, because he educated himself and was less  afraid of radon.

     Many  realtors  had at least  one experience with  buyers who
seemed interested in  a house until they  saw  radon fan/pipes and
showed no further interest in the  house.   Other realtors said that
seeing radon mitigation equipment caused other prospective buyers
to make  lower offers,  although it is not possible to  verify the
eventual sales prices of these homes.

     In  one instance  a buyer's  request for a  radon test was
rejected by the seller and the deal fell apart, although realtors
said that sellers usually agree to test requests.

     In another case the buyer  tested  and found a radon level of
29.6  pCi/1.   When  the  seller  refused to  remediate,   the  buyer
cancelled  the   agreement  of  sale.   The agent  felt   that  this
penalized  the  seller who  then  had  to  disclose the presence of
radon, possibly causing undue alarm in prospective buyers who may
have been unconcerned about radon.
7.  Comments On Outreach Effort

     Most realtors  seemed receptive to  EPA efforts to  find out
about  their problems.   Typical comments  were "it's  about time
someone from EPA talked to realtors'*; "EPA is too late, they should
have sent someone when the scare was big a few years ago"; "it's
good that EPA is taking the time to do this project"; "EPA should
be working  with realtors at the national level on  radon".   The
general opinion  was that EPA/DER outreach to  realtors  is a good
idea, because it will prevent  an adversarial role.   Five brokers
decided that the opportunity to discuss radon problems with EPA was
a  good use  of  their agents'  time,  and  invited  their  staff  to
participate.  It is important to note that the suggestion to have
group discussions came from the brokers themselves.

Realtor Comments on EPA/DER Brochures

     Local  real  estate offices  determine whether  to give clients
radon  brochures, but the realtors interviewed were all familiar
with the Citizen's  Guide.  Most believed that while it had good,
understandable  information,   it was  too  long for many people
involved in real estate transactions.  There was a definite opinion
also that since it didn't address real  estate time constraints,
that a shorter,  more specific summary aimed at buyers/sellers would
be helpful.
                                12

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     Many realtors liked the radon maps which showed the percentage
of readings over 4pCi/l by county in Pennsylvania.  They believed
that it showed how widespread radon was, and that its pervasiveness
was an important point for the public to understand.

     Generally,  just about all realtors interviewed had been to at
least one training seminar on  radon, and most seemed knowledgeable
about radon and  mitigation. Many realtors  felt that they had been
saturated with training on radon.

     Realtors and Board executives believed that the DER Guide to
Radon  Reduction  Contractor  Selection  and  the  Certified  Radon
Services Listing were useful.   Some were  not familiar with these
materials.    Many  realtors  are  asked to  recommend testers  or
mitigators, which is risky for the realtor,  and the certified list
would remove this burden.
6.   RECOMMENDATIONS

     EPA and the State have the challenge of informing the public
of the  risks from radon  exposure while relieving  their anxiety
about radon.  Both agencies must  educate the public on different
levels.  Some people  will  respond  to health warnings, while others
will respond to the possible financial impacts of radon when buying
or selling a house.   There is a role for diverse groups such as the
Lung Association and the League of Women Voters to assist EPA and
the state in educating people about the health risks, real estate
impacts, and consumer protection aspects of radon.

     The following specific recommendations  address the problems
identified in this report:

l.  Need For Clear Guidance For Real Estate Transactions

   The Citizen's Guide does not specifically address real estate
transactions.  It  does not consider  the time  limits  facing the
public, nor does  it help buyers  decide what to do if the home they
are interested in has a radon problem  and there  is not enough time
to do  a full year  of testing.   Realtors wanted to know  where
testing devices should be placed and how to interpret results for
real  estate  transactions.    Realtors  identified  a  need  for
information that realtors  and the  buying/selling public can use to
make decision*.  A condensed  version of the Citizens  Guide that
answers  these,  questions  would  be   helpful  for  real  estate
transactions.

2.  The Public Needs Clear Guidance On  Radon Levels, Especially For
Real Estate Transactions

     Realtors see  a  need  for a  range of values,  to  allow for
testing variation,  so that people  won't panic when a radon reading

                               13

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of 4.2, 5, or 6 pCi/1 is  found.  Many people don't know what to do
if a  reading over 4  is  found, and  realtors  must be  careful in
advising clients on what  to do  about radon.  The question realtors
hear from clients, is "what is  the acceptable radon level, and who
decides the  acceptable level?11,  and "how much variation over or
under  4  is acceptable?"   The  closer  to 4 pci/l, the  bigger the
problem  for  the  seller,  and  the  more  likely there  will  be
disagreements between parties  in the  contract.   Realtors believe
that the prospective buyer/seller needs to know what to do with a
short  term  radon level  between 4  and  20 pCi/1,  and  whether
remediation at 6pCi/l is advisable.

3.   EPA/State Outreach  Should  Encourage Homeowners To  Test For
Radon Before Homes Go On The Market

     According to realtors, EPA and DER are in a good position to
encourage  testing because  they have  no  financial interest in
raising radon  awareness  and should capitalize on  that position.
Non-technical programs on radon for realtors and  potential home
sellers would be  helpful.   Some  suggested that the State and EPA
simplify testing  for the public and make it inexpensive by giving
canisters to the general public.

     Realtors believed that EPA should emphasize that long term
tests would be much more reliable and that the results would make
a house more marketable.  This outreach should encourage homeowners
by letting them know that if they don't test, they may have more
problems later on.  People also need to know for how long the test
data is valid.

4.  Need For More Outreach To Realtors

     Many realtors expressed a desire to see EPA and the National
Association  of Realtors  (NAR)  cooperate  on  radon policies and
education.   They  suggested that the  national publication, Real
Estate Today would be a  good vehicle  for  articles  on  radon, and
that it was  important for EPA to work with NAR  since  radon is a
national problem.

     Although  many  realtors  say  they have  had  enough  radon
education,  and most seemed to  know  basic facts, there  is still
confusion on how  radon facts in the Citizen's Guide apply to real
estate.  There is also a need to train new realtors, which is the
managing broker's responsibility, but EPA and the State could help
by providing speakers on radon or  submitting  articles to realtor
newsletters.   EPA and the State could  solicit  opportunities by
approaching  county  realtor  boards   and  offering  to  speak  at
orientations  for  new realtors.

     state and county boards showed interest in accepting state or
EPA  articles  for their  newsletters.    If the  State wanted to
increase  radon awareness  and  increase  radon  testing,  it could

                                14

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target  specific counties,  and submit  newsletter articles  as a
follow up to this  outreach  project.   Agents said that they could
use information on the types of tests (canisters,  alpha track), the
differences between long and short term tests,  and the costs of do
it  yourself versus  contractor remediation.     Names  and phone
numbers of  contacts  at  EPA/DER could also  be  submitted to these
newsletters.

     Realtors and the public need to be reminded that they can call
the State or EPA to  get answers on radon questions.  Local board
officers  and  some  individual  realtors  referred  buyers  with
questions to DER, but not enough realtors seemed to be aware that
they or buyers could get answers to their  questions by calling
either agency.   There is a need for realtors to  know  more about how
DER can help home buyers and sellers with high radon readings.  A
radon business card with  some radon  facts and  State/EPA phone
numbers or a Rolodex card with phone numbers would help agents to
prepare clients in the early stages of a transaction.

5.  Need For Clear Information on Risk And Exposure

     In general, realtors felt that the public could benefit from
better information to answer the question: what are the risks from
radon?   There is  a need  not  for more  data,  but for  better
interpretation  of data.   Clear  explanations  of  current  risk
information should be  available  to the  public.    Some realtors
accepted that testing is important because of the potential health
risks, while  others questioned how EPA  arrived at  lung  cancer
estimates.  EPA can assume that this reflects the attitude of the
general public.  Some people resist scare tactics on lung cancer.
Others want to know:  how many  people have actually died from lung
cancer attributed to  radon?  Realtors see a need for good, accurate
information from the State and EPA.

6.  Need For More Consumer-Oriented Information

     Realtors believed that giving the  public  cost  data on radon
testing and remediation would  be a good  idea.   They  suggested
articles on the cost of different types of  remediation,  and how
geography and construction affect cost.  One  realtor suggested that
it would help the public if EPA would publish a regional study of
the average cost to remediate.
7.  CONCLUSIONS

Implications for EPA/DER Outreach Efforts

     At the start of the project, the Region wanted to find out how
high radon  levels affects residential  real estate and  if  radon
mitigation affects property  sales.   At the end  of the  project,

                                15

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there was no quantitative data  to  answer these questions because
there is no  data base which tracks real estate transactions by sale
price and radon level.  There was some information that supported
the conclusion that radon mitigation may stigmatize a house.

     This  report  analyzes  perceptions  and anecdotes  on  radon
problems, which  still has value to  EPA.  After  hearing similar
stories from many  realtors,  it  became apparent that realtors are
in a position to critique the strengths and weaknesses of current
radon policies and public information materials because they see
how the public interprets radon policy and how EPA guidelines are
being implemented.  Their analysis of the problems can help EPA and
the State understand the public's perceptions of radon and to use
these insights to  plan  future public education efforts.   EPA can
use that knowledge to improve outreach in other states as well.

     This outreach project is another step in building cooperation
between EPA and realtors in  helping the public  deal with radon and
its  risks.    EPA  and the  state  should take  advantage of  the
opportunity to submit articles  to  real estate  newsletters at the
national,  State  and  county levels  which  address  the  problems
identified  in this report.   Realtors in eastern Pennsylvania are
very well  informed about radon, but they need  solutions  to the
problems they encounter in real estate transactions.

     The Region  should  share its findings with the states, with
realtors, and with Headquarters.   There is potential  for EPA to
work with Realtor  Boards in other states.  By making an effort to
understand how radon affects real estate, and acting on the major
problems identified by realtors, the  public can benefit.  There is
potential for more outreach in the future.

Policy Implications

     This project  was an EPA Region III effort to  find  out how
realtors perceive  radon problems.  EPA should  continue to pursue
opportunities to look at how the general public perceives radon.
EPA has a wealth  of radon data but must recognize how confusing the
grey areas on radon are to the non-scientist, especially during a
real estate transaction.  The Agency must keep sight of what the
public  needs  to  know  as  it  continues  to  find  new  ways  to
communicate the  risks and implications  of radon.   Realtors, and
ultimately  the  general  public,  need  solutions  to  practical
problems.

     While  it is known  that the potential for liability problems
forces  some relocation companies  to require radon  tests,  it is
impossible to know why individual buyers insist on radon tests as
a  condition of the  agreement  of sale.   The State  and  EPA have
worked since 1985  to educate the public on the risks from radon,
and to encourage radon  testing.  Realtors themselves devised the
disclosure  form  which brings radon tests to the attention of the

                                16

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homebuying public.  Two points  are  noteworthy:   realtors devised
radon disclosure forms after the State and EPA alerted the public
on radon,  and it appears that real estate transactions trigger many
radon  tests  in  Pennsylvania  because  realtors  use  the  radon
disclosure- form.  It is impossible to determine whether government
or realtor effort has influenced the public's decision to test, but
it  appears  that  the combined  efforts of  EPA,  the  State,  and
realtors on  the communication of radon risks, has  made  the test
almost routine.   Future policies  on  radon should  consider this
interdependence.
                               17

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8.   BIBLIOGRAPHY


Brandes, Alan S.,  "Coping with Radon Risks",  REAL ESTATE TODAY, pp.
34-37, September, 1987.

Chess, Caron, and Billie Jo  Hance,  1988,  "Alerting the Apathetic
and Reassuring the Alarmed: Communicating about Radon Risk in Three
Communities", prepared for the  Office of Policy,  Planning,  and
Evaluation,   U.S.   Environmental   Protection   Agency,   Rutgers
University, New Brunswick,  New Jersey, August.

Desvousges, William H., V.  Kerry Smith, and Hillery H. Rink, III,
1988,  "Communicating   Radon  Risk Effectively:  Radon Testing  in
Maryland", prepared for Office of Policy, Planning,  and Evaluation,
U.S. Environmental  Protection  Agency,  Washington,  D.C.,  Research
Triangle  Institute,  Research  Triangle  Park,  North  Carolina,
October.

Eastern  Pennsylvania   Chaper  American  Association   of  Radon
Scientists  and  Technologists,  "Draft  Guidelines for Radon/Radon
Progeny Testing in Real Estate Transfers of Residential Dwellings",
March 1990.

Holmen, Ralph W., "Radon- Legal Issues for the Real Estate Agent",
PROBATE AND PROPERTY,  Vol.  2, No. 3, May/June 1988.

Kronreich, Mary  Rose,  "Dealing with the  Invisible Trap  of Radon
Liability", THE PRACTICAL REAL ESTATE LAWYER, September, 1987.

Mansfield,  Richard,  III,  "Establishing  and Maintaining  a Radon
Policy", MOBILITY, November/December, 1987.

Mansfield, Richard, III, "Formulating a  Radon Policy",  MOBILITY,
March/April, 1988.

Treffer, Brough E., "Radon  Gas May Seep into Your Liability",  The
Real  Estate Appraiser and Analyst,  The  Chicago Society  of Real
Estate Appraisers, pp. 21-24, Spring, 1987.

"Radon Goes to Court", INSURANCE REVIEW,  p. 9, November, 1986.

"Environmental  Hazards:  A Real  Estate Lender's View",  Mortgage
Bankers Association of America,  1988.
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9.   APPENDIX

Pennsylvania Association of Realtors Radon Disclosure Forms

1.   Radon Disclosure Addendum to Exclusive Right to Sell Agreement
    (8/87)

2.   Radon Disclosure Addendum to Agreement of Sale,  and Notice to
Sellers/Buyers     Regarding Radon Gas (4/89)

3.   Radon Disclosure Addendum to Exclusive Right to Sell Agreement
(revised 1/90)

4.   Radon Disclosure Addendum to Agreement of Sale (revised 1/90)

5.   Notice to Sellers and Buyers Regarding Radon Gas (revised 1/90)
                               19

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RADON DISCLOSURE ADDENDUM TO EXCLUSIVE RIGHT TO SELL AGREEMENT
RE: PROPERTY
AGENT:   	
OWNERS:  	
                                            NOTICE TO SELLERS REGARDING RADON GAS


      1.   Radon is a radioactive gas produced naturally in the ground by the normal decay of uranium and radium.  Uranium and radium are widely distributed in
          trace amounts in the earth's crust  Descendants of Radon gas are called Radon daughters, or Radon progeny.  Several Radon daughters emu alpha
          radiation, which has high energy but short range.

      2.   Studies indicate the result of extended exposure to high levels of Radon gas/Radon daughters is an increased risk of lung cancer.

      3.   Radon gas originates in soil and rocks.  It diffuses, as does any gas, and flows along the path of least resistance to the surface of the ground, and then to the
          atmosphere.  Being a gas. Radon can also move into any air space, such as basements, crawl spaces and living areas.

      4.   If a house has a Radon problem, it can usually be cured by (a) increased ventilation and/or (b) preventing Radon entry.

      5.   The EPA advises corrective action if the annual average exposure to Radon daughters exceeds 0.02 working levels.

      6.   Further information can be secured from the DER Radon Project Office, 1100 Grosser Road, Gilbertsville, PA  19525- Call 1-800-23RADON or
          (215)369-3590.
                                                      RADON CERTIFICATION

      I hereby acknowledge that I have been provided with a copy of "Notice to Sellers Regarding Radon" and certify that:

    (  ) The property was tested and Radon was found to be at or below 0.02 working levels (4 picocuries/liter).

    (  ) The property was tested and Radon was found to be above 0.02 working levels (4 picocuries/liter).

          (  )  The property was modified after which it was retested and Radon was found to be at or below 0.02 working levels (4 picocuries/liter).

      Seller does not warrant either the method or result of the test

    (  ) I have no knowledge concerning the presence or absence of Radon.

      I hereby authorize you, as my agent, and any subagents, to disclose the foregoing information to prospective purchasers.

AGENT   	   OWNER 	(s)
BY    	(s)   OWNER 	(s)
DATE   	, 19	   OWNER 	(s)



COPIES. WHITE; OWNER.   YELLOW; AGENT.    BLUE; 	                                                          8/87

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RADON DISCLOSURE ADDENDUM TO AGREEMENT OF SALE
                                                                                     	19.
RE: PROPERTY   	
SELLERS:   	
BUYERS: 	
DATE OF AGREEMENT   	  19	, SETTLEMENT DATE    	 19	, SALE PRICE S	
     1  BUYER acknowledges receipt of notice u set forth on reverse side hereof.
     2  SELLER hereby acknowledges receipt of notice is s«t forth on the reverse side hereof, and certifies that:
    ( )  The property was tested and Radon was found to b« at or below 0.02 working levels (4 picocuries/liter).
    ( )  The property was tested and Radon wu found to be above 0.02 working levels (4 picocuries/liter).
         (  )  The property was modified after which it was retested and Radon wu found to be it or below 0.02 working levels (4 picocuries/liter).
     Seller does not warrant either the method or result of the test
    ( )  I have no knowledge concerning the presence or absence of Radon.
     3.  BUYER'S OPTION (Check only one)
    ( )  BUYER acknowledges he has the right to have the buildings inspected to determine if Radon gas/daughters is present  BUYER waives this right and
         agrees to accept the property on the basis of SELLER'S certification and agrees to the release as set forth in paragraph 4 below.
    ( )  BUYER, at BUYER'S expense, shall within	days front the execution of this agreement, arrange a Radon test of the residential buildings on
         the property.
          If the inspection reveals the presence of Radon which exceeds 0.02 working levels (4 picocuries/liter). the BUYER, within five (5) days of the receipt of the
         report shall furnish the SELLER with a copy of the test results. Upon receipt of the test results, the SELLER may within	days submit a corrective
         proposal, in  writing, to the BUYER.  Upon receipt of the corrective proposal, the BUYER shall within five (5) days:
             a.  Accept the proposal in writing, which action shall constitute a release as set forth in Paragraph 4 below; or
             b.   Declare this agreement NULL and VOID, at which time all deposit monies paid on account shall be returned to the BUYER.
          Should the  SELLER fail to submit a corrective proposal within	days, then the BUYER shall within five (5) day*:
             a.  Accept the property in writing, which action shall constitute a release as set forth in Paragraph 4 below; or
             b.   Declare this agreement NULL and VOID at which time all deposit monies paid on account shall be returned to the BUYER.
         NOTE:  There are various firms in Pennsylvania through which a Radon test can be arranged
     4  RELEASE - The BUYER hereby releases, quit claims and forever discharges SELLER. SELLER'S AGENTS. SUBAGENTS, EMPLOYEES and any
         OFFICERor PARTNER or any one of them and any other PERSON, FIRM or CORPORATION, who may be liable by or through them, from any and all
         claims, losses or demands, including personal injuries, and all of the consequences thereof, where now known or not. which may arise from the presence of
         Radon in any building on the propeiriy.
WITNESS  	   BUYER   	(s)
WITNESS  	   BUYER   	(s)
WITNESS  	   SELLER  	($)
AGENT   	   SELLER  __^	(s)

COPIES WHITI; StUJH.  VEU.OW: AOfNT.  MM; MJVfft.   KM;  MOMTOAGff .  GOLD-	  .  GKEEN: BUYER'S AT TIMf OF SIGHING          4/19
                                                                  2U1

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                            NOTICE TO SELLERS/BUYERS REGARDING RADON GAS


I.   Radon is a radioactive gas produced naturally in the ground by 
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   RADON DISCLOSURE ADDENDUM TO EXCLUSIVE RIGHT TO SELL AGREEMENT
9                                                                     	19-
   RE: PROPERTY
   AGENT:  	
   OWNERS:  	
   1.  SELLER hereby acknowledges that he/she has read and understands the notice as set forth on the reverse side hereof and
   represents 'hat:
        (  )  A.  SELLER has no knowledge concerning the presence or absence of radon.

        (  )  B.  SELLER has knowledge that the property was tested on the dates, by the methods (e.g., charcoal canister,
                 alpha track, etc.), and with the results of all tests indicated below:

              DATE           METHOD                   RESULTS (picocuries/liter or working levels)
              SELLER DOES NOT WARRANT EITHER THE METHODS OR RESULTS OF THE TESTS.

        (  )  C.  SELLER has knowledge that the property underwent radon reduction measures on the date(s) and by the
                 method(s) indicated below:

              DATE            RADON REDUCTION METHOD
   2.  SELLER is hereby advised that SELLER may be required to provide details of any testingor remediation for the presence
   of radon, including copies of all test reports.

   3.  SELLER agrees to make property available for testing during the term of this agreement
   AGENT  	  OWNER  	(s)
   BY  	(s)  OWNER  	(s)
   DATE   	,I>	  OWNER  __	(s)


   COPIES: WHITi; OWNfB.   YtUOW* AHHf.   KM; 	                                            1/*>


   Form 113-3

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RADON DISCLOSURE ADDENDUM TO AGREEMENT OF SALE
                                                                                       	19.
RE: PROPERTY   	
SELLERS:   	
BUYERS: 	
DATE OF AGREEMENT	  19	, SETTLEMENT DATE	  19	, SALE PRICE $ 	

1   BU>"ER acknowledges thai he/she has read and understands the notice as set forth on reverse side hereof.

2   SELLER hereby acknowledges thai he/she has read and understands the notice as set forth on the reverse side hereof and represents that:
   (check appropriate response^))
    (   )  A.   SELLER ha* no knowledge concerning the presence or absence of radon.
    (   )  B.   SELLER has know ledge that the property wts tested on the dales, by the methods (e.g.. charcoal canister, alpha track, etc.). and with the results of all
             tests indicated below:
             DATE              METHOD                             RESULTS (picocunes/liter or working levels)
            COPIES OF ALL AVAILABLE TEST REPORTS will be delivered to BUYER with this addendum.
            SELLER DOES NOT WARRANT EITHER THE METHODS OR RESULTS OF THE TESTS.

    (  )  C. SELLER has knowledge thai the property underwent radon reduction measures on the date(s) and by the method(s) indicated below:
            DATE               RADON REDUCTION METHOD
3.  BUYER'S OPTION: (check only one)
    (  )  BUYER acknowledges that BUYER has the right to have the property inspected for radon by a certified inspector.  BUYER WAIVES THIS RIGHT and
         agrees to accept the properly on the basis of SELLER'S representation and agrees to the release as set forth in paragraph 4 below.

    (  )  BUYER, at BUYER'S expense, elects to obtain a certified radon test of the property and will deliver a copy of the test report to SELLER or SELLER'S
         AGENT within	days of SELLER'S acceptance of this agreement
         Failure to obtain and provide radoa lest results by this date will coMdnte a WAIVER of BUYER'S right to obtain tkc test.

         A.  I f the test report reveals the presence of radon at or below 0.02 working levels (4 picocuries/liter), BUYER shall be deemed to have accepted the property
             and to have agreed to the release as set forth in paragraph 4 below.
         B.  If the test report reveals the presence of radon which exceeds 0.02 working levels (4 picocuries/liter),
             SELLER may. within	days of receipt of the test results, submit a written, corrective proposal to BUYER.  The corrective
             proposal will include, but not be limited to, the name of the certified  mitigation company: provisions for payment, and completion date for
             corrective measures.

         Upon receipt of the corrective proposal BUYER, within five (S) days, will:

             1.  Accept the corrective proposal and At property in writing, which will constitute a release as set forth in paragraph 4 below, or
             2.  Declare this agreement NULL AND VOID, in which case all deposit monies paid on account will be promptly returned to BUYER.

         Should SELLER fail to submit a written uimum proposal within the time set forth in paragraph 3 (B). then BUYER will, within  five (5) days:

             1.  Accept the property in writing, which will constitute a release as set forth in paragraph 4 below, or
             1  Declare this agreement NULL AND VOID, in which case all deposit monies paid on account will be promptly returned to BUYER.

     IfBLYERftihtoMcerdse««yoflUYErSo»doMwJtMatlwll^
     have agreed to the release as set faftfc !• paragraph 4 beta*.
    RELEASE - BUYER hereby ntlMHi. quit claim* and forever discharges SELLER, SELLER'S AGENT. SUBAGENTS, EMPLOYEES and any OFFICER
     or PARTNER or any one of then ami aay other PERSON, FIRM orCORPORATION who may be liable by or through them, from any and all claims, losses or
     demands, including personal injuries, and all of the consequences thereof, where now known or not which may arise from the presence of radon in an> building
     on the property.
 WITNESS         '	BUYER(s)
 WITNESS	
 WITNESS	
 AGENT   	   -
      : WHITf: SCLUM.  YELLOW; AOCNT.   WNfc §UYf«.  BLUfc MOHTGAGCf .   GOLD:	GMI* •VYWS AT TIMt Of SIOMIMO          1/90


 Form 114-6

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                                 NOTICE TO SELLERS AND BUYERS REGARDING RADON GAS


1.   Radon is a. natural, radioactive gas that is produced in the ground by the normal decay of uranium and radium.   Uranium and radium are
widelv distributed in trace amounts in the  earth's crust.  As radon  gas decays,  it forms radwisotopes called radon daughters  or radon
progeny.  Radon daughters emit alpha radiation, which has high energy, bat ihort range.

2.   Studies indicate that the result of extended exposure to high levels of raiton ^as/ radon daughters ti aa increased risk of lung cancer.

3.   Radon gas follows the path of least resistance from the soil and rocks where it originates to the surface of the ground and, finally,  to the air.
Radon can find its way into any airspace, including basements and crawl spaces, and permeate throughout a home.

4.   If a house has a radon problem, it usually can be cured by increased ventilation and/or by preventing radon entry.

5.   The Environmental Protection Agency (EPA) advises corrective action if the annual average exposure to radon daughters exceeds 0.02 working
levels (4 picocunes/liter).

6.   As of July 23,1988. any person who tests for or mitigates or safeguards a building from the presence of radon gas and radon daughters in the state
of Pennsv Ivania must be certified by the Department of Environmental Resources (DER) of the Commonwealth of Pennsylvania, as mandated by
the Radon Certification Act of 1987.

7.   Any use of the word "certified" in this addendum refers to the certification  mandated by the Radon Certification Act of 1987.

8.   Neither the real estate broker nor the broker's agent is an expert on radon gas/radon daughters.  Neither the broker nor the broker's agent
warrants either the methods or results of any tests for the presence of radon gas/radon daughters.

9.   Information about radon and about certified testing and mitigation firms is available through DER. Bureau of Radiation Protection. P.O. Box
2063. Harrisburg. PA 17120:  1-800-23RADON or (717) 783-3594.

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