United States
Environmental Protection
Agency
Ot'ice of Radiation
Programs
December 1990
Radon Division
vvEPA
Second-Year Guidance for
the State Indoor Radon
Grants Program
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GUIDANCE
STATE INDOOR RADON GRANTS PROGRAM
Section 306, Indoor Radon Abatement Act
DECEMBER 20, 1990
Radon Division
Office of Radiation Programs
U.S. Environmental Protection Agency
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GUIDANCE
STATE INDOOR RADON GRANTS PROGRAM
SECTION 306, Indoor Radon Abatement Act
TABLE OF CONTENTS
Chapter 1: INTRODUCTION
1.1 Authority 1
1.2 Eligible Applicants 1
1.3 EPA Goals for the State Indoor Radon Grants Program 1
1.4 Priority Activities and Projects 2
1.5 EPA Policy Priorities for States in Year 2 of the SIRG Program 2
Chapter 2: STATE INDOOR RADON PROGRAMS 5
2.1 State Radon Program Framework: Functional Program Areas 5
2.2 State Program Development 6
2.3 Innovative Project Proposals 6
2.3.1 Innovative Project Activities 6
2.3.2 Proposal Format 8
2.33 Proposal Evaluation and Submission Deadline 8
2.4 Required Activities 9
2.5 Eligible Activities 9
2.5.1 Radon Surveys 9
2.5.2 Public Information and Educational Materials 11
2.5.3 Radon Control Programs 12
2.5.4 Measurement Equipment or Devices 14
2.5.5 Analytical Equipment 15
2.5.6 Training 16
2.5.7 Program Overhead/Administration 17
2.5.8 Data Storage/Management 17
2.5.9 Mitigation Demonstrations 18
2.5.10 Toil-Free Hotline 19
Chapters: ANNUAL ALLOTMENTS AND PROGRAM COSTS 20
3.1 Authorization 20
3.1.1 Authorization Restrictions 20
3.2 Annual Allotments 20
3.3 Allowable Costs 21
3.4 Assistance to Local Governments 21
3.5 State Match 21
3.6 Program Income 22
3.7 Limitations 23
3.7.1 Satisfactory Performance 23
3.7.2 50% Ceiling on Measurement/Mitigation Activities 23
3.7.3 25% Ceiling on Program Administration and Overhead 24
3.7.4 Financial Assistance to Persons 24
3.8 Carryover Funding .25
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TABLE OF CONTENTS (continued)
PAGE
Chapter 4: GRANT AWARD PROCESS AND REVIEW CRITERIA 27
4.1 Grant Award Process Overview 27
4.2 Preapplication Assistance 27
4.3 Deadlines for Submittal 27
4.4 Application Process 29
4.5 Innovative Project Proposal Evaluation Criteria 29
4.6 Application Evaluation Criteria 29
4.6.1 Application Evaluation Criteria for Second Grant Year 30
4.6.2 Evaluation Criteria for First-Year Grant Performance 30
4.7 Award Process 31
Chapter 5: APPLICATION REQUIREMENTS 32
5.1 Standard Form 32
5.1.1 Part I--General Summary Information 32
5.1.2 Part II--Budget Information 32
5.1.3 Part Ill-Assurances 33
5.2 Application Attachments 33
5.2.1 Statement of Work 33
5.2.2 Debarment and Suspension Form 35
5.2.3 Certification Leuer 35
5.2.4 Intergovernmental Review Comments 38
5.2.5 Quality Assurance Plan 38
Chapter6: GRANTEE REQUIREMENTS 46
6.1 Regulatory Requirements 46
6.2 Reporting Requirements 46
6.2.1 General Assistance Reports 46
6.2.2 Progress Reports 47
6.2.3 SIRG Data Reports 47
6.3 Budget Tracking 48
6.4 Audit/Audit Resolution 48
6.5 Performance Evaluation 49
EXHIBITS:
2-1 Model Framework for State Radon Program Development 7
2-2 Regional Radon Training Centers 14
4-1 Grant Award Process 28
5-1 Model Form for 3-Year Plan 36-37
5-2 Sample SIRG Application 39-45
APPENDIX A - Legislation-SIRG Guidance Crosswalk A-l
APPENDIX B - SIRG Program Contacts B-l
APPENDIX C - Guide to Preparing Class Category Budget Detail C-l
APPENDIX D - Standardized Data Fields for National Data Base D-l
APPENDIX E - Example Application of the Indirect Cost Rate E-l
APPENDIX F - Inclusive List of Data Elements for Tracking State Grants F-l
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Chapter 1: INTRODUCTION
In October 198i>, in response to growing national concern over the threat of radon gas and its progeny,
Congress enacted Title III, Indoor Radon Abatement Act (1RAA, 15 U.S.C. 2661 et seq.) as an amendment
to the Toxic Substances Control Act (TSCA, 15 U.S.C. 2601 et seq.). IRAA contains several provisions aimed
at the long-term goal of rendering the air within buildings in the United Stales as free of radon as the ambient
air outside of buildings. Included among these provisions is Section 306, which authorizes the U.S.
Environmental Protection Agency (EPA) to provide grants to States to support the development and
implementation of Slate programs for the assessment and mitigation of radon.
In September 1989, EPA published guidance that presented the policies and procedures that governed the
first year of this Federal assistance initiative, the Stale Indoor Radon Gram (SIRC) Program. This Guidance
presents an update to the first-year guidance to cover the second year of the SIRG program. As before, it
provides instructions to potential applicants on developing State radon programs and preparing grant
applications, submitting their applications to EPA for approval, and reporting to EPA on their progress.
Other subsections address the content of SIRG applications, the activities eligible for funding, Federal/State
cost share requirements, priorities for the award of funds, limitations on State expenditures, and other
elements of the program framework. These provisions are addressed in detail throughout this Guidance. The
SIRG Program is intended to provide seed money to initiate and enhance the effectiveness of State efforts to
reduce the threat to human health that radon represents.
1.1 Authority
As noted above, stalutory authority for the SIRG Program stems from IRAA Section 306. Specifically,
Section 306(a) authorizes the EPA Administrator lo award grants to States "...for the purpose of assisting the
State in the development and implementation of programs for the assessment and mitigation of radon." For
a crosswalk between IRAA provisions and their corresponding SIRG guidance sections, see Appendix A.
1.2 Eligible Applicants
IRAA Section 306 authorizes radon grant assistance to States, as defined by TSCA Section 3(13). The
definition of State includes the District of Columbia and specified lerritories (the Commonwealth of Puerto
Rico, the Virgin Islands, Guam, the Canal Zone, American Samoa, the Northern Mariana Islands, or any other
territory or possession of the United States).
1.3 EPA Goals for the State Indoor Radon Grants Program
IRAA establishes a national, long-term goal that "...the air within buildings in the United States should
be as free of radon as the ambient air outside of buildings." In accordance with this statutory objective, EPA
has established the following goals for the State Indoor Radon Grants Program:
To achieve widespread participation in the program among the States and Territories
To establish basic, core capabilities for radon response in States that have not yet developed radon
programs, and to stimulate innovation and expansion in States that have initiated programs
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To foster radon program development within the States that appropriately reflect the differences in
the scope and severity of radon problems across the States
To strengthen the Federal/State partnership by helping Slates develop programs that will continue to
effectively communicate and reduce radon risk beyond the life of the SIRG Program.
The Agency considers all of these goals to be equally important to the success of the program.
1.4 Priority Activities and Projects
If State applications for funds exceed the total amount of funds available for award in a Federal fiscal year,
IRAA Section 306(e) requires EPA to give priority to activities or projects proposed by States based on each
of the following criteria (which are not presented in any priority order):
1) The seriousness and extent of the radon contamination problem to be addressed.
2) The potential for the activity or project to bring about reduction in radon levels, including
measurements of the effectiveness of such efforts to reduce the public health risks of radon.
3) The potential for the development of innovative radon assessment techniques, mitigation measures
as approved by EPA, or program management approaches which may be of use to other States.
4) Any other uniform criteria that EPA deems necessary to promote the goals of the program and that
EPA provides to States before the application-process. As authorized, EPA has established the
following criterion: the potential for the activity to establish a basic radon program in all States who
wish to participate.
EPA may base its programmatic review of State Indoor Radon Grant applications on any technical or
administrative factors that satisfactorily reflect the program's goals. However, when available funds are limited
in relation to the amount of funds requested by eligible applicants, the Agency must employ the statutory
criteria presented above to determine which proposed activities will receive grant support.
1.5 EPA Policy Priorities for States in Year 2 of the SIRG Program
The overall goal of EPA's Radon Action Program is to reduce public health risks from radon by reducing
exposure in existing structures and preventing exposure in new ones. To accomplish this goal, EPA has
undertaken a non-regulatory program that is designed to: (1) assess the radon problem; (2) develop
inexpensive and reliable means to mitigate and prevent radon risks; and (3) transfer this capability to State
and local entities and to the private sector, which help citizens take informed radon response actions.
Therefore, in addition to the statutory priority activities and projects described above in Section 1.4, this
section specifies two EPA policy priorities for radon programs. EPA expects States to focus their activities
during the second year of the SIRG program to 1) achieve radon risk reduction, and 2) assess and improve
State program effectiveness.
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Listed below are specific examples of activities designed to accomplish these two EPA policy priorities;
However, all States are not expected to undertake all activities. Rather, EPA has prioritized these suggested
activities into three categories: basic activities, program infrastructure activities, and program enhancing
activities. While all States should consider undertaking basic activities to achieve these priorities, States with
identified radon problems are particularly encouraged to focus on program infrastructure activities.
1.5,1 Basic Activities
Achieve Radon Risk Reduction
Identify and address high risk areas
-- Assign priorities for radon project resource investment within the State, based on relative risk
-- Develop public information materials targeted to high-risk areas
- Develop effective approaches to increase testing and mitigation in high-risk areas
-- Innovative projects to study factors beyond geology
Focus public information activities on motivational materials
- Use Revised Citizen's Guide or State-developed brochures that motivate testing
-- Use Ad Council materials or State-specific materials
- Target special audiences, including high-risk areas, low-income households, and schools
Assess and Improve State Program Effectiveness
Assess the number of homes tested and mitigated to evaluate program effectiveness
- Conduct statistically valid surveys to determine the number of homes tested and fixed within the
State
- Collect data to evaluate the quality of mitigation techniques over time
Build self-sustaining program mechanisms
- Develop sources of program income, such as certification fees or local real estate taxes
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1.5.2 Program Infrastructure Activities
Achieve radon risk reduction
Build State certification capability, including consumer protection
-- Develop or enhance certification programs with an audit component
Develop worker protection standards
institutionalize radon testing and mitigation in real estate transactions
-- Develop and implement legislation to require disclosure and/or testing
Develop regulatory and non-regulatory approaches through key groups such as banks and real
estate regulators
Promote the adoption of radon-resistant model building standards
-- Promote legislation at the State and local level to adopt building codes
-- Encourage adoption by code organizations
1.5.3 Program Enhancing Activities
Achieve radon risk reduction
Emphasize school testing and mitigation initiatives
- Target motivational outreach programs for schools
- Conduct statistically valid surveys
-- Conduct school mitigation demonstrations
Foster local public and private initiatives
-- Innovative projects to use key local citizen's groups to motivate testing and fixing
- Promote the establishment of local government programs
Target low-income persons
Target motivational outreach programs for low-income areas
~ Provide financial assistance to low-income persons for radon testing devices and for mitigation
demonstrations
- Enhance capability of existing organizations in helping low-income populations address radon risk
reduction
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Chapter 2: STATE INDOOR RADON PROGRAMS
This chapter presents EPA's model framework for State radon program development. The Agency's intent
is to allow the Slates maximum flexibility in program development. Thus, this chapter does not prescribe a
specific set of State program activities except as may be necessary to reflect statutory requirements and
activities eligible for grant assistance.
State programs currently vary along many dimensions and are quite diverse in terms of their level of
development and maturity. EPA expects States from all across this spectrum to apply for State Indoor Radon
Grants and will, therefore, acknowledge the differences among State programs within the award process. Both
States with limited radon programs and States with mature programs are encouraged to propose activities that
build upon and enhance existing program elements. The Agency will fund activities that augment (but do not
supplant) existing State efforts, especially if the activities are innovative and appear to have national
significance.
2.1 State Radon Program Framework: Functional Program Areas
EPA has identified four functional areas that together form the framework for an effective, comprehensive
State Radon Program. These functional areas are derived from the document entitled Kev Elements of a State
Radon Program (EPA 520/1-88-006), developed by EPA and the Conference of (State) Radiation Control
Program Directors. They include:
(1) Program Management - This area encompasses basic organization and management activities designed
to establish an effective program infrastructure. Examples include policy and strategy development,
development of legislation and regulations, designation of responsibilities, resource acquisition,
implementation of data management systems, and projects to measure the success or effectiveness of
the program in reducing radon risks.
(2) Public Information - This area involves a number of proactive and reactive activities that provide
basic, up-to-date information to citizens concerning the sources of radon contamination, paths of
exposure, health risks, assessment techniques, mitigation methods, and prevention measures.
(3) Problem Assessment - An important radon-related activity includes the process of identifying,
documenting, and evaluating areas of potentially significant radon exposure and health risk. Activities
in this area may range from conducting (and helping others to conduct) isolated measurements in
houses, schools and other types of buildings to surveying potential "hot-spot" areas or undertaking
statistically valid, State-wide surveys.
(4) Problem Response - This functional area involves actions designed to reduce radon exposure and risk
to acceptable levels. Problem response encompasses both mitigation of risks in existing homes,
schools, and other buildings and preventing radon-related problems in new structures. Problem
response also includes encouraging radon legislation and regulation at the State and local level.
As an additional element of each of these program areas, States are encouraged to conduct activities to
support and coordinate with local radon programs.
All four of these functional areas should be addressed in a well-structured State radon program. State
officials should consider this framework carefully as they review their existing programs and determine the
most appropriate use of SIRG funds.
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2.2 State Program Development
Although the extent of State Radon Program development varies substantially, many States possess very
limited radon programs. EPA believes that every State should possess, at a minimum, the capacity to identity
and respond to its most serious radon problem areas. Therefore, the Agency has adopted the concept of a
"Core Program" for Slates that have not yet instituted this capacity. A core program is a set of activities
designed to establish basic capabilities in the four functional areas described above. The Agency does not
prescribe specific activities for a particular State, but expects that States will propose activities that reflect
logical first steps in each area. States that lack basic program capabilities in one or more of the functional
areas are strongly encouraged to complete their core framework prior to (or concurrent with) undertaking
more advanced activities in other areas.
Exhibit 2-1 on the following page presents a model, three-stage framework for State program development.
As reflected in this model, each State is encouraged to define an interim objective for each functional area
that builds upon the State's current capabilities in that area. The State may then craft activities that support
the objectives and that are appropriate to State needs. The model provides examples of core activities suitable
for States in the beginning stage of program development. It also suggests some of the more innovative and
pro-active initiatives that would be appropriate for States with more advanced programs. State officials should
employ this framework as a tool for evaluating their State's program and for designing a plan for the use of
SIRG funds. States should update their three-year program plan and must develop the second-year work plan
(See Section 5.2.1). These plans must consist of activities that are eligible for funding under the terms of
IRAA (see Section 2.5 below) and should reflect the four program functional areas. In general, EPA intends
for States to progress toward more effective program planning, more aggressive outreach, a more refined
understanding of the extent of the State's radon problem, and more widely available qualified testing and
mitigation services. Within this context, State officials are encouraged to be flexible and creative in designing
radon programs appropriate to their State's needs.
2.3 Innovative Project Proposals
Some States may wish to undertake projects or activities that employ especially innovative radon assessment
techniques, mitigation measures, or program management approaches. Such projects should be useful as
models either on a national or regional scale and have the potential to be adopted by other States. Innovative
projects should address radon-related problems or conditions that occur in many States.
2.3.1 Innovative Project Activities
States may propose projects under any of the functional program areas identified in the model
program framework (program management, public information, problem assessment, and problem
response). In addition, any single project proposal may cover more than one of these program areas
at the same time. Examples of innovative projects within each of the functional program areas include
the following:
Innovative program management proposals could include innovative projects to develop a
sustained source of income for the radon program, and projects to measure the success or
effectiveness of the program in reducing radon risks, including creative ways to estimate the
number of homes tested and mitigated;
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Innovative proposals for public information projects might include special outreach programs
designed to increase testing in schools, workplaces, and child-care centers, and proactive
approaches to work with key local organizations to motivate radon risk reduction; -
Examples of innovative problem assessment proposals may include development of a strategy
to target testing in high risk areas (i.e., to assign priorities for testing areas within a State based
on their relative risks), and studies of factors that contribute to high radon risks, other than
geological conditions; and
Examples of innovative problem response proposals may include surveys of the actions
homeowners take in response to radon measurement results, projects to develop effective
approaches to reduce radon risks, such as weatherization assistance for existing structures and
new construction techniques for new structures, and projects to encourage testing and fixing
of homes during real estate transactions.
2.3.2 Proposal Format
Innovative project proposals should contain concise descriptions (including approximate budget
data) of the proposed project(s). These proposals must be submitted to the EPA Regional Office by
no later than December 12,1990 (see Chapter 4 for a complete discussion of the application review
and grant award process). Proposals should address the following points:
(1) Problem Statement: State the nature of the problem to be addressed and the importance of
the issue in implementing State radon programs.
(2) Description of Project: Describe the scope of the project, including interim steps, deadlines,
and project outputs. If a multi-year project, describe the outputs at the end of each grant year.
(3) Budget: Provide a draft budget for the project by program element. The innovative project
is one part of the total grant request. States receiving second-year grants must provide a cost
share of 409c of the total grant award, not each specific project. Therefore, the State would
not necessarily provide a 40% cost share for each innovative project. If a multi-year project,
provide cost breakout for each grant period. Since funding will be provided for one year
initially, project results should not depend on multi-year funding.
(4) Demonstrated Expertise/Coordination: Applicants should state the expertise of the lead agency
and other participants that directly relates to the project area, and describe coordination with
appropriate parties such as local government or organizations.
(5) Plan for Evaluation and Transferring Knowledge: Include a plan for evaluating the success
of the project, and a plan for transferring the knowledge gained from the project to other
States. The latter may consist of papers published in journals, workshops and panel
presentations at national meetings, reports distributed to States or other comparable activities.
23.3 Proposal Evaluation and Submission Deadline
States may wish to propose second-year funding for an innovative project begun during their first-
year grant period. EPA will evaluate such proposals on a par with new innovative project proposals.
All proposals must be submitted to the EPA Regional Offices by December 12,1990.
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2.4 Required Activities
All participants in the SIRG Program must plan to comply with the information provision requirements
of Section 306(h) of IRAA. This section requires that any State receiving grant funds provide to EPA all
radon-related information generated in its activities, including the results of radon surveys, mitigation
demonstration projects, and risk communication studies. In addition, States receiving funds also must
maintain, and make available to the public, a list of firms and individuals within the State that have received
a passing rating from EPA's voluntary Radon Measurement Proficiency (RMP) Program, and the Agency's
Radon Contractor Proficiency (RCP) Program. (See The National Radon Measurement Proficiency Program
Cumulative Proficiency Report, EPA 520/1-904)01, and The National Radon Contractor Proficiency Program
Proficiency Report, EPA 52Qfl -90-004). These EPA lists (or the State's own lists if more restrictive than
EPA's lists and approved by the EPA Regional Office) must provide the address and phone number of such
firms and individuals which have passed the programs.
Finally, Section 306(h) authorizes the Agency to request any information, data, and reports developed by
the State that EPA needs to ensure the State's continued eligibility for grant assistance. For example, EPA
is authorized to request data on the numbers of homes tested or mitigated within a State that can be used as
long-term indicators of success. Reporting requested will be consistent with State and Federal confidentiality
requirements, and with the Agency's policy on Performances! Based Assistance. Applicants should consult with
their EPA Regional SIRG contacts for specific guidance on data requirements. Section 6.2.3 and Appendix
D of this guidance provide a standardized format that is not required but may be used by States for submitting
data to EPA.
2.5 Eligible Activities
Section 306(c) of IRAA presents a list of ten activities that are eligible for funding under this financial
assistance program. This section discusses each of these activities in detail, and provides explicit guidance
concerning limitations and restrictions, where applicable.
Applicants may request funding for tasks or items not addressed in this section that they believe are
necessary or legitimate expenses within an activity category. EPA will make eligibility determinations for such
requests on a case-by-case basis during its review of applications.
2.5.1 Radon Surveys
Statutory Provision
306(c)(l) "Survey of radon levels, including special surveys of geographic areas or classes of buildings
(such as, among others, public buildings, school buildings, high risk residential construction
types.)"
Discussion
Slates may undertake several survey activities under this subsection, including collecting existing
State measurement data, geologic mapping, developing survey strategies, and conducting radon
surveys. A survey can be used either to 1) determine a State-wide average level of radon across a class
of buildings, or to 2) determine levels of radon within potentially high risk areas in the State. All
surveys shall be designed to ensure that they are statistically valid so as to allow States to draw
conclusions about the subject of the study. The State may also choose and is encouraged to develop
strategies to target areas or buildings of high concern that are not representative of the State as a
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whole, such as suspected "hot spots," schools, public buildings, weatherized homes, mitigated homes,
or private wells/public underground drinking water sources. Both types of surveys will be given equa)
funding consideration. States may use SIRG funds to participate in EPA/State surveys; however, FY
1991 will be the last year that the surveys in homes will be conducted. Therefore, States that have
not yet participated in the EPA/State surveys should consider this a high priority in FY 1991. States
also may propose radon-in-water surveys, if they are coupled with air surveys. Guidance for
conducting radon-in-water measurements is available from the Office of Drinking Water at EPA
Headquarters or from Regional Drinking Water Program contacts.
Slate officials must adopt and implement quality assurance (QA) guidelines to maintain the
statistical/analytical quality of their surveys. The QA plan, or assurance that a QA plan will be
developed, must be included in the State's grant application and must be approved by EPA before any
measurement or diagnostic activity begins. Copies of EPA's Quality Assurance Guidance and specific
examples of radon measurement quality assurance plans are available from EPA's Regional Offices.
Measurements should be conducted within the guidance provided by EPA's measurement protocols,
and using measurement equipment and devices discussed in Section 2.5.4.
EPA can not yet predict elevated indoor radon levels as a result of particular architectural
characteristics. For this reason, EPA is not in a position at this time to identify "high risk residential
construction types" as denoted in the statute. If such construction types can be identified in the
future, EPA will consider funding at that time.
The following list includes items or tasks that EPA believes are within the definition of this
activity and thus are eligible for funding:
Survey design
Development of a random selection list
Development of strategies to target high-risk areas
Preparation of survey forms and data collection procedures
Training and use of interviewers
Analysis of radon detectors
Shipping and postage for all detectors
Analysis of data
Preparation of summary statistics and data tapes
Training of State staff for required expertise in geology, radon, statistics, etc.
Note that radon measurement equipment or devices are eligible for funding under IRAA Section
306(c)(4), described in Section 2.5.4. of this document.
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2.5.2 Public Information and Educational Materials
Statutory Provisions
306(c)(2) "Development of public information and educational materials concerning
radon assessment, mitigation, and control programs."
306(g) "States may....use funds from grants under this section to assist local
governments in implementation of activities eligible for assistance under
paragraphs (2), (3), and (6) of subsection (c)."
Discussion
Informing the public about radon is an essential component of any State Radon
Program. Public information campaigns should be designed to provide citizens with
sufficient information to lead them to test their homes for radon (or other structures
where indoor radon is likely to be a problem), and to remediate if necessary, or to take
preventive steps in new construction.
Studies have indicated that such information is conveyed most effectively when a
national or State information campaign is supplemented by an aggressive local outreach
effort. Hence, States are encouraged to coordinate with EPA's radon information
program by putting in place aggressive public education strategies with strong local
components. States may use grant funds to formulate and execute these programs, with
special attention to developing local outreach.
In addition to proactive outreach and education efforts, each State's public
information program should include efforts to make radon personnel available to speak
with private citizens upon request. Personnel should be available to meet with
concerned and interested citizens and to take telephone calls. For example, States
should receive and address citizen complaints concerning insufficient or faulty radon
equipment and response services. States may use SIRG funds for such reactive public
information and support activities.
An important EPA document that States should use in their own public
information program is A Citizen's Guide to Radon (OPA-86-004). The original Guide,
published in 1986, provides basic facts about radon, information to help people measure
radon in their homes, and information to help homeowners evaluate their persona! risk
and take appropriate action should they find elevated levels. EPA is in the process of
revising the Citizen's Guide in accordance with IRAA and to reflect the findings of
radon risk communication studies, improved radon mitigation technologies, and updated
radon health risk information. EPA will make camera-ready versions available to States
for distribution to the public. States are encouraged to discontinue use of the 1986
Guide, and to use instead either the revised Citizen's Guide once it is available or a
State-developed brochure that motivates testing. States are also encouraged to use grant
funds to update their own brochures that are based on the Citizen's Guide.
In addition, States may use other EPA brochures developed jointly with the
Advertising Council. These brochures are specifically designed to motivate the public
to test for radon and fix radon problems. States are encouraged to use such
motivational brochures, including these EPA/Ad Council materials and State-developed
brochures designed to increase radon testing and fixing. Recent risk communications
research shows that motivational brochures with a "localized message" are more effective
than brochures that discuss an issue from a broad national perspective. Therefore, in
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developing their own radon brochures, States are encouraged lo include substantial local
information and examples.
States with limited radon programs should plan 10 collect, copy, and distribute
relevant EPA materials within the State. EPA has determined that printing and
distribution costs incurred by the State to support radon program activities where the
primary audience is the public within the State are allowable expenses under the SIRC
program.
Specific items for which EPA will approve funding include brochures, booklets,
slide shows, videos for do-it-yourself measurement and mitigation information,
advertising and other public service radio and TV announcements, newsletters, and
publications to support State and local radon information campaigns. However, any
advertising and public service announcements must be specifically approved in the grant
agreement, as specified by OMB Circular A-87 (See Section 6.1), and applicants must
identify and include such costs in their proposed budgets. Note that Subsection 306(g)
of the statute allows States to pass S1RG funds through to local governments to develop
such public information materials.
2.5.3 Radon Control Programs
Statutory Provision
306(c)(3) "Implementation of programs to control radon in existing and new structures."
306(g) "States may....use funds from grants under this section to assist local
governments in implementation of activities eligible for assistance under
paragraphs (2), (3), and (6) of subsection (c)."
Discussion
A State may propose a broad range of eligible activities to control radon in existing
and new structures. EPA will consider funding well-designed projects to enhance State
and local program development or to implement innovative approaches in any of the
four functional program areas (program management, public information, problem
assessment, and problem response). Some examples of the types of programs EPA
considers appropriate for funding within this activity category include:
Program Management
Develop program policy such as radon worker protection guidance or standards
Encourage the development of and participate in local radon programs
Conduct a survey to evaluate effectiveness of the State Radon Program
Draft legislation, such as legislation to promote the development of program
income, for radon certification programs, or for worker protection standards
Public Information
Target radon information campaign to low-income households
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Conduct a study to determine the extent of homeowners' follow-up to elevated
radon measurements
Problem Assessment
Investigate high-risk areas
Examine new ways to measure radon or radon decay products
Problem Response
Develop State certification programs for measurement and mitigation of radon,
including the offering of proficiency rating exams, including an audit component
to assess the effectiveness of participants
Develop quasi-regulatory programs designed to encourage radon testing and
mitigation in homes during real estate transactions
Encourage State and local entities to adopt the EPA model construction
standards for new buildings
Develop programs to help schools, child-care centers, and workplaces address
radon problems
Conduct studies to determine the effectiveness of local radon mitigation
installations
Note that Section 306(g) of IRAA provides that States may pass SIRG funds
through to local governments to implement such programs. Also, SIRG grantees are
prohibited from lobbying1 Federal entities using Federal funds, and must disclose any
lobbying activities with non-Federal funds. These restrictions, however, apply only to
Federal entities, and grantees are not prohibited from (and do not have to disclose)
activities intended to encourage State and local entities to adopt the EPA model
construction standards for new buildings or any other State legislative initiatives, such
as certification of measurement and mitigation companies or disclosure of radon at the
time of real estate transaction.
In general, States may use SIRG funds to improve or adapt existing EPA projects,
although EPA would discourage States from duplicating EPA's efforts. For example,
States may undertake activities to encourage local governments to adopt the EPA model
construction standards and techniques for new buildings, or tailor the EPA Citizen's
Guide to a special audience. As another example, States may wish to provide training
courses and seminars to a general audience (See Section 2.5.6 for training State and
local employees). States are encouraged to request the Regional Radon Training
Centers (RRTCs), identified in Exhibit 2-2 on the next page, to deliver radon courses
within the State by coordinating such requests with the State's Regional SIRG program
contact (listed in Appendix B). The RRTCs have shown the ability to meet specific
1 The government-wide common rule for assistance agreements refers to lobbying as "influencing or
attempting to influence." EPA is implementing the common rule language in 40 CFR Section 34.105(h), which
states that "influencing or attempting to influence means making, with the specific intent to influence, any
communication or appearance before an officer or employee of any federal agency, a member of Congress, an
officer or employee of a member of Congress, or an employee of a member of Congress in connection with
any covered federal action or a federal commitment to ensure or guarantee a loan."
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State training needs. EPA would discourage States from duplicating the efforts of the
EPA-funded RRTCs. Stales should know that duplicative efforts may be considered
"unnecessary" and therefore declared unallowable costs during an audit (See Section 3.3).
However, EPA will consider funding State training course development for States with
special needs.
Exhibit 2-2
Regional Radon Training Centers
RTC.
Unhfwty oi MHVMMOM
367-5313
EMMmRTC,
RMB*n Unwwiily
(201)832-2582
(800)462-7459
491-7742
Southern RTC.
Auburn Univwwiy
(205)844-6261
Another point of clarification is that IRAA Section 306(j)(5) clearly prohibits the
use of SIRG funds for operating costs associated with EPA's voluntary radon proficiency
programs. Therefore, the costs of administering the RCP exam are not allowable for
SIRG funding because the RRTCs receive grant funds to provide this service, making
these administrative costs part of EPA's operating cost for the RCP program. EPA
encourages States to use radon measurement services from firms that have successfully
participated in the RMP program (i.e., RMP-listed measurement services). If a State
purchases radon equipment rather than measurement services of a firm with SIRG
funds, EPA policy requires States to participate in the RMP program. In these cases,
when States participate in the RMP program, the costs borne by States are not EPA
programmatic costs and may be paid for using SIRG funds.
2.5.4 Measurement Equipment or Devices
Statutory Provisions
306(c)(4) "Purchase by the State of radon measurement equipment or devices."
306(i)(2) "The costs of implementing paragraphs (4) and (9) of subsection (c) shall not
in the aggregate exceed 50 percent of the amount of any grant awarded under
this section to a State in a fiscal year. In implementing such paragraphs, a
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Stale should make every effort, consistent with the goals and successful
operation of the State radon program, to give a preference to low-income
persons."
Discussion
EPA defines radon measurement equipment or devices as those instruments used
to: 1) test for the presence of radon gas or radon decay products in residential, school,
commercial structures or water supplies to such structures; 2) perform diagnostic tests
related to development of a mitigation approach; 3) investigate effectiveness of
mitigation techniques; and 4) monitor workers or workplaces for radon contamination.
Subject to the ceiling imposed by Section 306(i)(2), SIRG funds may be used to
purchase testing equipment used for such purposes.
States should purchase the measurement equipment or devices that most
appropriately address the State's measurement needs. Equipment for measuring radon
gas or radon decay products in indoor air must be consistent with EPA's measurement
protocols (See Indoor Radon and Radon Decay Product Measurement Protocols - EPA
520-1/89-009). Measurement services which are purchased by the State must be those
which have successfully participated in EPA's RMP program, unless otherwise approved
by the EPA Regional Office. The RMP Cumulative Proficiency Report (EPA 520/1-90-
001) identifies the equipment and devices that have been approved by EPA for
measuring radon, and lists the measurement companies that have successfully passed
EPA's performance test for each method.
Equipment purchased for other purposes such as building diagnostics, measuring
radon and radon-decay products in ambient air, water or soil or other media, and
monitoring worker exposure, should be of the types currently accepted for such uses.
EPA Regional Offices can provide advice on equipment purchases.
Applicants should note that Section 306(i)(2) of IRAA requires that grantees make
every effort to give a preference to low-income persons when using radon measurement
equipment or devices purchased with grant funds. IRAA Section 306(i)(4) allows States
to provide financial assistance to persons if related to the purchase/analysis of radon
measurement devices. Section 3.7.4 of this document provides more detailed guidance
on financial assistance to persons under Section 306(i)(4) of IRAA.
Applicants should note that Section 306(i) of IRAA, "Limitations," prohibits States
from expending more than 50% of the amount of the grant award received in a Federal
fiscal year for the purchase of measurement equipment or devices and demonstration
projects, in the aggregate. This limitation is calculated as a percentage of the Federal
funds. More detailed guidance on how to apply this limit is provided in Section 3.7.2.
2.5.5 Analytical Equipment
Statutory Provision
306(c)(5) "Purchase and maintenance of analytical equipment connected to radon
measurement and analysis, including costs of calibration of such equipment."
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Discussion
States that purchase certain radon measurement devices will need 10 acquire calibration
services to ensure the accuracy of the devices. In general, EPA will approve the costs of
obtaining such services, but States will retain responsibility for demonstrating the validity of
the method. The Agency will consider the use of S1RG funds for the construction of radon
chambers only for States with legislation requiring the development of certification programs.
There are several sources from which calibration services can be acquired. One source
is the National Institute of Standards and Technology (MIST). States may also purchase
equipment calibration services from contractors participating in the nationally sponsored Inter-
Comparison Program. This program brings together private and public operators of radon
chambers twice a year to inter-compare their equipment. In addition, States may seek other
sources of calibration services, but must be prepared to demonstrate the validity of their
calibration method.
2.5.6 Training
Statutory Provisions
306(c)(6) "Payment of costs of Environmental Protection Agency-approved training programs
related to radon for permanent State or local employees."
306(g) "States may....use funds from grants under this section to assist local governments in
implementation of activities eligible for assistance under paragraphs (2), (3), and (6)
of subsection (c)."
Discussion
Agency policy is to approve the use of SIRG funds to support participation by permanent
State or local radon employees in the following types of training activities:
EPA-sponsored training courses on radon.
Attendance at the RRTCs (shown in Exhibit 2-2) for courses related to health effects
and risk communication, radon dynamics, measurement and mitigation strategies or
methodologies (including hands-on component), building investigation and diagnostic
testing, worker health and safety, radon prevention in new construction, and radon in
water.
Radon-related courses (similar to those offered by RRTCs) at accredited colleges,
universities, and, if specifically approved by the EPA Regional radon project officer,
other private sector institutions.
Radon conferences and symposia.
EPA defines a permanent radon employee as one who is officially classified as permanent
by the State or local government for which he/she works. Eligible costs under this activity
category include travel expenses associated with attending courses, workshops, and seminars, as
well as any fees that may be incurred. In general, States are encouraged to fully use the existing
mechanisms described above for training State and local employees. For State development of
its own training courses, see Section 2.5.3.
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Note again that Section 306(g) of IRAA provides that Slates may pass SIRG funds through
to local governmenis to use for training activities. States are encouraged to aggressively seek
local government participation (see Section 3.4).
2.5.7 Program Overhead/Administration
Statutory Provisions
306(c)(7) "Payment of general overhead and program administration costs."
306(i)(3) "The costs of general overhead and program administration under subsection (c)(7)
shall not exceed 25 percent of the amount of any grant awarded under this section to a State in
a fiscal year."
Discussion
Development of a State Radon Program must include the mechanisms and infrastructure
needed to administer the program. Elements of program administration that are eligible for
funding under the grant include mechanisms for providing information to decision makers,
acquiring and allocating key resources, designating staff responsibilities, providing management
oversight and direction, monitoring program progress, identifying the need for State executive or
legislative activities, and providing quick response capability. Also eligible are any indirect costs
which support the program such as clerical and administrative costs and rental of office space.
OMB Circulars A-87, "Allowable Costs" and A-102, "Grants and Cooperative Agreements with
State and Local Governments" can be used in conjunction with 40 CFR Part 31 for more specific
determinations on allowable costs (see Section 3.2 for further discussion.)
Applicants should note that Section 306(i) of IRAA, "Limitations," prohibits States from
expending more than 25% of the amount of the grant award received in a Federal fiscal year on
general overhead and program administration. This limitation is calculated as a percentage of
the Federal funds. More detailed guidance on how to apply this limit is provided in Section
3.7.3.
2.5.S Data Storage/Management
Statutory Provision
306(c)(8) "Development of a data storage and management system for information concerning
radon occurrence, levels, and programs."
Discussion
Development of a radon data storage and management system entails the design of
appropriate software vehicles and the definition of the relevant information for assembling into
a computerized database. SIRG funds may be used to cover such software design expenses and,
to a limited extent, to finance the purchase of micro or personal computers.
Radon-related information for which storage and management capabilities are needed may
include measurement locations; the type and location of measurement devices; screening results;
follow-up results; house characteristics; and mitigation characteristics. In general, EPA will
afford States flexibility in developing an approach to data storage and management. However,
to help ensure national consistency, Section 6.2.3 and Appendix D provide a standardized formal
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for EPA's national data base that is not required but may be used by Stales for organizing and
reporting radon measurement data to EPA. The Agency will prepare additional guidelines
concerning the compilation, format, and reporting of radon mitigation data, and in the meantime.
States should contact the EPA Regional Radon Offices for further guidance.
2.5.9 Mitigation Demonstrations
Statutory Provisions
306(c)(9) "Payment of costs of demonstration of radon mitigation methods and technologies as
approved by the Administrator, including State participation in the Environmental Protection
Agency Home Evaluation Program.
306(i)(2) "The costs of implementing paragraphs (4) and (9) of subsection (c) shall not in the
aggregate exceed 50 percent of the amount of any grant awarded under this section to a State in
a fiscal year. In implementing such paragraphs, a State should make every effort, consistent with
the goals and successful operation of the State radon program, to give a preference to low-income
persons."
Discussion
Radon grants may be used to fund State demonstration projects modelled after EPA's House
Evaluation Program (HEP), new HEP, and School Evaluation Program (SEP). Activities may
include diagnostic testing, mitigation design, implementation, and follow-up testing. The mitiga-
tion methods and technologies to be demonstrated may be similar in type and scope to those
covered by the Agency's evaluation programs or cited in EPA's training manual, Reducing Radon
in Structures. Alternatively, States may apply for funds under this section to demonstrate a new
and innovative mitigation technique, especially if the technique potentially may be of use to other
States.
Aside from planning and conducting their own independent demonstrations. States may use
SIRG funds to support their participation in EPA's House (or other building) Evaluation
Program. The grant may be used to cover operating expenses associated with such participation
such as development and production of written materials, reproduction of materials, rental of
classroom space, audio-visual materials, and course publicity.
EPA is in the process of initiating the National School Radon Survey, designed to study the
magnitude and distribution of radon levels in the nation's schools. EPA is also undertaking more
thorough evaluations of radon mitigation and prevention techniques in schools. If, as part of
these national efforts States undertake mitigation demonstration projects at schools, EPA
requests that States give priority to those schools that participated in the national school survey
and that have confirmed elevated radon levels.
Applicants should note that, as with activities discussed Section 2.5.4, Section 306(i)(2) of
IRAA requires grantees make every effort to give a preference to low income persons when
conducting mitigation demonstrations. In accordance with IRAA Section 306(i)(4), States may
use SIRG funds to provide financial assistance to persons to participate in a mitigation
demonstration project. Section 3.7.4 of this document provides more detailed guidance on
financial assistance to persons under Section 306(i)(4) of IRAA.
Applicants should also note that Section 306(i) of IRAA, "Limitations", prohibits States from
expending more than 50% of the amount of the grant award received in a Federal fiscal year for
the purchase of measurement equipment or devices and demonstration projects, in the aggregate.
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This limitation is calculated as a percentage of the Federal funds. More detailed guidance on
how to apply this limit is provided in Section 3.7.2.
2.5.10 Toil-Free Hotline
Statutory Provision
3Q6(c)(10) "A toll-free radon hotline to provide information and technical assistance."
Discussion
States may use SIRG funds to install and operate a toll-free radon hotline to provide basic,
radon-related information to the general public. Eligible costs include the telephone lines,
automated switching/answering machines, telephone answering staff, postage, and any other direct
cost of the hotline. States may choose to establish hotlines covering specific geographic areas.
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Chapter 3: ANNUAL ALLOTMENTS AND PROGRAM COSTS
This Section describes EPA's process of allocating and awarding funds, the cost share
requirements to which States must adhere, the rules governing program income, and the statutory
limitations on Slate Program expenditures.
3.1 Authorization and Grant Award Preference
IRAA Section 306(j) authorizes an appropriation of up to 510,000,000 for each of Federal
fiscal years 1989, 1990, and 1991 for the S1RG program. Because no grant funds were
appropriated in 1989, the first grant year for the SIRC program was in FY 1990, which had a
total budget of 58,806,600 for FY 90 grants. The FY 1991 appropriation for State Indoor Radon
Grants is $9,000,000.
3.1.1 Authorization Restrictions
(1) No more than 10% of the amount actually appropriated for the SIRG program may
be awarded to any one State, as specified by IRAA Section 306(j)(3). Because EPA's
goal is to encourage widespread development of effective, self-sustaining State radon
programs appropriate to the scope of the problem, it is unlikely that sufficient funds
will be available for any State to receive as much as 10% of the SIRG program
appropriation.
(2) Funds not obligated by EPA to States in the Federal fiscal year for which the funds are
appropriated shall remain available for obligation in the next Federal fiscal year, as
specified by IRAA Section 306(j)(4). However, funds awarded to States but not yet
obligated by the State are subject to EPA's official policy regarding carryover funds,
Comptroller Policy Announcement No. 88-09. published on May 6,1988. Carryover
funding is discussed in Section 3.8 of this guidance.
(3) SIRG funds may not be used to cover the costs of the proficiency rating programs
established by IRAA Section 305(a)(2), as specified by IRAA Section 306(j)(5). The
referenced proficiency programs include the Radon Contractor Proficiency (RCP)
program and the Radon Measurement Proficiency (RMP) program. Therefore,
activities associated with EPA's voluntary radon proficiency programs (e.g^ the costs
of administering the RCP exam) are not eligible activities under the grant, except for
providing EPA's proficiency program lists to the public as required by IRAA Section
306(h)(3). In addition, as discussed in Section 2.5.3 of this guidance, the costs borne
by States when they participate in the RMP program may be paid for using SIRG
funds.
3.2 Annual Allotments
EPA will allocate funds to the 10 EPA Regional Offices for award. Regional Offices are
responsible for determining the amount of Federal funding awarded to a State. EPA funding
for the first year of a SIRG grant does not obligate EPA to provide Federal funds for a second
year. Subsequent funding will depend on EPA's evaluation of State performance in the previous
grant year, as discussed in Section 4.6.2.
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States which submit proposals for innovative projects, may receive supplemental Federal
funding for the project through the State's grant. EPA Regional Offices will negotiate the final
awards.
3.3 Allowable Costs
States must ensure that the costs of proposed activities are allowable under the grant.
Allowable costs are required by Section 31.22 of EPA's general grant regulation, 40 CFR Part
31. For States, allowable costs are specified by categories in OMB Circular A-87. Allowable
costs are defined as those costs that are "eligible, reasonable, necessary, and allocable". Eligible
activities are specified by the statute (See Section 2.5). For a cost to be eligible, it must be
incurred while the State is implementing these eligible activities. Furthermore, for a cost to be
eligible, the cost must not be prohibited by the statute (See Section 3.7). Costs must be judged
in context to determine that they are reasonable and necessary. In addition, costs must be
incurred during the budget period, as specified by 40 CFR Section 31.23. All grant expenditures
are subject to audit (See Section 6.4) for the final determination of alienability of costs.
3.4 Assistance to Local Governments
States are encouraged to actively support the development of local radon programs. As
shown in Exhibit 2-1, a core program should, at a minimum, encourage and support local
initiatives where there are known radon problems. More extensive State programs are
encouraged to actively participate in and coordinate local activities, including the activities of
established local networks.
States may, at the lead State Agency's discretion, use SIRG funds to assist local governments
in implementation of the following eligible activities: public information and educational
material (Section 2.5.2), encouraging the development of and participating in radon control
programs (Section 2.5.3), and training (Section 2.5.6). States may wish to develop
Intergovernmental Agreements with those local governments for which the State will "pass-
through" SIRG funds. Since studies have suggested that radon programs are often most
effectively conducted at the local level, EPA encourages States to consider this option a key
element of the State radon program. Through an Intergovernmental Agreement, local
governments may contribute non-Federal radon program expenses which the State may then use
for meeting the required State match.
3.5 State Match
IRAA Section 306(f) stipulates that EPA may provide States with no more than 75% of the
allowable costs of approved Radon Program activities during the first grant year, and no more
than 60% the second year. The remainder constitutes the State's matching share. That is, any
State wishing to participate must plan to absorb at least 25% of the cost of its program activities
during the first year of Federal funding. Two States (Montana and South Dakota) did not
participate in the first year of the grant program and thus would have a 25% matching share in
FY 1991, during their first grant year. All the other States and territories that participated in
the first grant year in FY 1990 will be entering their second year of the program in FY 1991.
The statutorily required percentage of State share rises to at least 40% for the second grant year.
This change in the matching requirements will apply to any SIRG dollars obligated during
the second 12-month budget period. Thus if the State carries forward first-year SIRG dollars
into the second 12-month budget period, then those SIRG dollars become, in effect, second-year
SIRG dollars that must be matched at the 40% level. As a result, States are encouraged to make
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every effort to appropriately obligate their first-year SIRG dollars during the first 12-month
budget period, avoiding the need to carry funds forward. Additional issues regarding carryover
funding are discussed in Section 3.8 of this guidance.
Applicants for the second grant year should show how they will meet the 40% cost share
requirement for the total grant award. Thus, the applicant need not show a 40% match on an
activity basis. (For example, if an applicant plans to include the innovative project as part of the
entire SIRG grant, the applicant need not provide 40% of the actual innovative project costs,
as long as the applicant provides 40% of the costs of the grant as a whole.) State and Federal
dollars become blended under the grant such that the dollars cannot be attributed on an activity
basis. Each grant-related dollar is assumed to include both the Federal and the State share,
thus all dollars spent under the grant agreement (even dollars a State expends to meet its match)
must meet the requirements discussed throughout this Guidance.
This matching requirement may be satisfied with any combination of the following
alternatives, as long as the State's matching funds are used for grant activities: 1) State funded
activities; 2) third party in-kind contributions; and, 3) if allowed by the grant agreement, program
income (See Section 3.6). Examples of State funded activities would include any State personnel
funded by the State, a State's telephone bill for running a hotline, State survey costs, cash, etc.
EPA's general grant regulation, 40 CFR Part 31, defines third party in-kind contributions: as
"property or services which benefit a Federally-assisted project or program and which are
contributed without charge to the grantee." Therefore, examples of third party in-kind
contributions would include a company which donates detectors for a school survey, or a private
sector employee sent to help staff the Radon Agency's booth during an exhibition. Program
income is discussed below.
3.6 Program Income
Program income is defined as gross income (1) received by the grantee or subgrantee, (2)
directly generated by a grant supported activity, or (3) earned only as a result of the grant
agreement during the grant period. Program income might accrue, for example, if a grantee
conducts a mitigation demonstration under Section 306(c)(9) and charges a fee to participants
of the demonstration. Program income may also be developed by charging fees as part of real
estate transactions and through taxes on new homes to ensure compliance with new building
codes. All three of these approaches for developing program income may require State
legislative authority.
States are encouraged to generate program income and to use that income to help make
their radon programs self-sustaining after the Federal grant program has expired. States should
seek any or all of the three approaches mentioned above for generating program income, or any
other approach, for the purpose of developing a self-sustaining program. As noted in Section
2.3 of this guidance, innovative project proposals can include creative approaches to develop a
sustained source of income for the radon program.
In accordance with EPA's general grant regulation, 40 CFR Part 31, (Section 31.25), any
program income generated by a grant supported activity must be disposed of as program income
by one of three alternatives:
(1) Deduction: The income may be deducted from total allowable costs to determine net
allowable costs. The effect is to produce proportionate reductions in EPA's and the
grantee's contributions to the program, rather than to increase the funds committed
to the program.
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(2) Addition: When authorized, program income may be added to the funds committed to
the grant agreement by EPA and the grantee, and then used for the purposes and
under the terms of the grant agreement.
(3) Cost Sharing or Matching: When authorized, program income may be used as part of
the grantee's cost share, and the amount of Federal funds committed !o the project
remains the same.
Of these three alternatives, EPA encourages and will provide a grant special condition for the
Slates to use cost sharing and matching as a method of disposing of program income.
Section 31.25 specifies that program income is considered a deduction from total allowable
costs (i.e., alternative 1) unless otherwise specified in the grant agreement. The State can request
in its application that EPA consider the use of program income for cost share or addition. The
EPA Regional Office may permit States to use program income to meet the State's matching
funds requirement or to increase the award amount by funding additional eligible activities, if
such arrangements are specified within the terms of the grant agreement. However, in order for
the State to use program income Tor addition, the recipient must have access to these funds and
must expend the generated income on allowable radon program activities. Thus, if program
income is returned 10 the State's general treasury account, then EPA must deduct the Federal
share of the program income from the Federal funding of the gram award. Recipients are
encouraged to adapt their State monetary procedures to allow SIRG program income to be
returned to the recipient rather than the recipient's general treasury so that program income may
be used for radon program activities.
3.7 Limitations
This section reviews the statutory limitations applicable to the award and use of SIRG funds.
Some restrictions are discussed above. Specifically, restrictions concerning the maximum possible
State award, the allowability of carryover funding, and the eligibility of voluntary radon
proficiency program development costs are discussed in Section 3.1.1. Furthermore, restrictions
on the pass-through use of SIRG funds for local governments is discussed in Section 3.4. The
following restrictions are contained in 1RAA Section 306(i) and are discussed separately in other
sections of this guidance, where relevant. EPA will monitor compliance with these limitations
and restrictions as part of its ongoing evaluation of the performance of each grant recipient.
3.7.1 Satisfactory Performance: Section 306(i)(l)
"No grant may be made under this section in any fiscal year to a State which
in the preceding fiscal year received a grant under this section unless (EPA)
determines that such State satisfactorily implemented the activities funded by
the grant in such preceding fiscal year."
See Section 6.4 for a description of performance evaluation. EPA has developed
criteria to implement these restrictions for the second grant year (See Section 4.6.2).
3.7.2 50% Ceiling on Measurement Equipment/Mitigation Activities: Section 306(i)(2)
"The costs of implementing paragraphs (4) and (9) of subsection (c) shall not
in the aggregate exceed 50 percent of the amount of any grant awarded to a
State in a fiscal year. In implementing such paragraphs, a State should make
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every effort, consistent with the goals and operation of the State radon
program, to give a preference to low-income persons."
This limitation is calculated as a percentage of the Federal funds.
See Sections 2.5.4 and 2.5.9 for a description of the referenced eligible activities.
States must track their expenditures to ensure that the State does not spend more than
50% of the Federal funds on these two eligible activities combined. (See Section 5.2.1,
Budget). States are encouraged to give preference to low-income persons when
purchasing radon measurement equipment or devices and when performing mitigation
demonstrations. Section 3.8 provides additional guidance on how this limitation is
applied when federal funds are carried forward into the next budget period.
3.7.3 25% Ceiling on Program Administration and Overhead: Section 306(i)(3)
"The costs of general overhead and program administration under subsection
(c)(7) shall not exceed 25 percent of the amount of any grant awarded under
this section to a State in a fiscal year." [See Section 2.5.7 for a description of
the referenced eligible activity.]
As for the 50% limitation discussed above, this 25% ceiling on program
administration and overhead is calculated as a percentage of the Federal funds. States
must track their expenditures to ensure that the State does not spend more than 25%
of the total Federal grant award on program overhead and administration (See Section
5.2.1, Budget).
An issue that arose during the first year of the grant program was whether an
indirect cost rate of greater than 25% would constitute a violation of the statutory 25%
limit on general overhead and program administration. The indirect cost rate is simply
an accounting tool typically used to distribute general overhead costs (such as rent,
utilities, supplies), which cannot be directly attributed to one grant. An indirect cost rate
is a percentage, applied to a "base" (some dollar amount directly associated with the
grant), to calculate an indirect cost dollar amount. Therefore, in general, almost all of
the total indirect cost dollar amount is by definition one type of program
overhead/administration cost that must be limited to 25% of the total S1RG award. If
a States's indirect cost rate is higher than 25%, it is important to examine the
relationship between the base used to calculate indirect costs and the size of the total
amount of the grant award. The "base" amount to which the indirect cost rate is applied
may be less than the total direct costs of the grant, and therefore, the total indirect cost
dollar amount may still be less than 25% of the total SIRG award. Appendix E of this
guidance provides an example of how an indirect cost rate is applied to a base dollar
amount. Because indirect cost rates are negotiated individually on a State-by-State basis
and vary widely in terms of what they cover and how they are applied, questions and
problems for a particular State will have to be worked out with each Regional Grams
Management Office.
3.7.4 Financial Assistance to Persons: Section: 306(i){4)
"A State may use funds received under this section for financial assistance to
persons only to the extent such assistance is related to demonstration projects
or the purchase and analysis of radon measurement devices."
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States may use SIRG funds to develop a limited program for radon financial
assistance. Financial assistance can include subgrants, loans, or some other program to
provide money or property in lieu of money. Eligible "persons" for such a financial
assistance program would include individuals, corporations, partnerships, associations,
units of government, and other legal entities. However, SIRG funds used to provide any
financial assistance to persons must be limited to activities directly related to
demonstration projects (See Section 2.5.9) or to purchase and analysis of radon
measurement devices (See Section 2.5.4). Examples of projects that are eligible for
funding under this section include assistance to:
Individuals or community interest groups in high-risk areas to provide testing kits
to homeowners
Mitigation contractors to demonstrate new mitigation techniques
» Non-profit organizations to develop area-wide mitigation demonstration projects for
low-income neighborhoods
School districts to undertake comprehensive testing or to perform school mitigation
demonstrations
As mentioned in Section 3.7.2, States should make efforts to give preference to low-
income persons when providing assistance for these eligible activities.
Note that "financial assistance" is defined as "assistance in the form of money."
"Technical assistance which provides services instead of money" is clearly distinguished from
financial assistance under the definition of "grant" in the general grant regulations (40 CFR
Section 31.3). Thus, Stales may provide technical assistance to persons under any of the
eligible activity categories, not jusi activities directly related to demonstration projects or
to purchase/analysis of radon measurement devices. For example, a State could develop a
community outreach program and provide it to the public free of charge under radon
control programs (see Section 2.5.3).
3.8 Carryover Funding
Each State has their own full 12-month budget period (that is not necessarily linked to the
Federal fiscal year) to obligate all of their SIRG dollars. If, at the end of the 12-month period,
a State has remaining SIRG funds, then the grant can be amended to carry those dollars forward
to the State's second 12-month budget period. The EPA Regional Office, in consultation with
the State, decides whether the funds carried forward are to be made available either as additional
funding for the second year or as partial funding in lieu of a like amount from the second-year
Federal funds. The accounting procedures for carrying over funds are spelled out in EPA's
official policy regarding carryover funds, Comptroller Policy Announcement No. 88-09, published
on May 6, 1988.
States should be aware that any first-year SIRG funds that are carried over into the second
year become, in effect, second-year funds that must be matched by the State at the 40% level (as
discussed in Section 3.5, the State's matching share increases from 25% in the first grant year to
40% in the second year). Therefore, States are encouraged to make every effort to appropriately
obligate their first-year SIRG dollars during the first 12-month budget period, avoiding the need
to carry over funds.
States should also be aware that carrying over funds into the second year may result in an
exceedence of the 50% spending limit on measurement equipment/mitigation activities or the
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25% spending limit on program administration and overhead. When funds are carried into the
second year, the Federal funds obligated during the first year are less than the overall Federal
award (i.e., there is a downward adjustment to the first-year Federal funds), and the actual 50%
and 25% limitations for the year are lower than those projected based on the overall Federal
award at the beginning of the year. States should consult with their EPA Regional Office on a
case-by-case basis to resolve this issue.
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Chapter 4: GRANT AWARD PROCESS AND REVIEW CRITERIA
4.1 Grant Award Process Overview
Exhibit 4-1 on the following page shows the major steps in the grant award process. The process begins
with preapplication assistance. Before the State submits an application, the State should consult with the EPA
Regional Office in order to structure the application so that it demonstrates compliance with the statutory
requirements discussed in Chapter 5 as well as the applicable EPA regulations and OMB Circulars described
in Chapter 6. After the State submits the application, the EPA Regional Office will review the package for
compliance with technical and administrative requirements. When this review is completed, the EPA Regional
Office contacts the applicant to discuss any issues pertaining to the application. If agreement can be reached
on these issues, then the EPA Regional Office prepares the award document (EPA Form 5700-20A). Once
the award is signed by the EPA Award Official, the Regional Office must send 2 signed copies to the
applicant. The applicant must sign the award document, and return one copy of the agreement to the Grants
Management Office.
4.2 Preapplication Assistance
Before the State submits a formal application to the Region, personnel from both the Regional Radiation
Program Office and the Regional Grants Management Office will be available to provide preapplication
assistance. Applicants are encouraged to seek preapplication assistance to expedite the application process.
To obtain preapplication assistance, the State may arrange a site visit or an informal conference with
EPA personnel. The State also may submit a written, informal inquiry to EPA or make a formal inquiry using
the form "Preapplication for Federal Assistance," EPA Form 5700-30. Appendix B of this Guidance provides
a list of Regional Radon Program Office and Grants Management Office contacts.
4.3 Deadlines for Submitlal
The SIRG program was designed with a "project grant" (as opposed to a "program" grant) schedule to
give each EPA Region and State maximum flexibility for incorporating the grant into its radon program. As
a result, first-year grants were applied for, evaluated, and awarded according to different schedules, rather than
being tied to the federal fiscal year like a program grant. Second year grants will maintain this staggered
schedule and will begin 12 months after the first-year grant award date, with most second-year grants expected
to be awarded during the period January to May 1991. States seeking funding for the second grant year should
submit a completed application package to the EPA Regional Office according to deadlines set by each
Regional Office. For example, the Region may wish to set the deadline for each State no later than three
months before the expiration date of the first-year grant (for example, if a first-year pant expires on May 1,
1991, a Region may require each State to submit a completed application package by no later than February
1,1991). This would allow EPA three months to review the application and make a decision before the first-
year grant expires. In addition to this deadline, a brief summary of each innovative project proposed for
supplemental funding must be submitted to the EPA Regional Office by December 12,1990. Unlike first-year
grants, no Letter of Intent is required to be submitted prior to the innovative project proposal or completed
application package.
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There are two States thai have yet to apply for first-year grams but may do so during FY 1991, the
second year of the S1RG program. Any innovative project proposals from these States must be submitted by
December 12,1991 along with those from the other States. Completed application packages from these first-
year States must be submitted by the deadline set by their Regional Office.
4,4 Application Process
As noted above, States should submit their innovative project proposals by December 12, 1990. The
innovative project proposals will be evaluated by EPA according to the criteria discussed in Section 4.5 below.
EPA will notify States of approved proposals so that those States may incorporate their innovative project into
their SIRG application.
States are expected to work closely with the EPA Regional Offices to develop their applications well
before (e.g., three to four months before) the expiration date of tbeir first-year grants in order to meet the
deadline. States that apply for funding should submit three copies of their completed application packages
to the EPA Grant Management Office (listed in Appendix B) in their Regions. The grant applications will
be evaluated by EPA according to the criteria discussed in Section 4.6 below. The specific application
requirements are discussed in Chapter 5.
4.5 Innovative Project Proposal Evaluation Criteria
Applicants for projects of this type will be evaluated on the following criteria:
(1) Assessment of State Capabilities. Demonstrated expertise and effectiveness in implementing similar
programs within the general project area proposed.
(2) Innovation. Identification of new approaches to achieving the overall goat of reducing public health
risk from radon. Innovation can consist of new approaches that could reduce risk more effectively
or at lower cost, would improve on previously tried projects by performing them on a larger or
smaller scale, or would address problems that have not been addressed to date.
(3) Usefulness to Other States. Practical potential to be adopted by other States for radon program
implementation. EPA evaluations will consider whether the project proposed for the target region
or group has applicability beyond the State submitting the proposal.
(4) Project Characteristics. Innovative model projects may be proposed for any of the four functional
program areas: program management, problem assessment, problem response, and public
information. No single program area will have preference during EPA review.
4.6 Application Evaluation Criteria
EPA will use a two-stage process to review applications for second-year grant funding. In the first stage,
EPA will review the proposed activities for the second year (or for the first year for the two States that did
not participate during Federal fiscal year 1990) on the basis of the application package submitted by the State,
according to the criteria laid out in Section 4.6.1. In the second stage, EPA will incorporate an evaluation
of the State's first-year grant performance into the review of the proposed second-year activities, according to
the criteria laid out in Section 4.6.2.
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4.6.1 Application Evaluation Criteria for Second Grant Year
Both the EPA Regional Grants Management and the Radon Program Office reviewers will evaluate the
full application for several factors:
(1) Completeness. Applications must contain all the information discussed in Chapter 5.
(2) Sufficient level of detail. The Statement of Work should explain the State's planned activities in
each of the four program framework areas, with detailed cost estimates. These cost estimates must
be reasonable and justified by the detailed program activities.
(3) Internal consistency. The Budget Information Sheet provides summary budget figures. In the
Statement of Work, cost estimates are broken down for each activity. The aggregated costs in the
Statement of Work must match those in the Budget Information Sheet.
(4) Allowable Costs. Costs included in the application must be allowable for SIRG funding. Allowable
costs are defined as those costs that are "eligible, reasonable, necessary, and allocable." All costs
must be consistent with OMB Circular A-87, "Cost Principles for State and Local Governments".
Final determination of the reasonableness of the cost estimates in the application will be made by
EPA. All grant expenditures are subject to audit (See Section 6.4) for the final determination of
allowability of cost.
(5) Consistency with SIRG Program Goals. Proposed activities should allow States to develop the core
capabilities necessary to establish effective and self-sustaining radon programs appropriate to the
scope of the problem. EPA encourages States to use the program framework proposed in Section
2.2 as a flexible model for developing their own State radon program.
(6) Preference to Certain States. IRAA Section 306(d) specifies that, beginning in Fiscal Year 1991,
EPA shall give a preference for grant assistance to States that have made reasonable efforts to
ensure the adoption, by the authorities which regulate building construction within that State or
political subdivisions within States, of the model construction standards and techniques for new
buildings specified under IRAA Section 304, or other standards and techniques that are comparable
to or more stringent than those specified under IRAA. Since EPA expects these model standards
to be published during 1991, EPA shalt give funding priority to States that include activities to
promote the adoption of the standards in their proposed second-year activities.
4.6.2 Evaluation Criteria for First-Year Grant Performance
IRAA Section 306(i)(l) specifies that no grant may be made in any fiscal year to a State which in the
preceding fiscal year received a SIRG grant unless EPA determines that such State satisfactorily implemented
the activities funded by the grant in the preceding fiscal year. (See Section 6.5 for a description of
performance evaluation.) EPA will use the following criteria to evaluate each State's first-year grant
performance:
(1) Completion of Major Milestones. EPA will evaluate the degree to which each State completed the
milestones and achieved the objectives negotiated with the Region during the first-year application
process and updated through mid-year grant reviews.
(2) Emphasis of Priority Areas. EPA's priority activities and projects for the first year of the SIRG
program were spelled out in Section 1.4 of the first-year grant guidance (the first-year priorities
have since been expanded and updated in Sections 1.4 and 1.S of this second-year guidance). EPA
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will evaluate the first-year grant performance by examining the extent to which these statutory areas
(Section 1.4 only) were emphasized, as demonstrated by the planning and execution of projects in
each area.
(3) Indicators of Program Success and Effectiveness. EPA will consider any available measures of a
State's program effectiveness, such as the numbers of homes/schools tested and mitigated, the
volume of public inquiries and proactive information distributions, the infrastructure established
for Suae and local programs, the amount of program income, and the execution of innovative
projects that have been adopted in other States and Regions.
4,7 Award Process
When the State and EPA have resolved all of the issues pertaining to the grant application, then the
EPA Regional Grants Management Office prepares the award document (EPA Form 5700-20A). Pan I of
the award document requires EPA to provide general information, including the name of the EPA project
officer. Part II of the award document requires EPA to provide information on the approved budget. Part
III of the award document provides the space for EPA to add any special conditions deemed necessary.
The Regional radon Project Officer and the grant recipient should work closely with the Regional Grants
Office to ensure that adequate time is allowed to process the grant award. States should be aware that there
is a five-day congressional notification waiting period after the award is signed by the EPA Award Officer.
Once the award is signed by the EPA Award Official, the Regional Office must send 2 signed copies to
the applicant. The applicant must sign the award document, and return one copy of the agreement to the
Grants Management Office.
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Chapter 5: APPLICATION REQUIREMENTS
The applicant must use the "Application for Federal Assistance - State and Local Nonconstruction
Programs" (Standard Form-424). In the first year of the SIRG program, Slates may have applied for a two
year project grant with a one year budget period. Applications for additional funding in the second year need
to include only the revised pages of the grant application (which will primarily include a second-year budget
and a second-year workplan). Exhibit 5-2, beginning on page 36 presents a sample, completed application
form SF-424 that illustrates the required information discussed in this Chapter.
5.1 Standard Form
The form consists of three parts, plus instructions:
(1) Part I - General Information
(2) Part II - Budget Information
(3) Part III - Assurances and Certification
5.1.1 Part I - General Summary Information
This section provides general administrative information about the applicant and project. For example,
it asks for total proposed project funding, project start and end dates, project duration, and an administrative
contact (project manager). Detailed instructions for completing the application appear on the form.
5.1.2 Part II - Budget Information
This section identifies total costs for all activities to be undertaken as part of the proposed project for
the first budget year. The Budget Information Part includes six sections:
Section A: Budget Summary-identifies the cost per major activity (For example, innovative projects and the
four functional program areas of program management, public information, problem assessment,
problem response) to be funded.
Section B: Budget Categories-displays detailed breakdown of costs by object class category (such as travel
and equipment). Appendix C of this guidance provides additional detail on these object class
categories.
Section C: Non-Federal Resources-provides an area for listing funding sources and amounts to meet the
State's 40% match (or 25% for first-year grant applicants).
Section D: Forecasted Cash Needs-projects drawdowns for each quarter of the second-year budget period.
Section £: Budget Estimates-project funds necessary for the second grant year.
Section F: Other Budget Information-lists other out-of-the-ordinary direct charges, previously negotiated
indirect charges, and includes a "remarks" section. Under Item 22 of this section, States should
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indicate whether their indirect cost rale has been negotiated with the applicant's cognizant
agency.
5.1.3 Fart HI Assurances
Part III of the application form identifies standard assurances to which the recipient agrees when signing
the grant agreement form. The applicant assures EPA that it will comply all applicable requirements of all
Federal laws, executive orders, regulations, and policies governing the SIRG program. The assurances list
several important statutes specifically, such as: the Civil Rights Act of 1964, the Davis-Bacon, Copeland and
Contract Work Hours and Safety Act, the Uniform Relocation Assistance and Real Property Acquisitions Act
of 1970, and the Single Audit Act of 1987. All of these assurances are clearly identified in the application
form.
When the applicant signs the application form, the applicant certifies that it will comply with all
applicable Federal regulations. Two assurances of note that do not appear in the application form are
required by 40 CFR Part 32, "Govemmemwide Debarment and Suspension (Non-procurement)". The two
assurances are the drug-free workplace certification and the assurance that contracts will not be awarded to
firms/individuals on EPA's Master List for Suspended, Debarred, and Voluntarily Excluded Persons. The EPA
Regional Office may include these assurances as special conditions to ensure that the applicant is aware of
these requirements.
5.2 Application Attachments
In addition to the forms, the applicant must submit several attachments:
(1) A Statement of Work;
(2) A Debarment and Suspension Certification (EPA Form 5700*49);
(3) For first-year grant applicants, a certification letter from the State Governor or Attorney
General; in some Regions, second-year grant applicants need to submit» letter from the State
assuring that the certification letter submitted in the first year is still valid;
(4) Evidence of compliance with the State's intergovernmental review process;
(5) A Quality Assurance Project Plan.
5.2.1 Statement of Work
The Statement of Work (SOW) describes the purpose and scope of activities to be carried out as part
of the proposed project. In addition, the applicant should include the following statutory application
requirements (IRAA Section 306(b)) as part of the SOW:
Statement of Radon Problem: A description of the seriousness and extent of the radon exposure in
the State (i.e., a more detailed description based on information collected during the first grant year).
Lead Agency: An identification of the State Agency which has the primary responsibility for radon
programs and which will receive the grant, a description of the roles and responsibilities of the lead
33
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State agency and any other State agencies involved in the radon programs, and description of the roles
and responsibilities of any municipal, district, or areawide organization involved in radon programs.
Second-year grant applicants need only submit updated information (e.g., if the Lead Agency has
changed).
Work Flan: A description of the activities and programs related to radon which the State proposes
for the proposed budget year.
Budget: A budget specifying Federal and State funding of each element of activity of the grant
application for the proposed budget year.
Three-Year Plan: For first-year grant applicants, a three-year plan which outlines long range program
goals and objectives, tasks necessary to achieve them, and resource requirements for the entire three-
year period, including anticipated State funding levels and desired Federal funding levels. For second-
year grant applicants, these plans should be updated into a running three-year plan.
Statement of Radon Problem
The Statement of Work must contain a description of the seriousness and extent of radon exposure
in the State. The State should present geologic mapping and radon measurement data (as available) to
provide as complete an indication as possible of the State's radon exposure problem. EPA recognizes that
some States do not yet have adequate information on the seriousness or extent of radon exposure in their
jurisdiction. Such States should address this need in the activities proposed for funding. States with mature
programs should augment preliminary findings with results of statistically valid surveys of residences, schools
or public buildings, and areas of potentially high radon exposure. Second-year grant applicants should provide
description updates, based on information collected during the first grant year.
Lead Agency
The statement should contain the name of the State agency that has primary responsibility for radon
programs and will receive the grant, plus a description of the roles and responsibilities of the lead State agency
and any other State agencies, or municipal, district, or areawide organizations involved in radon programs.
Again, as long as the Lead Agency has not been changed, applicants in the second year of the S1RG program
only need to indicate that the first-year information is still valid, rather than provide new information.
Work Plan
The State should provide a description of the activities and projects related to radon that the State
proposes to undertake during the proposed budget year (i.e., a work plan). The work plan should highlight
major milestones planned for the proposed budget year and present a schedule for their accomplishment.
Each activity in the work plan should be accompanied by a detailed cost breakout which agrees with the
summary figures represented in Part III of the SF-424. All activities proposed for funding should be presented in
order of priority in accordance with the criteria discussed in Section 1.4. EPA will consider these priority rankings
when making award decisions, especially if the amount of funds requested by eligible applicants exceeds the
amount of funds available for award.
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Budget
Pan III of the SF-424 contains the summary budget figures, including the minimum State share
of the total project costs (or 25% for first-year grant applicants), which must agree with the detailed cost
breakout provided in the work plan. In addition, this section should show how the State's expenditures meet
the statutory budget limitations for program overhead and administration (no more than 25% of the Federal
funds) and for radon measurement devices and demonstration projects (in the aggregate, no more than 50%
of the Federal funds).
Three-Year Plan
The central element of the narrative statement is the State's three-year plan for radon program
development or expansion. The plan should outline long-range program goals and objectives, tasks necessary
to achieve them, and resource requirements for the entire three-year period, including anticipated State
funding levels and desired Federal funding levels. Information concerning all of the State's radon-related
efforts should be included so that EPA can evaluate the application in the context of the State's entire radon
program, rather than just the activities proposed for funding under the grants.
This statutory provision applies only to the initial year in which a grant application is made. However,
States in the second year of the grant program should provide an update of the three-year plan in the second
year that they apply for Federal financial assistance.
First-year grant applicants may use the sample format provided in Exhibit 5-1 on the following page for
developing the required three-year plan. The sample format allows applicants to prepare four one-page
descriptions, each corresponding to one of the four functional program areas discussed in Section 2.1.
Applicants may choose to use their own format; however, all three-year plans should address the following
elements: problem statement(s), objectives, proposed activities (including total anticipated funding), total State
funding (including SIRG State match and any other State funds spent on radon programs), and a narrative
summary (showing how activities support the objectives, and the role of other State and local agencies).
In short, the three-year plan should provide EPA with an overview of the radon program the State intends
to develop (or expand) during the years for which Federal funding is authorized and beyond. Howenr,
acceptance of the three-year plan does not obligate EPA to provide Federal funding in the succeeding years.
5,2.2 Debarment and Suspension Form
The applicant must include EPA Form 5700-49, the Certification Regarding Debarment, Suspension, and
Other Responsibility Matters. This form certifies that the applicant currently is not ineligible for assistance
due to a disbarment, suspension, or other infraction.
5.2.3 Certification Letter
A letter from the State Governor or Attorney General is required to certify that the lead State Agency
has the legal and administrative authority to enter into a grant with EPA. If such a letter is already on Gle
with the EPA Regional Office, as is the case for all States in the second year of the grant program, then a
letter does not have to be re-submitted with the second-year application, as long as there has been no change
in the State's program. However, some of the Regional Grants Offices require States in the second year of
the SIRG program to submit a letter attesting to the validity of the initial certification letter.
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EXHIBIT 5-1 SAMPLE FORMAT
Three Year Radon Program Plan
:
Functional Program Area:
Problem Statement-
Objectives:
Proposed Activities
TOTALS
1991
TOTAL $
1992
TOTAL $
1993
TOTAL $
Total State Funding
Summary:
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EXHIBIT 5-1 Instructions for Three Year Plan Sample Format
Information concerning all of the State's radon-related efforts should be included so that EPA
can evaluate the application in the context of the State's entire radon program, rather than just
the activities proposed for funding under the grants.
Functional Program Area: Complete a separate page for each of the four program areas:
Program Management, Public Information, Problem Assessment,
and Problem Response.
Problem Statement: Provide a coherent statement of the problem that you plan to address by
the activities proposed in the functional area. It is conceivable that, for
some program areas, more than one problem will be specified.
Objectives: Identify the goals you hope to achieve by the end of the three year period. The
objectives should be concrete and specific, and should relate closely to the problem
statement identified in the previous section.
Proposed Activities: Show the major activities you plan to undertake for the relevent functional
program area, and the total dollar amount you expect to spend on each
activity (including SIRG funds).
Total State Funding: Show the dollar amount of State funds you expect to spend (including
SIRG State match and any other State funds spent on radon programs).
Summary: Show how the proposed activities support your objectives, and explain the role of
other State and local agencies in conducting these activities.
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5.2.4 Intergovernmental Review Comments
All applications for Federal assistance under the Radon State Grants Program are eligible for
intergovernmental review under Executive Order (E.O.) 12372. Applicants must contact their State's Single
Point of Contact (SPOC) for intergovernmental review as early as possible to find out if their applications for
the SIRG program are subject to their State's official E.O. 12372 review process. If subject to their State's
E.O. 12372 review process, then the applicant must submit their application or any other material required
by their State to their SPOC for review. SPOCs should send their official intergovernmental review comments
on an application to the appropriate EPA Regional Office no later than 60 days after the receipt of the
application/other required material for review.
The State must specify, if applicable, what date the State submitted their application to their SPOC for
review.
5.2.5 Quality Assurance Plan
In addition to these statutory information requirements, regulations applicable to Federal assistance
programs require grantees to establish quality assurance (QA) policies and procedures if the grantee's project
involves environmentally-related measurements or data generation (40 CFR Section 31.45). If a State proposes
to include radon measurement activities for funding under the grant, then the applicant must include either
a QA plan or a schedule to develop a QA plan. The QA plan must be approved by EPA before any
measurement activity begins. EPA's "Interim Guidelines - Specifications for preparing Quality Assurance
Project Plans" (QAMS-005/80, EPA600/4-83-004) applies to the State Indoor Radon Grants Program. The
QA plan may be included as part of the applicant's narrative statement.
Exhibit 5-2 Sample SIRG Application
A sample application is presented on the following pages. The Standard Form 424 sheets have been
completed as an example. A checklist for both the application attachments and the Statement of Work has
been included.
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-X.-jILj.'! 5-2 Sample SIXG
APPLICATION FOB
FEDERAL ASSISTANCE
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program for the assessment and
mitigation of radon
Stan 0*1*
01-15-91
01-14-92
24
Statewide
130,000
86,667
10
«
tun raomwi OMOW inn
November 7, 1990
0»TI.
Nad
NOTOOMV
HMNOTI
TOTAL
C3N.
216,667
M «1
Harriet Martin
Executive Director
(703) 558-1500
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Not*:
As
ASSURANCES NON-CONSTRUCTION PROGRAMS
Certain of these aaturancts may not be applicable to your project or program. If you have question*
please contact tht awarding agw Furthtr, certain Federal »w*rdinf agencies may require artteante
to certify to additional assurances. If such it tht case, you will bt itotifitd ^ *Ppi»eante
ttv July authorised representative of the applicant C certify that tht applicant;
2
4.
{{as (he legal authority to apply for Federal
assistance, and the institutional, managerial and
tinancial capability (including funds sufficient to
pay the non-Federal share of project costs) to
ensuie proper planning, management and com-
pletion of the project described in this application.
'-Vni give the awarding agency, the Comptroller
O*r;t:ral of the United States, and if appropriate,
in* 5?at*. through any authorised representative.
ro and the right to examine all records.
u»-er«. or documents related to the award;
*.u establish a proper accounting system in
Krer dance with generally accepted accounting
ftaridbHs or agency directives.
Will establish safeguards to prohibit employees
t-jrri usmg their positions for a purpose that
om*Mutes or presents the appearance of personal
o>- organizational conflict of interest, or personal
Will initiate and complete tht work within the
applicable time frame after receipt of approval of
»ne awarding agency.
^ ill comply with the Intergovernmental
Personnel Act of 1970 (42 U.S.C. If 4728-4763)
relating to prescribed standards for merit systems
for programs funded under on* of the nineteen
statutes or regulations specified in Appendix A of
C'PM's Standards for a Merit System of Personnel
Administration (5 C F.R. 900, Subpart F).
Will comply with all Federal statutes relating to
nondiscrimination. Thesa include but art not
Umited to (a) Title VI of tht Civil Rifhta Act of
1964 (PL. 66-362) which prohibits diatrimination
on tht basis of net, color or national origin; (b)
Titlt IX of tht Sducatton Aatodmtnts of 197*, as
amended (20 U.&C. H 168M683. and 1686-1666),
which prohibit diarriminattoii on tht basil of sex;
(c) Section 504 of tht Rehabilitation Act of 1973, aa
amended (29 U.S.C. | 794), which prohibits dis-
crtminatioji on tht basis of handkapt; (d) tht Aft
Discrimination Act tf 1978, aa amtadtd (42
L* S C H 6101-8107). whkh prohibits discrim-
ination on tht basis of aft;
(e)the Drug Abuse Office and Treatment Act of
1972 (P.L. 92-255), as amended, relating to
nondiscrimination on the basis of drug abuse; (f>
tht Comprehensive Alcohol Abuse and Alcoholism
Prevention, Treatment and Rehabilitation Act of
1970 (P.L. 91-616). as amended, relating to
nondiscrimination on the basis of alcohol abuse or
alcoholism; (g) ft 523 and 527 of tht Public Health
Service Act of 1912 (42 U S C 290 dd-3 and 290 ee-
3), as amended, relating to confidentiality of
alcohol and drug abuse patient records; (h) Title
VIII of the Civil Rights Act of 1968 (42 U S C I
3601 et seq.). as amended, relating to non-
discrimination in tht salt, rental or financing of
housing; (i) any other nondiscrimination
provisions in tht specific statutes) under which
application for Federal assistance is being made;
and (j) the requirements of any other
nondiscrimination statutes) which may Apply to
tht application.
Will comply, or has already complied, with the
requirements of Titles IE and III of tht Uniform
Rtlocation Assistanct and Rtal Proptrty
Acquisition Policies Act of 1970 (P.L. 91-646)
which providt for (air and equitable treatment of
persons displaced or whose property is acquired as
a result of Federal or federally assisted programs.
These requirements apply to all interests in real
property acquired for project purposes regardless
of Federal participation in purchases.
Will comply with tht provisions of tht Hatch Act
(S U.S.C. II1501-1506 and 7324-7328) which Unit
tht political actiritits tf tnployees whtst
principal tmptoymtnt activities art funded in
whole tr in part with Federal funds
Will comply, as applicable, with tht provisions of
tht Davis-Baton Act (40 U S C II 276a to 276a-
7), tht Copeland Act (40 U.SC. I 276r and 18
USC || 874). and tht Contract Work Hours and
Safety Standards Act (40 U.S C. II 327-333),
regarding labor standards for federally assisted
«2
I Cmutti *-««!
Auwiortet* lor Local Rtyodurton
42
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10. Will comply, if applicable, with flood insurance
purchase requirements of Section 102(a) of tht
Flood Disaster Protection Act of 1973 (P L. 93-234)
which requires recipients in special flood hasard
area to participate in the program andto purchase
flood insurance if the total cost of insurable
construction and acquisition is 110,000 or more.
11 Will comply with environmental standards which
may be prescribed pursuant to the following: (a)
institution of environmental quality control
measures under the National Environmental
Policy Act of 1969 (PL. 91-190) and Eiecutive
Order (EO) 11514; (b) notification of violating
facilities pursuant to EO 11738; protection of
wetlands pursuant to EO 11990; (d) evaluation of
flood hazards in floodptains in accordance with EO
11988, («) tssurance of project consistency with
the appr.ved State management program
developed under the Coastal Zone Management
Act of 1972 (16 t'SC ft 1451 et seq ); (0
conformity of Federal actions to State (Clear Air)
Implementation Plans under Section 176(c) of the
Clear Air Act of 1955, as amended (42 USC I
7401 et seq.); (g) protection of underground sources
of drinking water under tht Safe Drinking Water
Act of 1974, as amended. (PL. 93-523). and (h)
protection of endangered species under the
Endangered Species Act of 1973. as amended, (P.L.
93-2051
12. Will comply with the Wild and Scenic Rivers Act
of 1968 (16 L'.S.C. ii 1271 et seq.) related to
protecting components or potential components of
the national wild and scenic riven system.
13. Will assist the awarding agency in assuring
compliance with Section 104 of the National
Historic Preservation Act of 1966. as amended (16
USC 470), EO 11593 (identification and
protection of historic properties), and the
Archaeological and Historic Preservation Act of
1974 (16 U S.C 469a-t et seq.).
14. Will comply with PL 93-348 regarding the
protection of human subjects involved in research.
development, and related activities supported by
this award of assistance.
15. Will comply with the Laboratory Animal Welfare
Act of 1988 (P.L. 89*544. as amended. 7 USC
2131 et seq.) pertaining to the cut. handling, and
treatment of warm blooded animals held for
research, teaching, or other activities supported by
this award of assistance.
16. Will comply with the Lead Based Paint Poisoning
Prevention Act (42 U S.C II 4801 et seq.) which
prohibits the use of lead based paint ia
construction or rehabilitation of residence
structures.
17. Will CHUM to be performed the required ftnaneiaJ
and compliance audits in accordance) withr the)
Single Audit Act of 1984.
18. Will comply with all applicable requirements of all
other Federal laws, executive orders, regulations
and policies governing this program.
i.GNATufti Of AumoaaoairrwYwa 0*110*1
TITU
OATtSUtttTTIO
43
SP «« <«*>
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EXHIBIT 5-2
Sample Application
APPLICATION CHECKLIST
Standard Form 424
I I Part I - General Information
I 1 Part II - Budget Information
I I Part III - Assurances and Certification
Application Attachments
I I 1) Statement of Work
| I 2) Assurances - Non-Construction Programs (SF 424B)
j I 3) Debarmenl and Suspension Certification
I 4) Certification Letter from State Governor (Check with Region)
I I 5) Intergovernmental Review Comments, if appropriate
I j 6) Quality Assurance Project Plan, or assurance
7) Drug-Free Workplace Certification
8) Certification Regarding Lobbying for awards over $100,000 (can be
submitted as a condition of award)
44
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EXHIBIT 5-2
Sample Application
STATEMENT OF WORK CHECKLIST
A description of the seriousness and extent of the radon exposure in the State
2)
An identification of the State agency which has the primary responsibility for radon
programs and which will receive the grant
.
A description of the roles and responsibilities of the lead State agency and any
other State agencies or any municipal, district, or areawide organization involved in
the radon programs
CD 4).
A description of the activities and programs related to radon for which the State
proposes in such year (the workplan), with detailed cost breakouts
5)
A budget showing how the State intends to meet the required 40% match (or 25%
for first-year grant applicants), and how the State's expenditures meet the statutory
budget limitations
6)
A three-year plan outlining long range program goals and objectives, tasks
necessary to achieve them, and resource requirements for the entire 3-year period,
including anticipated State funding levels and desired Federal funding levels
45
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Chapter 6: GRANTEE REQUIREMENTS
This chapter describes the post-award requirements a grantee must follow during the life of the grant,
and briefly describes the regulations which are applicable to the SIRG program.
6.1 Regulatory Requirements
EPA regulations that govern Stale activities under the SIRG Program are contained in the following
Parts of 40 CFR:
Part 4 - Implementation of the Uniform Relocation Assistance and Real Property Acquisition
Policies Act of 1980
Part 7 - Nondiscrimination in Programs Receiving Federal Assistance from the Environmental
Protection Agency
Part 29 - Intergovernmental Review of Environmental Protection Agency Programs and Activities
Part 31 - Uniform Administrative Requirements for Grants and Cooperative Agreements to State
and Local Governments
P Part 32 - Debarment and Suspension Under EPA Assistance Programs
Applicable OMB Circulars include Circular A-87, "Cost Principles for State and Local Governments";
Circular A-128, "Single Audit Act"; and Circular A-102, "Uniform Requirements for Assistance to State and
Local Governments.'1 Copies of some of these documents will be included in the State Indoor Radon Grant
application packages provided to eligible applicants at the start of the application period. The others may be
obtained by contacting the Regional Grants Management Office personnel listed in Appendix B.
6.2 Reporting Requirements
Grantees are required to submit three main categories of reports to EPA: general assistance reports,
progress reports, and SIRG data reports. Guidance for preparing each of these reports is provided in separate
sections below.
6.2.1 General Assistance Reports (40 CFR Part 31)
As discussed in Section 2.4 of this Guidance, States that receive Radon Grants must comply with the
information provision requirements of section 306(h) of the IRAA, In addition, Radon Grant recipients also
are subject to the reporting requirements specified in 40 CFR Part 31. This regulation requires grantees to
prepare and submit regular, timely and comprehensive reports on the activities funded by the grant. The
reports provide EPA with the information it needs to ensure that each State is meeting the schedule and
commitments in its assistance agreement. More importantly, they provide a mechanism for evaluating the
environmental progress brought about by the SIRG Program, and for reporting to Congress on this progress.
Reporting schedules and submittal dates are to be specified in the individual assistance agreements, and each
State will be expected to adhere to its agreed-upon schedule.
The types of reports that grant recipients must provide to EPA are listed below. The required contents
of these reports are discussed in Part 31.
46
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Annual, semiannual , or quarterly performance reports (the frequency of submission will be
determined by the Region)
. Financial Status Report (Standard Form 269)
Federal Cash Transactions Report (for grants paid by letter of credit)
Request for Advance or Reimbursement (Standard Form 270, if applicable)
Minority Business Enterprises/Women's Business Enterprises (MBE/WBE) Reports (Standard Form
334)
Disclosure of Lobbying Activities (SF-LLL)
6.2.2 Progress Reports
Radon grant recipients are required to submit quarterly progress reports to the EPA Regional Office.
The quarterly period starts the date the grants are signed, and the reports are due in the last month of the
quarter. The quarterly reports do not have to be extremely detailed, but they must follow a standard format.
The format includes the following five sections:
(1) Summary of Quarterly Radon Grant Activities. This section will provide a short summary of the
grant activities that have taken place during the quarter.
(2) Accomplishments/Problems. This section will discuss the progress to date, including the major
milestones that have been met. This section will also discuss any problems that have occurred or
are expected and what steps are planned to resolve those problems.
(3) Schedules. This section will compare the completed milestones against the program schedule and
provide an explanation of any discrepancies.
(4) Funds. This section will compare the funds spent during the quarter against the planned
expenditures and provide an explanation of any discrepancies.
(5) Estimates. Section 5 will provide estimates of the time and funds necessary to complete the project
and compare these to the time and funds remaining. The difference between Sections 3 and 4 and
5 is that Sections 3 and 4 mainly look back on the quarter, while Section 5 looks ahead to the rest
of the grant period.
The Agency has developed an "ideal" list of data elements that it expects to be available from either the
grant applications, the SIRG progress reports, and other information sources. This list is provided as
Appendix F of this guidance.
6.2.3 SIRG Data Reports
IRAA Section 306(h) requires that any State receiving grant funds provide to EPA all radon-related
information generated in its activities, including the results of radon surveys, mitigation demonstration
projects, and risk communication studies. Section 306(h) also authorizes the Agency to request any
information, data, and reports developed by the State that EPA needs to ensure the State's continued eligibility
for grant assistance. For example, EPA may request data on the number of homes tested or mitigated within
47
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a Stale as well as any other environmental measures that can be used as long-term indicators of success. See
Appendix D for a standard format that can be used to report radon measurement data to EPA. Reporting
requested will he consisicnt with State and Federal confidentiality requirements, and with the Agency's policy
on Performanced-Based Assistance. Applicants should consult with their EPA Regional SIRG contacts for
specific guidance on data requirements.
6.3 Budget Tracking
The State must be able to track its expenditures to determine compliance with the statutory budget
limitations for program overhead and administration (no more than 25% of the Federal funds) and for radon
measurement devices and demonstration projects (in the aggregate, no more than 50% of the Federal funds).
These limitations are discussed in detail in Section 3.7.
6.4 Audit/Audit Resolution
OMB Circular A-128 implements the Single Audit Act of 1984 and outlines requirements which State
agencies must follow. The Circular contains the following thresholds for conducting audits:
If the recipient receives 5100,000 or more in Federal financial assistance, they shall have an audit
made in accordance with OMB Circular A-128;
If the recipient receives between $25,000 and $100,000, they shall have an audit based on the
Circular, or in accordance with Federal laws and regulations governing the programs they participate
in; or
If the recipient receives less than $25,000 a year, they shall be exempt from compliance with the Act
and other Federal Audit requirements, yet shall follow audit requirements stated in State or local
law or regulations.
Audits shall be made annually unless the State had, by January 1, 1987, a constitutional or statutory
requirement for less frequent audits. The Single Audit Act requires that an independent auditor evaluate
internal control systems used in administering Federal assistance programs and to assign a cognizant agency
to oversee the implementation of the OMB Circular A-128.
If EPA conducts an audit, a copy of the final audit report is sent to the auditee within 15 days of the
report date. The auditee has 45 days to evaluate the report and any "questioned costs" (costs the auditor does
not think are applicable Federal expenses). The auditee can rebut portions of the report. The rebuttals and
the report are sent to the Divisional Inspector General for Audit (DIGA) to either concur or disagree with
the findings. If DIGA agrees with the findings in the report, accepts the reasoning of the rebuttal, or deems
the differences insignificant, DIGA will then notify the Action Official within 15 days of receipt of the
document. If DIGA significantly disagrees with the Action Official, he will try to resolve the disagreements
with the Action Official within 15 days of receipt of the document. If unresolved within 15 days, DIGA will
notify the Office of Inspector General for Audits (OIGA), who will review the DIGA referral. Jf the
disagreement is still unresolved within 45 days of receipt, OIGA will refer the issue to the Audit Resolution
Board (ARB) who will decide within 30 days of referral. (See Management of EPA Audit Reports and
Fj>llow-up Action - 2750V
48
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6.5 Performance Evaluation
The Policy on Performance-Based Assistance, issued by the EPA Administrator on May 31, 1985, also
applies to the State Indoor Radon Grants Program. This policy provides a set of guidelines to help EPA and
the States clarify expectations and solve problems related to the assistance agreement. Copies of this policy
document may be obtained from the Regional Grants Management Office.
At the onset of the assistance agreement, an EPA Project Officer will be assigned to monitor the progress
and performance of each State that receives a grant. The Project Officer will be the State's primary point of
contact with EPA for matters related to the assistance agreement. Section 306 (i)(l) of the IRAA specifies
that States awarded grants in a Federal fiscal year may not receive grant money in the following Federal fiscal
year unless they have ..."satisfactorily implemented the activities funded by the grant in [the] preceding fiscal
year." States will be expected to provide, upon request, evidence or information verifying that their programs
are on schedule and that planned milestones have been achieved.
The EPA Project Officer and other personnel also may conduct periodic site visits to States to inspect
program activities first-hand, consistent with program needs. (Regions are currently required to conduct on-
site mid-year reviews.) Recipients will be notified well in advance of such visits concerning probable discussion
topics and materials they may be requested to prepare. Potential items of concern to EPA personnel during
site visits include, but are not limited to:
Indicators of the program's success (or failure)
Actual versus scheduled performance/accomplishments
Condition of equipment/property used within, or purchased for, the program
Whether resources (personnel, equipment, facilities, etc.) charged to the Program budget are actually
employed for the program
Conditions that might adversely affect EPA's interest (e.g., a change in the recipient's financial
status, personnel problems, non-compliance with labor/civil rights laws or over-extension of
facilities).
In the course of their responsibilities, Project Officers may recommend changes or may require the State
to take corrective actions to resolve problems or issues of contention. Project Officers also rely upon and
maintain close contact with Regional Grants Management Offices, the Offices of Regional Counsel, Financial
Management Offices and other support units within the Agency. Recipients should refer to the Project Officer
for assistance with matters related to any aspect of performance under the assistance agreement.
Disagreements between EPA and a State concerning an assistance agreement requirement should be
resolved at the lowest level possible. EPA policy on Performanced Based Grant Assistance delineates
procedures for taking corrective actions. If agreement cannot be reached through other means, the dispute
will be resolved in accordance with procedures set forth in 40 CFR Part 31, Subpart F. The Project Officer
should coordinate with the Grants Management and/or Regional Counsel personnel if needed.
Applicants should keep in mind that subsection 306(i) of the IRAA stipulates that no grant may be
awarded to a State in a Federal fiscal year unless EPA has determined that the State satisfactorily implemented
the activities funded by the grant in the previous year. In accordance with this provision, the Agency will pay
close attention to each recipient's use of SIRG funds.
49
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APPENDIX A
Legislation - SIRG Guidance Crosswalk
Legislation
ntAAPnrinon
SIRG Guidance
306(a) In General
306(b) Application
306(c) Eligible Activities
306(d) Preference to
Certain States
306(e) Priority Activities
and Projects
306(0 Federal Share
306(g) Assistance to Local
Governments
306(h) Information
306X0 Limitations
3060) Autborizatk
IO
1.1 Authority
5.2.1 Statement of Work
15 Eligible Activities
4.6.2 Grant Award Preference
for Second Grant Year
1.4 Priority Activities
and Projects
3.5 State Match
3.4 Assistance to Local
Governments
14 Required Activities
6.12 SIRG Data Reports
3.7 T
3.1 Authorization
A-l
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APPENDIX B
REGIONAL STATE INDOOR RADON GRANT CONTACTS
Note to reviewers: this list needs to be updated further
SIRG Program Contacts
Maria van der Werff
U.S. EPA Region I (ATR-118)
JFK Federal Building
Boston, MA 02203
FTS: 8-835-4502
ODD: (617)-565-4502
Michael Miller
U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202-2733
FTS: 8-255-7223
DDD: (214)-655-7223
Larainne Koehler
U.S. EPA Region II
26 Federal Plaza
New York, NY 10278
FTS: 8-264-0546
DDD: (2l2)-264-4118
Bob Dye
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
FTS: 8-276-7605
DDD: (913)-551-7605
Aquanetta Dickens
U.S. EPA Region III
841 Chestnut Street
Philadelphia, PA 19107
FTS: 8-597-9303
DDD: (215)-597-8320
Denise Scheberle
U.S. EPA Region VIII
999 18th Street, Suite 500
Denver, CO 80202-2405
FTS: 8-330-7682
DDD: (303)-294-7682
Paul Wagner
U.S. EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365
FTS: 8-257-3907
DDD: (404)-347-3907
Mike Bandrowski
U.S. EPA Region IX
1235 Mission Street
San Francisco, CA 94103
FTS: 8-454-8378
DDD: (415J-556-5633
Patricia A.J. York
U.S. EPA Region V
230 South Dearborn Street
Chicago, IL 60604
FTS: 8-886-6035
DDD: (312) 886-7935
Misha Vakoc
U.S. EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
FTS: 8-399-7660
DDD: (206)-442-7299
B-l
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Regional Grants Management Office Contacts
Henry Burrell, Chief
Grants Information Management Section
U.S. EPA Region I
JFK Federal Building
Boston, MA 02203
FTS: 8-835-3839
DDD: (617)-565-3S39
Linda Thompson, Chief
Grants and Audits Section
U.S. EPA Region VI; 6MPG
1445 Ross Avenue
Dallas, TX 75202-2733
FTS: 8-255-6530
DDD: (214)-655-6530
Dennis Debrowski, Chief
Grants Administration Branch
U.S. EPA Region II; 2MGT
26 Federal Plaza
New York, NY 10278
FTS: 8-264-9860
DDD: (212)-264-9860
Carol Rompage, Chief
Grants Administration Section
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
FTS: 8-276-7346
DDD: (9l3)-236-2800
Fred Warren, Chief
Grants Management Section
U.S. EPA Region III
841 Chestnut Street
Philadelphia, PA 19107
FTS: 8-597-6166
DDD: (215)-597-6166
Martha Nicodemus, Chief
Grants Management Branch
U.S. EPA Region VIII; 8PMGM
999 18th Street, Suite 500
Denver, CO 80202-2405
FTS: 8-330-1730
DDD: (303)-293-1603
Ed Springer, Chief
Grants Administration Unit
U.S. EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365
FTS: 8-257-7292
DDD: (404)-347-7292
Melinda Taplin, Chief
Grants Management Section
U.S. EPA Region IX; P-2-2
1235 Mission Street
San Francisco, CA 94103
FTS: 8-484-1626
DDD: (415)-744-1626
Tom Jackson, Chief
Grants Management Section
U.S. EPA Region V; 5MFG-14
230 South Dearborn Street
Chicago, IL 60604
FTS: 8-886-7523
DDD: (312)-886-7523
Arv Aurdal, Chief
Grants Administration Section
U.S. EPA Region X; MD-100
1200 Sixth Avenue
Seattle, WA 98101
FTS: 8*399-2930
DDD: (206)-442-2930
B-2
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APPENDIX C
GUIDE TO PREPARING OBJECT
CLASS CATEGORY BUDGET DETAIL
The Standard Form (SF) 424A, Section B - Budget Categories, should be supported in at least the level of
detail described below.
When there is a match or cost-sharing requirement, the provisions of 40 CFR 31.24 must be met. All in-kind
contributions used to meet or match cost-sharing requirements shall be fully documented, and must comply
fully with 40 CFR 31.24.
Allowability of all costs are governed by applicable cost principles set forth in 40 CFR 31.22.
Personnel - Line 6a: Identify each type of staff position by job title and the number of employees in each type
of staff position. Enter the annual salary for each type of staff position, percentage of time assigned to the
project and total cost for the budget period. Do not include costs of consultants or personnel costs of
subcategories or subcontractors.
Fringe Benefits - Line 6b: Enter the total cost of fringe benefits unless treated as part of an approved indirect
cost rate. Provide break-down of amounts and percentages that comprised fringe benefits costs, such as health
insurance, F.I.C.A., retirement insurance, etc.
Travel - Line 6c: Identify the number and purpose of trips for program activities, e.g., inspection, monitoring,
enforcement, etc., and administrative activities; e.g., attendance at specific conferences, meetings, training, etc.
Specify the cost of each activity and the basis for determining the cost. For example, list the number of trips
and average cost per trip based on last year's data or specify the location, duration and estimated cost of
attending an annual conference, based on air fare and applicant per diem rates. Enter the total cost for travel.
Equipment - Line 6d: Identify each item of equipment to be purchased which has an estimated acquisition
cost of $5,000 or more per unit and a useful life of more than one year. An applicant may use its own
definition of equipment provided that such definition would at least include all equipment defined above.
Enter individual, as well as total cost for equipment.
No equipment may be purchased without the expressed approval of U.S. EPA. The assistance agreement shall
indicate the total approved amount of the agreement which may be expended for equipment. Any equipment
purchases proposed after award must be approved by U.S. EPA in writing.
If equipment purchased wholly or partially with assistance agreement funds is to be used on more than one
project/program, acquisition costs or usage fees must be approved and allocated properly.
Supplies - Line 6e: List all tangible personal property other than "equipment" as defined above. The budget
detail should be as descriptive as possible. Categories of supplies to be procured; e.g., laboratory supplies or
office supplies, are acceptable if items cannot be reasonably separated. Enter individual, as well as, total cost
of supplies.
Contractual - Line 6f: Identify each proposed contract and specify its purpose, nature, period of performance
and estimated cost. Do not include procurement contracts which are reflected in other object class categories
such as equipment, supplies, etc. If funds allocated to this object class category include proposed expenditures
not usually categorized as services to be procured at the market place, explanatory footnotes must be included.
Enter total cost for contracts.
C-l
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Construction - Line 6g: Construction costs are generally not allowable in non-construction assistance
programs. U.S. EPA will provide additional guidance upon request.
Other - Line 6h: List each item of cost in sufficient detail for U.S. EPA to determine its reasonableness and
allowability. Such costs, where applicable, may include, but are not limited to, insurance, space rental,
equipment rental, printing, publication, computer use, training fees, utilities, telephone, as well as any cost an
applicant customarily identifies as other cost. Enter individual, as well as, total cost for other.
Total Direct Charges - Line 6i: Show the totals of Lines 6a through 6h.
Indirect Charges - Line 6j: Enter the total amount of indirect costs. If indirect charges are budgeted, indicate
the approved rate and its base on line 22 of Section F - Other Budget Information (SF 424A). It is important
to note that when indirect costs are budgeted, those costs included in the indirect cost pool cannot also be
charged as direct costs to the assistance agreement. Finally, include a copy of your current indirect cost
agreement which reflects the approved rates.
C-2
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BUDGET WORKSHEET EXAMPLE
OBJECT CLASS CATEGORY BUDGET DETAIL SUMMARY
6.a
6b.
6c.
$30,000
24,000
20,000
40,000
x
X
X
X
100
25
75
5
-
=
ss
=
$30,000
6,000
15,000
2,000
Personnel Salary Percent
Environmental Scientist I
Public Information Spclst.
Administrative/Clerical II
Supervisor Environ. Scientist
TOTAL PERSONNEL
Fringe Benefits (examples) -- include only if not covered under indirect cost rate
PICA Social Security
Total
Life Insurance
Retirement
Health/Dental Ins.
Disabilitv Ins.
7,56% x TOTAL PERSONNEL
(0.756 X 53,000.00)
0.88% x TOTAL PERSONNEL
11.58% x TOTAL PERSONNEL
8.58% x TOTAL PERSONNEL
0.81% x TOTAL PERSONNEL
TOTAL FRINGE BENEFITS
(These percentages are available from the personnel office.)
Travel
Public Education:
24 trips within the Slate to provide radon information to the general public.
Transportation costs = S480.00
Average trip distance is 100 miles at mileage rate of S0.20/mile.
Per diem (including lodging) = $3,600.00
Based upon a per diem rate of $75.00 per day for an average two day trip.
Incidental expenses = S480.00
Based upon an average cost of $10.00 per day.
TOTAL = 54,560.00
Radon Training Seminars:
6 trips to provide radon, training to local experts/schools/safety engineers.
Transportation costs = $120.00
Average trip distance of 100 miles at state mileage rate of $0.20.
Per diem (including lodging) = $1350.00
Based upon a per diem rate of $75.00 for an average three day trip.
Incidental expenses = $180.00
Based upon an average costs of $10.00 per day for unexpected associated costs.
TOTAL = $1,650.00
$53,000
$ 4,006.80
466.40
6,137.40
4,547.40
429.30
15,587.30
C-3
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USEPA Regional Office:
6d.
1 trip to Regional Office for State Directors Meeting.
Air fare = $200.00
Per diem = $300.00
Based upon per diem rate of S 100.00 per day, and an average three day trip.
Incidental expenses = 530.00
Based upon an average cost of $10.00 per day.
TOTAL = S530.00
Internationa] Radon Symposium:
1 trip to New Utopia, UT for attendance at symposium and presentation of State radon innovative
project results.
Air fare = $400.00
Per diem = $450.00
Based upon per diem rate of $90.00 per day, and an average five day trip.
Incidental expenses - $50.00
Based upon an average cost of S10.00 per day.
TOTAL = $900.00
Midwest Universities Radon Consortium training:
1 trip to Interstate City to participate and train in the "Radon in Schools" training program.
Transportation = $20.00
Based upon a 100 mile trip at a mileage rate of $0,20 per mile.
Per diem = $375.00
Based upon a per diem rate of $75.00 per day and an average five day trip.
Incidental expenditures = $50.00
Based upon an average cost of $10.00 per day.
TOTAL = $445.00
TOTAL TRAVEL EXPENSES = $8,085.00
Equipment
1 Liquid scintillation system for alpha counting
1 programmable radon continuous monitor
$30,000.00
5,000.00
6e. Supplies
Personal Computer
CPU and Keyboard
Monitor (Color)
Printer (Laser)
Software
Database (dBase)
Spreadsheet (Lotus)
Optical Scanner (+Interface)
Modem
SUBTOTAL
TOTAL - $35,000.00
$2,200.00
400.00
2,000.00
600.00
400.00
1,400.00
200.00
7,200.00
C-4
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Micromanomeier (digital) = 300.00
E-perm system
Reader = $ 1,500.00
Electreis (50 short term at 15.00 each) = 75U.OO
(40 long term at 15.00 each) = 600.00
Shells (25 at S60.00 each) = 1,500.00
SUBTOTAL $ 4,350.00
Office supplies = $200.00
TOTAL SUPPLIES « 12,050.00
6f. Contractual
Interagency Agreement with State laboratory for radon analyses of 2,000 charcoal canisters from
August 1990 - March 1991 = $20,000.00
Purchase Agreement with private profit organization for the study of radon potential mapping in four
counties from July 1990 - June 1991 = $25,000.00
Interagency Agreement for public outreach program with local health department to raise public
awareness of local radon problem from July 1990 - June 1991 = 515,000.00
Interagency Agreement for national innovative project with State University to develop mode! code
adoption strategy from July 1990 - June 1991 = 512,000.00
TOTAL CONTRACTUAL EXPENSES = $72,000.00
6g. Construction None.
6h. Other
Postage to mail 5,000 radon brochures, x two mailings = $2,500.00
Print 15,000. four-page booklets on radon = $1,500.00
Reproduce the USEPA 30-minute Radon Measurement video for 100 public libraries = $1,000.00
Registration fee for MURC training in Interstate City for one employee = $150.00
Subscription for the Radon Industry Review for one year = $25.00
HVAC monitoring rental fee for two months = $500.00
Radon Equipment reference book = $80.00
(800) Hotline for 1 year = $12,000.00
TOTAL OTHER EXPENSES = $17,755.00
C-5
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APPENDIX D
STANDARDIZED DATA FIELDS FOR NATIONAL DATA BASE
EPA encourages States to track the number of buildings tested for radon and mitigated. These types
of environmental indicators can be used to evaluate the effectiveness of a State's radon program, as well as
the effectiveness of the overall national radon program.
As discussed in Section 2.4 of this guidance, all participants in the SIRG Program must comply with
the information provision requirements of Section 306(h) of IRAA. This section requires that any Stale
receiving grant funds provide to EPA all radon-related information generated in its activities, including the
results of radon surveys, mitigation demonstration projects, and risk communication studies. Through this
requirement, EPA is formatting State/EPA survey data to assemble the National Radon Data Base, which is
expected to be completed by the end of next year (fiscal year 1992). The format for entering measurement
data into the national data base is shown on the following pages. States should organize their ration
measurement data into this format and send a hard copy and electronic copy to EPA. EPA also plans to
develop a comparable format for mitigation data and will issue separate guidance for organizing and
transmitting measurement data in the future.
The data format that appears on the following pages is organized into four main columns:
The "name" column identifies the substance of the data to be included;
The "type" column indicates whether the data should be entered in the form of characteis (ie.,
letters), a logical yes/no response, or numbers (i.e., numeric);
The "width" column indicates how many letters or numbers should be provided for each data entry,
and
The "decimal" column shows how many digits after the decimal point should be provided. For
example, one decimal is specified for the radon concentration, so that an appropriate entry may be
10.4 pCi/1; an appropriate entry for the working level may be 2.089, which has a decimal field of
three.
Items in bold print are the most important and should be considered for prioritization if the money and time
are very limited. For more information on the National Data Base, contact Sharon Wirth, Problem
Assessment Branch, Radon Division, U.S. EPA, (202) 475-9605.
D-l
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1.
2.
3.
4.
5.
6.
7,
8.
9.
10.
11.
12.
13.
14.
DATA FORMATS
NAME
Test Number
Unique Test ID.
Concurrent Test?
Same information in another record?
Concurrent Test ID Number
Detector Type
CC, AT, EP, etc.
Detector Subtype
Allows differentiation within detector generic types
CC: O - Open Mesh
D - Diffusion Barrier
L - Liquid Scintillation
AT: M - Membrane
O Open Cup
Q - Quick Screen
EP: S - Short Term Type
L - Long Term Type
Start Date
Date YYMMDD
Start Time
Time HHMM
End Date
Date YYMMDD
End Time
Time HHMM
Radon Concentration (pCi/1)
Working Levels
Error
Building ID
Unique building designator
Geological Region
Assigned by USGS geologic Map
TYPE
Character
Logical
Character
Character
Character
Numeric
Character
Numeric
Character
Numeric
Numeric
Numeric
Character
Character
WIDTH
6
1
6
6
1
6
4
6
4
8
8
8
10
2
DECIMAL
1
3
3
D-2
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DATA FORMATS
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
NAME
Type of building
1 - Single Family
2 - Multi-Family
3 - Business
4 - School
5 - Other
Building Specification
If other, describe here
Basement, Crawl Space, Slab?
1 - Basement
2 Crawl Space
3 - Slab
4 - Other
Test Location Floor
0 - Basement
1 - First Floor
2 Second Floor and Above
Room Type
1 » Bedroom
2 - Family Room
3 Living Room
4 - Unfinished Basement
5 - Office
6 - Classroom
7 . Other
Room Specification
If other, describe here
Building Owner's Comments
Heat Distribution Type
A - Hot Air
W - Hot Water
R - Radiant
I - Individual Room Units
Building Site Location
If different from mailing address
City
County or Parish
FIPS county code
STATE
TYPE
Character
Character
Character
Numeric
Character
Character
Character
Character
Character
Character
Character
WIDTH
2
20
1
2
2
20
1
50
15
5
2
DECIMAL
D-3
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DATA FORMATS
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
NAME
Zip Code
Closed House?
N - Closed House
Y - Doors and Windows Open
Fireplace in use?
Yes or No
Air Conditioning in use?
Central Air System, Yes or No?
Weather Anomalies
Rainfall Amount
Inches during measurement period
Comments
By EPA or State
Entered by
Initials
Date Entered
Date YYMMDD
Verified by
Initials
Date Verified
Date YYMMDD
TYPE
Character
Character
Character
Character
Character
Numeric
Character
Character
Numeric
Character
Numeric
WIDTH
5
1
1
1
25
5
60
2
6
2
6
DECIMAL
D-4
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APPENDIX E
EXAMPLE APPLICATION OF THE INDIRECT COST RATE
In the following example, the Slate of Utopia has an indirect cost rate (ICR) of 40%, which is applied
to a "base" of direct salary and wages expenses charged to a gram.
State of Utopia
Grant Budget:
Direct Costs
Radon Detectors: $45,000
Salaries: $60,000
Public Info. Campaign: $20,000
Administrative Costs
ICR (40% of 560,000): 524,000
Personal Computer: $1,000
TOTAL PROJECT COSTS: $150,000
Federal Share: $112,500
State Share: $37,500
ADMINISTRATIVE: $25,000 (less than 25% of Federal dollar cap = $28,125)
EQUIPMENT/MIT DEMO: $45,000 (less than 50% of Federal dollar cap = $56,250)
Thus, although the State of Utopia has a 40% ICR, once the indirect costs are calculated on the basis
of direct salary and wage expenses, the State's total indirect costs fall under the 25% administrative cap (Which
is based on the Federal dollars). This allows the State to charge other administrative costs, up to the $28,125
limit, to the grant as well (in the example, the State charges $1,000 for a PC used for all of the activities under
the grant).
As shown in the example, radon measurement devices fall under the equipment/mitigation
demonstration cap. The general grant regulations (40 CFR Section 31.3) define equipment as 'tangible,
nonexpendable, personal property having a useful life of more than one year and an acquisition cost of $54)00
or more per unit." Supplies are defined as "all tangible personal property other than 'equipment'." Thus,
radon measurement devices fall under the general grant definition of "supplies." Nonetheless, the purchase
of these devices falls under the equipment/mitigation demonstration cap as specified by the statutorily
mandated limitations of certain eligible activities. The above example also shows that the purchase of a PC
is not subject to the equipment/mitigation cap, but it is subject to the administrative cap.
E-l
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APPENDIX F
Inclusive List of Data Elements for Tracking State Grants
The Agency has developed the following "ideal" list of data elements that EPA expects to be
available from either the grant applications, the SIRG progress reports, and other information sources
(internal STARS and Regional reports). This list was distributed to the SIRG Program Contacts earlier in
1990. The information sources that EPA expects to get (he information from is noted in the left column
as follows: GA - Grant Application, PR - Progress Report, and O - Other.
Information
Sources DataElements
I. Program Management
A. State Policy
HQ-GA 1. Goals (1990 and beyond)
HQ-GA 2. Strategy (1990 and beyond)
HA-GA 3. Documented policy (1990 and beyond) supporting testing and
mitigation?
HQ-PR 4. Adoption of model state certification program
B. State Legislation and Regulations
Indicate whether proposed or enacted:
HQ-PR.O 1. Establishment of State radon program
HQ-PR,O 2. Regulation of measurement and mitigation contractors
(example: registration/certification)
HQ-PR.O 3. School activities
HQ-PR,O 4. Buikline code changes
HQ-PR.O 5. Provision of tax incentives to reduce radon
HQ-PR.O 6. Disclosure of radon problems when transferring real estate
HQ-PR.O 7. Other
C. State Agencies
HQ-GA 1. Lead Agency
a. Name
b. Position on organization chart
c. Funding
d. Staff (FTEs) and role if given
Appropriated
Available
e. Role
HQ-GA 2. Other agencies
a. Name/role
b. Coordinated activities, linkages, task forces
F-l
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Information
Sources Data Elements
D. Assistance to Local Governments
HQ-PR 1. Number of local initiatives and proportion of State matching
from local funds
II. Public Information
A. Telephone Inquiries
HQ-PR,O 1. #/month (hotline, other)
HQ-PR.O 2. Existence of hotline (toll free and other)
HQ-PR.O 3. Presence and number of designated staff to handle inquiries
B. Outreach Activities
HQ-PR 1. Publications/resources
a. Titles
b. Medium (print, video, etc.)
c. Target population
low income?
high-risk groups?
local communities?
d. Developer (EPA, State, other)
e. Date developed, if by other than EPA
HQ-PR 2. Presentations given
HQ-PR 3. Activities targeting high-risk population
III. Problem Assessment
A. Testing and Research
HQ-PR.O 1. Survey and measurement activity
Info to be collected for each type of activity listed below:
target population
geographic area
sponsor
structure type (schools, homes, child-care centers, public
buildings, work place)
# tested
date of study
date findings published
HQ-O a. EPA/State survey
HQ-PR b. SIRG activity
R-O c. State (non-SIRG) activity
HQ-O d. EPA (non-SIRG) activity
2. Measurement assistance programs
HQ-GA,PR a. Type of program (i.e., home, school, work place)
b. # of low income persons or schools receiving assistance
c. Amount of assistance received
d. Other
3. Geology/Land evaluation
F-2
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Information
Sources
HQ-O
HQ-O
HQ-PR
R-PR
HQ-O
HQ-GA.PR
HQ-GA,PR
HQ-GA.PR
HQ-GA.PR
HA-GA
Data Elements
a. Mapping of high-risk areas?
b. Other?
4. Health risk studies
5. Follow-up activities in high-risk/low-income situations?
6. Number of structures tested annually before and during SIRG
B. State Measurement Capability
1.
2.
3.
4.
5.
Labs
Radon measurement equipment (Total of each type owned?
Purchased with SIRG dollars? Maintenance?)
Other analytical equipment (Purchase? Maintenance?)
Personnel
Use
HQ-GA
IV.
HQ-PR
HQ-PR
HQ-PR
HQ-GA,PR
HQ-GA.PR
C Data Management
1. Database developed/operational
a. Policy (confidentiality?)
b. Data included?
Use of private company data
Mitigation statistics
Measurement statistics
2. Computerized?
Problem Response
A. Measurement
1. Measurement company referrals
a. Existence/type of list (EPA/State)
b. Comments on use: available to public? number
referrals?
2. Follow up activities in high-risk/low-income situations
B. Mitigation
1. Mitigation company referrals
a. Existence/type of list (EPA/State)
b. Comment on use: available to public? number referrals?
2. Mitigation demonstration projects
a. Number of projects
b. Type of system
c. Measurements before and after
d. Cost of system
e. Cost of project
3. Mitigation assistance programs
a. Type of program (i.e., homes, schools, workplace)
b. Number of low income persons or schools receiving
assistance
F-3
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Information
Sources
Data Elements
HQ-PR
R-PR
HQ-GA.PR
HQ-GA.PR.O
HQ-GA.PR
c. Amount of assistance received
4. Follow up activities in high-risk/low-income situations
5. Number of structures mitigated annually before and during
SIRG
C. Training
1. Measurement (course, times offered, sponsor, number and type
of participants)
2, Mitigation (course, times offered, sponsor, number and type of
participants)
3. Other (course, times offered, sponsor, number and Type of
participants)
D. Consumer Protection Measures for Measurement and Mitigation
Contractors
HQ-GA
HQ-GA
HQ-GA
HQ-GA
HQ-PR
HQ-PR
HQ-GA
HQ-0
HQ-0
HQ-0
HQ-O
V. Other
A. Participation in SIRG
1. Number of participating states and territories for each grant
year
2. Geographic distribution of States and territories for each grant
year
3. Number and geographic distribution of States and territories
B. Innovative Projects
1. Number of innovative projects and type of project (program
management, public information, problem assessment, problem
response)
2. Nature of innovative projects (local initiative, targeted
population, child care, residences, other)
3. Plan for sharing innovative project was part of the approved
plan
4. How was information from innovative project disseminated?
5. Is there evidence the innovative project is being used in other
states?
6. Number and geographic distribution of states and territories
C. Appropriateness of Program to Radon Problem
1. Number of States in moderate risk area and number of States
with core programs
2. Number of States in other than moderate risk area and the
number of States with programs beyond the core
3. Evidence of plans of States without advanced programs to
expand their program based on data received during grant
period
D. Ad Council Polls/Calls
F-4
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Information
Sources Data Elements
E. Grant-Specific Information
HQ-GA 1. Dollar amount
a. Total project dollars
b. Federal dollars
c. State dollars
d. Program management dollars
e. Public information dollars
f. Problem assessment dollars
g. Problem response dollars
h. Innovative project dollars
HQ-GA 2. Agency
a. Name and address
b. Phone number
c. Contact
HQ-GA 3. Date of award
F-5
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