v>EPA
           United States
           Environmental Protection
           Agency
              Office of
              Radiation Programs
              Washington, D.C. 20460
EPA 520/1 -88-006
May 1988
           Radiation
Key Elements  of a
State Radon  Program

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      KEY ELEMENTS OF A
     STATE RADON PROGRAM
    Office of Radiation Programs
U.S.  Environmental Protection Agency
               and
  Conference of Radiation Control
         Program Directors
            July  1988

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                              ACKNOWLEDGMENTS
This report  was  prepared  by the  Environmental Protection  Agency  (EPA),  Office of
Radiation  Programs, in Washington,  D.C.  and  the  Conference  of  Radiation Control
Program  Directors  (CRCPD).   Jamie  Burnett  of the  Office of  Radiation  Programs
coordinated  this  project.    The  Conference  of  Radiation  Control  Program  Directors
Radon Policy  Committee and EPA regional offices reviewed the report  and provided
valuable suggestions.   Technical support was provided by  Putnam,  Hayes  & Bartlett,
Inc., Washington,  D.C.  20036.

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                                    CONTENTS
                                                                               Page

Figures	iv
Tables	iv

   1      EXECUTIVE SUMMARY	1-1
               1.1   Introduction	1-1
               1.2   Summary of  Key Elements	1-2
               1.3   Conclusions	1-7

   2      INTRODUCTION	2-1
               2.1   Purpose	2-1
               2.2   Summary of  Key Elements	2-3
               2.3   Review of the Radon Problem	2-6
               2.4   EPA Experience	2-9
                    2.4.1   Problem Assessment	2-10
                    2.4.2   Mitigation and Prevention	2-11
                    2.4.3   Capability Development.	2-11
                    2.4.4   Public Information.	2-12

   3      DESCRIPTION OF KEY ELEMENTS	3-1
               3.1   Public  Information	3-3
                    3.1.1   Activities	3-3
                    3.1.2   Policy Issues	3-8
                    3.1.3   Potentially Useful Existing Resources	3-10

               3.2   Goals and  Policies	3-11
                    3.2.1   Activities	3-11
                    3.2.2   Policy Issues	3-14
                    3.2.3   Potentially Useful Existing Resources	3-15

               3.3   Strategy	3-16
                    3.3.1   Activities	3-16
                    3.3.2   Policy Issues	3-18
                    3.3.3   Potentially Useful Existing Resources	3-20
                                         ii

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                                 CONTENTS
                                  (continued)

                                                                         Page
   3     DESCRIPTION OF KEY ELEMENTS (continued)
              3.4  Administration	3-21
                  3.4.1  Activities	3-21
                  3.4.2  Policy Issues	3-26
                  3.4.3  Potentially Useful Existing  Resources	3-27

              3.5  Problem Characterization	3-28
                  3.5.1  Activities	3-28
                  3.5.2  Policy Issues	3-33
                  3.5.3  Potentially Useful Existing  Resources	3-35

              3.6  Problem Response	3-36
                  3.6.1  Activities	3-36
                  3.6.2  Policy Issues	3-40
                  3.6.3  Potentially Useful Existing  Resources	3-43

   4     CONCLUSIONS   	4-1
APPENDIX A       CONFERENCE OF RADIATION CONTROL
                  PROGRAM DIRECTORS	A-1

APPENDIX B       U.S. EPA REGIONAL RADIATION  REPRESENTATIVES	B-1

APPENDIX C       EPA RADON PROGRAM CHRONOLOGY	C-1
                                      iii

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                              FIGURES AND TABLES

Figure                                                                        Page

  1*1     Summary of Key  Elements, Activities, Issues,
          and Resources	1-5

  2-1     Key Elements  of a State Radon  Program	2-4

  3-1     Public Information	3-4

  3-2     Goals and Policies	3-12

  3-3     Strategy	3-17

  3-4     Administration	3-22

  3-5     Problem Characterization	3-29

  3-6     Problem Response	3-37

  C-1     Chronology of  EPA Indoor Radon Activity	C-2


Table

  1-1     Summary of the Key  Elements of a
          State Radon Program  	1-3

  2-1     Summary of the Key  Elements of a
          State Radon Program  	2-5
                                        IV

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                                    Chapter  1
                              EXECUTIVE SUMMARY
1.1    INTRODUCTION

This  report was  prepared  on  behalf  of the  U.S.  Environmental  Protection Agency
(EPA)  in  cooperation with  the  Conference  of Radiation Control  Program  Directors
(CRCPD).   The purpose  of the report is to assist States in their development  of indoor
radon  programs;  it  was prepared in  response to State requests  for information  on
other State radon activities.   Based  on  a detailed review of existing State programs,
this  report represents an abstraction of the common features of these radon  programs
in the form of  "Key Elements."   In  this context,  Key Elements  are essential features
of a radon program  and  follow logically  from the  nature  of the  problem and  ex-
perience to date.

The  report describes the "Key Elements" of a  State radon program and  illustrates  the
implementation  of  these Key  Elements  using examples from  various   State  radon
programs.   By  illustrating a  range of  radon  activities, the  report  is intended to  be
useful to States  with  radon  programs at all levels of development.

The  nature  of the radon problem varies  from  State to  State, as does the institutional
framework  within  which a   radon  program  is  developed.    Accordingly,  this  Key
Elements  report is not designed  to  present a "model program," nor does it evaluate
whether a particular  program is  good  or bad.  However, the report does attempt to
describe  an  approach  to  the  development  of  a State  radon  program that  takes
advantage  of knowledge  and  experience already gained by the  States and EPA.

In  December   of   1984, extremely  high naturally-occurring  radon  levels  were  first
discovered  in   houses  located   in  the  Reading  Prong,  a  geologic  formation  in

                                        1-1

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Pennsylvania, New Jersey, and New York.   From this  discovery, it  became  clear that
indoor radon was a  serious  public health problem to which no Federal, State, or local
programs were  in place to respond.

In partnership with the States, EPA developed a program to educate the public about
the health risks, improve the  quality of measurement and mitigation  services, and  help
citizens  make informed decisions  about  how to reduce indoor  radon levels.  Over the
past few years,  a number of States have also developed substantial  radon programs in
response to specific conditions within those States, while others have sought to address
the problem in  a  more  limited  context.  Recognizing that  these States'  experiences
provide  valuable insights for  further  State  program development,  EPA  and CRCPD
developed a 'Summary of State Radon Programs' (State Summary). The State Summary
was published in August 1987, and provides  a  retrospective  "snapshot" of State radon
program development.

In October 1987, the CRCPD and  EPA co-sponsored  a Radon  Workshop in  Atlanta,
Georgia.  The  Workshop was  designed  to provide a forum for the States and  EPA to
share and discuss ideas and concerns about the  development of State and Federal radon
programs.    This Key Elements  report extends  the  EPA/CRCPD  cooperative effort in
order to further assist  States  in  their  development of indoor radon  programs.    In
parallel with this report, the CRCPD is also developing  'Criteria for Adequate Radiation
Control  Programs (Radon).'   The  CRCPD document, which  will  appear in a  shorter,
summary form,   will  recommend specific criteria for adequate State radon programs.
These criteria will be used in  CRCPD's State Comprehensive  Review  Program.
1.2  SUMMARY OF KEY

This report describes six Key Elements, as follows:

1.    PUBLIC  INFORMATION            4.   ADMINISTRATION
2.    GOALS AND POLICIES            5.   PROBLEM CHARACTERIZATION
3.    STRATEGY                        6.   PROBLEM RESPONSE

Table 1-1  provides a brief  definition of each Key Element.
                                      1-2

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                                    Table 1-1

                       SUMMARY OF THE KEY
                         OF A STATE RADON  PROGRAM
KEY ELEMENT


1.   PUBLIC  INFORMATION
2.   GOALS AND POLICIES
3.   STRATEGY
4.  ADMINISTRATION
5.   PROBLEM CHARACTERIZATION
6.   PROBLEM RESPONSE
DEFINITION
Development   and  dissemination  of  both
technical and  nontechnical  radon informa-
tion to homeowners, private  companies, the
media, local officials,  and other concerned
parties.

Formulation of goals and policies,  including
health-based  goals,  informal recommenda-
tions,  policies which  define  State  respon-
sibility  and   action,   and  formal  radon
guidance or standards.

Development  and  implementation  of  a
strategy  for  a   State   radon  program.
Identifies   objectives  and   measures  of
success, authority, overall  resource commit-
ment, areas of activity, coordination within
States and  with   other  States  and  other
parties,  and level  and timing of activities.

Operation  of the  radon program,  including
personnel  and budgeting decisions, monitor-
ing  and  feedback,  legislative  initiatives,
quick  response capability, internal informa-
tion   flows,  and   enforcement  of   State
requirements.

Activities   that   measure,   predict,  and
analyze  radon exposure, including local  or
State-wide surveys (air and water), geologic
assessment, data  collection  and  analysis,
health risk assessment, and  data quality as-
surance.

Activities that  reduce  existing indoor radon
exposure and prevent  elevated levels  in new
homes,  including   training,  demonstration,
diagnosis, quality assurance,  development of
preventive  techniques, and  formulation  of
building codes.
                                       1-3

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Across the 50 States, implementation of each Key Element is likely to involve a range
of program activities depending  on the availability of  resources, the perceived severity
of the radon problem in the State,  and the level of program  development.  This report
illustrates  the  activities that might be  involved, and describes both the advantages and
disadvantages  of  a  given  activity  based  on State experience.   These activities are
summarized for each Key Element in  Figure 1-1.

Each  Key Element also comprises a number of policy  issues  which  generally should be
addressed in  at least a  preliminary  fashion  very early  in program development.  These
policy issues  are also described  in this  report.   Further, as  a  result  of  the  substantial
progress that  has already  been  made by the States and EPA,  many informative docu-
ments  have been prepared  and  many  other sources  of expertise or  information have
been  developed  and  used by  the  States.   These sources could serve  as potentially
useful existing resources for other  States,  especially for those  States  that must imple-
ment  a  radon  program in  the  context of severe budgetary constraints.  Figure 1-1  also
summarizes the common policy issues and  potentially  useful existing resources for each
Key Element.
                                        1-4

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               PUBLIC
            iNFCRVIATK
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                          ADMINISTRATION
    PROBLEM
  CHARACTER.
                                        RADON LEVELS
          RADON INFO TO HOMEOWNERS

          RESPOND *o PHONE: INQUIRIES
o DEVELO0 A STRATEGY

o DEVELOP AN .:M»LEMENTAT'C.\
                                                                                  o  ACQU RE & ALLOCATE
INDOOR RADOH LEVELS IN A=

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0 TECHNICAL INFORMATION
0 LIST OF "QUALIFIED" FIRMS

0 PUBLIC MEETINGS
0 DEVELOP & IMPLEMENT
COMM.UNICAT'ON STRATEGY



o AVOiD OVER-/UNDERREACTION
0 RISK COMMUNICATION
0 MEANS OF INFO DISSEMINATION

o EFFECT VENESS FOR AJD'ENCE
c UNINTENDED INFORMATION
EFFECTS




o STATE BROCHURES
o "A CITIZEN'S GUIDE" 4:
OTHER EPA BROCHURES
c- RADON REFERENCE MANUAL

o RMP REPORT. MEASUREMENT
PROTOCOLS
0 "TECHNICAL GUIDANCE"
0 DEVELOP GUIDANCE
o DEVELOP STANDARDS







o STATE ROLE IN PROBLEM
SOLUTION
NFFD /Al -TnQplfy PQP

'STANDARD VS. CU'DANCE
:• BALANCE .jNCER'AIN'Y &
DESIRE FOR GUIDANCE





o STATE GUIDANCE
o CPCPD REPORT

TO RADON '

o NCRP REPORT j?^8
o RELATED EPA RADIATION
STANDARDS
PLAN .^Liuy^ULS
o REEVALUATE STRATEGY & PLAN ° DESIGNATE RESPONSIBILITIES
AS NEEDED 0 MANAGEMENT OVERSIGHT Si
DIRECTION

c MONITOR PROGRAM PROGRESS
o SUPPORT EXECUTIVE OR
LEGISLATIVE INITIATIVES
o QUICK RESPONSE CAPABILITY
o PROBLEM DEFINITION ° KOW TO COPE WITH
INADEQUATE RESOURCES
o CHOICE OF TARGET
o CHOIC" OF FOCUS








o STATE TASK FORCE REPORTS ° "SUMMARY OF STATE
RADON PROGRAMS"
0 EPA STRATEGY DOCUMENT
0 STATE RADON/RAO'ATION
EXPERTISE
~ EXPERTISE IN STATE
HEALTH LABS

o GEOLOGY VS. INDOOR RADON
LEVEL RELATIONSHIP
0 DATA CONSISTENCY &
REL'AB'L'TY

c FREE ~EST NG
o REGISTER/CERTIFY/LICENSE
MEASUREMENT COMPANIES
o RADON/CANCER REGISTRY
0 CONFIDENTIALITY OF RECORDS
0 COMPARABILITY/QUALITY OF
PRIVATE DATA

c 'ND-JS'RIAL VS. NATURAL
NDOGR RAD-ON
0 REAL ESTATE TRANSACTIONS





0 STATE MEASUREMENTS
0 EPA MEASUREMENTS
0 STATE E=A RADON SURVEY
PROGRAM

o OTHER FEDERAL DATA
0 PRIVATE & LOCAL
GOVERNMENT DATA
o DEVELOP PREVENTIVE
CONSTRUCTION TECHNIQUES
0 DEMONSTRATION PROJECTS
o REC.STER/CERTY/L CENSE

M'-(GATICN CONTRACTORS
o CONSIDER FINANCIAL
ASSISTANCE
o BUILDING CODES
0 AVAILABILITY OF STATE
RESOURCES
o ACTIVE vs PASSIVE MITIGATION

o TECHNOLOGY VS. EXPCSJRE-
3ASED GCALS
o WORKER PROTECTION

0 PRIVATE MITIGATION DATA
0 LEGAL LIABILITY


o STATE LEGISLATION
a NY DIAGNOSTICS &
MITIGATiON TRAINING PROGRAM
D ERA DAGNOS'iCS &
MITIGATION TRAINING PROGRAM
0 EPA RMP PROGRAM
o EPA HEP & NEWHEP
O
00
LU
cc
        o NJ & PA COMMUNITY

          OUTREACH PROGRAMS
                                                 o STATE/FEDERAL GEOLOGIC DATA

                                                 o EPA RADON MEASUREMENT

                                                   PROTOCOLS
                                                                           E=A DEMONS-RATON PRCcECT

                                                                           CAPAB,uTIES OF EXPERTS IN
                                                                           ACADEMIC INSTITUTIONS
                               Figure  1-1.   Summary  of Key  Elements, Activities,  Issues, and Resources
                                                                                                                                                     1-5/1-6

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1.3   CONCLUSIONS

The  nature  of  the  radon problem varies from  State  to  State, as  does the  institutional
framework  within which  a radon  program  is developed.   Each State is therefore likely
to respond to the  radon problem from  a different  perspective.   Nonetheless,  a  few
generalizations  are  possible  with  respect to the implementation of the Key Elements of
a radon  program:

•    Timing  of Activities:   Public information  is likely  to be  the  first  Key Element to
     require  State  activities.    As  the  State  radon  program  grows and  develops,
     additional  information  activities  are  required.     After  Public  Information,   the
     sequence  of   Key  Element  activities logically  should   be  Goals  and  Policies,
     Strategy,  Administration,  Problem  Characterization,  and  Problem  Response.    In
     fact, many activities tend to proceed  in parallel.

•    Public .Information:    This  first  Key  Element  addresses  the  need  to  provide
     information  to citizens, private  firms, local  officials, and  other  affected  parties
     outside of  the State  radon  program.   Among   the  six  Key Elements,  Public
     Information  activities are the most widespread.  States  continue  to  respond to a
     large  number  of telephone inquiries, ranging  from  1,500  to 3,000  calls  per  month
     in  New Jersey,  Pennsylvania, New York, Maryland, and  Virginia, to 40 to 50 calls
     per month in  Idaho, Rhode  Island, Oklahoma, and  Vermont.   Use of the media as
     part of the  communication  strategy  is  an  increasingly important  activity.    For
     example,  WJLA  TV   in  Washington,  D.C.  sponsored  a  three-month  public
     information campaign which  included distribution of 75,000 radon detectors.

•    Goals and Policies:  Program goals provide broad direction  for  policy and strategy
     development, a general measure of  program effectiveness, and a sense of program
     priorities.  Policies  deal with more specific issues  and generally require  more time
     for  gathering factual information  with  which to choose among  alternative policies.
     State  activity  in the development of goals  and  policies is  increasing  as  radon
     programs  evolve.    A  number  of States  have  established  legislative  resolutions
     pertaining to radon (for example, Alaska recently declared radon to be an issue of
     concern  to  the  State, and  is  following  up  with testing).   The Washington
     Department  of Health now recommends measurement in  five northeastern counties,
                                        1-7

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     and Oregon  also  recommends  measurement.    These  public  policy  statements,
     together with  both health-based  and  internal  administrative  goals,  establish the
     radon  programmes a priority  in the State and  provide  motivation and direction  for
     its  implementation.

•    Strategy:   Strategy development  helps to  focus the  State  effort  and  provide  a
     basis  for  program   implementation  decisions  such  as   resource  allocation,
     measurement  initiatives, etc.    The strategy development process  benefits  radon
     programs at  all stages  (formative, developing,  and  operational),  since  even  for
     established  programs,  new information (e.g.,  program  experience,  measurement
     data, mitigation effectiveness)  prompts  a revaluation of implementation efforts  as
     States strive  to improve  their programs.   Legislative  or Executive  branch task
     forces  often  provide   a focal point  for  strategy  development.    For  example,
     Georgia  and  Tennessee recently  created legislative committees to  study radon;
     Georgia  also  formed  an interagency  task force that includes EPA  Regional and
     private sector participation.

•    Administration:  This Key  Element addresses the operation  of the  radon program
     in the context  of  the  existing  State institutional framework.   The  availability  of
     adequate resources continues to  be  a principal concern of  State  radon program
     administrators.   Many  States  are still  waiting for adequate  resources to develop
     and expand their radon programs, or require additional resources to  continue their
     programs and respond to an  increasing public awareness of potential radon risks.
     State legislatures   are  beginning  to  address  this  and  other radon issues with
     increasing frequency.   As  of  March  1988,  13  States  had legislation pending  on
     subjects  that  include:     establishing  radon   programs,   certifying  measuring
     companies,  supporting Federal radon legislation,  requiring surveys,  and  clarifying
     real  estate transactions.

•    Problem  Characterization:     Problem  Characterization  involves   activities  that
     measure,  predict,   and  analyze  radon  exposure  and  radon  health  risks.   State
     indoor radon  air  measurement activity continues to accelerate and broaden  in
     scope.   Eleven States  conducted  school surveys during the winter of 1987/1986.
     Ten  States continued house surveys of  various designs in early 1988.  The Virginia
     State legislature recently enacted  a bill  requiring  registration  of measurement and
                                        1-8

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mitigation companies, thereby  increasing to  at  least five  the number  of States
with  some form of mandatory  registration of  measurement companies.

Problem  Response:   Finally,  Problem  Response  includes  activities  designed  to
reduce  existing indoor  radon  exposure  and to  prevent  elevated  levels  in  new
houses  and  reoccurrence in houses where  elevated  levels have  been  mitigated.
The  availability to  States of private  sector mitigation  information continues to be
a problem for  most states.  Although a few States mandate the reporting  of this
information  (e.g.,  New  Jersey,   Nebraska),  more  State   information  collection
activity  is likely.   At the same time, States  are  increasing the number  of  trained
radon mitigation and diagnostician personnel  through radon training courses.  Five
States are offering  such courses  in  the  spring  and summer of 1988.   EPA  will
offer an  updated course  in  eight  States in FY 1988.
                                    1-9

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                                     Chapter 2
                                  INTRODUCTION
2.1  PURPOSE

This  report was  prepared on behalf of  the  U.S.  Environmental  Protection  Agency
(EPA)  in  cooperation  with  the Conference  of  Radiation  Control  Program  Directors
(CRCPD).   The  purpose of the report is to assist States in their development of indoor
radon  programs  and was prepared  in response to State requests for  information on
other State  radon activities.    Based on  a detailed review of existing State programs,
this  report represents an abstraction of the common features of these radon programs
in the form  of 'Key  Elements.'  In  this  context, Key Elements are  essential  features of
a  radon program  which follow logically from the nature of the problem and  experience
to date.   The report describes the  "Key  Elements' of  a State  radon program and il-
lustrates the  implementation  of these Key Elements using examples from various State
radon  programs.  By illustrating a  range  of  radon activities,  the report  is  intended to
be useful  to  States with radon programs  at all  levels of development.

In  December  of 1984,  extremely  high  naturally-occurring  radon  levels  were   first
discovered in  houses located  in the  Reading Prong,  a  geologic fault in Pennsylvania,
New Jersey,  and  New  York.   From this discovery, it  became clear  that indoor radon
was a serious public health problem  to which no Federal,  State, or  local  programs were
in place to respond.

In partnership with the  States, EPA  developed  a program to educate the public about
the health risks, improve the  quality of measurement  and mitigation services, and  help
citizens make  informed decisions   about  how  to  reduce indoor  radon levels.    The
Reading Prong States - Pennsylvania,  New Jersey, and New York « rapidly expanded
their radon testing programs  and most of the Agency's  initial activity was  directed at
                                        2-1

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assisting these States  based on their requests for assistance.   EPA also  developed a
strategy to  begin  identifying and  addressing  similar problems  throughout  the country.
In October 1985, the Radon Action Program was established to coordinate the Agency's
technical assistance to the States  and its radon research activities.  Since  the program
was established, elevated concentrations have been found in  many houses across  the
country.

Over the past few years, a number of States have  developed substantial radon programs
in response  to  specific conditions within  those  States,  while others  have  sought to
address  the  problem  in  a more limited  context.   Recognizing  that these States'
experiences  provide valuable insights for further State program  development,  EPA and
CRCPD developed a "Summary  of State Radon Programs" (State  Summary).   The State
Summary  was published  in  August  1987, and  provides  a retrospective  "snapshot" of
State  radon   program  development.    In  October  1987, the CRCPD and  EPA  co-
sponsored a  Radon Workshop  in Atlanta, Georgia.  The Workshop was  designed to
provide  a forum  for the States and EPA to share and discuss ideas and concerns about
the development of State and  Federal radon programs.  This  Key  Elements  report
extends the  EPA/CRCPD  cooperative effort  in  order  to further assist States in their
development  of indoor radon programs.  In parallel with  this  report, the CRCPD is also
developing  "Criteria for Adequate  Radiation Control Programs  (Radon)."   The CRCPD
Criteria  document,  which  will  appear  in  a  shorter, summary  form, will recommend
specific  criteria for  adequate  State  radon programs.   These  criteria will  be used in
CRCPD's State Comprehensive Review Program.

The nature of the radon  problem varies from State to State, as does the institutional
framework  within  which  a  radon  program  is   developed.    Accordingly,  this  Key
Elements report  is  not designed to  present a "model  program," nor does it evaluate
whether a particular program is good  or  bad.   However, the report does attempt to
describe an   approach to  the  development  of  a State radon  program that  takes
advantage of knowledge and experience already gained by the States and  EPA.
                                       2-2

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Questions regarding  a specific State  program should  be directed to the State contact
provided in  Appendix A  or to a U.S. EPA Regional  Radiation Representative  (listed in
Appendix  B).  Questions regarding this  report should  be directed to:

                         Richard J.  Guimond
                         Director,  Office  of Radiation  Programs
                         U.S.  Environmental Protection Agency
                         401  M  Street, S.W.
                         Washington, DC   20460
                         (202) 475-9600
2.2  SUMMARY OF KEY ELEMENTS

This report describes six Key Elements, as follows:

1. PUBLIC INFORMATION
2. GOALS AND POLICIES
3. STRATEGY
4. ADMINISTRATION
5. PROBLEM CHARACTERIZATION
6. PROBLEM RESPONSE

Figure  2-1  illustrates the six  Key Elements and  Table  2-1  provides a  brief  definition  of
each.

Across the 50  States,  implementation of each Key  Element is  likely to involve a range
of program  activities depending on  the availability  of  resources,  the  perceived  severity
of the  radon problem in the  State,  and the level of program development.  This report
illustrates the activities that might be involved,  and  notes  when the activities  are most
important, depending on the level  of  program  development.   Each  Key Element  also
comprises a number of policy issues which generally should be addressed in  at least a
preliminary fashion  very early in  program development.   These policy issues are  also
described in this  report.   Finally,   as  a result  of the  substantial  progress  that  has
already  been made by the States  and  EPA, many informative documents have been
prepared and many  other  sources of expertise or information have been developed and
used by  the States.  These sources could serve  as potentially  useful  existing  resources
                                       2-3

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                                   Table 2-1

                      SUMMARY OF THE KEY
                        OF A STATE RADON  PROGRAM
KEY  ELEMENT

1.  PUBLIC INFORMATION
2.   GOALS AND POLICIES
3.   STRATEGY
4.   ADMINISTRATION
5.   PROBLEM  CHARACTERIZATION
6.   PROBLEM  RESPONSE
DEFINITION

Development  and  dissemination  of  both
technical  and  nontechnical radon  informa-
tion to homeowners, private companies, the
media, local officials, and other  concerned
parties.

Formulation of goals and policies, including
health-based goals, informal  recommenda-
tions,  policies  which define State respon-
sibility  and  action,  and  formal   radon
guidance or standards.

Development   and  implementation  of   a
strategy  for  a   State  radon   program.
Identification  of  objectives and  measures of
success,  authority,  overall resource commit-
ment,  areas of activity,  coordination  within
States  and  with  other  States and  other
parties, and level and timing of activities.

Operation of the radon  program, including
personnel   and   budgeting   decisions,
monitoring   and  feedback,  legislative
initiatives,   quick  response  capability,
internal   information   flows,   and
enforcement of State requirements.

Activities  that  measure,  predict,  and
analyze  radon  exposure,  including  local  or
State-wide surveys  (air and  water), geologic
assessment,  data  collection and analysis,
health risk assessment,  and data  quality as-
surance.

Activities  that  reduce   existing  indoor
radon  exposure and prevent elevated levels
in  new  homes,  including   training,
demonstration,  diagnosis,  quality assurance,
development of preventive techniques, and
formulation of building  codes.
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for other  States, especially for  those States  that must implement a radon program in
the  context  of severe budgetary  constraints.   The  State Summary is an  important
example of such an existing resource and is the source of many  of the illustrations of
State activities that are provided in  this  report.   Chapter 3 of this  report describes in
more detail the activities  which  fall within each Key  Element,  summarizes  policy issues
that frequently arise, and lists potentially  useful existing resources.   The Key  Elements,
activities,  issues, and resources  are summarized  in Figure 1-1  (see Chapter 1).
2.3  REVIEW OF THE RADON  PROBLEM

Indoor radon  is estimated  to cause 5,000 to  20,000  lung  cancer deaths annually in the
United States alone.  In the past few years,  a number of countries, including the U.S.,
have begun studying radon in houses and developing methods to reduce elevated levels.
Most  of the  international  activity  involves national  surveys to determine  the  general
distribution of  radon concentrations, the  magnitude  of individual  exposures,  and  the
number of dwellings which may require remedial action.  Among the countries involved
are Canada, the United Kingdom,  Ireland, the Federal  Republic  of Germany,  France,
Luxembourg,  Switzerland,   Italy,  Denmark,  Norway,  Sweden,  Finland,  Austria,  the
Netherlands,  Greece,  and  Japan.   Other foreign  activities include the development of
national  exposure  reduction  goals  (Sweden), development  of action levels  (United
Kingdom), and initiation of epidemiotogical  studies (Sweden and Canada).   Radon is  a
national problem that deserves  some attention in  every State.   In  Section 402  of the
Radon Gas and Indoor  Air Quality  Research Act of 1986,  the U.S. Congress concluded,
among  other things, that  (1) 'High  levels  of  radon gas pose a serious health  threat in
structures in  certain  areas of  the country,*  and (2)  "Various scientific studies have
suggested that exposure to radon,  including  exposure to naturally occurring radon and
indoor air pollutants,  poses a  public health risk.1  These findings  are corroborated by
compelling statistics.   As  mentioned above,  EPA  has  estimated  that 5,000 to  20,000
lung cancers per year in  the  U.S.  can  be attributed to radon  exposure.   EPA recently
conducted   an  in-house,   comparative review1   of   the entire range of environmental
1    'Unfinished  Business:    A  Comparative Assessment  of Environmental  Problems.
     Overview  Report.'    Office of  Policy  Analysis,  U.S.  Environmental  Protection
     Agency, February 6, 1987.
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problems  the  Agency  handles.   The problems  were ranked as  to  severity  with respect
toseveral  different aspects:   cancer risk, noncancer health  effects,  ecological effects,
and   welfare  (economic   effects).     With  respect  to  population  cancer  risk,  two
environmental  problems  headed  the list  of  31  issues considered:   indoor  radon,  and
occupational exposures to all carcinogens combined.  Thus,  indoor radon  was judged
relatively  to  be  the  most serious  class  of  environmental  carcinogen  to which  the
general public is currently exposed.   In  addition,  the radon  levels  that  have been
measured in some  houses are sufficiently  high to  pose a lifetime risk of  lung  cancer
above 50 percent under certain living conditions.  Based on 1987 surveys in ten  States
covering 11,600 homes, over 21 percent of the houses were found  to have screening
levels above 4 pCi/L.   In  fact, at least a few screening measurements  in virtually every
State have indicated levels above 4 pCi/L, based both on EPA and State measurements
and  on published private  measurement statistics.  While these figures are uncertain  and
potentially subject to  differing interpretations,   and  while a radon 'problem11  may  not
exist  in  every  State,  the  figures do suggest  that  careful  consideration  of a potential
radon problem would  be  prudent.

The  health  risk   due  to radon  exposure is  uncertain;  however,  relative  to  other
environmental  risks,  radon health  risks are well-documented  since the  risk estimates
are based on  human epidemiologic studies of radon  exposure.   Recently, on January 4,
1988, a committee of  the  National Research Council published a report entitled "Health
Risks  of  Radon  and Other  Internally  Deposited  Alpha-Emitters: BEIR  IV."2     The
committee estimated that,  for every  one  million people  exposed over  a lifetime to  one
Working  Level Month  (WLM) of radon, about 350 additional  deaths would occur due to
lung cancer.  This  new estimate,  which results from the application  of new  statistical
techniques to  previously collected data, is nearly three times  higher than a  widely used
estimate of 130  additional deaths  in  one  million  published  in  a 1984 study by  the
National  Council  on  Radiation  Protection.    The  committee cautioned  that  its  risk
estimates  "should not be considered  precise  because they are  based on incomplete data
and  involve numerous uncertainties.  Most of  the  committee's conclusions are  drawn
from  studies of  miners  exposed to radon, and  the conditions  under which  radon is
inhaled  in the home may be significantly  different from conditions  in the mines."   EPA
     "Health  Risks of Radon and Other  Internally Deposited Alpha-Emitters:  BEIR IV.*
     Committee on  Biological  Effects of  Ionizing Radiation, National  Research  Council,
     National Academy Press,  Washington, DC,  1988.
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and the Nuclear Regulatory Commission jointly sponsored  and requested the  National
Research Council  report in 1984.   The  new risk  estimate  falls  within the  range of
risks  published in EPA's "A Citizen's Guide to Radon."

The radon  problem  is also complex;  much  of this complexity  stems  from the great
uncertainty that  surrounds  the  degree of indoor radon exposure.   The great majority of
houses have not yet been  measured, and  the precise number of houses with  elevated
levels  of radon  is  still unknown.   Radon  exposure to  a  given  indoor radon  level
depends on the fraction of time  spent indoors and the  period  over  which  a given
individual remains in  the same house.  Radon levels  also vary depending on location in
the house,  indoor/outdoor  pressure, the use of appliances or fireplaces in  a manner
that alters  indoor pressure, and so forth.   The American  Medical  Association's (AMA's)
Council  on  Scientific  Affairs  has  recommended additional  radon  studies,  including
surveys  of  residences  having  different construction  and  different ventilation,  heating,
and cooling  systems.^   Finally, the rate at which radon enters the house depends on
the source (e.g., soil  gas beneath the house,  water used in the house, or stone or other
materials used to build  the house), and  the way the  house is constructed (e.g., the type
of foundation substructure,  or whether  the basement floor has been paved with  con-
crete  or left as  bare soil).   Scientists  are still investigating  the  often  subtle  relation-
ships  among these many variables.

The physical properties of  radon  contribute  further to  the  difficulty  of determining
where  elevated   levels  are  present and  how elevated   levels   can be  reduced  or
prevented.   Since radon is a colorless, odorless, inert gas, its presence  must be meas-
ured  by special  devices that  are  not  generally familiar to homeowners.  Radon  can
diffuse through small cracks and fissures, thus, the  potential for indoor  buildup is  hard
to predict.    Although a homeowner may obtain a  measurement  easily, the quality of
measurement services  is difficult  for a  homeowner  to judge since he  or she  cannot
easily corroborate the measurement.

Mitigation measures that  consistently  and  reliably reduce  indoor  levels   are still under
development,  as are preventive  construction techniques.    Typically, mitigation  costs
     "Radon  in Homes," Journal of  American  Medical  Association. Vol.  258,  No.  5,
     August 7, 1987.
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range  from $200 to $1500.   Finally, only a  limited  number of technicians  have been
trained for radon  mitigation and building codes have not yet incorporated  changes that
address  new  radon-resistant  construction  techniques.    Some  States  have  initiated
mitigation training seminars.   EPA's Office of  Radiation Programs (ORP) is  conducting
the  House  Evaluation  Program  (MEP),  which  is  designed  to  assist the  States  in
transferring  technology  to   perform   house   evaluations   and  provide   mitigation
recommendations.   ORP  is also helping States to provide training to  individuals and
private firms.

The presence of  highly elevated  indoor  radon levels due  to  naturally-occurring  sources
was discovered   relatively  recently  (elevated  levels  in the  Watras  home  in  eastern
Pennsylvania were discovered  accidentally in December 1984).  As a result,  the institu-
tional  mechanisms  to  deal with indoor  radon  are  still in the  process  of  formation.
Homeowners  typically  know  little about  radon.    Policy-makers  require information  in
order to  create  institutional mechanisms  and evaluate the  radon problem in the context
of competing policy and environmental  priorities. Since  the elevated indoor radon  levels
are  naturally occurring,  they  are  not  subject to  regulatory  control  under  existing
environmental statutes  as  are other environmental  hazards,  such  as  industrial  plant
emissions.  Hence,  even the authority to address the problem is sometimes unclear or
inadequate.   Finally, since radon is naturally  occurring, has  potentially serious health
risk  and economic  implications,  and has only  recently gained national attention, legal
liability and property transfer issues have yet to be resolved.
2.4  EPA

After  the discovery of the  Watras house  in  1984,  States requested  assistance  from
EPA in  responding to  the  problem.  In discussion with the States, seven radon program
needs were outlined, as follows:

1.   The need to assess  the  size of the problem, determine what  parts of the country
     are affected, and determine  how to predict  where radon will be  a problem.

2.   The need to standardize  measurement methods.
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3.   The  need  to  evaluate  the  competence  of  firms  and  laboratories  that  offer
     measurement services.

4.   The need  to develop cost-effective ways to  reduce  radon levels in existing  and
     new homes.

5.   The need  to develop technical expertise within State and local governments, as
     well as in  the private sector.

6.   The need to develop and publish  guidelines  explaining  the health risks  associated
     with various  levels of radon  and offering  recommendations  on what actions should
     be  considered by homeowners.

7.   The need to develop effective  communication tools to present health concerns and
     recommended solutions to the public.

In response to  this  list  of needs, EPA developed the  Radon  Action  Program.   A
chronology of EPA radon activities is described in  Appendix  C.

Since many  States are already receiving some  EPA assistance in developing a  radon
program,  it is  also  useful to  review the four major elements of EPA's  Radon Action
Program:   (1) Problem Assessment; (2) Mitigation  and  Prevention;  (3) Capability Devel-
opment;  and (4) Public  Information.    Many of the  features  of  the  Radon  Action
Program  are also listed in Table 2-1 under the appropriate Key  Element.

2.4.1   Problem Assessment

With respect to  Problem  Assessment,  EPA  has developed a program (the State  EPA
Radon Survey  Program) to help  States conduct State-wide statistically designed  radon
surveys.   EPA provides survey design  assistance and  measurement  devices  (charcoal
canisters).   The design work  includes a preliminary  geologic characterization  to identify
areas with a high likelihood  of elevated measurements.  Ten States  participated in the
program  in fiscal year 1987 (FY 87), and seven States and Indian Tribes in  three States
are participating  in FY 88.   In addition, EPA is  designing  a  national survey to  meet
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the national  indoor  radon  assessment requirement contained  in  the  1986  Superfund
Amendments and Reauthorization Act (SARA).

Also as part of its Problem Assessment program, EPA  issued standardized measurement
protocols  for seven  measurement methods and  protocols for screening and follow-up
measurements to guide homeowners in the measurement process.  These protocols help
to ensure that  measurements are comparable  and assure the public that readings are
made accurately.  States must  follow the protocols in the State EPA  survey.  EPA is
also beginning  to identify those geological factors and  characteristics  which are most
useful as indicators  of  high  radon  levels.   EPA  is conducting preliminary work on the
use of  soil  gas measurements  to  predict the  radon  potential for  individual  parcels of
land.

2.4.2  Mitigation and Prevention

Under   Mitigation  and   Prevention,  EPA's  Office  of  Radiation   Programs  (ORP)  is
conducting the  House Evaluation Program (HEP), which is  designed to  assist  the States
in  transferring   technology   to   perform  house  evaluations  and  provide  mitigation
recommendations.  Eighty houses in Pennsylvania were evaluated under  Phase I of HEP;
Phase II will  have covered an additional 80 houses  in 5 States and the  Seneca Indian
Nation.   Phase ill  will cover  at  least 90  houses in 9 states.   EPA's Office of Research
and  Development  (ORD)  is also  conducting  a  Mitigation  Demonstration  Program.
Demonstrations  are   underway  in  New  Jersey,  New York,  Pennsylvania,  Maryland,
Tennessee,  Florida,  and Ohio.   The New  House  Evaluation Program  (NEWHEP)  was
initiated   to  provide  data to  support  verification  of  the  radon prevention  techniques
outlined in EPA's publication, "Interim Guide to Radon Reduction in New Construction,'
and to  serve as a basis for a technical guide  on new construction.  Over 200 houses
will be built and tested under NEWHEP in 1988.

2.4.3  Capability Development

Under  Capability Development,  EPA's activity  includes  two major programs, one on
diagnostic  and  mitigation training  and the  other  on measurement proficiency.   The
mitigation training  program   is  designed  for  State  personnel  and private  contractors
chosen  by the States.  Twenty-seven courses have been  completed and 1,000 people in
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40  States  have been  trained.   A  few States  have offered their  own  training  courses
using the EPA materials.  EPA prepared a videotape of the course, which many States
are duplicating for use.  EPA and the CRCPO  are  also working on  a cooperative basis
to  exchange  both  training  and  measurement information, as  illustrated  by a recent
EPA/CRCPD meeting in Atlanta.   EPA is  also providing  training  information  to States,
The Radon Measurement Proficiency (RMP)  program is a voluntary program designed
to  test  the  ability  of  radon  measurement firms  to  measure accurately  the radon
concentration  in a control  chamber with a radon level known to EPA.  Approximately
250 firms have demonstrated adequate proficiency (based on the results for participants
in the  fourth round of  the program) and were listed in the last  RMP Report.

2.4.4   Public Information

Under  Public  Information,  EPA has  developed several  publications for  distribution  to
the  public.  These include three brochures:  "A Citizen's  Guide to Radon:   What  It Is
and What To Do About  If  ('A  Citizen's  Guide"), "Radon  Reduction  Methods:   A
Homeowner's  Guide"  ("Radon Reduction  Methods"),  and "Removal  of  Radon  from
Household Water.*   "Radon  Reduction  Methods"  was revised in  1987.   To  provide
supplemental information to be used by State  administrators and  others  in conjunction
with "A Citizen's  Guide," EPA  published the Radon Reference  Manual in 1987.   EPA
also developed a technical manual for use by contractors and  interested homeowners:
"Radon Reduction Techniques  for Detached  Houses:   Technical  Guidance"  ("Technical
Guidance").    States were  provided  with  camera-ready  copies  of the  brochures for
reprinting  and distribution,  as well  as copies of the "Technical Guidance" and Radon
Reference  Manual.    States  distribute  EPA's  Radon  Measurement  Proficiency (RMP)
Report, or a  list  of firms operating within the States that is extracted from the  RMP
Report.   In  addition,  "Radon Reduction  in  New  Construction:    An Interim  Guide,"
developed  by EPA  with the  National Association  of Homebuilders (NAHB)  Research
Foundation, is also being distributed  by EPA.  In  1986, EPA published 'Interim Indoor
Radon  and Radon Decay Product Measurement Protocols," which  was followed  in  1987
by  "Interim  Protocols for Screening and  Follow-up  Radon  and Radon  Decay  Product
Measurements."
                                       2-12

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                                     Chapter 3
                         DESCRIPTION OF KEY
The  1984 discovery  of the Watras  house prompted serious radon  program development
at both  the State  and Federal levels.   As  summarized in  the last  chapter,  EPA's
program  was developed in response to State requests for assistance, and resulted in the
Radon Action Program.   At the same time, over the last two years, State attention to
indoor radon has  increased substantially, in parallel with a broadening public awareness
and  a growing body of data that continues to suggest that  elevated  radon levels could
be widespread.

Recently,  many States have  developed  significant radon programs  and  have  initiated
different  activities  as part of these programs.   The activities  depend on the perceived
need  in  the  State,  the   size  of the  program,  and  the  availability  of resources.
However, regardless  of these  facts,  which vary by State, many  of  the activities  have
common features  that  are  interesting  to  other States.   From  detailed  examination of
existing State radon  programs  and activities,  it  was  possible to  abstract the  common
features  of  these  programs  in  the form of  "Key  Elements."   In this context,  Key  Ele-
ments are  essential features   of  a  radon  program which   follow  logically  from  the
nature of the problem and  experience to date.

This chapter surveys  each  of  the six  Key  Elements of a  State  radon program.   As
introduced  in Chapter 2, these  Key Elements include:

1.   Public Information
2.   Goals  and Policies
3.   Strategy
4.   Administration
5.   Problem  Characterization
6.   Problem  Response
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In  the  following  pages,  each  Key  Element  is  described  by  a  series of  activities
presently  found in some State programs.  These  activities are intended to illustrate the
implementation  of  each  Key  Element,  but  are  not expected  to  capture  all of  the
activities currently included  in  State  programs.  Finally, the discussion of  Key Element
activities is followed by a  discussion  of several  of  the  major policy issues that have
arisen  in  the  context  of each  Key  Element  and a list  of  potentially  useful  existing
resources.
                                         3-2

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3.1  PUBUC  INFORMATION

This first Key Element  addresses the  need to  provide  information to  citizens, private
firms,  local officials, and other affected  parties outside  of  the  State radon  program.
The type of information  differs  somewhat  depending on what decisions are being made
and by  whom.   For  example, citizens need information  to  help them  interpret  health
risks,  to make  measurements (or  have  them  made)  and  interpret  results,  to  make
mitigation choices  (whether to  mitigate, who to hire, or how to do it), and  to  evaluate
new construction techniques  that  reduce radon  entry.   Private firms  need  information
about  market needs  and  opportunities,  quality requirements,  regulatory  (if any)  and
legal  obligations  (e.g.,  with  respect to  potential  liability),  and  training  needs.    The
range  of potential information activities is  characterized by five activities,  as follows:

1.  Make Available  and/or  Send  Radon Information to Homeowners.
2.  Respond  to Telephone  Inquiries.
3.  Provide Technical  Information.
4.  Publish  a Periodic List  of "Qualified" and/or Certified  Firms.
5.  Attend/Hold  Public Meetings.
6.  Develop and Implement Communication Strategy.

These  activities are illustrated  in  Figure 3-1 and are  individually  described  below.    A
discussion of  State  policy issues  and potentially  useful existing  resources follows.

3.1.1   Activities

3.1.1.1   Make Available  and/or Send Radon Information  to  Homeowners.   This activity
entails  ongoing  information  collection  from  a variety   of  sources,  development  of
general  information  brochures  for the  public  (such  as  EPA's  "A Citizen's Guide"  or
"Radon  Reduction  Methods"),  and  distribution  of the  information  to the  public.   This
distribution  can  involve  either mailings  only  in   response to  telephone  or  written
requests, or  a more proactive (and  resource-intensive)   effort to  mail  information  to
homeowners  without request  or make it available at libraries, local health  departments,
and  elsewhere.   In  some cases,  information could also  be  made  available via central
clearinghouses (e.g., through  the  State  equivalent of the  National Technical  Information
Service (NTIS) or the Government  Printing Office (GPO), if such an equivalent exists).
                                        3-3

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Finally, other media, such as radio, television, and  local newspapers, can be utilized by
issuing press  releases and holding  media  briefings.  All States already distribute  some
kind of information on radon, such  as EPA's  "A Citizen's  Guide."   Some States have
modified  EPA's pamphlet by adding  State-specific or other information  (e.g., designation
of the Radiation Control  Program  as the  primary contact).   A few  States,  such as
Hawaii,  Mississippi,  and Louisiana,  send  information  only  upon  request.    Colorado,
Michigan,  and Idaho  distribute the  EPA  brochures through district  and  county health
departments.  Pennsylvania and Colorado distribute to inquiring  homeowners a standard
information  packet  which  includes "A  Citizen's  Guide,"  "Radon Reduction Methods," a
list of companies offering  radon  services, and a  description  of  the low  interest  loan
program.  New Jersey includes a map of the State with recommendations for testing by
homeowners.

3.1.1.2    Respond  to  Telephone  Inquiries.    Inevitably, the State  will receive  some
telephone inquiries from either homeowners or  private companies seeking more informa-
tion  about radon.  Responding  to  telephone inquiries  provides an opportunity for  the
State to  monitor events  in the State,  but also requires that knowledgeable individuals
are available to  handle the calls.  As of  August  1987, the number of calls received  per
year  varied from less  than  24  to  over  30,000;  hence, the  need  for full-time  staff
varies  substantially  from  State to State.   In  any event, it is useful to  ensure that  the
existence  of one State  contact (or at most  a  small number) is  communicated to  the
public (e.g.,  in   brochures,  local newspapers,   a telephone book  listing,  a  "hot  line"
listing, etc.) so that information can  be collected centrally and  responses given consis-
tently.   In many  cases, support staff have been used to field incoming  calls, and only
technical  questions are referred to  specialists.  Almost all  States  keep  track of  the
number of  incoming  calls.   This  information  provides  States with a  gauge  of public
awareness and  knowledge, and  may indicate  the effectiveness  of public information
dissemination.  Some States, such as Oklahoma, maintain a computer database of public
inquiries.   The database is used  to send additional information  to homeowners  as it
becomes  available.   Eight  States, including  Illinois, Maryland,  Minnesota,  New Jersey,
New York, Pennsylvania,  Virginia,  and Wyoming,  have toll free radon hot lines.

3.1.1.3   Provide  Technical Information.  In order  to facilitate  the exchange of current
scientific findings and to promote the use of  the  latest measurement,  mitigation, and
prevention techniques  by private firms and  homeowners, technical information will also
                                        3-5

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be  required.  States vary  in terms  of whether State-specific technical  information has
been created,  whether  the State actively reproduces  information from EPA or  other
States,  or whether  it simply distributes a  limited amount of  information on  request.
Several States,  including Alabama, Colorado, Florida, Illinois,  Indiana, and  Ohio, have
distributed 200 to 300 copies of  EPA's "Technical Guidance*  to  private  contractors and
some homeowners.   EPA  also  released two new radon  pamphlets in the fall of  1987,
"Removal  of Radon  from Household  Water" and "Radon Reduction in  New Construction:
An  Interim Guide," which are available for distribution by the States.

3.1.1.4    Publish a  Periodic List of  'Qualified'  and/or "Certified'  Firms.   This activity
responds  to a  homeowner's need to identify  private sector  firms that are capable  of
providing  reliable measurement,  mitigation, and/or prevention services.   Discussion  of
the  issues  surrounding  a State's   decision  to  require registration,  certification,  or
licensing can be found on  page 3-32 (for measurement companies) and page 3-39 (for
diagnostic and mitigation companies).   If a State  certification program exists, the need
for  information  dissemination  can  be  met simply  by  making  available  the  list  of
certified firms (on request,  through local media via  a press release,  in public  libraries,
etc.).  In  the absence  of  such a program, the  State can  still provide the names  of
firms within the State that  have successfully participated  in EPA's Radon Measurement
Proficiency  (BMP) program  (though  this program  does  not  certify a firm  in any legal
sense;  it  only  provides  an  indication  that  the  firm  is  capable  of   performing
measurements),  or  a list  based  on other  criteria (e.g., those  firms that  contact the
State).   Almost all  States currently use  EPA's  RMP  list  as  a reference for  radon
measurement firms.    Delaware  and  Nebraska  are two  States that  legally  require
radiation  measurement  and  mitigation  firms  to  register with  the   State.    Delaware
distributes the names of the five  companies  currently registered  to measure radon, and
suggests  two  mitigation firms  that  have  attended  EPA's  Diagnosis and  Mitigation
Training  course.   New  Jersey  distributes  a  list of all measurement and mitigation
companies  that voluntarily  participate in the  State  certification  program.   New York
sends  out a list of mitigation  firms  that have  taken the  EPA course.  In Oregon, the
Bonneville Power  Authority  (BPA) has  taken the lead  in  providing  homeowners with
information on  consultants  or mitigation contractors.

3.1.1.5  Attend/Hold Public Meetings.   Public meetings  provide  an important forum for
addressing public concerns, especially those of homeowners, and disseminating informa-
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tion  to  others based  on  State  experience.   State  participation  could  range from a
simple question  answering role  -  for example,  explaining what the State  is  doing,
where to  go  for more information,  advice  with respect to  testing, etc.  - to  briefings
or delivery  of technical papers  at  State or  national  conferences.   For  example,  in
order to facilitate public outreach,  Pennsylvania retains a  Community Relations  Coor-
dinator,  who,  among  other  things,  administers  Pennsylvania's  Hispanic  Community
Outreach Program for  Hispanic residents in the Reading  Prong  area.  Representatives of
New York's Department of Health (DOH) and State  Energy Office (SEO) attend  public
meetings  upon  request  and  arrange  meetings for  homeowners  in  high measurement
areas.   New Jersey has developed  a slide show for public presentations of the  radon
problem.   In  Tennessee, the Department of  Health  and Environment worked  with  the
American  Lung Association and held 20 public meetings on radon.

3.1.1.6  Develop and  Implement Communication Strategy.   Use of the media,  such as
radio, television,  and  local newspapers,  provides  a powerful tool  to  inform  the  public
about all  aspects of radon.   However, because of  this power, and  the  possibility  that
counterproductive  or  misleading  information  will be given,  it is important that   the
State actively  promote  a balanced presentation and  cooperate with  the  media to help
maximize  its  effectiveness.   One way to facilitate this  involvement  is to develop  and
implement  a communication strategy.   The  strategy could  include  frequent contact  with
appropriate  individuals at   local  TV  stations,  making  State   personnel available  for
interviews,  provision to  the media  of background  information  and information  about
new radon developments in the area, and  encouragement of media-sponsored information
and/or testing campaigns.   For example, WJLA  TV (Channel 7)  in Washington, D.C.
recently sponsored  a  three-month  public information campaign to increase  awareness
and  encourage  measurement in the  metropolitan Washington  area.   The  program
included distribution through Safeway food stores  of 75,000  radon detectors at reduced
rates by  an  RMP-listed vendor.    Giant food  stores  have recently started  a  similar
campaign   in  the  area.   Local  newspapers  and  TV  stations have  also  sponsored
measurement  programs  of varying  sizes in  Los  Angeles, California; Chicago, Illinois;
Boston, Massachusetts;  Twin  Cities,  Minnesota;  Biloxi,  Mississippi,  and  Dayton  and
Cleveland,  Ohio.
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3.1.2  Policy Issues

3.1.2.1    Avoidance  of  Public  Over- or  Underreaction.    One  of the  most difficult
information-related  judgments  required  of  a  radon  program  involves  the  tradeoff
between  a message  that  draws  too  little  attention to  the  problem and,  therefore,
results in  no action, and a message that exaggerates the problem and,  therefore, causes
panic.   At  a practical  level,  panic is most  easily overcome by  being prescriptive, for
example,  by providing  the  action  level  guidelines that relate screening level result and
homeowner response, such as  are already included a number of State pamphlets (e.g.,
Pennsylvania and New York) and in EPA's  "A Citizen's Guide."  On  the  other  hand,
apathy  may also be a problem since  some homeowners  may  be reluctant to  get  a
measurement and  face  a   potential  problem.    In this   case,  a  clear,  convincing
explanation  of the potential risk  is  required.
         Risk Communication.   Like many other environmental  hazards,  the health  risk
due  to radon  exposure  is measured  by a  fractional increase in the probability of  a
health  effect (in  the  case of radon, lung cancer).  Since  estimation and  interpretation
of this  risk is  technically  complex, communicating it  to  the  public  is difficult.   At  the
same time, the public  must understand the risk sufficiently in order to make individual
choices and take action.   In determining how  best to portray risks to  the  public,  the
State must  consider  a number  of factors,  including the  uncertainty of  the risk  es-
timates themselves, the range of  radon levels to which the  public may be  exposed,  the
influence of  individual  living habits on risk, for  example, occupancy of  a  given house
and  smoking habits,  and  the widely varying ability  of different members of the public
to understand the health  risk.   A number of  State radon  pamphlets  (e.g., Virginia's), as
well  as  EPA's  "A  Citizen's  Guide,"  illustrate  the  treatment  of  these  issues.    For
example, in  "A Citizen's Guide," a  chart that  visually  represented risk  as a  function of
indoor radon level was included, as well as a  table which compared radon  risks with
other risks  that  might  be familiar to a  homeowner.  EPA's  Radon Reference  Manual
also provides  substantial  discussion  of radon  risks,  and  an  illustration  of how  risk
estimates are derived.   EPA  is currently  involved in a number of research  projects to
improve  risk  communication,   including  a  project  with  the  State  of  Maryland   to
determine  the  most  effective  methods of communicating  the health risks  of  radon.
Results of  these  studies will be available in late 1988.
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3.1.2.3    Means of  Information  Dissemination.   Ideally, public  information  on  radon
would  be  made  available  through  a  variety  of  media  (written  material,  telephone
responses,  videotapes, television  and radio,  public speaking engagements, conferences,
etc.).  In fact, resource constraints - at least early  in a program's development  -- are
likely to  force a choice among the various  options  and limit the frequency of  distribu-
tion.    The  least  expensive  means  of distribution  typically  involves  short  written
materials  and  telephone responses.   Virtually all States  engage in  these activities, at
least by  distributing  EPA  materials.     In   addition,   several  States  have  targeted
information  to homeowners  who  live  in  areas  likely to have elevated  radon levels.  By
providing press releases to  the local  media, a wide  audience can be reached with few
State resources  expended  (although  the  State loses editorial control of the information
that is   presented).   New  Jersey and  Pennsylvania  also  have  community  outreach
programs.

3.1.2.4    Effectiveness for Intended  Audience.   Depending  on  the intended  audience,
different  types of  information,  presented  in different formats, tend to  be  most  effec-
tive.   Short  pamphlets, with many  visual representations,   are  appropriate  for  home-
owners,  while longer, detailed manuals  are  appropriate  as  references for technicians
and videotapes  or live presentations  are useful  for  training.    Similarly, the  content
should vary depending  on  the purpose of  the information (e.g., general introduction,
technical  reference,  specific information  on  measurement  interpretation,  measurement
protocols,  sources  of private services,  radon in water, etc.).   Generally,  introductory
material  is  needed by  homeowners  at  a very early  stage  of  program  development,
followed  by  material on measurement procedures  and measurement interpretation, and
finally,  information on mitigation and  prevention.

3.1.2.5    Unintended Information  Effects.   Publishing  a  list of  "qualified"  or  "certified"
companies  to inquiring  citizens  is a valuable activity  because  it identifies firms that
the  State  believes  are  capable  of  providing  reliable  measurement,  mitigation and/or
prevention services.  Homeowners  can  choose among firms on  the list or seek other
firms on their own.

However, although  these  lists  are intended for State use   only, there may  be  some
unintended  effects  of  relying  on  such  a list.    Just like advertising,  distribution  of
public  information,   such   as  a  list  of "qualified"  or  "certified"  companies,   which
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mentions some processes or companies but excludes others, could convey an advantage
to  those  companies  that are  mentioned.   While  the intent  of this  information  is
generally to  ensure minimum  quality  service,  the market advantage of being a "listed"
company may not be consistent with the State's intention.   For example, the use  of a
list may thwart competition from excluded but qualified  new firms (which may result in
higher  prices), or it  may exaggerate  the perceived quality  differences among  firms
where,  in  fact,  very  little difference  exists.   Similarly,  if a  State decides  to  provide
free or  subsidized  testing,  qualified  "for  profit1 testing  firms  may be  forced out  of
business  to  the   long-term detriment  of  consumers.    The frequency  with  which  the
information  is  distributed  and  its content  (e.g.,  disclaimers,  caveats)  also affect  the
degree  to which  it  is  likely to affect  the private market (like  advertising, wider,  more
frequent distribution  with few disclaimers has a stronger  impact).

3.1.3   Potentially Useful Existing Resources

1.   State brochures (e.g., PA, NY, NJ, VA,  CA, MN).
2.   EPA "A Citizen's Guide to Radon," other EPA brochures.
3.   EPA Radon Reference Manual.
4.   EPA RMP Report, and  Measurement Protocols.
5.   EPA "Technical Guidance."
6.   Use of  existing State hot lines.
7.   Private  sector  sources  (e.g.,   American  Lung Association,  American  Medical
     Association,  trade  associations   (e.g.,  National  Association  of  Realtors (NAR),
     National Association of Home Builders (NAHB)).
8.   Local health  departments,  schools, public libraries.
9.   New Jersey and  Pennsylvania Community Outreach programs.
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3.2  GOALS AND POLICIES

Early  involvement of senior  State  program  administrators and  managers is needed in
order to define the role  and  objectives  of  the  State  radon program.   Since the  prin-
cipal  characteristic  of the radon  problem  is the  potential  health  risk  to humans,  risk
reduction  is logically  a  central  component  of  the  goals  that should  be  established.
However,  such a goal  should be further defined (e.g., which risks are  high enough to
address?) to  assist in  the development  of a strategy to achieve  it.   Moreover,  while
some goals may be  management-oriented  (e.g.,  a goal  such as "address the radon
problem using minimal resources"), some should  also  be provided as guidance to the
public.   Use  of the  guidance  can  be voluntary,  or,  as  in  the case  of standards,
mandatory.    Activities  which  fall  under  this  second  Key  Element are. illustrated  in
Figure 3-2  and include:

1.  Develop Goals.
2.  Develop Policies.
3.  Develop Guidance.
4.  Develop Standards.

3.2.1  Activities

3.2.1.1  Develop Goals.  Program  goals  provide broad direction for policy and  strategy
development,  a  general  measure  of  program  effectiveness, and  a sense  of  program
priorities.    Development  of  program  goals should  be  one  of  the  earliest  activities
initiated.  The most important goals are likely to be health  risk-related,  for example,
a  hypothetical goal  might be to  "reduce  the  health risk  due  to radon as  low  as
reasonably  achievable."   Goals may  also  be embodied in existing  State statutes which
lay out  public  health  objectives,  or may  extend from  executive-level  objectives.   A
further example of  a goal can be drawn  from the  experience of Sweden, which  has set
a  national   goal  of reducing  radon  levels  in  all  Swedish  houses  by  50  percent on
average within 100  years.

3.2.1.2   Develop Policies.  While initial goals are required early in the program devel-
opment, policies deal  with  more  specific  issues  and  generally require  more  time for
gathering   factual  information with which to choose among alternative policies.    Like
                                        3-11

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goals, policies  may be  either  internally  directed  (management-oriented)  or  externally
directed  (public-oriented).   For example,  as a  policy matter,  a State may choose to
provide measurement services free  to  the public.  Clearly, this policy affects both the
need for State resources and  the demands placed on private measurement  companies.
For  example, New  Jersey  and  Pennsylvania  will  provide  free follow-up  testing for all
houses where  private sector  screening  results  are above a  specific  level.   Virginia, as
part  of the  "Report of the  Secretary  of  Human  Resources'  Task  Force  on Radon"
(December 1987), has  developed policy positions  on  nine  key  issues, including testing,
follow-up study, certification, and others.

3.2.1.3   Develop Guidance.  Whereas goals indicate desirable results of  the  program,
guidance provides recommendations regarding how to achieve specific objectives and is
primarily targeted  to  an  external  audience.     Such  guidance  is useful  for  both
homeowners  and technical  personnel involved  in radon measurement  or mitigation.   For
example, EPA's "A  Citizen's Guide" provides homeowners with guidance on a number of
issues,  such  as evaluation of  homeowner  risk,  where to  go  and  how to  interpret
measurements, and what to  do in the event that elevated  levels  are detected in the
home.  Guidance differs from  standards, however, in that the recommendations are not
mandatory;  accordingly, guidance  has  the advantage that  no regulatory enforcement
program is  necessary.   However,  States  should  note  that  although  guidance is   less
structured than  setting standards (because guidance is simply a  recommendation),  it
carries with it the disadvantage that  people may  choose to  ignore the recommendations.
Guidance  is  likely to change  over time as the  state  of  technical  knowledge improves;
however, at least some preliminary  guidance is  desirable at  an early  stage  in order to
avoid clearly undesirable  actions.   For  example, Pennsylvania  initially issued  a testing
advisory  for  35  of  the 67 counties  in the State in 1987  (primarily to  address  the
Reading  Prong),  but may extend it to all  of the State's counties  on  the basis of  new
data.  In October 1987, New Jersey issued a press statement extending testing to areas
not previously officially listed as having a  potential for elevated  radon levels.

3.2.1.4  Develop Standards.   Standards comprise the strongest form  of guidance  and,
since they  are mandatory,  generally require more time and  resources to  develop   and
implement.    Standards  also   require  specific statutory   authority and  an  enforcement
program; these program are sometimes cumbersome and  expensive  but are necessary to
ensure compliance.   Since  indoor  radon involves a homeowner's  private  actions within
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his  or  her  own  house,  enforcement  of some  types  of  radon  standards  may be
particularly difficult.   For  example,  Florida is  gathering  information  with  which it will
finalize  implementation  of  radon  standards for  new houses;  enforcement  of these
standards  will  occur prior to  occupancy.   Finally,  informal  policy  statements, rather
than  either guidance or standards,  may be  adequate.   The appropriate tool (policy,
guidance, or standard)  may  also vary over the life of  the  program.

3.2.2  Policy Issues

3.2.2.1  State Role  in Overall  Problem Solution.   The process of developing goals and
policies - especially the  guidance  and standards that are  externally  directed -  pro-
vokes a number of questions which require  policy choices.  The most fundamental of
these questions is  the  State's role  in the overall  radon problem  solution.  Since many
other parties are also involved (EPA, local governments,  the  private sector, and home-
owners, to name a few), the  State  should consider the  extent of its own involvement,
i.e.,  where its  expertise and  capabilities  are most  usefully  applied,  and  a  level  of
activity that is consistent with  its public mandate.

3.22.2   Need/Authority for Standard  vs.  Guidance.   With  respect  to standards  and
guidance  in  particular,  the  State  may  want to  choose   between these  two forms  of
directives.  Both provide information and direction; however,  standards  are much  more
stringent,  are likely  to  be  more  effective  in  achieving  a  given  objective,  require  a
longer time to develop  (as a result  of both technical development needs and the extent
of public  participation and comment), require resources for monitoring and enforcement,
and  require specific statutory  authority.   Finally, because  compliance with the  standard
typically  entails  some cost,  a  standard  involves a careful balancing of the  magnitude
and  distribution  of costs and benefits.   In many cases, guidance  (rather than standards)
may be  sufficient, for example, when State needs change with time, since guidance is
often more flexible.
         Balance  Between  Uncertainty  and Desire for Specific  Guidance.   Finally, for
either guidance or standards, a  balance must  be struck between the uncertainty that
currently  surrounds the  radon  problem  (and,  therefore, the  difficulty  of  formulating
specific recommendations)  and  the  need  of  citizens  to  have  clear  and unambiguous
guidance.
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3.2.3   Potentially Useful Existing Resources

A  number of States have already developed  guidance  of  some sort (especially for
homeowners), and EPA has also developed a number of documents that illustrate radon
goals and guidance.   In  addition,  EPA standards dealing with  other  kinds of radon
problems  contain useful  discussion and analysis that  could assist States in formulating
their own  guidance and standards.  Specific sources of information include:

1.    State guidance (e.g.,  PA, NY, VA).
2.    CRCPD 'Criteria for Adequate Radiation Control Programs  (Radon).*
3.    EPA brochure:  "A Citizen's Guide  to Radon:  What  It  Is and  What to Do About It.'
4.    National  Council on Radiation Protection, Report #78 ("Evaluation  of  Occupational
     and  Environmental Exposures to Radon Daughters  in the United  States").
5.    Related  EPA  radiation  standards  (e.g.,  1983  Uranium  Mill  Tailings  Standards;
     Superfund  Records  of Decision  pertaining  to  radon;  1979 Radiation Protection
     Recommendations to  the State of  Florida).
6.    "Health  Risks  of Radon and Other Internally Deposited Alpha-Emitters:  BEIR IV,"
     National  Academy  Press, Washington,  DC, 1988.
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3.3  STRATEGY

Strategy is the  third  Key Element  of  a State  radon program.  A strategy consists of  a
plan to  achieve explicit goals  or  objectives,  and  should  include  a clear  statement of
objectives,  a  process  to  develop  policy  options,  collect  sufficient  (not  "perfect")
information with which to choose among these options, and analyze and present options
to management in a clear  framework  is desirable.   Choices among various strategic
options  may require the  participation  of  senior-level  management.   A  number  of
questions must  be addressed  in order to make a strategy choice.  For example,  which
agency or agencies should be responsible for the  program?  Should a separate formal
program be  created?  To what extent should the  State be involved in actual  measure-
ment or  mitigation  (versus,  for  example,  local governments  or the  private sector)?
Should  the  involvement  take  the  form of regulation and  enforcement  or  guidance?
Broadly defined, what should be the  relative priority of the radon program versus other
competing programs?   After  an  initial  strategy is  developed,  the  strategic planning
activity becomes an ongoing  part of the program in order to adapt the strategy to new
circumstances or new information.   As  illustrated  in  Figure 3-3, the activities included
in this Key Element are:

1.   Develop a Strategy.
2.   Develop an Implementation Plan.
3.   Reevaluate  Strategy and Plan  as Needed.

3.3.1   Activities

3.3.1.1    Develop a  Strategy.  Strategy  development  is  likely  to be one  of the  first
activities the State undertakes  as  part  of a radon program  -  even if the  "strategy"
or program  plan  is implicit  or ad  hoc  in  nature.   Some strategy  is often  developed
before a  task force or  working group  meets.  The  development of a strategy  initially
entails identification  of  objectives  and  measures  of  success,  available authority, and
other external factors which  limit  available  strategic  options.   Within these  limits, the
State should identify strategic options  that  can  achieve its  objectives,  and  should
choose among  them.   Ideally, the process should include a number of  components,
including  a review of the problem  as  it is known in the State, a  statement  of program
                                        3-16

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goals, an identification  of the elements  of the strategy  (e.g., problem assessment), and
options to implement each  element.   In  a number of States, strategy formulation has
been delegated to task forces  or radon-specific working groups.   The report  of a task
force  can provide  the foundation  for an  initial  strategy  or support for the further
development of a strategy  already  in place.   For example,  in  Colorado, a  Governor-
appointed  task force submitted  a  draft  workplan for the Governor's approval which
addresses   the  need  for  problem   identification  and  assignments  of  interagency
responsibilities  and coordination.  Maryland's task force was  also  created  to  determine
the extent  of the  radon problem and  to recommend a  course of action.   Virginia's task
force recently  published  its  summary  of  the  radon  problem, which included in  the
Executive Summary a six-point  recommendation to address  the situation.

3.3.1.2   Develop  an Implementation  Ran.  This  activity  is typically a follow-up to the
development of  the  strategy  and  entails a  determination  of specific  implementation
actions.  For example,  the implementation plan might choose among the activities  listed
in this report,  develop  a schedule  and approach  for  implementing them,  and estimate
specific resource requirements.  The schedule can  be updated  annually, or  as  necessary
to reflect  new  activities and  projects.

3.3.1.3   Reevafuate  Strategy  and  Ran As  Needed.   While any strategy should be
reevaluated  periodically, this reevaluation  is particularly  useful for  a radon  program,
since the level of  public  understanding, availability of  measurement data, and technical
capabilities are changing rapidly.   As public understanding grows, information targeted
to specific homeowner conditions might be appropriate.  By  providing a  more reliable
assessment of the problem, measurement  data   permit an  important  reassessment  of
strategy,   which   may  range   from  redirection  to  a  program  of  information  and
prevention  (if  little or no  problem  is  found) to expansion  of the program to address
mitigation  (if   elevated  levels  are  widespread).     Finally,  the   development  of  new
technology  can  prompt  a  reevaluation  of guidance  or  standards  (e.g., a  low-cost
mitigation technique might make a  lower standard achievable  at reasonable cost).

3.3.2  Policy Issues

3.3.2.1  Problem  Definition.     Initial   determination  of whether   indoor  radon  is  a
significant concern in a State presents a practical  problem.  Without measurements, the
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State is unable to  determine that radon  is a problem.   However,  measurements require
resources, and the demand for resources generally requires  evidence  of  a problem.
Small-scale  surveys and collection of private measurement data may provide a solution
to this "catch-22" if they happen to detect elevated levels.   Alternatively, a State must
rely  on larger  surveys  or  on the development of reliable  predictive  techniques in  order
to measure the scope of  the radon problem  in  the State.  At present,  since  a reliable
predictive technique  does  not  exist,  testing  across the  State  is the  best available
solution.

3.3.2.2   Choice  of Target  Few Houses at High  Risk  vs.  Many Houses at Low Risk.
While attention to  high and low  risk houses is not necessarily  mutually exclusive, a
focus  on  one of  the two is typically  a  practical  result of  budget  and  resource
limitations.   This  priority  may also  change with time,   as  the  program  develops.
Typically,  only a few  houses have  very high levels, while a  much  larger number  of
houses  may have  lower,  but  still  elevated levels.   In  the former case,  individual risks
could  be very high  and,  hence,  very  quick action is  needed  to  mitigate  the  risk.
However,  a program  that  successfully  identifies  and  mitigates  all  of  the  high risk
situations (for example, above 20 pCi/L) may still have  only reduced a small fraction  of
the  total  public health risk,  since  the  bulk  of  the   population  risk is  likely  to  be
associated with relatively low  levels of indoor radon (for example,  between 4 and 20
pCi/L).   To date, most operational radon programs  have  developed in response  to the
discovery of high risk areas (e.g.,  the Reading Prong States of New Jersey, New  York,
and  Pennsylvania).   One  solution to  the  tradeoff  problem  is  to  use the  discovery  of
highly  elevated levels  as  a trigger  for  local  area  testing.   This  approach is used  in
both New Jersey and New York, which  use a trigger level of 200 pCi/L.

3.3.2.3   Choice of  Focus:  Mitigation  vs.  Prevention.   Another  tradeoff  involves the
choice of focus: mitigation or prevention.  Once again, even though  a radon program
can  mix  mitigation  and  prevention elements,  resource  limitations may  require  that
priority be given to  one  or  the other.   In this case,  the  facts  normally suggest that
mitigation is more  important, since the number of  existing houses is much greater than
the number of new houses each  year.   However,  the  cost of prevention might  be far
less  than the  cost of  mitigation; if this  is the case, it  may be prudent  to  contain the
scope  of  the problem  by focusing on  prevention.   Thus  far,  only Florida  has focused
primarily  on  prevention (since its radon  problem was discovered  initially  in  the context
                                        3-19

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of  reclaimed  phosphate  mining  lands,  which  are  the  site  of  new  construction).
However,  other  States  with  operational  radon  programs  are  also  expanding  their
prevention activities (e.g., in New Jersey).

3.3.3  Potentially Useful  Existing Resources

1.   State Task Force reports (e.g.,  ME, IL, VA, CO).
2.   EPA Strategy  Document, 'Health Risks Due to  Radon  in Structures: A Strategy
     and Management Plan for Assessment and Mitigation,1  September  1985.
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3.4  ADMINISTRATION

The  fourth Key  Element is Administration,  which addresses the operation of the radon
program  in  the  context  of   the   existing   State   institutional   framework.    While
administrative  techniques  and procedures are  likely to  vary from  State  to  State, seven
activities (as shown in Figure  3-4)  illustrate the range  of  potential  radon activities  and
are fairly basic to any environmental program.   These seven activities are as follows:

1.  Provide Information to Decision makers.
2.  Acquire and  Allocate  Resources.
3.  Designate Responsibilities of Staff and  Other Groups.
4.  Provide Management  Oversight and Direction.
5.  Monitor Program Progress  and Provide Feedback.
6.  Identify the Need for, and  Support Executive or Legislative Initiatives.
7.  Provide Quick Response Capability.

3.4.1   Activities

3.4.1.1   Provide Information to Decisionmakers.  Typically, responsibility for the day-
to-day operation  of  a  State radon program will  be vested in  a division,  department,  or
some other operational group.   The  head of such a group, as well as more senior levels
of management,  will be required to make policy  and  administrative decisions  and  will
need   information to  do  so.    Examples of  useful  information  include  reports  and
briefings  that  provide  background   information  such  as  statistical   summaries   of
measurement  data, management tracking system outputs that  indicate program progress
(e.g., number of houses  measured,  number of  demonstration  projects completed),  and
options papers  that  brief management  on policy choices.   While  the nature of  the
information  will  change,  information  is  needed on  a  continuous  basis starting with
program inception.

3.4.1.2  Acquire and Allocate Resources.   Any significant response to the radon  problem
will obviously  require resources, both in  terms  of personnel and  dollars.   The  level  of
resource commitment depends  on the role the State chooses to play  (as indicated by  its
goals and  objectives).  This commitment  also depends on the  availability of resources,
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the  relative  priority   of  radon  versus  other  environmental  and   non-environmental
programs,  and the extent of the problem within  the State.  Early in program  develop-
ment,  resource requirements  should  be estimated for desired program activities,  recog-
nizing  that many  activities  can  be  accomplished  with  varying  degrees of  resource
commitment.    Ideally,  the  resource  estimates  should  be  prepared   sufficiently  in
advance of program  requirements to allow time to acquire additional  resources through
the normal budgetary  or  legislative  process.   Alternatively,  a number  of States have
borrowed or reprogrammed resources from other programs pending a  specific appropria-
tion.   In some States, specific  radon appropriations allocating both  dollars and person-
nel have been passed by  State  legislatures,  for  example,  in Pennsylvania, New  York,
New Jersey,  Florida,  Connecticut, and  11  other States.   Resources should be allocated
among the various  program  activities  in  order  of priority,  as established by the stra-
tegic implementation  plan.   As the program develops and  circumstances change, resour-
ces will  probably  need to  be reallocated  to accommodate changes  in  priorities,  quick
turnaround tasks,  and so forth.

So far,  resources have  been   acquired  and  allocated  in  a  variety of  ways.   For
example, Maine has  no specific  radon appropriation,  although  three and  one-half full-
time equivalent employees are working on radon-related tasks using general funds from
the Department of Human Services and the  Maine Public  Health Laboratory.  Maine has
also sponsored  an  "at  cost"  testing  program  for radon  in  air  and   water.   New
Hampshire, Iowa,  and several other  States have  obtained funds through  appropriations
from the Exxon  oil overcharge litigation.  New Hampshire is  using the funds  for an 18-
month  State  radon survey,  and Iowa is studying  the effects  of home weatherization on
indoor  radon  levels.    New  York is using these funds  for free testing  and training
programs.

3.4.1.3   Designate Responsibilities of Staff and Other Groups.   Effective  administration
of a  radon  program entails designation of  both  the responsibility and authority  to
implement  various program activities.   In addition, in the  context of the  radon problem,
it  is also essential to utilize existing expertise throughout the State administration, and
to involve  in the  program groups or individuals that will  necessarily  play  an  important
role in  implementing the program.  In most States, a single agency has been designated
(often  informally)  as  the  radon  program  lead; however,  in  New  York and Idaho, the
lead is shared  among two or  three agencies based on expertise.   In  many States,
                                       3-23

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interagency involvement  has  been  effected  by  formal  or  informal cooperative agree-
ments,  task forces, working groups, and jointly sponsored research or other programs.
in order  to  determine where  additional  joint  efforts  might  be useful,  radon  activities
by other  States, EPA,  and other Federal agencies should also be monitored  (which is
useful also as  part of an ongoing  information collection effort).   EPA  Regional radia-
tion  representatives can  be  particularly  helpful  in this regard.   State agencies  that
should  be contacted or considered  as members  of a working group  include  the State
Radiation  Control  Program,  the  State  environmental  agency,  the  State  health
department, the State agencies for air pollution control, energy, and housing,  the State
geologist, health laboratories,  radiophysics laboratories,  State academic  institutions,  and
State finance  agencies.   In addition, task forces have  sometimes included representa-
tives  of local governments, citizens groups, contractor  groups and trade  associations,
realtors, technical  specialists,  and members of  the medical community.

3.4.1.4   Provide  Management Oversight and  Direction.   Several  characteristics of  the
radon  problem  suggest  that  management oversight  and  direction will  be particularly
important.   First,  the  nature  of the problem  is  still  under  study, and new information
is now frequent.    In  this environment,  it will often be necessary  to   reconsider  im-
plementation tactics, and  to  reprioritize  activities  based on  unanticipated findings.    In
this  event,  it is  particularly  important that  new information is routed  to  the proper
person  or agency so  that it is  used effectively, especially  as the program  develops.
Second, since  the radon  problem does  not fall  within a  conventional regulatory frame-
work, but rather involves  a wide variety of parties -  and directly involves  homeowners
- few good analogies exist from  which to borrow administrative experience.

3.4.1.5   Monitor Program Progress  and Provide Feedback.  A mechanism  to evaluate
program progress and  to  provide feedback is also needed.   The structure of the moni-
toring  program  will depend  in  part on  the  size  and  complexity of the  State  radon
program (a larger, more complicated system benefits from a  more elaborately structured
approach).  A  highly  structured monitoring program may be difficult to  achieve  in  the
case  of radon,  since measures of "success" are not easily  established.   A system  that
tracks  several   indicators  of  program  effectiveness  (e.g.,  number  of   calls   handled,
number of  houses  measured or mitigated,  number of brochures distributed)  may be
sufficient,  at  least  as  a start.  Additional measures ideally  should be described  in  the
implementation plan, along with milestones for  each activity.
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3.4.1.6    Identify  the  Need  for,  and  Support  Legislative  or  Executive  Initiatives.
Because the  risk of naturally-occurring indoor radon typically  is not  already  addressed
in  State  legislation  or  executive  mandates,  resolution  of  program  authority  is  an
important prerequisite  tor  formulation  of  a radon strategy.    At first,  authority  can
often be found in  State  general public  health  statutes.   However, after  the  initial
strategy  is developed, new circumstances may create a need for additional legislative or
executive-level action, the  development of  which will require information and  support
from the  State  radon program.  Specific tasks might  include  identification of additional
authorities that  may be  required,  monitoring  of  legislative  developments  within the
State or  in   other  States, and  the  development  of  analyses  or options  papers  for
presentation  before executive committees  or State legislatures.   Whether or not  addi-
tional authority  is  required  depends  strongly  on  the  objectives of  the State  radon
program and  the role the State chooses to  play in  addressing the radon  problem.  The
National  Conference of  State  Legislatures  has prepared  an  issue  and  policy  option
report that examines the nature  and  extent of the  radon problem, existing Federal  and
State programs,  and policy options available to State legislators.4

3.4.1.7   Provide Quick  Response Capability.   The  discovery  of highly elevated  radon
levels  in  the  Reading  Prong  in December 1984,  elevated levels  apparently  off the
Reading  Prong  in Clinton, New Jersey in 1986, and elevated  levels in  a Fairfax  County,
Virginia  elementary school  in  1987 demonstrate that surprises can occur which  require
relatively  urgent attention.    This activity  is oriented  towards  providing a  quick  re-
sponse  process  in anticipation  of such  problems.   At a  minimum, this  activity  should
include  preparation of guidance regarding  how  to proceed,  and definition  of critical
events (i.e.,  what  constitutes  an "urgent*  problem).   Additional  efforts  might  include
designation  of a "quick  response" team (which  may  serve similar functions for other
urgent events) that is  prepared  to visit a site or  consult with  a homeowner on rela-
tively short  notice.   Since  radon  risks depend  on  exposure  over a period of  time,
"short notice"  probably means  days or  perhaps weeks, rather than minutes or hours.
     State Radon Programs:  The Role of Legislation. P. Doyle and L  Morandi, Vol. 13,
     No.  10,  National Conference  of  State  Legislatures,  1050  17th  St.,  Suite  2100,
     Denver, CO 80265,  April 1988.
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3.4.2  Policy Issues

3.4.2.1  How to Cope With Inadequate Resources:   While substantive policy issues arise
mostly in the context of specific program  activities, overall administration of  the radon
program itself poses several  important policy  questions.   The most common of these
questions is how to administer a viable and effective radon program in the absence of
"sufficient*  resources.   So  far, States  have shown a  great  deal  of resourcefulness in
utilizing existing funds and capabilities effectively.   For example,  West Virginia  has  no
funds  allocated specifically  to radon; however,  the  West  Virginia  Industrial  Hygiene
Division in DOH handles about 10 calls a week,  provides phone  consultation  on next
steps  after an  initial  screening,  and  has  performed  follow-up measurements  (about
once a month).  In North Dakota, another State with  no  radon funding,  the Division of
Environmental Engineering has devoted about one full-time equivalent employee  and has
used existing  funds from the  Division to  disseminate  information,  answer homeowner
inquiries, and  perform follow-up measurements.

States can also leverage private sector resources  in  a variety of ways.   For example,
Massachusetts  collects measurement  data  from private companies  performing  tests in
the  State.   In addition, there  exists  a  growing amount  of  information from EPA  and
from  States  that  can  be  of  use to a  State implementing  a program  on a limited
budget.  Many examples  of published materials are  included in this document under the
sections  entitled "Potentially  Useful  Existing  Resources/   Private  sector participants
often  have  an  incentive  to  exchange   information  with   the   State (e.g.,  State
measurement  data  provide  market information), and sometimes can be called upon  for
help (e.g.,  as a source of private measurement data).   Nonprofit organizations  can  be
used  as   sources   of information  or  means  of  information  distribution   (e.g.,  the
American  Cancer  Association,  American  Lung  Association,   American   Medical
Association).   States  can also use  local authorities to assist them (e.g., local  health
departments),  such as in California,  Colorado,  Montana,  New  Jersey, New York, Ohio,
Oklahoma,  and  Virginia.   In addition, States can use local colleges or universities, such
as in Iowa, Kansas, Maine, Minnesota, New Hampshire, and  North  Dakota.   Inevitably,
however, policy-makers must allocate resources among  competing programs.  From the
perspective of the radon problem, it is important that these resource decisions be made
with  an adequate  appreciation of the extent  of the  radon  problem, and the  cost of
activities required to address it.
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3.4.3  Potentially Useful Existing Resources

1. "Summary of State Radon Programs."
2. Radon or radiation expertise in  State health and/or environmental agencies.
3. Expertise in  State  health labs.
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3.5  PROBLEM CHARACTERIZATION

Problem Characterization  involves activities which measure, predict,  and analyze  radon
exposure  and  radon  health  risks.   As  illustrated  in  Figure  3-5,  it includes activities
such  as  surveys,  geologic  assessment, data  collection  and analysis,  collection  of
epidemiologic data, data quality assurance, and subsidized measurement programs. The
following seven  activities are described individually below:

1.  Measure Indoor Radon  Levels in Air.
2.  Measure Radionuclides  in Water.
3.  Determine Geology vs.  Indoor Radon Level Relationship.
4.  Ensure  Data Consistency  and Reliability.
5.  Provide Free Testing.
6.  Register/Certify/License  Measurement Companies.
7.  Maintain Radon/Cancer  Registry.

3.5.1   Activities

3.5.1.1  Measure Indoor  Radon  Levels in Air.  This activity potentially includes a wide
variety  of   separate  tasks,  including  measurement  of 'hot  spot"  areas,  wide-scale
surveys, both screening and follow-up measurements, collection of private  measurement
data,  and  evaluation of measurement  data.   Since radon cannot  be detected by the
senses, measurement constitutes an ongoing component of  a radon  program.   Early on,
this provides critical input to  the process of  defining the State's role and  developing a
radon program strategy by  indicating the scope and magnitude of  the problem.   Later,
measurements  indicate  the  success  of mitigation and prevention efforts.

To  date, State  involvement in  this activity varies  widely.   Some States,  such as the
Reading Prong  States,  have completed  extensive State-funded screening programs and
have measurement  follow-up programs in  place and well underway.   Other States have
performed  a limited number  of measurements, but  collect and review private or other
public  measurement data as  an indication of the extent of the radon problem in their
States   (e.g., Oregon and Washington use Bonneville Power Administration (BPA)  data).
Vermont,  Idaho, and  others  have  performed  surveys  based on  potential hot  spots.
Maryland compiles  and analyzes private data.
                                        3-28

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Data   management  practices  also  vary;   many   States,  including   Massachusetts,
Pennsylvania,  and Virginia,  have  computerized the  measurement  data  in  order  to
perform statistical analyses to aid policy  decisions,  design of further surveys, targeting
of information campaigns,  and so  forth.   Ten  States  have also completed State-wide
surveys as  part of the EPA State Radon  Survey Program,  and seven  more States and
Indian Tribes  in  three  States  are  participating  in  FY  88.  The cost  to a State  of
participation in the EPA  State program has ranged from $30,000 to $100,000, depending
on whether an experienced research group already exists in the  State.

3.5.1.2  Measure  Radionuclides in Water.   While only a few States  are likely to have a
significant problem with  radon in water, it is  a  very  important problem in  those States
(e.g.,  in Maine and possibly  New Hampshire).  Radon can be transported in  the water
through several  means, either  as a  dissolved  gas or,  indirectly,  through transport  of
the parent isotopes, uranium  and  radium (which  themselves present radioactive hazards).
Water measurements are at present the only reliable  means  to determine  whether well
water  contains  elevated radon levels  (municipal water  supplies  are far less  likely  to
contain significant levels  of  radon if  they   have  been aerated,  since the  radon  is
released  prior to consumption).

3.5.1.3  Determine Geology vs. Indoor Radon  Level Relationship.  While reliable methods
of predicting elevated  indoor  radon  levels are still being developed, geologic formations
naturally  enriched in  uranium, thorium,  or radium  may  provide an indication of where
elevated indoor  radon levels  might  be found.   Although it  is  believed that  geology and
indoor radon levels are  related, current  research is ongoing.  A  correlation has  not yet
been   statistically  established  and  variables  have  yet  to  be  determined.    Such   a
relationship  can  initially  be investigated based  on  existing surface geology  data (for
example,  using  the U.S.  DOE National Uranium Resource Evaluation  (NURE)  fly-over
data)   on  either  radium,  uranium,   or  thorium   concentration and  known centers  of
population.   This approach has been used  successfully by  States  participating in the
State  EPA Radon Survey  Program  in order to target  measurement activities to  specific
locations which  geologic data suggest are more likely to contain elevated levels.  Such
information,  if  supplemented by further data analysis and/or actual measurements, could
also   be  used for the  purpose  of  advising  homeowners  in  areas with a high  radon
potential that measurements would  be advisable.  Since this activity  is of particular use
in the design of  State  surveys, and since it also provides a preliminary  indication  of
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the likelihood  of elevated radon levels in the State, it should generally  be performed at
a fairly early stage of  program development and before a State survey  is conducted.

3.5.1.4  Ensure Data Consistency and Reliability.  Since homeowners and State agencies
will depend strongly on measurements  in  choosing whether to  pursue or recommend
mitigation,  and in  assessing the severity and scope of the radon  problem,  it is essential
that  measurement data  are  collected and  interpreted  in a  consistent,  reliable fashion.
A  number  of  different  steps  can be  taken  to foster data consistency; one  of  the most
important is the establishment of standard  measurement  procedures or  protocols.  EPA
has already developed radon measurement protocols for residences, and has published
these protocols in two reports.  EPA is  also developing protocols for new  measurement
methods to be  published  in  early  1988, and is working on protocols  for schools and
workplaces.  Thus, a  simple (and  so far common)  step for the State  is  to  adopt the
EPA protocols, and to use them in the conduct of any State measurements.  Whether
or not these  protocols are adopted,  the State will still  need to confront the issue of
interpreting  measurements  by  private  measurement companies that  may  not have
followed  the protocol.    One  way  is to incorporate the  protocols in training programs
for private companies, and to disseminate literature describing the  protocols. Certifica-
tion  or licensing  (see below) is  another  way to  help  to  ensure  the consistency  of
private data, although  these  mechanisms entail other potential drawbacks.

3.5.1.5   Provide  Free  Testing.   Free testing is  an  effective way to encourage home-
owners to  have  measurements performed, and also represents one way for the State to
collect measurement  information.    While  free  testing  can  be resource-intensive,  a
number  of options  exist  by which  the resource  requirements  can be limited.   For
example,  several  States will  provide free retesting,  provided  that the  homeowner first
performs a screening  test at  his  or  her  own expense.   Other  States provide  retests
only if the screening  test is above  a certain threshold.    Finally,  free tests  can be
limited to homeowners in a region  already known to have a high probability of elevated
radon levels.  Utah  provides  testing  at  cost.   However, some  States avoid free testing
due to a concern that it may imply  government responsibility to solve  the problem,  or
because  State-sponsored testing is  costly  and  inexpensive  detectors  are  available  to
almost all  homeowners.
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3.5.1.6  Register/Certify/License Measurement Companies.  The advantage of registering,
certifying, or  licensing measurement  companies is that  the State is able to  exercise
some control  over the reliability, consistency, and quality of the measurement data that
the companies provide,  thereby discouraging  unethical  or  incompetent firms from doing
business.  When unethical practices occur, existing State consumer protection laws  may
provide some  relief.   For example, the  Indiana  Attorney General  sued a  measurement
and  mitigation  company under State law.  This case  was settled successfully  in 1987.

In general,  the difference between registration,  certification,  and  licensing  (the form of
each can  vary)  centers around  whether  the process is mandatory, whether nonpar-
ticipating  (e.g., non-certified  or non-licensed)  firms are excluded  from the  market,  and
whether a  fee  is charged by the  State for the process.  Licensing is typically the most
restrictive form of "quality  control," while registration  is  the  least  restrictive.   EPA's
voluntary  Radon  Measurement  Proficiency  program  is  a  form  of  registration  which
currently entails  no fee.  Licensing and  certification require  a greater  State resource
commitment for   administration,  especially  for  mandatory  licensing  programs  which
necessitate  an enforcement  program by  the State.  In  Nebraska, regulations exist which
allow the  State  to require  registration  of  anyone  performing radiation  protection or
health  physics consultations or surveys.   The State  is currently  developing the criteria
that  must  be met prior to  certification  or registration  of individuals  or firms.   in
Delaware, a registration  requirement for any radiation measurement also  exists  which
specifies minimum training  and work  experience.    Recently,  the Virginia Task  Force
recommended  that Virginia  not require  licensing at this time  (registration  and  certifica-
tion  were not discussed  as  separate possibilities).  As a result of an August 1986  law,
New Jersey is developing a mandatory  program  of certification of  testing and mitigation
firms.  Pennsylvania passed  a similar law in  July 1987.

3.5.1.7   Maintain Radon/Cancer  Registry.    Currently,  a number  of  States maintain a
cancer registry (e.g., Colorado, Florida,  Idaho, and South Carolina), wherein  the  States
record epidemiologic information about  cancer victims  for use  in  later medical studies.
However,  only a few States  (New Jersey and  New  York  among  them)  have  added
information  regarding  radon exposure  to the registry.   While  maintenance of  a  radon
registry will  only provide results   in  the  long   term,  this  information  collection  effort
can  assist in  addressing the uncertainty regarding radon  health risks.   In  general, the
activity  requires  that radon  measurements be associated  with homeowner names  and
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other information  describing  living  habits,  and  that  such  information  be  maintained
(confidentially) by  the State health department responsible for  the cancer registry and
thereby associated with cancer  patients at a later  date.

3.5.2  Policy Issues

3.5.2.1   Confidentiality of Records.  The homeowner has  an interest  in maintaining the
confidentiality  of his  or her  measurement  result  in  order to maintain privacy and  to
protect   the   property  value   of  his  or  her  house.     However,  this   desire  for
confidentiality  must be  balanced against the need of the  State to gather measurement
data in order to assess and  respond  to a  potential public health  hazard.  Since  many
States  have  disclosure laws,  it  is  often  difficult for the  State to  keep  the  data
confidential, even  if it so desires.   States have responded to this issue in a variety of
ways.   In many cases,  measurement data are stored only  at an aggregate level, so that
an  individual  house cannot be identified.   For example, Virginia records measurement
data using a location code that was devised originally for  other public health  purposes.
Nine States maintain the test data at a zip  code  level  (without the address).   In a few
cases (e.g., New Jersey, Pennsylvania), submission of measurement data to the State is
now mandated  by  law; however, the  law  also  requires  the State to keep  the  data
confidential.

3.5.2.2   Comparability/Quality  of  Private  Data.   States have an  interest  in  collecting
measurement  data from homeowners or private measurement firms; however, this source
of data does  not  always conform  to the type of  measurement method or measurement
protocol that  may be used in  State-sponsored surveys, nor are  private data likely  to
represent a statistically designed  measurement sample.   As a result,  mixing the two
sources  of data could  bias the overall interpretation, and decrease  its reliability.   This
issue can be addressed in  several ways.  First, through the distribution of recommended
measurement  protocols (e.g.,  the  EPA  Radon  Measurement Protocols) or institution of a
certification program  (see below), the State  can promote the use  of consistent, reliable
measurement  methods and a  common documentation.   With  respect to  analysis  of
private data,  some States are including the  data within  the same database that contains
State measurement data,  but adding a notation to identify the data source, while other
States are maintaining the  private  data in a separate database or as paper  copy  only.
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Computer  databases in  Idaho,  Maine,  and Massachusetts include  private  measurement
data.

3.5.2.3   industrial vs. Natural Indoor Radon.   A number of radon measurements have
been made that reflect technologically  enhanced sources of radon, such as  phosphate
slag, uranium and thorium mine and mill tailings, and  building materials that  have been
contaminated  by  radioactive waste  or uranium fuel  cycle programs (e.g., at  Grand
Junction, Colorado,  or the Montclair/Glen  Ridge Superfund  site in  New Jersey).   These
industrial sources of radon  imply a  much  different State response than  natural  radon,
even though the health risk  may be  similar.  Both natural and technologically enhanced
sources may  result  in elevated  indoor  radon  levels;  however, a specific legal response
against  the cause  of the  problem  (e.g.,  an  action  against  a potentially  responsible
party under  CERCLA)  may  be  available  for a  technologically  enhanced  source.
Industrial sources of radon  are  also  subject to different remedial action programs (e.g.,
DOE programs, or Superfund),  and  are  frequently governed   by  existing  Federal
radiation standards   (e.g.,  for  uranium mine and mill  tailings sites).    Hence, it  is
important  to  identify industrial  sources of  radon  as   such  in order to respond  in  an
appropriate manner.  However,  experience  gained  by  the States in responding to these
industrial problems provides  a base of measurement experience that can be  particularly
useful in addressing the natural indoor radon issue.

3.5.2.4  Real  Estate Transactions.  Radon  measurements are now frequently requested
as  part of real  estate transactions  in  order to determine  prior  to purchase  whether
houses  have  elevated radon levels.   A difficulty arises, however, because radon  meas-
urements that reflect the long-term  average  radon level also require time - often too
long  in  the context  of a  real estate  transaction, which may be contractually  concluded
in a  few  weeks.   Furthermore, the  seller, while  still  residing in  a  house,  can  easily
bias a measurement by ventilating the  house  more than  usual or by  other methods.   In
some areas where  elevated radon levels have  been  discovered (e.g., on the Reading
Prong),  real  estate  agents  are  required to inform prospective  buyers of the potential
problem, thereby promoting the use  of measurements.  Rather  than using screening
measurements alone (which  only provide an  initial conservative measure  of  radon level
and,  therefore,  do  not necessarily  provide  a  good  indication of  long-term  average
levels),  escrow  accounts are now  being used  in  the  Reading  Prong area in order to
protect  the buyers'  interest.   In  such  a  case, an agreed-upon  amount  of money  is
                                       3-34

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placed in escrow to cover  mitigation  of  high  radon  levels  if they are found,  and  a
long-term  measurement  is  initiated  (e.g.,  using an alpha track device).    If elevated
levels are  not  present,  the  escrow  is  returned to  the  seller.   Recently,  the Virginia
Task  Force  recommended that the State refrain from mandating radon testing prior  to
real estate transactions,  although  it affirmed the right  of  the  buyer to request such  a
test.

3.5.3  Potentially Useful  Basting Resources

1.   State  measurements.
2.   EPA measurements.
3.   State  EPA  Radon Survey Program.
4.   Other Federal data  (e.g., from BPA, DOE).
5.   Private  data  and   local government  data,  individual  measurements,  and  small
     surveys.
6.   State  measurement capability for industrial  radon.
7.   State  geologic data;  U.S.  DOE  NURE data;  U.S. Soil  Conservation  Service Soil
     Reports.
8.   EPA Radon Measurement Protocols.
                                       3-35

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3.6  PROBLEM RESPONSE

This sixth Key Element includes activities designed to  reduce existing  indoor radon
exposure and to  prevent elevated levels  in  new  houses  and  reoccurrence  in  houses
where  elevated levels  have been mitigated.   As  illustrated  in Figure  3-6,  Problem
Response includes  training  of  mitigation  contractors,   demonstration  of   mitigation
techniques, diagnosis,  quality  assurance,  development  of preventive  techniques,  and
formulation of building codes.  Seven activities are discussed below:

1.  Provide Mitigation Training.
2.  Assist Diagnosis.
3.  Develop  Preventive Construction Techniques.
4.  Conduct Demonstration  Projects.
5.  Register/Certify/License  Mitigation Contractors.
6.  Consider  Financial Assistance.
7.  Develop  Building Codes.

3.6.1   Activities

3.6.1.1    Provide Mitigation  Training.   Training  could include programs for health risk
assessment,  measurement,  diagnosis, and/or mitigation oriented towards both private
sector  contractors   or  suppliers and government  (potentially  both  State  and local)
personnel.  An educational program is required  because the  existing base  of knowledge
is changing  rapidly, very few   private contractors have been trained,  and training  is
needed due  to the  complexity  of the problem and the  custom  nature  of  the  mitigation
solution  (i.e.,  every  house  is  different,  hence  mitigation  requires  skilled technicians).
A variety of training programs   have  already  been offered by States, most notably by
New York,  which  developed a prototype  training program for  radon diagnosis  and
mitigation in 1986.  EPA and  New York subsequently developed an expanded and revised
training  program  in  a  cooperative  effort.   This  new  training  program has  been
delivered  by EPA to representatives  of 40  States; a  videotape  of the  program  is  now
available to the States from EPA regional offices.
                                        3-36

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3.6.1.2   Assist  Diagnosis.   In addition  to the mitigation  itself,  a critical  part  of  the
mitigation  process is the diagnosis of the  source of radon, and design  of  the most
cost-effective  mitigation  technique.    In  most   areas,  only  a  limited   number  of
technicians are  now  skilled  in  radon diagnostic work;  as a result, State  participation in
the diagnosis is  useful, both as a  form of direct aid to the homeowner, and  as a  means
to  learn  about  the  effectiveness  of various types of  mitigation.   Many  States (New
Jersey, New York, Ohio, Pennsylvania,  Tennessee, and  Virginia) are now participating in
EPA's Office  of Radiation Programs'  House  Evaluation Program, which provides free
diagnostic work  (the homeowner  pays for the mitigation,  except  in  Pennsylvania)  in
return for  access to  the house in  order to monitor radon levels and  obtain information
regarding the effectiveness of the  mitigation  effort.

3.6.1.3  Develop Preventive Construction Techniques.   While  it  is important to mitigate
elevated levels where they are  discovered to be present,  it  is also important to contain
the scope of the  problem  by  preventing  new problems  from  being  created  -  in this
case,  by ensuring that  new houses are constructed in a  way that  does  not lead  to
elevated radon  levels.   While  the  degree  of  State involvement in  the  development of
preventive construction techniques  depends  largely on  whether  it becomes significantly
involved in technical  research,  it  is still vital  that State efforts  that  relate to  predic-
tion  be  publicized and  communicated  to other researchers in  order  to  aid  Federal  or
academic  efforts in this  area.   Two States are currently involved  in  the  development
and  demonstration  of preventive  construction  techniques:    New Jersey  and Florida.
EPA's New  House Evaluation  Program  (NEWHEP)  will also provide  data to support
verification of radon  prevention  techniques.  Over 200  houses  will  be built and  tested
under  NEWHEP  in 1988.

3.6.1.4  Conduct Demonstration Projects.   Initial  estimates by EPA  and some  States
suggest  that as many as 8 million houses could have elevated radon levels. Logically, a
central  part  of  the  solution  must entail  mitigation  of  these  elevated  levels.    This
activity assumes  that the  State role  will be  limited to  research,  demonstration, and
technology  transfer  activities,   rather  than   participation  directly   in   the   mitigation
effort.    Technical  mitigation capabilities  are  not  yet fully  developed in  most  areas,
especially  diagnosis,  and  further development  oriented towards increased  reliability  or
decreased cost is still important.  Since the radon problem is complex, this  development
effort  is  also likely to be  multi-faceted  and,  in  some  cases, is  predictably time-  and/or
                                        3-38

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 resource-intensive.   Seven  States -  Maryland, New  Jersey,  New York,  Pennsylvania,
 Florida,  Ohio,  and  Tennessee  -  are participating  in  joint  mitigation  demonstration
 projects with EPA's  Office  of  Research and Development  as  part of ORD's Mitigation
 Demonstration Program.

 3.6.1.5    Register/Certify/License  Mitigation  Contractors.    Similar  to  measurement,
 radon mitigation  is  typically  poorly  understood  by  homeowners,  who are, therefore,
 poorly equipped to judge whether the mitigation is likely to be successful in the long
 run  or is worth  what the  contractor  charges for  it.    EPA  gives some  guidance  on
 types  and costs of mitigation  techniques  in  EPA's "Radon  Reduction  Methods."  To a
 certain extent, existing  State  consumer protection  laws will deter unethical firms from
 providing  worthless  mitigation.   Such laws  also  provide  an  enforcement mechanism
 against  unqualified  firms.    A  direct approach  to  this  quality  control   issue  is  to
 encourage  or require  registration, certification,  or licensing  of mitigation  contractors.
 The distinction between these  forms of State control revolve around  (1) the  degree to
 which a  contractor must initially  or  periodically demonstrate competence,  (2)  whether
 the State  prohibits mitigation  by contractors  that are not certified or licensed,  and  (3)
 whether  a fee is  charged by  the State.   In  general,  licensing is associated with more
 stringent  requirements,   and   is  often  associated  with a fee.    New   Jersey and
 Pennsylvania  currently  require  certification  of mitigation  contractors   (regulations  are
 now  being  written).     Nebraska  requires  registration  and  State  approval  of  the
 mitigation  plan  prior to  mitigation.   Delaware  requires  registration  of  all  persons
 providing  radiation services,  including indoor radon  services.

3.6.1.6   Consider  Financial Assistance.    While  provision of financial  assistance  to
 homeowners   for  mitigation   activities   may   not  be  appropriate   for  all  States,
consideration  of such a program is an important activity.  Two States, New Jersey and
 New York,  have or expect  to  have low interest loan  programs  in  place.   However, a
low  interest  loan  program  was available  in  Pennsylvania but  proved  to  be  ineffective
 (very  few homeowners used the program).  The reasons  that the  Pennsylvania program
did not work are  still unclear.   As an alternative  to  low  interest loans,  a number  of
other financial assistance mechanisms  could be considered,  for example, tax credits and
direct  subsidies  (e.g.,  only  for testing  and diagnosis,  as  in  the  EPA/ORP  House
Evaluation   Program).    Clearly,  financial   assistance  could  require   significant  State
monetary   resources;  however,  this  cost  should  be  weighed  against the  ability  of
                                        3-39

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homeowners to pay for  mitigation if elevated levels are  present  in  low income areas.
Furthermore, by providing  even  partial financial assistance,  the State is typically  able
to monitor the  quality  of mitigation and to collect  information regarding its success in
various circumstances.

3.6.1.7  Develop Building Codes.   In addition to the need for predictive techniques, an
important part  of  ensuring prevention of  new  problems can  be  fulfilled  by  building
codes.  However,  the  current  difficulty is that,  since the technical knowledge about
mitigation is still  developing,  the  appropriate content  and form  of  building codes is
difficult to establish.  At the same time,  building codes vary from  location to location,
and  changing them will take time.  Accordingly, it  is  useful to begin early to consider
building code changes, even if the changes themselves are implemented  at a later date,
for example, by establishing a dialogue with the State  building association.   EPA is also
working  with  the  National  Association  of  Home  Builders  (NAHB) and  other organiza-
tions to review  building  codes to  identify  areas which may require  a change in order
to address indoor radon.

3.6.2  Policy Issues

3.62.1   Availability of  State  Resources.   Relative to other radon  program activities,
mitigation and prevention have  the potential  to require very large  amounts of  resour-
ces,  both for demonstration and  for actual construction.   Only those States  that have
already made substantial resource commitments to radon programs (e.g.,  New  Jersey,
New York,  Pennsylvania, and  Florida) are individually  active in  mitigation or prevention
demonstration programs, or offer  mitigation  financial  assistance  to  homeowners (e.g.,
through  low interest loans).   Several other States  (Virginia,  Maryland,  and  Ohio)  with
less  resource-intensive  programs  are relying  on  cooperative efforts  with  EPA's Office
of Radiation Programs (through the  House  Evaluation  Program),  or with the Office of
Research and Development (through  the mitigation demonstration  program).

3.6.2.2  Active vs. Passive Mitigation.   In formulating advice  to  homeowners concerning
mitigation,  or in  choosing  to fund  various  mitigation efforts,  a  State may  need  to
address  the technical concerns that  differentiate active and  passive mitigation.   Active
mitigation techniques,  such as forced air  subsurface  ventilation, are  likely  to require a
greater degree  of  ongoing  monitoring  and maintenance  by  homeowners  than  passive
                                        3-40

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techniques which  involve few if any moving  parts or power input  (e.g.,  for fans).  The
concern  is that over an extended  period  of time, or  after transfer  of  the house  to  a
new owner,  an  unwary  homeowner  may  neglect  or accidentally  deactivate  an active
system,  thereby  defeating the mitigation and allowing  elevated  radon  levels  to return.
However, some scientists also  believe that passive techniques,  at the  present level of
development,  are less  effective than  active techniques.   While this  issue  is unlikely to
be  resolved  in the near  future (it depends  in  part on long-term  demonstration), the
State must still be  in  a position to offer  advice to  homeowners,  if necessary, on the
choice of mitigation or prevention techniques.  One approach  is simply for the State to
keep abreast of current scientific  developments.   Both  active and  passive  techniques
are  described  in  EPA's "Radon  Reduction Techniques  for  Detached Houses: Technical
Guidance."

3.6.2.3   Technology vs. Exposure-Based Goals or Requirements.   If States choose to
establish  goals,  standards,  or  other  requirements for  mitigation  or  prevention,  they
must choose  among alternative forms of requirements  - for example,  between  technol-
ogy and exposure-based requirements.  Since few States have established  requirements,
this issue  is still  somewhat prospective.   However, Florida's experience offers  a good
case in  point.    Pursuant to  1984  legislation,  Florida  initially  established  land-based
emissions  standards for new construction  in  specific areas of the  State (counties with
reclaimed  phosphate mining  regions).  As  part of the  process,  Florida  considered  a
system  wherein all  new houses must meet a 0.02  WL (4 pCi/L)  standard for indoor
radon  level,  unless  specified  preventive  construction  techniques were employed.5
Florida  is  still  considering  the  most  appropriate  form  of regulation  (and  where  it
should apply),  and will base  its  decision in part on a survey that was initiated in 1987.

3.6.2.4   Worker Protection,   in  the  few  cases  where indoor radon  levels are highly
elevated, the  cumulative exposure  to  mitigation  workers may be  significant over  time.
Since the  extent of private  mitigation  efforts is  still largely  unknown,  this issue  has
yet to be addressed in any detail.  In the extreme, it might be  possible to monitor the
     WL is the notation  for Working Level.   A Working Level  is a unit of measure of
     the concentration of radon  decay products  defined  as the quantity  of  short-lived
     decay products that will  result  in  1.3 x  10s MeV of potential  alpha energy.  In a
     house,  one Working Level is approximately equivalent to  a  radon level of about
     200 pCi/L
                                        3-41

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exposure to workers and limit their  cumulative  exposure, either  by altering  mitigation
procedures (e.g., to include better ventilation)  or by  limiting the  duration of  mitigation
work.   This issue  is likely to receive  greater attention as  radon programs develop, and
if mitigation becomes widespread.

3.6.2.5   Collection of Private Mitigation Data.   Since few  States subsidize or  pay for  a
share  of  mitigation  (even  those  that  do,  such  as  through   a  low interest  loan,
participate  in   only  a  fraction   of  the  mitigation  work),  very  little  information  is
available  to States  on the  extent  of  private mitigation efforts.   Recently, a few States
have  begun to implement mechanisms that will  require that  the  States be informed of
private  mitigation.   For example,  Nebraska  will  soon  require that  mitigation contractors
register  with   the  State  and  gain   State  approval   of  the  mitigation  plan  prior  to
implementing  it.  Pennsylvania will require  that all mitigation be  reported to  the  State
together with  pre- and post-mitigation  measurement data.

3.62.6   Legal  Liability.  While a number of radon activities raise potential legal  liabil-
ity issues, these issues  are  most  pronounced  in  the  context of mitigation  and  preven-
tion.   Legal liability  concepts, such  as  negligence,  gross negligence,  personal injury,
standards  of  practice, and  implied  warranties  which  do  apply   to  other  construction
situations,  may also  apply to radon mitigation.  Similar issues could  conceivably  arise in
the context of  property  transfers  (affecting  the  seller, or  in  some cases the broker  if
inadequate  warning  was given),  and retrospectively,  affecting contractors  or building
product  suppliers  (e.g.,  if such  products are  demonstrated  to be the  source of  the
indoor radon,  as is  infrequently the case).   To  date, such  potential legal  issues have
apparently resulted  in at  least  one   actual legal claims  regarding naturally-occurring
indoor  radon   levels.6    However,  legal issues  may  arise in  the future as  mitigation
becomes  more prevalent.     From  the  State's  perspective,  legal  issues  could  be
significant  for  either of  two  reasons.  First, the State  itself  may  become  liable  for
injury to  the  homeowner if  it recommends mitigation practices  that  later  turn out  to
be  ineffective.    Second, the  State may  become involved in  legislative issues which
establish  the  legal  basis for  liability   (e.g.,  toxic tort  laws  which specifically allow a
     One case has  been  reported, in eastern Pennsylvania, in November 1987.   The
     case  involved the  use of radon  measurements in  a real  estate  transaction.   The
     court held that  the radon tests in this case were  conclusive  in  their  indication  of
     a radon problem in the house.   Radon News Digest.  January 1988.
                                         3-42

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homeowner to seek compensation for injury caused by  exposure to a toxic substance, if
the exposure resulted from a violation of the law).

3.6.3   Potentially Useful Existing Resources

1.   State  legislation  (PA, NJ); NCSL report.
2.   New York Diagnostics and Mitigation training program.
3.   EPA Diagnostics and  Mitigation training program and training tapes.
4.   EPA RMP program (including  worker protection plan).
5.   EPA House Evaluation  Program  (HEP), New House Evaluation Program (NEWHEP),
     and Technical Guidance.
6.   EPA Demonstration Project.
7.   Capabilities of experts in academic institutions.
                                       3-43

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                                     Chapter 4
                                   CONCLUSIONS
Since  the nature  of  the  radon  problem varies from  State to  State,  as  does  the
institutional framework within which a radon program is developed,  each State tends to
respond  to  the radon  problem  from  a unique  perspective.    Nevertheless,  a  few
generalizations  are  possible:

•    Timing  of  Activities:   Public  information is likely  to  be  the  first  Key Element to
     require  State  activities.    As  the   State  radon  program  grows  and  develops,
     additional   information  activities  are  required.    After  Public  Information,  the
     sequence   of   Key  Element  activities  logically should   be  Goals  and  Policies,
     Strategy,  Administration,  Problem  Characterization, and  Problem  Response.   In
     fact, many activities tend to proceed  in  parallel.

•    Public  Information:    This first  Key  Element  addresses  the  need to  provide
     information  to citizens, private  firms,  local officials, and  other  affected  parties
     outside  of  the State  radon  program.    Among the  six  Key Elements,  Public
     Information  activities  are the  most  widespread.   States  continue  to respond to  a
     large number of telephone inquiries,  ranging from 1,500  to 3,000  calls per month
     in New Jersey, Pennsylvania, New  York, Maryland, and  Virginia, to 40 to 50 calls
     per month in  Idaho,  Rhode Island,  Oklahoma, and Vermont.  Use  of the media as
     part of the  communication  strategy is an increasingly important  activity.    For
     example,   WJLA  TV  in  Washington,   D.C.   sponsored  a  three-month  public
     information campaign which included  distribution of 75,000 radon  detectors.
                                         4-1

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•    Goals  and Policies:   Program goals provide broad direction for policy and strategy
     development, a general measure of program effectiveness, and a sense of program
     priorities.   Policies  deal with more specific issues and generally  require more  time
     for gathering factual  information with  which to choose among  alternative policies.
     State  activity  in the  development of goals  and  policies  is  increasing  as radon
     programs  evolve.  A  number  of  States  have  established  legislative  resolutions
     pertaining to radon (for example,  Alaska  recently  declared radon  to  be an issue of
     concern  to  the State,  and  is  following  up  with  testing).    The  Washington
     Department of  Health now recommends measurement  in five northeastern counties,
     and  Oregon also  recommends  measurement.   These public  policy statements,
     together  with   both  health-based  and  internal administrative  goals, establish  the
     radon  program  as  a  priority in  the State and provide motivation and direction for
     its implementation.

•    Strategy:   Strategy development  helps  to  focus the State  effort  and provide  a
     basis  for  program   implementation  decisions  such  as  resource  allocation,
     measurement  initiatives,  etc.    The strategy  development  process  benefits radon
     programs  at all stages  (formative, developing,  and  operational), since even for
     established  programs,  new  information  (e.g.,  program  experience, measurement
     data, mitigation effectiveness) prompts a  reevaluation  of implementation  efforts as
     States strive to improve  their  programs.   Legislative or  Executive  branch  task
     forces  often provide  a  focal  point  for  strategy  development.   For  example,
     Georgia  and Tennessee  recently  created  legislative committees to study  radon;
     Georgia  also formed an  interagency  task force  that  includes EPA Regional  and
     private sector participation.

•    Administration:   This  Key  Element addresses  the  operation of the  radon  program
     in  the context  of  the  existing State institutional framework.    The availability  of
     adequate  resources continues  to  be a  principal  concern of  State radon  program
     administrators.    Many States  are still waiting for adequate  resources to develop
     and  expand their radon programs, or  require additional resources to continue  their
     programs and  respond  to an increasing  public awareness  of  potential radon risks.
     State  legislatures  are  beginning  to address this  and other radon  issues  with
     increasing  frequency.    As of March 1988,  13 States had  legislation pending on
     subjects   that   include:     establishing   radon  programs,   certifying  measuring
                                        4-2

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companies,  supporting Federal radon legislation,  requiring surveys, and clarifying
real estate transactions.

Problem  Characterization:    Problem  Characterization  involves   activities   that
measure,  predict, and analyze  radon  exposure  and  radon  health risks.   State
indoor  radon air measurement  activity  continues to  accelerate and  broaden in
scope.   Eleven  States conducted  school surveys  during the winter of  1987/1988.
Ten States continued house surveys of various designs in  early 1988.  The Virginia
State  legislature  recently  enacted  a bill  requiring  registration  of measurement  and
mitigation companies, thereby  increasing to  at  least  five the  number of States
with some form of mandatory registration of measurement companies.

Problem Response:   Finally,  Problem   Response  includes  activities designed to
reduce  existing   indoor  radon  exposure  and  to  prevent  elevated  levels  in   new
houses  and  reoccurrence in houses where elevated levels  have been mitigated.
The availability to States  of  private sector  mitigation information continues to be
a problem for most states.   Although a few  States  mandate the reporting of  this
information   (e.g.,  New  Jersey,   Nebraska),   more  State   information  collection
activity  is likely.   At the same time, States are  increasing the  number of trained
radon mitigation  and diagnostician personnel through radon training  courses.   Five
States are offering  such courses  in  the spring and summer of 1988.   EPA will
offer an  updated course in eight  States  in FY 1988.
                                    4-3

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                                  Appendix A

         CONFERENCE OF RADIATION CONTROL PROGRAM  DIRECTORS
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
Aubrey V. Godwin, Director
Division of Radiological Health
State Department  of Public Health
State Office Building
Montgomery, AL  36130
(205) 261-5315

Sidney D. Heidersdorf, Chief
Radiological Health Program
Department of  Health and Social  Services
Box H
Juneau, AK  99811-0613
(907) 465-3019

Charles F. Tedford, Director
Arizona Radiation  Regulatory  Agency
4814 South 40th Street
Phoenix, AZ 85040
(602) 255-4845

Greta  Dicus, Director
Division of Radiation Control  and
  Emergency Management
Department of  Health
4815 West Markham Street
Little Rock, AR  72205-3867
(501) 661-2X1

Jack McGurk, Acting Chief
State Department  of Health Service
Radiological Health Branch
714 P  Street,  Office Building  #8
Sacramento, CA  95814
(916) 322-2040
                                      A-1

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COLORADO
CONNECTICUT
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
A.J.  Hazle, Director
Radiation Control  Division
Department of Health
4210 East 11th Avenue
Denver, CO  80220
(303) 331-8480

Kevin T.A. McCarthy, Director
Radiation Control  Unit
Department of Environmental Protection
165 Capitol Avenue
Hartford, CT 06106
(203) 566-5668  or  5134

Allan C. Tapert, Program Adminstrator
Office of Radiation Control
Division of Public Health
Robbins Building, Silver  Lake Plaza
P.O. Box 637
Dover,  DE   19903
(302) 736-4731

Frances A. Bowie, Adminstrator
Department of Consumer and  Regulatory Affairs
Service  Facility  Regulation Administration
614 H  Street, N.W., Room  1014
Washington,  DC  20001
(202) 727-7190

Lyle  E.  Jerrett,  Director
Office of Radiation Control
Department of Health  and Rehabilitative Services
1317 Winewood Boulevard
Tallahassee,  FL  32399-0700
(904) 487-1004

Thomas Hill, Acting Director
Radiological  Health Section
Department of Human Resources
878 Peachtree Street,  Room 600
Atlanta,  GA  30309
(404) 894-5795

Thomas M. Anamizu,  Chief
Noise and Radiation Branch
Environmental Protection and Health Services Division
Department of Health
591 Ala Moana Boulevard
Honolulu,  HI  96813
(808) 548-4383
                                       A-2

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IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
Ernest  Ranieri, Senior Radiation Physicist
Compliance  Section
Department  of Health and Welfare
450 West State,  5th  Floor
Boise,  ID 83720
(208) 334-5876

Terry Lash,  Director
Department  of Nuclear Safety
1035 Outer  Park Drive
Springfield, IL 62704
(217) 785-9868

Hal S.  Stocks, Chief
Radiological  Health Section
State Board  of Health
1330 West Michigan  Street,  P.O.  Box 1964
Indianapolis,  IN  46206
(317) 633-0152

John A.  Eure, Chief
Bureau of Environmental  Health
Iowa Department of  Public Health
Lucas State  Office Building
Des Moines, IA  50319
(515) 281-4928

John Irwin,  Manager
Bureau of Air Quality and Radiation Control
Department  of Health and Environment
Forbes Field, Building 740 321
Topeka,  KS   66620-0110
(913) 296-1542

Donald R. Hughes,  Manager
Radiation Control Branch
Cabinet for  Human  Resources
275 East Main Street
Frankfort, KY  40621
(502) 564-3700

William H. Spell, Administrator
Nuclear Energy Division
Office of Air Quality  and Nuclear Energy
Department  of Environmental Quality
P.O. Box 14690
Baton Rouge, LA  70898-4690
(504) 925-4518
                                       A-3

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MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
Donald Hoxie, Director
Division of  Health Engineering
Department of Human Services
State  House,  Station 10
Augusta,  ME   04333
(207)  289-3826

Roland G. Fletcher,  Administrator
Community Health Management Program
Department of Health  and Mental  Hygiene
7th Floor Mail Room
201 West Preston Street
Baltimore,  MD  21201
(301)  333-3155

Robert M. Hailisey,  Director
Radiation Control Program
Department of Public Health
150 Tremont  Street
Boston, MA  02111
(617)  727-6214

George W.  Bruchmann, Chief
Division of  Radiological Health
Bureau of Environmental & Occupational Health
Department of Public Health
3500  North Logan Street
P.O. Box 30035
Lansing, Ml  48909
(517)  335-8200

Alice  T. Dolezal Hennigan, Chief
Radiation Control Section
Environmental Health Division
Department of Health
717 Delaware Street, S.E.
P.O. Box 9441
Minneapolis, MN  55440
(612)  623-5351

Eddie S. Fuente, Director
Division of  Radiological Health
State  Department of Hearth
3150   Lawson Street
P.O. Box 1700
Jackson,  MS  39215-7700
(601)  354-6657
                                      A-4

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MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
Kenneth V. Miller, Administrator
Bureau of Radiological Health
Department of Health
1730  East Elm  Plaza
P.O. Box 570
Jefferson City, MO   65102
(314)  751-6083

Larry  L Uoyd,  Chief
Occupational  Health  Bureau
Department of Health and Environmental  Sciences
Cogswell Building
Helena, MT   59620
(406)  444-3948

Harold R.  Borchert, Director
Division of Radiological Health
Department of Health
301 Centennial  Mall,  South
P.O. Box 95007
Lincoln, NE   68509
(402)  471-2168

Stanley R. Marshall,  Supervisor
Radiological  Health Section
Health Division
Department of Human Resources
505 East King Street, Room  202
Carson City,  NV  89710
(702)  885-5394

Diane E.  Tefft, Manager
Radiological  Health Program
Department of Health and Human Services
Six Hazen Drive, P.O. Box 148
Concord, NH  03301-6527
(603)  271-4588

Gerald Nicholls, Acting Assistant Director
  for  Radiation  Protection  Programs
Division of Environmental Quality
Department of Environmental Protection
380 Scotch Road
Trenton, NJ   08625
(602)  530-4002
                                       A-5

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NEW MEXICO
NEW YORK
NEW YORK
NEW YORK
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
Benito Garcia, Program Manager
Radiation Licensing and Registration
Environmental Improvement Division
Department of Health and Environment
1190 St.  Francis Drive, P.O. Box 968
Sante Fe, NM   87504-0968
(505) 827-2948

Karim Rimawi, Director
Bureau of Environmental Radiation Protection
New York State Health Department
Empire State Plaza,  Corning Tower
Albany, NY  12237
(518) 458-6461

John Paul Reese, Director of Radon Programs
New York State Energy Office
Two Rockefeller Plaza
Albany, NY  12223
(518) 473-7243

Joe Rizzuto, Program  Manager
New York State Energy Research
  and Development  Authority
Two Rockefeller Plaza
Albany, N.Y.  12223
(518) 465-6251

Leonard Solon,  Director
Bureau for Radiation Control
New York City Department of Health
111 Livingston Street
Brooklyn,  New York 11201
(718) 643-7967

Dayne  H. Brown,  Chief
Radiation  Protection Section
Division of Facility Services
Department of Human Resources
701 Barbour Drive
Raleigh, NC  27603
(919) 733-4283

Dana K.  Mount, Director
Division of Environmental  Engineering
Department of Health
Missouri  Office Building
1200 Missouri Avenue
Bismarck, ND   58501
(701) 224-2348
                                      A-6

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OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
PUERTO RICO
RHODE ISLAND
SOUTH  CAROLINA
Robert Quillin, Director
Radiological Health Program
Department of Health
1224 Kinnear Road
Columbus,  OH  43212
(614) 481-5800

J.  Dale  McHard, Chief
Radiation and Special  Hazards Service
State  Department  of Health
P.O. Box 53551
Oklahoma City,  OK  73152
(405) 271-5221

Ray D.  Paris, Manager
Radiation Control  Section
Health  Division
Department of Human Resources
1400 Southwest Fifth Avenue
Portland, OR 97201
(503) 229-5797

Thomas M. Gerusky, Director
Bureau of Radiation Protection
Deputate of Environmental Protection
Department of Environmental Resources
P.O. Box 2063
Harrisburg,  PA  17120
(717) 787-2480

David Saldana,  Director
Radiological Health Division
G.P.O. Call Box 70184
Rio Piedras, PR   00936
(809) 767-3563

James E. Hickey,  Chief
Division of  Occupational  Health and Radiation Control
Department of Health
Cannon Building,  Davis Street
Providence, Rl  02908
(401) 277-2438

Heyward G. Shealy, Chief
Bureau of Radiological Health
Department of Hearth
  and Environmental Control
2600 Bull Street
Columbia, SC  29201
(803) 734-4700
                                      A-7

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SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
Sue  Lydie, Director
Department of Health
  Licensure and  Certification
Joe  Foss  Office  Building
523  East Capital
Pierre,  SD  57501
(605) 773-3364

Michael H. Mobley,  Director
Division of Radiological Health
TERRA Building
150  Ninth Avenue, North
Nashville,  TN  37219-5404
(615) 741-7812

David K.  Lacker, Chief
Bureau of Radiation Control
Texas Department of Health
1100 West 49th  Street
Austin, TX 78756-3189
(512) 835-7000

Larry Anderson,  Director
Bureau of Radiation Control
State Department of Health
P.O. Box  16690
288  North 1460  West
Salt  Lake  City, UT  84116-0690
(801) 538-6734

Raymond  N.  McCandless, Director
Division of Occupational
  and Radiological Health
Department of Health
10 Baldwin Street
Montpelier, VT   05602
(802) 828-6886

Phillip Shaeen, Acting  Director
Bureau of Radiological Health
Department of Health
109  Governor Street
Richmond, VA  23219
(804) 786-5932

Terry R. Strong,  Head
Office of Radiation Protection
Department of Social  and Health  Services
Mail Stop LF-13
Olympia, WA  98504
(206) 753-3468
                                       A-8

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WEST VIRGINIA
WISCONSIN
WYOMING
William H. Aaroe, Director
Industrial Hygiene Division
Department of Health
151 11th Avenue
South Charleston, WV   25303
(304) 348-3526

Lawrence J. McDonnell, Chief
Radiation Protection  Section
Division of  Health
Department of Health and Social Services
P.O. Box 309
Madison, Wl   53701
(608) 273-5181

Julius E. Haes, Chief
Radiological Health Services
Division of  Health and  Medical Services
Hathaway  Building
Cheyenne, WY  82002-0710
(307) 777-6015
                                        A-9

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                                  Appendix B

               U.S. EPA REGIONAL RADIATION REPRESENTATIVES
Byron E. Keene                                         FTS:         835-3234
Radiation Representative, Region I                         COMM: (617) 565-3234
U.S. Environmental Protection Agency
John F. Kennedy  Federal Building
Boston,  MA 02203


Paul A.  Giardina                                        FTS:         264-4418
Radiation Representative, Region 2  (2AWM-RAD)           COMM: (212) 264-4418
U.S. Environmental Protection Agency
26 Federal Plaza
New York, NY 10278?


William Belanger                                        FTS:         597-4084
Radiation Representative, Region 3  (3AH14)                COMM: (215) 597-4084
U.S. Environmental Protection Agency
841 Chestnut Street
Philadelphia, PA 19107


Chuck Wakamo                                         FTS:         257-3907
Radiation Representative, Region 4                        COMM: (404) 347-2904
U.S. Environmental Protection Agency
345 Courtland  Street,  N.E.
Atlanta,  GA 30365


Larry Jensen                                            FTS:         886-6175
Radiation Representative, Region 5  (5AR26)                COMM: (312) 886-6175
U.S. Environmental Protection Agency
230 S. Dearborn Street
Chicago, IL 60604
                                       B-1

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Henry D. May                                           FTS:         255-7208
Radiation Representative,  Region 6 (6T-AS)                 COMM:  (214) 655-7208
U.S. Environmental Protection Agency
1445 Ross  Avenue
Dallas, TX 75202-2733


William L. Brinck                                         FTS:         757-2893
Radiation Representative,  Region 7                        COMM:  (913) 236-2893
U.S. Environmental Protection Agency
726 Minnesota Avenue
Kansas City, KS  66101


Milton W. Lammering                                     FTS:         564-7624
Radiation Representative,  Region 8 (8HWM-RP)             COMM:  (303) 293-1709
U.S. Environmental Protection Agency
999 18th Street
One Denver Place, Suite  1300
Denver,  CO 80202-2413


David L  Duncan                                         FTS:         454-8378
Radiation Representative,  Region 9 (A-3)                   COMM:  (415) 974-8378
U.S. Environmental Protection Agency
215 Fremont Street
San  Francisco, CA 94105


Jerry Leitch                                             FTS:         399-7660
Radiation Representative,  Region 10                       COMM:  (206) 442-7660
U.S. Environmental Protection Agency
1200 Sixth  Avenue, Mail  Stop AT092
Seattle, WA 98101
                                       B-2

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                                   Appendix C
                      EPA RADON PROGRAM CHRONOLOGY
Figure  C-1 presents the development  of  EPA's Radon Program in  chronological form.
While not all  of  EPA's activities are listed, Figure C-1 illustrates generally the  relative
time at  which activities  were initiated,  as  well as the expansion  or further development
of activities over  time.  As  shown  in  Figure C-1,  preliminary information dissemination,
goal development,  and strategy  development were  the first areas of activity, followed
by   administration,  policy   development,  more  public  information,   and  problem
characterization and response  activities.   For  the most  part, this  same development
process has been repeated  in those States that now have substantial, operational radon
programs.
                                       C-1

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KEY ELEMENT




PUBLIC
INFORMATION








GOALS AND POLICIES



STRATEGY





ADMINISTRATION





PROBLEM
CHARACTERIZATION









PROBLEM
RESPONSE





1984 & EARLIER
UMTRA AND BACKGROUND
DOCUMENT
URANIUM MILL TAILINGS
MONTCLAIR/SUPERFUND

























FLORIDA PHOSPHATE LANDS
GUIDANCE
BUTTE, MONTANA STUDY
SOW SPRINGS AND
POCATEUO. IDAHO SCAN
EPIDEMIOLOGY STUDIES
MONTCLAIR/SUPERFUND



GRAND JUNCTION, COLORADO
REMEDIATION
MONTCLAIR/SUPERFUNO













D
2

C
0
V
E

R
Y

0
F

W
A
T
R
A

s


H
0
U
S
r-
DEC.
1984














1985
RADON FACT SHEET











REDUCE PUBLIC HEALTH RISKS
OF INDOOR RADON
CREATE STATE-FEDERAL
PARTNERSHIP
STATES AND EPA IDENTIFY
7 PROGRAM NEEDS
READING PRONG STRATEGY
RADON ACTION PROGRAM (RAP)
STRATEGY
RADON ACTION PROGRAM
ESTABLISHED

ClAQ RADON WORKING CROUP
RADON MANAGEMENT COMMITTEE
RADON WORKING CROUP




















1986
A CITIZEN'S GUIDE TO RADON
RAOON REDUCTION METHODS
RADON REDUCTION TECHNIQUES
FOR DETACHED HOUSES:
TECHNICAL GUIDANCE









ACTION LEVEL GUIDANCE








RADON DIVISION ESTABLISHED

SARA. TITLE IV




MEASUREMENT PROTOCOLS
(HOUSES)
RMP PROGRAM (3 ROUNDS)
STATE/EPA RADON SURVEY
(10 STATES)
NATIONAL GEOLOGIC
ASSESSMENT
HEALTH RISK ESTIMATE


HOUSE EVALUATION PROGRAM
(HEP). PHASE I
RADON DEMONSTRATION
PROGRAM
DIAGNOSTICIAN AND MITIGATION
TRAINING COURSE





1987
STATE/EPA RADON SURVEY
RESULTS (10 STATES)
SUMMARY OF STATE RAOON
PROGRAMS
RADON REFERENCE MANUAL
HADON REDUCTION IN NEW
CONSTRUCTION: AN INTERIM
GUIDE
RADON REMOVAL FROM
HOUSEHOLD WATER

RAOON REDUCTION METHODS
REVISION
MEASUREMENT PROTOCOLS:
SCREENING AND FOLLOW-UP

RADON SUDE SHOW





CRCPD AND EPA MEETING TO
REVIEW PROGRAM DIRECTIONS



RADON-SPECIFIC CONGRES-
SIONAL APPROPRIATIONS

CONGRESSIONAL LEGISLATIVE
INITIATIVES


RMP (4TH ROUND)
STATE/EPA RADON SURVEY
(7 STATES AND INDIAN
TRIBES IN 3 STATES)





HEP. PHASE II
RADON DEMONSTRATION
PROGRAM CONTINUES
DIAGNOSTICIAN AND MITIGATION
TRAINING COURSE CONTINUES
NEW HOUSE EVALUATION
PROGRAM {NEW HEP)
STUDY WITH STATES AND
NAHB OF PREVENTOE
TECHNIQUES

1988
STATE/EPA RADON SURVEY
RESULTS (7 STATES AND
INDIAN TRIBES IN 3 STATES)
KEY ELEMENTS OF A STATE
RADON PROGRAM
NEW CONSTRUCTION TECHNICAL
GUIDANCE
RADON REDUCTION TECHNIQUES
FOR OETACtiEC, nOuSES:
TECHNICAL GUIDANCE
REVISION
RADON AUDIO/SLIDE SHOW
COOPERATIVE OUTREACH WITH
NATIONAL ORGANIZATIONS:
ANA, ALA, NCSL

RISK COMMUNICATION STUDY




RAP STRATEGY REVISION











RMP (5TH ROUND)
STATE/ EPA RAOON SURVEY
NATIONAL SURVEY
SCHOOL MEASUREMENT
GUIDANCE
MEASUREMENT PROTOCOLS
(HOUSES) REVISION

SOIL CAS AND LAND
EVALUATION CONTINUES
HEP. PHASE III
RADON DEMONSTRATION
PROGRAM CONTINUES
DIAGNOSTICIAN AND MITIGATION
TRAINING COURSE CONTINUES
NEW HEP CONTINUES
STUDY WITH STATES AND
NAHB OF PREVENTIVF
TECHNIQUES CONTINUES

MOOEL BUILDING COOES
Figure C-1.   Chronology of  EPA Indoor  Radon Activity

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