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
-------
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
r
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=
RADCNUCLIDES IN WATER
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p.z
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( r\
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UJ
o
Z)
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
-------
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.
2-5
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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.
2-6
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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.
2-7
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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."
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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.
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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
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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
3-9
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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
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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
3-13
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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
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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
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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,
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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.
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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.
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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.
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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
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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
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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
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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.
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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.
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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.
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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.
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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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