EPA 402/B-17/004
Quality Assurance Project Plan
Name of Tribe
Tribal Radon Monitoring Program
Measuring Indoor Radon Concentrations using Name of Detector
Submitted to
Name of Project Officer, Project Officer
U.S Environmental Protection Agency
75 Hawthorne Street
San Francisco, California 94105
Submitted by
Name of Tribe
Address
Prepared by
Tribal Environmental Officer or Contractor
Department
Organization
Date
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Table of Contents page #
1.0 Introduction
1.1 Sampling Area 5
1.2 Survey Location and Sampling Sites 6
1.3 Responsible Agency 6
1.4 Project Organization 6
1.5 Statement of Specific Problem 7
2.0 Background 7
2.1 Site Description 7
2.2 Operational History 7
2.3 Previous Investigations/Regulatory Involvement 7
2.4 Geologic Information 7
2.5 Environmental and/or Human Impact 7
3.0 Project Quality Objectives 8
3.1 Project Task and Problem Definition 8
3.2 Data Quality Objectives 8
3.3 Data Quality Indicators 9
3.4 Data Review and Validation 9
3.5 Data Management 9
3.6 Assessment Oversight 10
4.0 Sampling Protocol 10
4.1 Sampling Locations 10
4.2 Element of Concern 11
4.3 Frequency 11
5.0 Analytical Methods 11
5.1 Analysis Narrative 11
5.2 Analytical Laboratory 11
6.0 Field Methods and Procedures 12
6.1 Field Methods for use of Alpha-Track Radon Test Kits 12
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Table of Contents (continued) page #
6.1.1 Method 12
6.1.2 Measurement Conditions 12
6.1.3 Measurement Device Location 13
6.1.4 Retrieval of Detectors 13
6.2 Field Equipment 13
7.0 Disposal of Residual Materials 14
8.0 Sample Documentation and Shipment 14
8.1 Field Notes and Logbooks 14
8.2 Labeling 14
8.3 Chain-of-Custody forms and Custody Seals 14
8.4 Packaging and Shipment 15
9.0 Quality Control 15
9.1 Field Quality Control Samples 15
9.1.1 Duplicates (Collocated) Detectors 15
9.1.2 Field Control Detectors 16
9.2 Laboratory Quality Control Samples 16
9.2.1 Spiked Samples 16
10.0 Field Variances 16
11.0 Field Health and Safety Procedures 16
List of Appendices: 17
Appendix A: References
1) Indoor Radon and Radon Decay Product Measurement Device Protocols
EPA 402-R-92-004, July 1992
2) Protocols for Radon and Radon Decay Measurements in Homes
EPA 402-R-93-003, June 1993
3) A Citizen's Guide to Radon: The guide to protecting yourself and your family
from Radon
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EPA 402-K-07-009, Revised May 2007
Appendix B: Laboratory Standard Operating Procedures, Technical References, and
Forms
1) QA Program for Radon Testers
2) Technical Information for Test Kit:
3) Radon System Calibration:
4) Background Calculation:
5) Sample Chain of Custody form:
Appendix C: Forms
Field Data Form
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1.0 Introduction
General sentence about the Tribe (location, area, population, types of buildings). As part of the
Tribe's on-going effort to investigate site-specific and area-wide environmental and human
health concerns, the name of environmental department proposes to assess the homes, public
buildings, and planned buildings located on Tribal land for the presence of radon.
This Radon Project is designed as a research and screening program to assist in the evaluation of
the presence of radon in homes and public buildings on Tribal lands. Results from the Radon
Project (RP) will be reviewed to develop a plan for mitigation, if necessary, as funding becomes
available.
1.1 Sampling Area
The homes and other buildings are located (describe location of Tribe on map (Figure 1).
Place may here
Figure 1
1.2 Survey locations and Sampling Sites
The Tribal lands include extent of physical boundaries. All Tribal lands shall be referred to as
the "Tribal Lands" in this document. The name of Tribal Community is located {location within
the U.S.) Radon levels in existing residential and public buildings, as well as planned buildings
(after construction); will be determined at as many locations as are practical on Tribal lands.
1.3 Responsible Agency
The Project Manager will be responsible for conducting sampling necessary to execute and
maintain the RP. Name of Tribe has committed personnel and resources to implement the RP,
including, but not limited to, the training of staff to conduct sampling in accordance with the
procedures provided in the plan.
1.4 Project Organization
The general organizational structure to carry out the RP is detailed below:
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Project Manager:
Quality Assurance Manager:
Analytical Laboratory:
The Project Manager will be the primary contact and will implement monitoring, collect and
prepare samples, and maintain records. The Quality Assurance Manager provides independent
oversight for project quality. The name of lab will provide name of detectors to the Tribe and be
responsible for their analysis after exposure.
1.5 Statement of the Specific Problem
Name of Tribe manages activities that promote the protection of human health and the
environment. The inhalation of radon in levels greater than 4.0 pCi/L over prolonged periods of
time poses a significant risk to human health. Prolonged exposure to radon and its decay
products can increase the potential of developing lung cancer. Radon is present at some level in
almost every region. The amount of radon in a particular building depends on the geology
specific to the location of the building, building design and ventilation, and the amount of force
that draws radon into the building from the soil. Due to the fact that the geology beneath
different buildings varies significantly, as do the materials used to construct individual buildings,
it is recommended that each building be tested for the presence of radon. The data gathered in
this investigation will be used to determine the need for remedial action.
2.0 Background
2.1 Site Description
Air samples will be collected in residential and public buildings, as well as new buildings (after
construction), located on Tribal land. All Tribal buildings will be tested. Testing will also be
made available to private homeowners within the Tribal communities.
2.2 Operational History
The name of Tribe operates and maintains public and Tribal Community buildings.
2.3 Previous Investigations/Regulatory Involvement {if applicable)
A preliminary assessment of radon contamination was conducted on Tribal lands in year.
2.4 Geologic Information
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Name of Tribe is located geographic location. The general type of soil is composed primarily of
(soil composition) rock and has (drainage characteristics). General description of the landscape.
2.5 Environmental and/or Human Impact
Inhalation of radon at levels greater than 4.0 pCi/L over prolonged periods of time poses a
significant concern to human health. Prolonged exposure to radon and its decay products can
increase the potential of developing lung cancer.
3.0 Project Quality Objectives
3.1 Project Task and Problem Definition
The name of Tribe will establish a site-specific monitoring program to test all residential
properties in the Tribal community, as well as existing Tribal public buildings and buildings that
may be constructed in the future, to determine levels of radon gas present that may be impacting
human health.
Monitoring will include:
• Sampling for radon.
• Analysis of samples to determine the level of exposure to radon.
• Reporting of results to Tribal Government and members.
• Recommendations for remediation of high levels of radon.
• Retesting properties with radon levels over 4.0pCi/L
3.2 Data Quality Objectives
Data for this project is intended to assist the name of Tribe in decision making for remediation of
residential and public buildings exhibiting levels of radon equal to or greater than 4.0 pCi/L. The
data should be adequate to address the following concern:
What is the average level of radon present in individual buildings located on Tribal lands
at a level equal to or greater than the U.S. EPA's action level of 4.0 pCi/L?
In the event that the radon concentrations meet certain action levels, name of Tribe will
implement the following actions in accordance with Protocols for Radon and Radon Decay
Product Measurements in Homes (EPA 402-R-93-003, June 1993), Sec. 2.3.3;
Action Levels
Undo n
Actions
Data in individual building less than
4.0pCi/L
No further monitoring required.
However levels between 2.0 and
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4.0pCi/L may be considered for
mitigation.
Data in individual building equal to or
greater than 4.0pCi/L
Interim mitigation by balancing
HVAC system and/or increasing
ventilation. Follow up with second
test.
Average of the data of initial test and the
data of the second test equal to or greater
than 4.0pCi/L
Recommend remediation of building
in accordance with EPA 402-R-93-
078 Radon Mitigation Standards, as
funding becomes available.
3.3 Date Quality Indicators (DQI)
Data quality indicators (DQI) (accuracy, precision, completeness, representativeness,
comparability and method detection limits) refer to quality control criteria established for various
aspects of data gathering, sampling, or analysis activity. Due to the limited scope of the project,
the pertinent data quality indicators are:
• Detection limits of the analytical method (see Section 5.1)
• Standard quality control conducted by the laboratory
• Field duplicates and field blanks collected by the monitoring technicians will be submitted
blind to the analyst (see Section 9.0)
• Thorough record keeping by field and data entry technicians
• Review of data entered into database
3.4 Data Review and Validation
The Project Manager will review the laboratory report for compliance with the DQI's.
If the sample results do not comply with quality standards, the Project Manager will:
• Flag the data that is not in compliance
• Review the field notes for irregularities or inconsistencies
• Contact the analytical laboratory to discuss actions taken by the laboratory to correct
problems
3.4 Data Management
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The Project Manager will conduct or supervise staff completion of the following tasks to compile
and evaluate the data collected, based on recommendations outlined in EPA guidance Indoor
Radon and Radon Decay Product Measurement Device Protocols (EPA 402-R-92-004, July
1992) Sec. 1.2.4; a copy of the document is included as a reference in Appendix A.
• Data will be transferred to a spreadsheet or database approved by the environmental
department. Summary data tables will be created and statistics performed to determine if
the sampled residential and public buildings meet the long-term exposure action level of
4.0 pCi/L or greater.
• A summary report will be prepared showing the results of the monitoring including Task
1 above, the laboratory reports; field data sheets, chain of custody forms, and the
assessment conducted by the title of environmental officer. The results will be reviewed
with respect to the data quality objectives (see Section 3.2), and changes will be
recommended to the QAPP if appropriate.
• After the data have been entered into electronic spreadsheets and/or databases, copies of
all hard and/or electronic documentation will be stored off-site in a locked, fire-proof file
cabinet.
3.6 Assessment Oversight
The title of Environmental Officer will review the project to determine that:
• Field quality control measures have been conducted (e.g. duplicate and blank sample
collection)
• Laboratory quality control measures have been conducted in accordance with the
Standard Operating Procedures
• Data transferred from laboratory reports has been entered correctly into tables, charts, or
graphs for evaluation
• Data quality objectives have been met
• Procedural changes made in the field or laboratory are incorporated in the QAPP
The title of environmental officer will document the Radon Program evaluation in a
memorandum. This shall be submitted to the Project Manager in a timely manner. A hard copy
will be placed in the project file.
4.0 Sampling Protocol
4.1 Sampling Locations
Radon is present at some level in almost every region. The amount of radon in a particular
building depends on the geology specific to the location of the building, the amount of negative
pressure that draws radon into the building from the soil, and the effectiveness of the building's
ventilation. It is recommended that each building be tested for the presence of radon. The
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environmental department will test all residential buildings of the Tribal community and all
public Tribal buildings that are currently in use. This includes: titles of buildings in addition to
residential buildings.
4.2 Element of Concern
Radon is the element of concern for which sampling is to be conducted in buildings on Tribal
lands. The inhalation of radon at levels equal to or greater than 4 pCi/L, over prolonged periods
of time, poses a significant concern to human health. Levels above lOpCi/L are more hazardous
and are cause for immediate mitigation. Since it has not been absolutely determined what
constitutes a safe level of exposure, homeowners with radon levels from 2 to 4pCi/L may want to
take mitigation measures. A long term goal of the federal government is to reduce indoor levels
of radon to the average outdoor level of 0.4pCi/L. Prolonged exposure to radon and its decay
products can increase the potential of developing lung cancer.
4.3 Frequency
Sampling frequency under this plan is proposed to serve as a screening for the presence of radon
in individual buildings on Tribal lands. EPA guidance A Citizen's Guide to Radon: The Guide to
Protecting Yourself and Your Family From Radon, 402-K-07-009 recommends that action be
taken to reduce indoor radon levels in public and residential buildings if there is a radon test with
results of 4pCi/L or higher. The name of Tribe will sample for 60 to 90 days initially and then
will determine whether or not a second test is needed depending on the results of the first test.
Additional sampling events may take place in the future to evaluate any future construction on
Tribal land.
5.0 Analytical Methods
5.1 Analysis Narrative
Radon Test Kits will be placed in homes and public buildings according to EPA Guidelines as
detailed in "Protocols for Radon and Radon Decay Product Measurements in Homes'' (EPA
402-R-92-003). Radon samples will be collected at as many building locations as possible using
the name of detector. Test duration will be 60 to 90 days. Duplicates will be collected at 10% of
the locations. Field blanks will be collected at 5% of the locations tested. Test kits will then be
sent in for analysis to the laboratory using laboratory protocols and following chain of custody
procedures with supporting documentation.
Winter is the preferred season for sampling because there is usually less outside air coming into
buildings.
5.2 Analytical Laboratory
The analytical laboratory selected for the project is name of laboratory. The laboratory is
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licensed by the licensing agency, License # .
Samples collected by the environmental department will be shipped to the laboratory in a timely
manner after collection according to name of laboratory protocols.
6.0 Field Methods and Procedures
6.1 Field Methods for use of name of test kits.
6.1.1 Method (EPA 402-R-92-004, 1992, Sec. 2.2)
Name of detectors are passive sampling devices, requiring only to be open to the atmosphere to
operate. The name of kit contains an alpha sensitive foil inside a filtered diffusion chamber.
During the decay of radon inside the chamber, alpha particles are released that damage the foil,
hence the "track." When the detector is analyzed, describe the processing steps for the analysis.
Radon concentration is calculated from the number of tracks and number of days the kit was
deployed. Concentration is reported in picocuries per liter (pCi/L)
Name of detector is designed for long term use, from two (2) weeks to one (1) year and does not
require closed house conditions.
6.1.2 Measurement Conditions (EPA 402-R-92-004, 1992, Sec. 1.2.2)
To the extent possible, environmental department will ensure that the following conditions exist
prior to and during a measurement period to standardize the measurement conditions:
• Winter is the preferred season for sampling as windows and doors are more often closed
to cold weather. If measurements must be made during a warmer season, meeting the
criteria listed below will satisfy the closed-building conditions.
• Internal-external air exchange systems (other than a furnace) such as high-volume attic
and window fans will not be operating during measurements of and for at least 12 hours
before measurements are initiated.
• Air conditioning systems that recycle interior air do not need to be turned off.
• Normal operation of permanently installed air-to-air heat exchangers may also continue
during closed-building conditions.
• Where permanent radon mitigation systems have been installed, the operational schedules
of these systems should continue to be followed during the measurement period.
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• Closed-building conditions will be verified and must be maintained when they are not the
normal living conditions.
6.1.3 Measurement Device Location (EPA 402-R-93-003, 1993, Sec. 2.2) and (EPA 402-R-92-
004, 1992, Sec 1.2.3).
• Short-term measurements will be made in the lowest lived-in level of the house. The
following criteria will be applied to select the location of the detector within a room on
this level. A position will be selected where the detector will not be disturbed during the
measurement period and where there is adequate room for the device.
• The measurement will be away from made near drafts caused by heating, ventilation, and
air conditioning vents, doors, fans, and windows. Placing detectors near excessive heat,
such as a fireplace or in direct sunlight, and areas of high humidity will be avoided.
• The measurement location will not be within 90 centimeters (3 feet) of windows or other
openings in the exterior wall. If there are no potential openings (e.g. windows) in the
exterior wall, then the measurement location will not be within 30 centimeters (1 foot) of
the exterior walls of the building.
• The detector will be at least 50 centimeters (20 inches) from the floor, and at least 10
centimeters (4 inches) from other objects. For those detectors that may be suspended, an
optimal height for placement is in the general breathing zone, such as 2 to 2.5 meters
(about 6 to 8 feet) from the floor.
• In general, measurements will not be made in kitchens, laundry rooms, closets, or
bathrooms.
6.1.4 Retrieval of Detectors (EPA 402-R-92-004, 1992 Sec. 2.4.8)
At the end of the monitoring period, the detector will be inspected for any deviation from the
conditions described in the logbook at the time of deployment. Any changes will be noted. The
detector will be resealed using the original protective cover, then returned to the laboratory as
soon as possible for analysis.
6.2 Field Equipment
The following will be used to measure radon:
• A test kit (provided by the laboratory) that includes name of detector sealed with a
protective cover;
• An instruction sheet and sampling data sheet for the test location;
• A shipping container, along with appropriate mailing label; and
• A data collection logbook.
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7.0 Disposal of Residual Materials
In the process of collecting environmental samples at the testing sites during the investigation, the
monitoring technician will generate different materials for disposal:
Disposable sampling equipment
For the low levels of contamination and routine sampling that will likely be found, the following
disposal methods will be used:
Disposable equipment will be double bagged and placed in a municipal refuse dumpster.
These wastes are not considered hazardous and can be sent to a municipal landfill.
8.0 Sample Documentation and Shipment
8.1 Field Notes and Logbooks
At a minimum, the following information will be recorded during the collection of each sample.
(EPA 402-R-92-004, 1992, Sec. 1.2.4)
• Sample location and description
• Name of technician
• Date and time of sample collection
• Field observations and details related to analysis and/or integrity of samples (e.g. weather
conditions, noticeable drafts in testing room, unusual temperatures, noticeable humidity,
and/or any other unusual condition present during the time of testing.)
A copy of the field data/instruction sheet is included in Appendix C.
8.2 Labeling
All samples collected will be clearly labeled for proper identification in the field and for tracking
in the laboratory. All labels are pre-applied to the individual test kits. Each name of detector and
information card has a unique 6-digit identifier that corresponds to the foil in the detector. These
numbers are used to reduce the potential for sample mishandling. The following information will
be included on the label:
• Resident identification number (or applicable duplicate or blank identification number)
• Detector number
• Test location
• Start date and end date of sample
8.3 Chain of Custody Forms and Custody Seals
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A chain of custody record will accompany all sample shipments for analysis. The chain of
custody form will identify the contents of each shipment and maintain the custodial integrity of
the samples. Generally, a sample is considered to be in someone's custody if it is either in that
person's physical possession, in someone's view, locked up, or kept in a secured area that is
restricted to authorized personnel only. When samples are shipped, the custody of the samples
will be the responsibility of the name of tribe. The designee will sign the chain of custody form
in the "relinquished by" box and note date, time, and unique monitor number.
Sample numbers for all samples, field duplicates, and blanks will be documented on this form. A
request for the laboratory to use one of the samples for laboratory QC sample will also be noted
on this form. A copy shall be made for the environmental department project files. A copy of the
chain of custody form is included in Appendix C.
8.4 Packaging and Shipment
The following packaging procedures will be followed for all samples.
All sample containers will be placed in a strong outside shipping container if needed.
• Seals will be checked on the individual test kits for tightness.
• Empty space in the shipping container will be filled with bubble wrap or Styrofoam
peanuts to prevent movement and possible loosening of seals on test kits during transport
or shipment.
• Each shipping container will be securely taped shut with fiberglass strapping tape, and
custody seals will be affixed to the front, right and back of each shipping container.
Records will be maintained by the name of Tribe of the following information:
• Copy of the chain of custody form
• Total number of test kits shipped to the laboratory
• Carrier, airbill number(s), method of shipment (i.e. priority, next day)
• Shipment date and date the laboratory should receive the test kits.
9.0 Quality Control
9.1 Field Quality Control Samples
9.1.1 Duplicates (Collocated) Detectors (EPA 402-R-92-004, 1992, Sec. 2.4.11.3)
Duplicate detectors (field duplicate) samples will be collected to monitor the precision of
the measurements. A duplicate will be collected for 10% of the devices that are
deployed. Duplicates will be labeled with a unique location identification number known
only to the staff of the environmental department and will be submitted blind to the
analytical laboratory.
Precision will be monitored using the results of the duplicate detector analyses. Duplicate
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measurements should achieve a relative percent difference of 10% or less at 4pCi/L or
greater. (EPA 402-R-92-004, 1992, Sec. 2.4.10.2)
9.1.2 Field Control Detectors
Field Control Detectors (field blank) samples will be used to monitor the name of
detector response to handling, storage, and shipment. Field blanks are unexposed
detectors that are moved through the sampling protocol and handled in the same manner
as exposed detectors, then analyzed. Blanks will be collected for 5% of the devices that
are deployed. Blank samples will be labeled with a unique identification number known
only to the staff of the name of Tribe and will be submitted blind to the analytical
laboratory. Any value above the lower limit of detection (LLD) will prompt an
investigation at the laboratory to determine the cause of the elevated reading.
9.2 Laboratory Quality Control Samples
The laboratory will conduct QC checks in accordance with its Standard Operating Procedures
and Quality Assurance Plan. (See Appendix B)
9.2.1 Spiked Samples
Spiked samples are detectors that have been exposed to known concentrations in a radon
calibration chamber traceable to NIST or equivalent Standards Laboratory. Spiked
samples should be at least 3% of all measurements performed. The average value of the
spiked detectors must be within +/- 25% of reference value.
10.0 Field Variances
As conditions in the field vary, it may become necessary to implement minor modifications to
sampling as presented in this plan. When appropriate, the QA Manager will be notified and a
verbal approval will be obtained before implementing the changes. Modifications to the
approved plan will be documented in the final report (Section 3.6). Significant revisions should
also be incorporated in the written plan.
11.0 Field Health and Safety Procedures
Monitoring technicians must follow the safety guidelines required by environmental department
in accordance with the Occupational Safety and Health Administration (OSHA) Standards and
Guidelines and provisions of the Occupational Safety and Health Act of 1970.
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Appendices:
Appendix A: References
1) Indoor Radon and Radon Decay Product Measurement Device Protocols
EPA 402-R-92-004, July 1992
2) Protocols for Radon and Radon Decay Measurements in Homes
EPA 402-R-93-003, June 1993
3) A Citizen's Guide to Radon: The guide to protecting yourself and your family
from Radon
EPA 402-K-07-009, Revised May 2007
Appendix B: Laboratory Standard Operating Procedures, Technical References, and
Forms (Quality Assurance Manual)
Pg. QA Program for Radon Testers Using name of detectors
Pg. Technical Information for name of detectors
Pg. Radon System Calibration:
Pg. Background Calculation:
Pg. Sample Chain of custody form
Appendix C: Forms
Field Data Form
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