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SCHOOL & COMMERCIAL BUILDING TESTING REQUIREMENTS

Performing radon measurements in schools and/ or commercial buildings requires amending a residential or real estate measurement license. The following information must be provided in your commercial building procedure for the department evaluation.

INTRODUCTION

The Agency's rule is based on the USEPA's Radon Measurements In Schools, which was the only guidance available at the time.  In the interim, more detailed information about commercial building and school measurements has become available.  Thus, the Agency requires procedures for measurements in schools and commercial buildings to describe in detail the characterization for potential mitigation.

FACTORS THAT IMPACT RADON & RADON PROGENY


Procedures for measurements in schools and commercial buildings must describe in detail the characterization for potential mitigation that includes the following: Locating and evaluating the impact on radon / radon progeny concentrations of: unusual radon entry mechanisms and/or elevated radon concentrations on upper floors;localized vacuums created by forced air systems such as: exhaust fans, spot exhausts, unbalanced air flows, leaky ductwork, sub-slab duct work, and rooms used as return air plenums;Characterizing the effects on radon / radon progeny concentrations of:opened and closed doors;fresh-air makeup of rooms with exhaust fans but without makeup air;Identifying and evaluating the impact on radon / radon decay product concentrations of:inappropriate energy conservation applications;structural features that affect soil gas entry, such as: expansion joints, utility chases, sub-slab access holes, utility access points, rooms used as return air plenums, return ducts beneath the slab; andcrawlspaces, especially those used as return air plenums;Calculating actual equilibrium ratios, rather than assuming a 50% equilibrium ratio; and Characterizing / comparing the radon / radon decay product concentrations to determine exposure schemas during hours of occupation versus periods of non-occupation.

EFFECTS OF HVAC SYSTEMS ON RADON & RADON PROGENY

Because of increased air movement from the building's HVAC system(s), a school or a commercial building with a high radon concentration would not always have assumed radon decay product concentrations.  Increased air movement may create unexpected equilibrium ratios, which would affect the Working Level concentration, the true exposure concern.  Variations in the radon / radon decay product concentrations created by operation of the HVAC system are not unusual.  Simply measuring the radon level may result in incomplete characterization of the radon / radon decay product scenario and in unnecessarily high mitigation costs.

In addition, the Agency further recommends that your procedure include a:Quality Assurance Project Plan for the building being characterized, following USEPA's Quality Assurance Project Plan guidance;Communication Plan, agreed upon with the building's management, that includes an entry meeting, employee information sessions to inform employees of the characterization activities and about radon and its health effects; and an exit meeting to explain the findings; and a final written report of the characterization. Such a procedure may include the following general steps:Develop and approve the Quality Project Plan;Develop the Communication Plan, implement as designed;Verify architectural drawings of the building, its characterization elements, and review the HVAC system;Perform concurrent short-term screening tests throughout the building;Set Continuous Radon Monitor (CRMs) and Working Level Monitor (WLMs);Perform additional diagnostic tests, as needed to complete characterization;Review characterization elements, as necessary; and Complete a written final project report.


 

 

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