Pennsylvania’s Radon Program- Certification, Fees, and Regulations September 21, 2016 San Diego, CA Denise S. Bleiler Radiation Protection Program Supervisor

History 1984 Employee, Stanley Watras, coming to Limerick Power Plant was setting off the alarms Questioned leak at plant?? Prompts engineers at facility to look closer and measure radon in Stanley’s home 2700 pCi/L

History Radon Certification Act – 1987 Requires anyone performing radon services in the Commonwealth of PA to be certified Pa. Code Title 25 Environmental Protection Chapter 240 Radon Certification 240.308 Testing & Mitigation protocols 240.401 Inspection 240.305 Health & Safety program The primary purpose of the Act and the subsequent Chapter 240 Radon Certification Regulations is to protect the health & safety of the public and to protect the public from unqualified or unscrupulous persons Requires the Dep’t. to establish, by regulation, a certification program for persons conducting radon gas and radon progeny testing, lab analysis, and mitigation of radon contamination in buildings Radon certification has been required by PA since 9-21-88

Bob Lewis – Program Manager Organization in PA: Central Office Radon Division Staff Bob Lewis – Program Manager Denise Bleiler –Monitoring Program Supervisor Kelley Oberdick –Certification vacant– RHP2 - Mitigation Jennifer Daly – RHP2 vacant– RHP1 - Quality Control/Testing Support Staff Tina Bowers-Paris – Management Technician - Greenport Gail Ramsey – Clerical vacant- Clerical This is our Central Office staff in Harrisburg. Certification is done through the Central Office. Inspections are sent out of Central Office but support comes from the Regional Offices.

Organization in PA: Regional offices Southwest Region 1 dedicated inspector Southcentral Region Southeast Region 4 – 5 inspectors

Present day 450 Certified Testing Individuals 81 Certified Testing Firms 23 Certified Laboratory Individuals 18 Certified Laboratory Firms 139 Certified Mitigation Individuals 64 Certified Mitigation Firms

Certification Application Pennsylvania Radon Certification Forms and Information Department sends a reminder letter 90 days before renewal – every 2 yrs Industry may access these forms on line through e-library www.elibrary.dep.state.pa.us/

Regulations and Protocols Penna. Certification Guide Indoor Radon & Radon Decay Product Measurement Device Protocols, EPA-402-R-92-004 July ’92 Protocols for Radon & Radon Decay Product Measurement in Homes, EPA-402-R-93-003 June ‘93

Proposed Regulation Revisions Max number of employees for test/mit FIRMs Deleting Exposure Tracking for the tester Cross check requirements being dropped Minimum 3 spikes requirements dropped when no testing done Several additions are already industry practice EPA protocols Add/drop device when uncalibrated

Proposed Fee Revisions

Proposed Fee Revisions Increase Fees by 50% - previous slide No increase since 2009 Adding a $50.00 Mitigation Tag Fee

Inspection Categories Routine - regularly scheduled (2-4 years) Complaint - received from public and evaluated by Radon Division to warrant inspection. Courtesy - Offered to new testers/labs. Conducted within 6-9 months of initial certification.

Inspection Checklists Firm/Individual Lab/Tester Inspection Checklist Mitigation Office/Mitigation Field Checklists Device Specific Inspection Checklists Activated Charcoal (AC) Continuous Monitor (CR) Electret Ion Chamber (ES/EL) Alpha Track (AT) Liquid Scintillation (LS)

Standardized Inspection Letters Appointment letters/email/phone call Inspection Results Letters Notice of Violation (NOV) Acknowledgement Courtesy Results

Inspection Program Responsibilities Central Office Select candidates Review file Prep checklist Forward to Region Track progress Maintain files & computer records Provide assistance Regional Office Schedule inspection Conduct inspection (complete checklist) Issue inspection results letter Forward completed checklist & letters to Central Office

Common Inspection Findings Crawl Space Vents, Placed/Retrieved By, Health Risk Info. Calculation, Charting of RPD for Passive Devices. Cross Checks/Intercomparisons for Active Devices. QC Checks (Spikes, Blanks) ES/EL Voltmeter/Reference Checks

Enforcement Historically, most enforcements have been for uncertified activities- both testing and mitigation Within the past 4-7 years, the majority of enforcements have been for uncalibrated devices (monitors and electret readers) Within the past 3 years, the majority of enforcements have been for uncalibrated devices that have been used for testing

Enforcement Reasons for success: Initial letters/reminder letters sent to industry Collect serial numbers through Greenport History of education and compliance assistance Enforcements used when compliance assistance fails Enforcements on repeat violations during inspections

Penalty Calculation

Penalty Calculation

Conclusions Certification began late 1980s Worked at bringing industry into compliance for many years using regulations, EPA protocols, and guidance documents Continue to work on having a robust inspection program Enforcements occur when necessary to protect the health and safety of our citizens Increase fees and regulation changes are part of a growing program

Radon Monitoring Supervisor Thank you !! Questions ? Bob Lewis Radon Program Manager 717-783-9485 rolewis@pa.gov Denise S. Bleiler Radon Monitoring Supervisor 717-783-4870 dbleiler@pa.gov Denise S. Bleiler Radon Monitoring Supervisor 717-783-4870 dbleiler@pa.gov

Denise S. Bleiler Radiation Protection Program Supervisor DEP Bureau of Radiation Protection PO Box 8469 Harrisburg, PA 17105-8469 Tel: 717-783-4870 dbleiler@pa.gov www.dep.pa.gov