Midwest Lenders Association HUD Radon Policy Update September 27, 2017 Kyle Hoylman, Chair Executive Stakeholder Committee AARST Consortium on National Radon Standards

Radon Report Included in the pre-application or application – required Prepared, signed and certified – Radon Professional Content includes: Testing results Mitigation details, including timing and cost estimate Amended to include post-application items Exceptions include: Valid justification – Radon Professional 223(f) low-risk areas – testing exemption 223(a)(7) – no report required Testing encouraged – regardless of exceptions

Radon Professional Credentialed by National Radon Proficiency Program (NRPP) or National Radon Safety Board (NRSB) and certification / licensure for state where work is being done (if applicable) Direct supervision for all radon testing and mitigation Responsible for preparing and certifying Radon Report Environmental Law Institute Database of State Indoor Air Quality Laws – Radon Excerpt eli.org 40 states with radon law(s) in effect

Radon Standards ANSI/AARST MAMF 2017 (3/1/2017) – MF testing ANSI/AARST MALB 2014 – RCF testing ANSI/AARST RMS-MF 2014 – MF mitigation, existing ANSI/AARST RMS-LB 2014 – RCF mitigation, existing ASTM E2121-13 – single family mitigation, existing, MF/RCF ANSI/AARST CC-1000 2017 (3/1/2017) – new construction, passive mitigation system design, MF/RCF ASTM E1465-08a (new construction) withdrawn, July 2017 Most current version of standard is applicable

Testing Direct supervision – Radon Professional MAMF 2017 (multifamily), MALB 2014 (RCF) – standard 1 year – testing threshold (prior to application) Key items: Minimum testing period (48hr MF, 72hr RCF) Upper floor testing (10%) Non-residential areas – ground contact Closed building conditions (short term testing) Resident notification Exceptions include: 25% screening deviation Mitigation required > 4.0 pCi/L

Testing - Methodology Multiple protocols: Extended testing method – most prevalent Time-sensitive method Testing periods: Short term – up to 90 days, closed building conditions Long term – 91+ days, no closed building conditions Closed building conditions (12 hours prior to deploy): All windows and doors – closed Fans, portable AC units (fresh air), etc. – not operating Resident notifications – must be delivered to all units in the building, regardless of whether or not the unit is tested

Testing – Methodology

Testing – Methodology

Testing – 25% Screening Deviation Only exception to MAMF-2017 / MALB-2014 25% of all ground contact units in each building – required Upper floor testing (10%), non-residential areas – required Closed building conditions, resident notifications – required If screening indicates the potential for elevated radon concentrations exist at the property, follow up assessment: 100% of all ground contact units/areas in all buildings on the property included in the screening 10% of upper level residential units in all buildings If a full assessment is not conducted, all units in all buildings require mitigation Option may not be beneficial in high risk areas

7 Buildings, 80 Residential Units Testing – 25% Screening Deviation Meriden, CT Example 7 Buildings, 80 Residential Units

Testing – 25% Screening Deviation Meriden, CT Example 25 % Initial 1: 2/5 units > EPA action level 2: 1/2 units > EPA action level 3: 4/4 units > EPA action level 4: 0/3 units > EPA action level 5: 0/7 units > EPA action level 6: 1/3 units > EPA action level 7: 1/5 units > EPA action level 100% Follow Up 1: 13 units > EPA action level 2: 5 units > EPA action level 3: 8 units > EPA action level 4: 8 units > EPA action level 5: 8 units > EPA action level 6: 9 units > EPA action level 7: 3 units > EPA action level 100% follow up assessment of the buildings identified 16 residential units in 2 buildings Total of 44 additional residential units identified through full site characterization

Testing – 25% Screening Deviation Lexington, KY Example 10% screening of 1 unit in 18 buildings, total of 144 ground contact residential units (Freddie) 14 residential units in 14 buildings > EPA action level – policy requirement to mitigate 14 residential units 100% assessment of ground contact units conducted – 108 of 144 residential units > EPA action level (16 units greater than EPA respirator rate, none on initial screening list) Client chose to mitigate 108 residential units, Freddie required 14 residential units – liability consideration

Follow Up Assessment Analysis Testing – 25% Screening Deviation Follow Up Assessment Analysis 20 Most Recent Projects 4 properties: states requiring 100% initial assessment (1-IL, 3-OH): 20% 4 properties: client chose 100% initial assessment (1-AZ, 3-IN): 20% 3 properties: contained only 1 building (1-AZ, 1-PA, 1-TN): 15% 1 property: follow up assessment did not identify residential units with Rn > EPA action level in other buildings (1-CO): 5% 8 properties: follow up assessment identified residential units with Rn > EPA action level in other buildings (1-CA, 1-GA, 2-IN, 1-MI, 1-MN, 1-VA, 1-WA): 40%

Mitigation Direct supervision – Radon Professional RMS-MF 2014 (MF), RMS-LB 2014 (RCF) or ASTM E2121-13 1 year – mitigation threshold (after Closing) Key items: Unit mitigation versus building mitigation Collateral mitigation Resident notification – required Post-mitigation testing – required O+M program plan – required Amended Radon Report, certificate of completion – required

Operation and Maintenance Active mitigation – required for duration of insured mortgage (condition, Firm Commitment) RMS-MF 2014, RMS-LB 2014, CC-1000 2017 – Section 12.0 Key components: Routine maintenance Non-routine maintenance Ongoing testing Records management Inclusion in amended Radon Report – required Protect building occupants by minimizing the potential for exposure to radon gas – primary objective

Sub Rehab and Conversions Applies to all radon zones Early Testing Feasible (minimal HVAC, building envelope rehab) < 4.0 pCi/L – no further action required > 4.0 pCi/L – mitigation required Early Testing Not Feasible (typical gut rehab) Letter of determination – Radon Professional Option to include mitigation in design – high risk areas Post-construction testing required – mitigation required > 4.0 pCi/L

Sub Rehab and Conversions RMS-MF 2014 (MF), RMS-LB (RCF) or ASTM E2121-13 – standards Mitigation timing – prior to Final Closing Reporting requirements – no mitigation: Testing assessment report – 1 year threshold Reporting requirements – mitigation: Mitigation scope and budget – initial application Cost estimate (may require pilot test to determine) Post-mitigation testing assessment Certificate of completion – Radon Professional O+M program plan

New Construction Applies to all radon zones CC-1000 2017 – standard Project architect responsible for development of design Direct supervision - Radon Professional Mitigation system installation Post-construction test Non-residential areas – included (clubhouse, maintenance) Post-construction testing – required Activation of passive system > 4.0 pCi/L – required

New Construction Reporting requirements: Passive mitigation system design Activation details, if applicable Post-construction test results Certificate of completion – Radon Professional O+M program plan

Mitigation – Design

Protect Environmental Kyle Hoylman Managing Partner Protect Environmental 502-410-5000 Kyle@ProtectEnv.com