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

2. 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

3. 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 states with radon law(s) in effect

4. 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 E – single family mitigation, existing, MF/RCF
ANSI/AARST CC (3/1/2017) – new construction, passive mitigation system design, MF/RCF
ASTM E a (new construction) withdrawn, July 2017
Most current version of standard is applicable

5. 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

6. 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

7. Testing – Methodology

8. Testing – Methodology

9. 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

10. 7 Buildings, 80 Residential Units
Testing – 25% Screening Deviation
Meriden, CT Example
7 Buildings, 80 Residential Units

11. 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

12. 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

13. 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%

14. Mitigation Direct supervision – Radon Professional
RMS-MF 2014 (MF), RMS-LB 2014 (RCF) or ASTM E
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

15. Operation and Maintenance
Active mitigation – required for duration of insured mortgage (condition, Firm Commitment)
RMS-MF 2014, RMS-LB 2014, CC – 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

16. 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

17. Sub Rehab and Conversions
RMS-MF 2014 (MF), RMS-LB (RCF) or ASTM E – 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

18. 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

19. 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

20. Mitigation – Design

21. Protect Environmental
Kyle Hoylman
Managing Partner
Protect Environmental