1. Proposed Radiological Health Rulemaking
Public Webinar
May 31, 2017
Bob Lewis
Radiation Control Division Chief
Bureau of Radiation Protection
Patrick McDonnell, Secretary
Tom Wolf, Governor

2. DEP/BRP Radon Division
Keith Salador, Assistant Counsel
Kelley Oberdick, Radon Certification Section Chief
Denise Bleiler, Radon Monitoring Section Chief
Bob Lewis, Radon Division Chief
Previously results from the lab could only be reported to the owner or occupier of the building tested.

3. Regulations Open for Public Comment
Comment period: May 13, 2017 to June 26, 2017
Options for public comment:
DEP’s eComment site,
Written comments mailed or ed to DEP
Previously results from the lab could only be reported to the owner or occupier of the building tested.

4. DEP/BRP Radon Division
Changes to Radon Certification Exemptions
§ (5) Under Purveying added:
Test results may also be reported to the certified mitigator who installed a mitigation system at the property.
Purveying does not include the activities of either placing or retrieving radon test devices.
Previously results from the lab could only be reported to the owner or occupier of the building tested.

5. DEP/BRP Radon Division
Changes to Radon Certification Exemptions
§ 240.2(6) Exceptions from certification
For local government or school personnel if the following exist:
The practice is limited to their official duties and no fee is charged
All testing is performed using passive secondary devices
Must have taken a school/large building course
Have a Department approved QA plan
Test only buildings owned or occupied by local gov’t or school

6. DEP/BRP Radon Division
Changes to Certification Exemptions (cont’d)
Applications in general
Any change to one’s certification must be submitted to the Department in writing.
The change does not take effect until the Department provides written approval of the change.

7. DEP/BRP Radon Division
Certification Requirements for both Testing and Mitigation Firms
The firm may list only five employees at one time.
This is a major change. This is not a interference in business activities, it is a means for the responsible individual to maintain oversight of the firm employees. This however, does not preclude the company from adding a new firm to their company to add additional employees if necessary.

8. DEP/BRP Radon Division
§ Prerequisites for Radon Testing Individual Certification
Removed the one year radon measurement experience requirement.
Thought it most unlikely that one could get the prior one year experience.

9. DEP/BRP Radon Division DEP/BRP Radon Division
§ Required client information
Notice to Clients. Slight change to the wording.
Be sure to incorporate the new language in your documentation.
The notice shall read substantially as follows: …

10. DEP/BRP Radon Division
§ Reporting of Information
Retain test, laboratory, or mitigation reported activity for 5 years.

11. DEP/BRP Radon Division DEP/BRP Radon Division
§ Reporting of Information, cont.
Do not report:
Invalid data
Diagnostics testing
QA data

12. DEP/BRP Radon Division DEP/BRP Radon Division
§ (3) Reporting to Clients
The tester or lab report shall be provided to the client within 10 days after testing or lab analysis.
This used to be 45 days.

13. DEP/BRP Radon Division
§ Health and Safety program
Mitigator shall retain worker exposure records for 5 years.
Testers not required to track worker exposure.
4 WLM/yr is still the exposure limit for radon progeny.

14. DEP/BRP Radon Division
§ Radon Mitigation Standards
To codify the current PA RMS.
This section has only what we considered the most important parts of PA RMS in regulation.

15. DEP/BRP Radon Division
§ Testing Protocols
Codifies four current radon testing protocols:
EPA Protocols for Radon and Radon Decay Product Measurements in Homes.
Indoor Radon and Radon Decay Product Measurement Device Protocols.
EPA Radon Measurement in Schools.
ANSI/AARST Protocol for conducting Radon and Radon Decay Product Measurements in Multifamily Buildings.
Yes, we did not use the newer AARST radon testing protocol or the latest AARST Schools protocols.
We are not codifying the actual documents but the contents in general from the documents. For instance min. 48 hour msmt., closed-house conditions, etc.
Schools document and the ANSI/AARST Multifamily are referenced in full.

16. DEP/BRP Radon Division
§ Testing Protocols (cont’d)
Tester shall have a Department approved report form.
Tester shall provide the client the test results within 10 working days from the completion of the test. .

17. DEP/BRP Radon Division
§ Quality Assurance Requirements
Codifies QA requirements for testers and laboratory analysis.

18. DEP/BRP Radon Division
§ General QA Requirements
The certified individual is responsible for all QA requirements.
QA records shall be maintained for 5 years.
Others can perform or help with the QA activities but the certified individual is ultimately responsible.

19. DEP/BRP Radon Division
§ QA Requirements for testing using primary devices.
Continuous radon monitors, continuous working level monitors, electret ion chambers.
Removed the requirement to do a cross-check every six months.
This section just specifies the individual requirements for each device such as calibration, background msmts., check sources, intercomparison msmts., etc.
Intercomparisons still required every 10th test

20. DEP/BRP Radon Division
§ QA Requirements for testing using secondary devices.
Secondary devices could be CRM’s, EIC’s, AC, LS, ATD.
Mentions specific requirements, logging requirements, and control charts/limits.
No longer require minimum of 3 spikes when no testing activity.
Secondary for CRM’s would be only for those that one is placing and retrieving only, such as Radalink.

21. DEP/BRP Radon Division
§ QA Requirements for Labs
AC, CRM, ATD, EIC, LS
Specifies the QA requirements for each device, the frequency of the QA activity, logging QA data, and control charts/limits.

22. DEP/BRP Radon Division
Appendix B
Non-interference Agreement for Real Estate Radon Testing
Specifies the building conditions necessary to ensure a valid radon test during a real estate transaction
Normal operation of HVAC, closed house conditions, ASD system on during test, etc.
If no one is there to sign the form make sure you document this.

23. DEP/BRP Radon Division
Appendix C, Radon Exposure Tracking Record
Provides a form for tracking exposure under (Health and Safety Program).
Helps to assure that exposure does not exceed exposure limit (4 WLM/yr).
Applies to mitigators only.
Exposure tracking now only required for mitigators.

24. DEP/BRP Radon Division
Finally, What’s not covered.
Radon Resistant New Construction.
Radon in Water.

25. Robert Lewis, 717 783-9485 or rolewis@pa.gov www.dep.pa.gov