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CEMM QUALITY ASSURANCE PROJECT PLAN
Office of Research and Development
Center for Environmental Measurement and Modeling (CEMM)
Atmospheric and Environmental Systems Modeling Division (AESMD)
Emissions Systems Analysis Branch (ESAB)
Radon Measurement and Mitigation in Puerto Rico
EPA/ORD QA Track: G-AEMD-0032146-QP-1-0
March 2021
Prepared by Marc Menetrez and Oleg Povetko
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Approvals
QA Project Plan Title:
NRMRL QA Tracking ID:
Radon Measurement and Mitigation Techniques in Puerto Rico
QTRAK No. G-AEMD-0032146-QP-1-0
If Intramural or Extramural, EPA NRMRL Project Approvals
Name: Oleg Povetko/Technical Lead Person
(TLP)
Signature/Date:
Name: Matt Laurita/TLP’s Supervisor and
Branch Chief
Signature/Date:
Name: Christine Alvarez /AESMD QA Manager
Signature/Date:
Name: Marc Menetrez/EPA/ORD PI
Signature/Date:
If Extramural, Contractor Approvals
Name: Contractor Manager/Lead
Signature/Date:
Name: Contractor QA:
Signature/Date:
Name: Other Contractors:
Signature/Date:
Name: Other Contractors:
Signature/Date:
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Change History
Change
No.
0
Description
Original issuance
Date
Revised
9/12/2019
N/A
Changes
N/A
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Table of Contents
Approvals ........................................................................................................................................2
Figures ............................................................................................................................................5
Tables..............................................................................................................................................5
Distribution List ..............................................................................................................................6
Disclaimer and Acknowledgments .............................................................................................6
Acronyms and Abbreviations.......................................................................................................7
1.0 Project Description and Objectives ..................................................................................9
1.1
Background ..............................................................................................................9
1.2
Project Objectives ..................................................................................................11
2.0 Project Organization and Responsibilities ....................................................................12
2.1
Project Personnel ...................................................................................................12
2.2
Project Schedule.....................................................................................................13
2.2.1 Planning .....................................................................................................13
2.2.2 Scoping/Outreach.......................................................................................14
2.2.3 Training ......................................................................................................14
2.2.4 Kick-off/Sampling .....................................................................................15
2.2.5 Analysis/Mapping ......................................................................................16
2.2.6 Communications/Reporting .......................................................................17
3.0 Scientific Approach ...........................................................................................................17
3.1
Sampling Design ....................................................................................................17
3.2
Process Measurements ...........................................................................................18
4.0
Sampling Procedures .............................................................................................19
4.1
Site-specific Factors ...............................................................................................23
4.2
Sampling Equipment & Calibration.......................................................................23
5.0 Analytical Procedures ......................................................................................................24
5.1
Measurement Methods ...........................................................................................26
6.1
Data Quality Indicator (DQI) Goals ......................................................................26
6.1.1 Accuracy ....................................................................................................27
6.1.2 Precision.....................................................................................................30
6.2
Quality Control Checks.........................................................................................31
7.0 Data Analysis, Interpretation, and Management .........................................................34
7.1
Reduction ...............................................................................................................34
7.2
Validation...............................................................................................................34
7.3
Data Storage Requirements....................................................................................35
8.0 Data Reporting ..................................................................................................................35
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8.1
Reporting Requirements ........................................................................................35
8.2
Data-Related Deliverables .....................................................................................35
9.0 References......................................................................... Error! Bookmark not defined.
Appendix A ....................................................................................................................................39
Appendix B ……………………………….………………………………………………………………………36
Figures
Figure 2-1 Organizational Chart ...............................................................................................12
Figure 4-1 MAH Test Locations …………………………………………………….………. 18
Figure 4-2 MAH Time-Sensitive Testing Protocol…………………..………………………19
Figure 4-3 MAH Extending Testing Protocol……………………………………..…………19
Figure 6-1 AARST-NRPP DPT Error Criterion……………………….……….……………25
Figure 6-2a AARST-NRPP Device Evaluation Error Criterion……………………………26
Figure 6-2b Sample Standard Deviation………………………………………….…………27
Figure 6-3a MS-QA Field Operations Duplicates Procedures………….……...…………28
Figures 6-3b MS-QA Warning and Control Limits………………………….………………29
Tables
Table 2-1 Organization Table…………………………………………………………….…. 12
Table 6-1 DQI Goals ...................................................................................................................27
Table 8-1 Data-Related Deliverables .......................................................................................37
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Distribution List
Copies of this plan and all revisions will be sent to the following individuals. It is the
responsibility of the U.S. Environmental Protection Agency Office of Research and
Development Principal Investigator (PI) to make copies of the plan available to all project
personnel.
EPA Region 2, Air & Radiation Division: Oleg Povetko, Juan Gutierrez
EPA Region 2, Caribbean Environmental Protection Division: Alex Rivera
EPA, Office of Research & Development: Marc Menetrez
University of Puerto Rico at Mayagüez (UPRM): Dr. Pedro Tarafa, Dr. Ismael Pagan
Disclaimer and Acknowledgments
Any mention of trade names, products, or services does not imply an endorsement by the
US Government or the United States Environmental Protection Agency (EPA). EPA does
not endorse any commercial products, services, or enterprises.
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Acronyms and Abbreviations
AARST
AEMD
ANSI
CEPD
CH
COC
COV
CRM
DQI
DSBB
DPT
EPA
GIS
HASP
IPE
KSU
NRMRL
NRPP
NRSB
ORD
OSL
OTL
pCi/L
PI
PR
PSI
QA
QAO
QAPP
QC
RLS
RTP
SME
American Association of Radon Scientists and Technologists
Air and Energy Management Division
American National Standards Institute
Caribbean Environmental Protection Division
Corentium Home Radon Devices
chain of custody
Coefficient of variation
Continuous radon monitors
data quality indicator
Distributed Source and Buildings Branch
Device Performance Test
U.S. Environmental Protection Agency
Geographic Information System
health and safety plan
Individual percent error
Kansas State University
National Risk Management Research Laboratory
National Radon Proficiency Program
National Radon Safety Board
Office of Research and Development
On-site Student Leader
On-site Technical Leader
Picocuries per liter of air
Principal Investigator
Puerto Rico
PSI Services
quality assurance
quality assurance officer
quality assurance project plan
quality control
Research Laboratory Support
Research Triangle Park
Subject matter expert
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SOP
UPR
UPRM
USGS
Standard operating procedure
University of Puerto Rico
University of Puerto Rico at Mayagüez
United States Geological Survey
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1.0
Project Description and Objectives
1.1
Background
Radon is one of the most widely studied environmental pollutants and has some of the
most extensive human data to provide proof of its harmful effects. Radon has been
found to be the second leading cause of lung cancer, and first amongst non-smokers.
EPA estimates that radon is responsible for approximately 13% of lung cancer deaths in
the United States, and 26% among non-smokers each year. Despite the wealth of
information available on radon, there is still little knowledge of its extent in Puerto Rico
(PR). The data that are available did not follow the methodology the EPA employed to
produce the Radon Zone Maps (EPA, 1992). This lack of information creates a barrier in
the path of successfully reducing the risk of radon exposure in the region. Educating the
communities in the seven identified municipalities with geologic potential, as well as
testing a subset of indoor radon levels will aid in addressing these discrepancies.
Although the typical methods of testing, such as charcoal canisters and alpha-track
detectors, are considered cheap, they are simply not logistically feasible in PR. This is
because these methods require access to a certified lab for analysis. The majority of PR
does not have access to these labs. The samples collected via the traditional methods
would have to be shipped to a certified lab for analysis. Additionally, these methods are
sensitive to humidity and time, so utilizing them proves to be impractical for use in the
tropical climate of PR. To remedy these issues the EPA is implementing the New
Testing Method for Community Mapping of Radon. The new method uses the
Corentium Home (CH) radon detection device by Airthings (Airthings Inc, 2021). The
device is compact, portable, and delivers readings without needing to be delivered to a
certified lab for testing. It will be used to test radon levels in homes. The devices will be
distributed throughout seven target municipalities. Project team members will receive
training on both radon and the radon detection equipment in order to maintain
capabilities during the project period. Once the tests are complete, devices and data will
be collected and analyzed. E-Perm® EIC radon monitors will be used for duplicate and
confirmatory measurements. If a building requires remedial action, trained individuals
will advise the occupants of their options. Additional information on training can be
found under 2.2.3 Training.
Project team members will receive training on both radon measurements and the radon
detection equipment in order to maintain capabilities during the project period. The
radon measurement training will be provided by the National Radon Proficiency
Program’s (NRPP) approved course provider. After passing the exam, team members
will be able to obtain NRPP certification.
Absence of knowledge regarding the extent of radon in PR presents a barrier to
success to reduce radon risk, as well as, for Region 2 to fully and informatively
distribute radon resources across the Region. A summary of radon measurements in
PR was published by USGS (USGS, 1995), but the data collected were not based on
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the methodology that EPA employed in a larger, statistically valid study that produced
the Radon Zone Maps. The maps are important pieces to guide Region 2 policy as they
were developed to assist national, state and local organizations to target their resources
and to implement radon-resistant building codes (EPA, 2021). Without knowing where
to direct radon policies, PR is unable to protect citizens and visitors from radon. In
addition, citizens themselves are not armed with knowledge to protect themselves even
if they wanted to. In 2017, PR experienced back to back hurricanes, Irma and Maria,
which resulted in severe devastation on the island. As part of the long-term recovery
effort, PR is undergoing massive renovation and rebuilding, and as such, has begun to
investigate adoption of sustainability practices with new construction and renovations.
Having a better understanding of the extent of radon in these newer homes will allow
the territory to inform future policy. The PR Department of Health-Environmental
Protection Division, in collaboration with EPA, determined radon data and education to
be science priorities.
Past radon monitoring of PR conducted by USGS as noted above, has demonstrated
the potential for high radon levels. USGS found that several areas of PR have the
geologic potential to generate indoor radon levels exceeding 4 picocuries per liter of air
(pCi/L), perhaps locally reaching very high levels (>50 pCi/L), if house construction and
ventilation allow the soil-gas radon to enter and concentrate within structures. Higher
than average indoor radon levels occur primarily in the areas of northern and
northwestern PR that are underlain by residual limestone soils. The island of PR is
divided into 20 municipalities and with the two additional islands: Vieques and Culebra.
Neighborhoods in known or suspected high radon areas as noted in the USGS report
(USGS, 1995) will be targeted for testing. The city of Camuy recorded 8% of homes
exceeding the 4.0 pCi/L recommended limit (EPA action level), in addition the cities of
Ciales 10%, Hatillo 6%, Lares 18%, Morovis 5%, and San Sebastian 15% also tested
high percentages of homes exceeding the 4.0 pCi/L limit. The City of Arecibo was
added at the request of the Health Department of Puerto Rico. These results include a
total of 10% of tests exceeding the action level (11 of 111 tests). Though none of the 13
measurements taken in the USGS study were found above the action level for Arecibo,
this additional municipality will be targeted as it surfaced as another area with potentially
high radon levels as outlined in the August 1996 report published by the Puerto Rico
Department of Health (PR DOH, 1996).
Newer building practices that include tightening homes and relying more on airconditioning and, increased populations building homes over a wider range of
geological structures has ensued. As part of long-term disaster recovery effort to rebuild
PR wisely and utilizing the Healthy Buildings (Homes/Public Housing/Schools) Initiative.
the territories are primed to build their capacity on radon testing and implementing
radon-reducing features into sustainable building practices, if needed.
While EPA maintains that testing is cheap, this statement is general and doesn’t
consider the remote areas that don’t enjoy typical access to credentialed radon service
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providers or devices that require laboratory testing. Typical devices, such as charcoal
canisters and alpha-track detectors don’t allow users to see the current radon level and
they require shipping on and off the islands. Canisters are particularly time and humidity
sensitive, which can fluctuate more in the Caribbean climate. Alpha-track detectors
need to be deployed for several months in order to obtain reliable results. Radon
professionals can be costly for low-income citizens and are starkly, if at all, available on
the islands.
Monitoring radon in neighborhoods will provide citizens with information and inform local
and regional policy on the health benefits for radon protection, including, building
sustainable radon monitoring capacity at the local level and incorporating radonreducing features into newly-adopted or pending sustainable building practices in the
disaster recovery renovation/rebuild effort. Radon technology has improved
considerably over the years, yet charcoal canisters are often the recommended device;
this project updates the approach to radon test devices.
1.2
Project Objectives
The primary objective of this project is to safeguard the communities of Puerto Rico
from radon risk through education, testing, and remedial action as necessary. The longterm objective is to build capacity on the island if radon is a serious issue. Extensive
home interventions (i.e. radon mitigations) are beyond the scope of this project;
however, this project includes identifying hot spots where homes, schools, and other
public buildings reside for next steps, such as needs for testing, mitigation, and new
construction features, and to provide technical assistance to communities and the
UPRM Team to build local technical capacity for reducing radon risk.
The Healthy Buildings (Homes/Public Housing/Schools) Long-Term Recovery Initiative
has developed strategic partnerships with Universities (UPR-Mayaguez-DHS Coastal
Resilience Center of Excellence; Dept.’s of Engineering & Surveyors, Environmental
Science), community organizations (Servicios Legales, Heart to Heart, HopeNow, etc),
PR Mayors Association, and the territorial agencies. Those partnerships will be
leveraged to train and empower community leaders in the identified municipalities in
PR.
Innovation Approach: This project involves both citizen science and crowdsourcing
and advanced monitoring technologies. The neighborhood focused sampling strategy
engages the communities by empowering them to be directly involved in testing for
radon in their homes. This project will be creating new opportunities for the utilization of
new, citizen-friendly, cost-effective monitoring equipment for remote areas.
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2.0
Project Organization and Responsibilities
2.1
Project Personnel
The primary project personnel from EPA are as follows:
EPA R2 Project Lead
Oleg Povetko
EPA R2 Project CoLead Juan Gutierrez
EPA ORD
Marc Menetrez
EPA ORD QA
Christine Alvarez
Figure 2-1. Organizational Chart
Table 2-1. Organizational Table
Roles and Main Activities, Project Team/Personnel and Affiliation
Radon Technical Lead/EPA Project Lead, give
presentation at UPR, fact sheet, provide
training, Contract Alternate WAM
Oleg Povetko
EPA R2
Radon Communications Lead, EPA Project
Co-Lead, give presentation at UPR, provide
training, community engagement, fact sheet,
Juan Gutierrez
EPA R2
Onsite Facilitator, Onsite Project Logistics,
Onsite Quality Assurance/Control
Alex Rivera,
John Aponte
EPA R2-CEPD
Radon Spanish Communications Lead, EPA
Project Logistics, Onsite Coordinator for UPR
Team Activities, Develop Spanish Materials,
Radio Communications, HQ-R2 Liaison
Carmen Torrent
EPA HQ
Radon Spanish Communications, HQ-R2
Liaison
Brenda Reyes
EPA R2-CEPD
Science Oversight, Quality Assurance/Control,
sampling methodology
Marc Menetrez
EPA ORD
Review/Approve QAPP for EPA ORD QA
requirements, provide QA/QC guidance as
requested
Christine
Alvarez
EPA ORD
Onsite Technical Lead (OTL), attend training,
and Communications Team member, pre-postinterventions
Lupita Montoya
Contractor
EPA ORD
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Radon Technical Advisor, give presentations
at UPR, provide training, Technical Team
member
David Grammer
Contractor
Jacobs
Onsite Technical Lead (OTL), attend training,
lead OSL and Student Team, postinterventions
Contractor
UPRM
Onsite Student Lead (OSL), attend training,
sampling, post-interventions
Contractor
UPRM
Onsite Student Team, attend training
Contractor
UPRM
Subject Matter Expert (SME), provide training,
technical radon consultations and lead field
adjustment activities and post-interventions
Contractor
N/A
Technician, fact sheet, field adjustments
Contractor
N/A
Community Lead(s), attend training
Contractor
Varies
2.2
Project Schedule
The project schedule is split into distinct categories which overlap at times. Categories
described include:
•
Planning (Sept 2020-May 2021),
•
Scoping/Outreach (Jan-July 2021),
•
Training (June-Aug 2021),
•
Kick-off/Sampling (June-July 2021),
•
Analysis/Documentation (June 2021-Aug 2022),
•
Communications/Reporting (June 2021-Dec 2022)
2.2.1 Planning
Project Planning Meetings—Planning meetings are intended to plan travel dates,
ensure and practice consistent messaging that will be communicated in the field and to
onsite project leaders and community members.
Community Leader Identification—EPA and other partners (UPR, CEPD), Mayor’s
Association, etc) will utilize partnerships and relationships to identify leaders and
meeting hosts who will aid in shepherding the flow of information and radon test devices
within communities in the seven targeted municipalities. Phone meetings will be
attended by EPA with leaders and hosts and plans to meet in person will be made.
Meetings and project decisions will be documented in Microsoft Word files and stored
by date on the Agency SharePoint site and then shared with contractors and project
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team via e-mail.
Purchases—95 Corentium Home (CH) Radon Measurement Devices that read in pCi/L
have been purchased (Airthings Inc, 2021). The project will use about 90 devices.
Purchase additional 360 AAA batteries for the devices. Purchase four EIC E-Perm® ST
chambers and 60 electrets. Purchase incentives in the following maximum
denominations $1000 for the onsite student leader (OSL) (not to exceed $1,000), 12 of
$100 for the Onsite Student Team Members (not to exceed 12 members and $1,200),
and $1000 for the Technician (not to exceed $1,000). Purchase travel in terms of
lodging, airline tickets, and rental car for 5-7 days for subject matter expert (SME);
lodging, and airline tickets for 5-7 days for Technician; lodging for 5-7 days for OTL and
OSL. Alternatively, a lump sum can be paid to SME, OTL, OSL and Technician at an
agreed upon amount not to exceed project budget. Other purchases shown under 2.2.3
Training.
2.2.2 Scoping/Outreach
Seminar for UPRM Students—EPA to provide a two-hour presentation and
informational session for UPRM engineering students and other community members
with interest. The purpose is to provide project information and to garner interest from
students with the desired outcome of identifying onsite project leadership. EPA has
begun identifying two individuals to become certified radon measurement and mitigation
professionals who reside on the island and will work on this project. Those individuals
are referred to as the OTL and OSL.
Community Scoping—EPA to visit as many communities as possible for further
informational and questions and answers sessions with community members prior to
radon sampling. The purpose is to identify a subset of communities where sampling can
begin first. EPA and Technician to prepare a project-specific fact sheet prior to visits.
2.2.3 Training
Radon Certification Courses—Purchase the courses. OTL and OSL will attend radon
measurement and mitigation online courses designed specifically to lead to National
Radon Proficiency Program (NRPP) or National Radon Safety Board (NRSB) Radon
Measurement and Mitigation certification (Courses: https://radoncourses.com/online,
last accessed 2/23/2021).
Radon Mitigation Field Training—Purchase the training. SME will conduct 8-hour radon
mitigation field training sessions attended by the OTL and OSL which specifically lead to
NRPP or NRSB Radon Mitigation certification (NRPP:
https://nrpp.info/certification/how-to-become-certified/, last accessed 2/23/2021),
NRSB: www.nrsb.org/, last accessed 2/23/2021).
Radon Certification—Purchase the exams. OTL and OSL will take the measurement
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and mitigation exam proctored by a third party: PSI Services
Exams: https://candidate.psiexams.com/, last accessed 2/23/2021.
Train-the-Trainer—EPA and SME will provide training to the project team that will
include training on data entry methods in sampling methodology, RadResponder
(Chainbridge Technologies, 2021) E-Perm® system (Rad Elec Inc., 2021), RAD7 device
(Durridge Inc., 2021), interventions, and project-specific topics. RadResponder
accumulated large online Resource Library that will be used in training (Chainbridge
Technologies, 2021). Copies of User’s Manuals for CH and E-Perm® will be provided to
the Team Members (copies are available in the Attachments). In addition, EPA will
provide training to Project team members on citizen science, crowdsourcing, and the
best approaches in engaging communities. The community training sessions
attendance, instructors and content will be tracked and documented.
2.2.4 Kick-off/Sampling
Kick-off and Operations Meeting— After the UPRM students have completed
coursework and certification, we will schedule a EPA-UPRM-RaData (RaData, 2021)
tutorial training secession. The sampling plan is simple. When six to ten homes have
been selected in a target area, a UPRM student will arrange an appointment for each
home, gather an appropriate number of monitors (always carrying one or two extras,
they may have a neighbor that wants their home measured, or a monitor malfunctions),
and forms for signature and handout.
Covid-19 protocols issued by local and territorial jurisdictions, UPRM and EPA will be
followed at the meeting and during all fieldwork. Personal Protective Equipment (PPE)
will be provided for all team members engaged in field activity. The meeting is intended
for team members to meet, plan the following days’ field activities, check instruments for
batteries and operations, and ensure consistent messaging regarding project goals,
standards, and sampling methodologies. Team members will be provided radiation and
radon measurement training. EPA field work guidelines contained in EPA Guidelines
(EPA, 2020) or later revision of the Guidelines will be shared with the Project Team
members. Radon monitors, appropriate Personal Protective Equipment and supplies will
be assigned and distributed at the meeting.
Then the work finally begins. All radon monitor placement and retrieval will be
performed by UPRM or EPA team members. Each house will receive one Monitor which
is started and runs for seven days. At least 10 percent of homes will also receive one
E-Perm® monitor as a QA confirmation check. One communication package form also
is given to the homeowner. After seven days, the student returns, retrieves and
disinfects monitors, documents results on information sheet in writing, transmits results
to the OTL and uploads results into RadResponder database (Chainbridge
Technologies, 2021). At UPRM all database requirements are completed, and the
process starts again. If there is an opportunity for a student to pick-up a monitor and
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immediately drop it off in another home, to save a trip and save time. We require
seven-day minimal integrated samples. Monitors can keep running for a longer period if
a pick-up date is not convenient for the student or the homeowner.
Community Informational Meetings—Communities slated for sampling will be provided
informational meetings where the Project Team Leads will provide citizen-level radon
related information to Community Leads and the public and provide technical assistance
for questions from attendees.
Radon Sampling—Sampling will occur in a total of seven municipalities listed in Section
1.1 Background. Project team members (i.e., Data Collectors) will comply with the then
current Covid-19 Health and Safety protocols imposed by local, territorial jurisdictions,
UPRM and their contracts. In addition to local and territorial protocols, EPA staff will
comply with the field work guidelines issued by EPA (EPA, 2020) or their most updated
revision. CH and E-Perm® radon measurement devices will be distributed among
sampling team members. A radon measurement device will be disinfected and deployed
in each home and upon completion of the test period, collected and disinfected by the
Data Collector. A data point representing the seven-day average radon level will be
recorded in project documents and RadResponder cloud-based database (Chainbridge
Technologies, 2021), and then the device will be reset and transferred to the next
sampling location. EPA Project Leads will work with Community Leads via the UPRM
Team to ensure radon data are collected and home assistance is provided. See Section
4.2 Sampling Equipment and Calibration for more details about the devices.
See Sections 3.0 Scientific Approach and 4.0 Sampling Procedures for further details
about sampling.
Quality Assurance Testing—Duplicate or sequential testing with a certified device (such
as E-Perm®, Corentium Pro, RAD7) or alternate approved device will occur at a rate of
10% of all homes that demonstrated indoor radon levels of 4 pCi/L or higher. Homes
identified for interventions will be tested by the RAD7 or other certified device after the
interventions. An alternate approved device may substitute for the RAD7 if necessary;
however, all efforts will be made to utilize the RAD7 for follow up sampling. See and
Section 3.1 Sampling Design and 6.2 Quality Control Sampling for further QA details.
Data Collection - Monitors will be collected, disinfected and readings recorded by
members of the Project Team.
2.2.5 Analysis/Mapping
Data analysis—For purposes of identifying areas of policy implications, clustering of
radon levels (hot spots) will be identified by community, municipality, or geographical
area, depending on how the results of the data fall out. Mean radon level is the most
logical identifier at this point; however, UPRM and Department of Health may find
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unique ways to utilize the data points. Individual occupants will be provided verbal
information on their own home’s radon level and what that means in terms of risk and if
further action is needed. Town Mayors will be included to the extent practicable on
reporting out of the average radon levels in their jurisdiction.
Mapping— The measured radon value, along with the address and coordinates will be
uploaded from sampling location to the RadResponder, cloud-based EPA sponsored
radiological database (Chainbridge Technologies, 2021). This information will not be
publicly shared. Data Collectors will be able to have access only to the data that they
uploaded to RadResponder themselves, not to any other data and maps. Generalized
geolocations, with generalized addresses and coordinates, excluding personally
identifiable information (PII), will be utilized in conjunction with radon test results to
generate a workable geodatabase for radon levels in Puerto Rico. This dataset will be
created within ArcGIS and will be used to create a geospatial map of radon levels for
the various communities being tested, including a story map. See Section 8.2 DataRelated Deliverables for additional details.
Interventions—The Project Team will perform limited building manipulations and inform
adult occupants of next steps needed, such as sealing connections with soil gas,
recommending ventilation strategies, and manipulating pressure points in the homes.
Post-intervention activities include follow-up radon measurements.
2.2.6 Communications/Reporting
Maintenance Calls—After sampling begins, the Project Team will attend by phone
weekly conference calls for Q&A, troubleshooting, updates, and communication with
partners and communities. Conference call notes will be documented in Microsoft Word
files and stored by date on the Agency SharePoint site and then shared with contractors
and project team via e-mail.
Reporting—Final activities reporting, data reports, summaries, charts and maps for
post-project communication pieces. Produce final report of results, lessons learned,
and scalability to other communities. Produce final report of selected policy options to
municipalities based on results of sampling. See Section 8.0 Reporting for further
details.
3.0
Scientific Approach
3.1
Sampling Design
Technical description:
Five rounds of seven-day sampling periods per cohort in each municipality is expected,
resulting in at least 350 samples. Sampling cohorts are defined as 10 devices deployed
at a time in one community such that 10 samples begin on day one and end on day
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seven resulting in one round of sampling. As an example, after kick-off, at least three
communities receive 10 devices (excluding duplicates for simple illustrative purposes),
to commence round one sampling, resulting in 30 samples. The first round is complete
after the first seven-day sampling period, and those devices will then be re-deployed for
another round of sampling in other community members’ homes. Project Team and
Community Leaders shepherd the devices from one home to the next and record a final
radon reading for analysis. The CH devices read out a seven-day average radon level in
pCi/L.
Approach: General instructions, sampling strategy and the health benefits of
monitoring radon will be provided to citizens as appropriate via the Community Leads
and by the Project Team when practicable, preferably remotely.
RAD7, CH, E-Perm® and other certified devices will be utilized for home indoor radon
sampling, as well as undergo QA testing according to project-modified versions of three
radon measurement national standards: ANSI/AARST MS-PC 2015 (ANSI/ARST,
2015), ANSI/AARST MS-QA 2019 (ANSI/AARST, 2019), ANSI/AARST MAH 2019
(ANSI/AARST, 2019). and according to this QAPP. The scope of these standards is
briefly described below.
• ANSI/AARST MS-PC 2015 (ANSI/ARST, 2015) standard specifies minimum
performance criteria and testing procedures for instruments and/or systems
designed to quantify the concentration of 222Rn gas in air
• ANSI/AARST MS-QA 2019 (ANSI/AARST, 2019) standard specifies minimum
requirements for quality systems designed to quantify the concentration of 222Rn
gas in air by qualified professionals and laboratories, whose data are intended to
be used to determine the for radon mitigation
• ANSI/AARST MAH 2019 (ANSI/AARST, 2019) standard specifies procedures
and minimum requirements when measuring 222Rn gas concentrations in singlefamily residences for determining if radon mitigation is necessary to protect
occupants
A standard operating procedure is under development to describe the approach
succinctly for the project team. See 9.0 References for links to view the standards
online. The project-specific modification is essentially in how the CH devices are treated
in this project for regular experimental sampling and for QA testing. Section 4.0
Sampling Procedures describes the radon home sampling project-specific
modifications. Section 4.2 Sampling Equipment and Calibration describes the devices
used in this project. Section 6.0 describes of the QA project-specific modifications.
3.2
Process Measurements
The amount of radon in the air is measured in pCi/L. A Curie is a unit of radioactivity
that describes the quantity of radium emanation (radon gas) in equilibrium with 1 gram
of radium, and the prefix "pico" means a trillionth.
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•
•
•
Radon levels will be measured in pCi/L.
Test duration will be measured in days (six to nine).
All other data will be measured in metric units. (e.g. centimeters, Celsius, liters,
etc.)
4.0 Sampling Procedures
At least one CH radon device will be deployed in each home. Some homes will receive
one test, some simultaneous (duplicate) tests and others will receive sequential testing.
In addition, if the home is greater than 189 m2, an additional device will be placed for
each additional 189 m2, and the test result will become part of the average radon result
for that home. Monitors will remain in the structure for sample collection at least one
week. If the home is being re-tested post-intervention, then a two-day diagnostic test is
approved by the manufacturer. See Section 4.2 Sampling Equipment and Calibration for
more information about the test devices used.
According to EPA recommendations, homes should be tested according to best
practices in the most updated consensus-based standards of practice, ANSI/AARST
MAH(ANSI/AARST, 2019). Accordingly, the lowest livable area of the home should be
tested. Most homes in PR have no basements, so the lowest livable areas will likely be
the first floor. The devices should be placed in a secure position in an area
representative of the scenario that will best represent radon exposure including:
• 12 hours of closed home condition before any 44-48-hour testing,
• all windows remain closed on every level of the building during the test, and
doors opened only long enough for entry and exit until completion of the test,
• placed in lowest livable area,
• normal entry/exit,
• normal/average use of ventilation,
• placed in normally occupied living space (not closet, kitchen, bathroom or
storeroom).
• device should not be exposed to direct sunlight for long periods of time or in
humid locations.
Upon completion of the test, residents will be advised of any subsequent testing or risk
reduction needs. The monitors will be set up at least 50 cm above the floor, 90 cm away
from any doors, windows, or ventilation points, 30 cm from exterior walls, and at least
30 cm below the ceiling. Duplicates (simultaneous testing) should be placed no more
than 20 cm apart. Figure 4-1 shows the ANSI/AARST MAH (ANSI/AARST, 2019)
advisement for device placement.
Figure 4-1. MAH Test Locations
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The adult home occupant will be remotely advised not to move the device, not to tamper
with the test, keep all doors and windows closed during the test and keep ventilation
pattern normal. They will be supplied with a citizen-level SOP and a phone number to
call for questions. In addition, to the extent practicable, Community Leads and UPRM
Team can respond remotely to any questions on placing and retrieving devices.
A project modification to the ANSI/AARST standards seeks to ensure quality of
measurements by treating the CH devices as if they were devices that perform tests
with less precision, such as short-term tests by charcoal canisters, and not as CRMs.
The result is that more tests will occur, which helps to ensure accuracy. Therefore,
sampling will occur according to ANSI/AARST MAH (ANSI/AARST, 2019), the TimeSensitive Testing Protocol (Figure 4-2) and the Extending Testing Protocol (Figure 4-3)
for the “short-term test” option depending on the type of test (regular or simultaneous)
and depending on the result of the first test (for regular tests).
The two tables shown in Figures 4-2 and 4-3 specify protocols from ANSI/AARST MAH
(ANSI/AARST, 2019) when deploying short-term test devices versus CRMs. In this
project, for any non-duplicates (non-simultaneous), the CH will be treated as a CRM
when the initial test is below the action level, in which case no additional test is called
for (Figure 4-2 “continuous monitor”). For simultaneous tests, the CH will be treated as a
short-term test device (e.g. charcoal canister), and two devices will be deployed
simultaneously (Figure 4-2 “simultaneous testing”). When one CH is deployed, if the first
test meets or exceeds the action level, then the test will be immediately followed by
another test (Figure 4-3, step 2, retest, second and third lines). This test: one test
followed immediately by another test, is considered the “sequential” testing option. The
resultant average measurement to be recorded is the average of the two tests when two
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tests are performed, otherwise, a single result from the CH will be recorded. Results
represent a 7-day average.
Figure 4-2. MAH (ANSI/AARST, 2019)Time-Sensitive Testing Protocol
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Figure 4-3. MAH (ANSI/AARST, 2019)Extended Testing Protocol
Some home testing will be considered QC testing. At least 10% of tests will be
simultaneous tests (duplicates), the rest will follow the sequential test protocol. If after
receiving a duplicate or a sequential test, the average level is less than 4 pCi/L (average
of the first test plus the second test), no additional test is warranted. However, homes
that showed averaged levels at or above 4 pCi/L will be evaluated for retest. If the home
already received a duplicate, no retest is necessary; if the home received only one test
(this could happen if the immediate retest was not practicable for the home occupant),
then a retest will occur with the RAD7 (following the “continuous monitor procedure” in
Figure 4-2) or alternate approved device (following the sequential test in Figure 4-3) at a
rate of 10%. The result for these QC tested homes will be reported as the 44-48-hour
average from the RAD7 or an average of the first and second test with the CH devices if
an alternate approved device is used for the second test. In some homes that showed
averaged levels at or above 4 pCi/L and have compartmentalized basements,
sequential tests will include, to the extent practicable, testing every room on the lowest
livable area. See Section 6.2 Quality Control Checks for more information on QA
procedures.
If the final test result in a test indicates levels at or above EPA’s action level of 4 pCi/L,
a designated project team member will inform the tenant of their options to reduce
exposure. Any initial test of 50 pCi/L or above will be followed by a consultation with the
adult home occupant and a retest without delay. Once a test is complete, a designated
project team member will record the test results. The Community Lead or other
designated team member will facilitate the movement of the test device to the next
home to begin new testing. See Section 4.1 Site Specific Factors and 4.3 Sample
Information for discussion of results recording.
Designated project team member(s) will perform limited temporary interventions for as
many homes as practicable that show radon concentrations at or above the action level
after testing is completed for each specific home. All homes with interventions will be
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tested again, post-intervention, for 44-48 hours with either the RAD7 or 48 hours with an
alternate approved device. See Section 3.1 Sampling Design for more information.
4.1
Site-specific Factors
Site-specific factors for sampling include placement of the device, type of home (slab on
grade, basement, crawlspace, etc), home-specific pressure field, extent of natural
ventilation from outdoors (not from soil pore space), underlying geology, weather, and
test duration. Some factors will be known, others observed, some unknown. A form will
be developed before testing which includes space to record site-specific factors for each
test site and whether the factors are known, measured, assumed, observed, etc. UPRM
Team will collect and record the information in Word, RadResponder or another
electronic format.
4.2
Sampling Equipment & Calibration
Though the CH devices are not professional devices, the expectation is that the
consumer devices will perform within a similar level of quality. The RAD7 meets the
AARST-NRPP requirements. Quality assurance guidance is found in the ANSI/AARST
standards ANSI/AARST MS-QA (ANSI/AARST, 2019) and ANSI/AARST MS-PC
(ANSI/ARST, 2015)). Home radon measurement guidance is found in ANSI/AARST
MAH (ANSI/AARST, 2019). In addition, the AARST-NRPP program certifies devices for
professional testing but is not fully aligned with ANSI/AARST MS-PC (ANSI/ARST,
2015) device specifications. See Section 9.0 References for a link to access the
standards online.
Several types of radon devices are described by the ANSI/AARST MS-PC (ANSI/ARST,
2015). The standard seeks to address needs of measurement professionals,
manufacturers, citizens, private proficiency programs, regulators, and anyone
concerned with conducting measurements of radon gas. The specifications and
practices in the standard can be adopted as requirements for contractual relationships
or as recommendations or requirements of a state, country, private proficiency program,
or other jurisdiction of authority. The standard describes the Continuous Radon Monitor
(CRM), which for all intents and purposes, the CH is most like a CRM than other
devices described in the standard in that it continuously monitors radon and can store
hourly data. The standard further defines a CRM as follows: an electronic device that (1)
is capable of providing reviewable, numeric measurements of radon concentration
averaged over time intervals of 1 hour or less, (2) has a minimum detectable
concentration (MDC) of no greater than 148 Bq/m3 (4 pCi/L) for a 1-hour measurement,
and (3) has a calibration factor of at least 2 counts per hour per 37 Bq/m3 (0.054 counts
per hour [cph] per Bq/m3 or 2 cph per pCi/L). To demonstrate meeting all guidance put
forth in ANSI/AARST MS-PC (ANSI/ARST, 2015) for a CRM is cost-prohibitive for the
90 consumer devices employed in this project; therefore, five percent of devices will
receive enhanced QA (above and beyond what would normally occur with a consumer
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device), and all CH devices will receive a comparison check with the enhanced devices
prior to deployment. See Section 6.1.2 Precision for details.
4.3
Sample Information
All sample information will be input into a data collection form and must include, but is
not limited to, radon level readings, home type/structural design, weather, collection
start and end date and time, average geolocation, excluding PII and any other
extenuating circumstances that the designated Project Team member has collected by
onsite visuals. Average geolocations will be identified with each result ensuring not to
collect PII. Residential owner names and addresses will be available to the project
team members exclusively, and not to publicly available information releases. The result
is an average radon level representing the deployment period. The designated Protect
Team member will collect the device, record the readings, upload readings into
RadResponder database and transmit results to the Team Leader. The Project Team
will collect Site Specific Factors forms to aid in analyzing data. See Section 4.1 Site
Specific Factors.
5.0
Analytical Procedures
The Regional RadResponder (Chainbridge Technologies, 2021) Administrator will
create new Event in RadResponder. Instrument names along with their serial numbers
will be entered into the database and assigned to the Data Collectors. Final radon
results as read from devices will be entered into RadResponder by the Project Team’s
Data Collectors using geolocations.
The RadResponder Network is the national standard and Whole Community solution for
the management of radiological data. It is a product of collaboration between Federal
Emergency Management Agency (FEMA), Department of Energy (DOE)/National
Nuclear Security Administration (NNSA), and the Environmental Protection Agency
(EPA), and is provided free of charge to all Federal, state, local, tribal, and territorial
response organizations. RadResponder's flexible architecture enables organizations to
rapidly and securely record, share, and aggregate large quantities of data while
managing their equipment, personnel, interagency partnerships, and multijurisdictional
event space. RadResponder can be accessed on smartphones, tablets, and via the
web, allowing it to be seamlessly and rapidly employed at all levels of government
during a response to a radiological or nuclear emergency or collection of radiological
data. Currently a special platform is being developed for indoor radon; however, until
such time, the existing platform allows radon entries. Additional information is available
on https://www.radresponder.net/ (as accessed on 9/25/2020).
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Region 2 RadResponder Administrator and Equipment Coordinator will receive,
consider, approve/disapprove Data Collectors’ RadResponder account applications,
enter qualified equipment models, serial numbers, assign monitors, provide training,
monitor data collection and validate or reject uploaded data. All data entries will be
verified at 100% with photos and forms by the Administrator and Coordinator.
Each Data Collector will create an account in RadResponder’s EPA Region 2
organization. Each Collector will be assigned several radon monitors, the monitor
models and serial numbers will be recorded in RadResponder. For data collection, the
corresponding event will be created in RadResponder. Data Collectors will install
RadResponder app on their mobile devices and/or computers, they will be trained in
uploading the data that would include monitor readings, locations, photos, comments
and site-specific factors described in Section 4.1. During sampling, Data Collectors will
upload collected data into the database directly on-site or, if there is no cellular
connection, collected data is automatically saved in the apps. The data will be
automatically uploaded once the cellular connection is restored. Alternatively, the data
will be uploaded using computer app.
In RadResponder database, only designated EPA persons, such as Regional
RadResponder Administrator and Equipment Coordinator, has access to the collected
data and only in the specific authorized Regional Events. Individual Data Collectors
have authorizations to access only those data that they collected and uploaded
personally. Non-authorized personnel and public do not have access to the data in
RadResponder. Instruments, serial numbers, maintenance records, specific instrument
and task assignments are integral parts of the RadResponder.
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5.1
Measurement Methods
Radon measurement will take place according to ANSI/AARST MAH (ANSI/AARST,
2019) and device manufacturer’s recommendations for the CH and RAD7 devices
except as noted for research modifications in Section 4.0 Sampling Procedures. The
consumer device will be left to test radon levels for no less than one week. The
professional device (RAD7) provides an accurate measurement within 44-48 hours. The
instruments will be placed in areas of the home/building according to Figure 4-1
ANSI/AARST MAH (ANSI/AARST, 2019)Test Locations: at least 50 cm above the floor,
90 cm away from any doors, windows, or ventilation points, 30 cm from exterior walls,
and 30 cm below the ceiling. Duplicates (simultaneous testing) will be placed no more
than 20 cm apart. Sequential tests will be placed in the same location as the first test.
Once placed, the device should not be moved for the duration of the test.
The adult home occupant will be given remotely citizen-level training on radon testing,
along with literature in Spanish or English (as needed) which provides additional
information at the citizen level for testing and personal safeguarding from radon
exposure. The designated Project Team members (i.e., Data Collectors) will collect and
disinfect the device, collect and record other site-specific information. Additional projectspecific documents (i.e. project-specific sampling SOP, site specific factors and data
form) are under development and will be added to a revised QAPP as necessary.
Appendix A contains a draft data collection form.
According to previously collected data from USGS described in Section 1.1
Background, approximately 10% of homes in this project’s targeted areas were found
above the action level, while EPA estimates that approximately six percent of homes in
the US have radon levels above the action level (EPA, 2016). The USGS study (USGS,
1995) provided a baseline for understanding the potential of radon risk in PR, but it
included far fewer test results than EPA’s national study. However, the National Study
excluded PR. Thus, it remains a reasonable assumption that the range of test results
could fall within 6-10% of tests with levels above 4 pCi/L. Therefore, at least 10% of
tests will receive a combination of QC sampling in the form of retests and duplicates.
Additional quality assurance is discussed in Section 6.2 Quality Control Checks.
6.0 Quality Assurance and Quality Control (QA/QC)
6.1
Data Quality Indicator (DQI) Goals
Table 6-1 lists the DQI Goals for the critical measurements.
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Table 6-1. DQI Goals
Measurement
Parameter
Analysis Method
Assessment
Accuracy
QA Testing in Lab
Device Performance
Test (RAD7,
Corentium Pro);
Approved Alternate
Device Performance
Accuracy
25% IRE
QA Testing in Lab
Device Evaluation
Test
Precision (5% CH)
Comparison Test
MS-PC Modified
Intercomparison
Remaining 95% CH
Field Duplicates and
Sequential Tests
MS-QA, MAH
10% of all tests
(duplicates), all sequential
25% RPD
Retest
MS-QA, MAH
10% at or above 4 pCi/L,
sequential tests not
meeting 25% RPD for
levels above 2 pCi/L
25% RPD
Precision
25% RSD
25% IPE
15%/25% COV
6.1.1 Accuracy
Accuracy of measurement parameters is determined by comparing a measured value to
a known standard. The accuracy statistic is the Individual Relative Error (IRE), which
represents the degree from which a single measured value deviates from the
conventionally true value. The IRE is calculated using the following equation and
accuracy description from the AARST-NRPP DPT protocol in Figure 6-1. To assess
accuracy, the RAD7 and 5% of the CH devices (approved alternate devices) will be sent
to the laboratory under the AARST-NRPP Device Performance Testing (DPT) protocol.
Measurements are expected to fall within the tolerances shown in Table 6-1.
Device Performance Testing is unique in that the analytical service provider is being
graded on their ability to produce accurate and reliable radon test results. Although
there is knowledge that the tests are taking place, there is no prior knowledge of the
radon chamber environment. The results of the performance tests are going to be
related to the quality of the calibration and maintenance services, but more importantly,
the DPT indicates whether the user knows his/her equipment well enough to produce an
accurate assessment of the radon chamber conditions. DPT requires that radon
measurement devices be exposed to a known amount of radon gas in a NRPPapproved radon chamber facility. The chamber returns the devices to the company
performing the analysis services. The device(s) are analyzed to determine the radon
concentrations during their exposure in the radon chamber. The results are then
submitted to the chamber that grades the analytical results against the chamber values.
Each device must measure within 25% of the chamber value for a passing test result.
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If the RAD7 or Corentium Pro fail the DPT, the devices will be inspected and repaired
as needed and reevaluated. Because the CH are consumer devices and not expected
to adhere to the same device standards as professional devices, any failures or
deviations from the criteria in Table 6.1 will be noted and used for data reporting
purposes.
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Figure 6-1. AARST-NRPP DPT Error Criterion
The devices for this project will be sent to the KSU (KSU, 2021) Radon Chamber for
DPT or spiking. The procedure is spelled out here:
• All devices will be exposed for number of hours indicated in the request (RAD7:
two days, CH: seven days).
• For devices requiring a 48-hour to seven-day exposure, a minimum constant
radon concentration of 4 pCi/L or higher will be used.
• The radon will be kept at a constant value (within 10% COV) during the
exposure. The radon concentration will be verified at the beginning of exposure
and at the end of exposure (and every 72 hours during exposure) by a pair of
grab samples read with an EPA inter-compared measuring system
• The chamber temperature will be held to a constant 72 degrees (+/- one degree)
and the humidity will be held between 20 % and 50% RH.
• At the end of the exposure period, the device(s) will be shipped back to you for
your analysis and reading using the shipping method you pre-paid and supplied.
• The final report includes the temperature, barometric pressure and average
humidity information appropriate to your exposure period.
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6.1.2 Precision
Precision is evaluated by making replicate measurements of the same parameter
and assessing the variation of the results. Precision is assessed in terms of relative
standard deviation (RSD) for device evaluation testing and comparison testing of the
CH devices, while relative percent difference (RPD) is used for duplicates and
sequential tests in this project. RPD is described in Section 6.2 Quality Control
Checks. Measurements are expected to fall within the tolerances shown in 6.1.
RSD for Device Evaluation Testing—The six CH devices (approved alternate
devices) will be tested in the KSU laboratory by radon spiking. Results of spiking will
be evaluated for precision by RSD in a Device Evaluation Test, which is described in
Figure 6-2a. Sample standard deviation “s” for the RSD calculation is shown in
Figure 6-2b. where “s” equals the sample standard deviation, “x1…x2…xN” are
observed values of the sample items, “x-bar” is the mean value of observations and
“N” is the number of observations in the sample. The expected RSD is 5% according
to ANSI/AARST MS-PC (ANSI/ARST, 2015), but the adopted criterion is 25%
according to AARST-NRPP Device Evaluation Testing Protocol. While the devices
are not evaluated on this statistic for the DPT, the results will be recorded and
considered when evaluating sample data.
Figure 6-2a AARST-NRPP Device Evaluation Error Criterion
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Figure 6-2b Sample Standard Deviation
RSD for Comparison Testing—The remaining 95% of CH devices that were not
evaluated by DPT will undergo a modified comparison check prior to deployment
utilizing the requirements in ANSI/AARST MS-PC (ANSI/ARST, 2015) as a guide. The
devices will then be compared against the 5% of devices that were analyzed in a DPT.
The devices will be placed in a home, along with the reference device (approved
alternate device), and each device readout will be mathematically compared against the
reference. ANSI/AARST MS-PC (ANSI/ARST, 2015) notes the guidance of COV of less
than or equal to 15%; and that individual devices must demonstrate an individual
percent error (IPE) within ±25% at 6-15 pCi/L. Currently, the NRPP certification program
has not adopted the most stringent standards put forth in ANSI/AARST MS-PC
(ANSI/ARST, 2015), so devices sent for certification are required to meet 25% RSD
(COV) and IRE (IPE).
The modified-comparison test will proceed as follows:
• Five groups of 20 devices will be deployed in residential environments for
seven-day tests.
• Each group will contain one device that underwent professional testing
(approved alternative device).
• The 20 devices will be deployed in homes according to Section 5.1.
• RSD of 19 devices will be compared to known value as read from the CH
approved alternate device.
The RSD of the 19 devices will ideally meet the same as professional devices according
to ANSI/AARST MS-PC (ANSI/ARST, 2015) of less than or equal to 15% and IPE within
±25% at 6-15 pCi/L. However, this level of radon is unlikely to be found in many
residences; therefore, defaulting to a wider range to meet a COV of 25% is reasonable
for levels greater than 2 pCi/L. If the average of the two measurements is less than 2
pCi/L, the device qualification criterion is met if the absolute value of the difference
between the two results is less than 1.0 pCi/L (ANSI/AARST MS-QA (ANSI/AARST,
2019) ). As data are collected, a better determination of limits will be evaluated if meters
fall outside expected limits.
6.2
Quality Control Checks
Duplicates—Upon deployment, 10% of the home measurements will be duplicated.
Approximately 10% of homes are expected to reach this threshold based on the USGS
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report (USGS, 1995). For this project, 350 samples are expected to be collected, so at
least 36 will have received duplicates.
Duplicates will be performed according to ANSI/AARST MAH (ANSI/AARST, 2019)
(Figure 4-2) and as described under ANSI/AARST MS-QA (ANSI/AARST, 2019),
Section 5.4 Field Operations (2019) as shown in Figure 6-3a. The requirement to send
duplicates to the laboratory is moot since the devices read out electronically. The test
statistic for duplicates is the Relative Percent Difference (RPD), which represents
imprecision as a percentile of the best-known concentration estimate. Note that the
RPD is always positive, as the smaller measurement result is subtracted from the
larger measurement result. The average of the two detectors is used in the
denominator because the best estimate of the true concentration is the average of
the results; the RPD therefore represents the imprecision as a percentage of the
best true concentration estimate. The RPD is calculated as follows:
RPD = [(A – B) / mean] * 100
where A = the larger result,
B = the smaller result, and
mean = the average of the two results.
(6)
EPA will oversee the control charts and validate 100% of duplicate statistics.
Figure 6-3a. MS-QA (ANSI/AARST, 2019) Field Operations Duplicates Procedure
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Warning and control limits for duplicates and comparison checks are shown in
Figure 6-3b. If any duplicate pair result exceeds these criteria operations will be
reviewed for potential field effects (e.g. low battery, damaged device, incorrect
placement). If more than 5% of QC checks fall outside warning limits or more than 1%
fall outside control limits, an investigation should result in either corrective action or,
when applying more stringent limits, regeneration of the limits that reflect actual incontrol operations. Duplicates outside the warning limits result in retesting the home
with a RAD7 or alternate approved device according to ANSI/AARST MAH
(ANSI/AARST, 2019).
Figure 6-3b. MS-QA (ANSI/AARST, 2019) Warning and Control Limits
Retesting—Quality control checks will include evaluating homes to be retested, and if
more than 10% meet the criteria for retesting, then at least 10% of home tests will be
retested. Homes will be evaluated in the following order for the need to be retested:
1. homes that had completed sequential tests above 4 pCi/L with an RPD that
exceeds 25%,
2. homes that had initial tests under the sequential test option, but no additional test
to complete the sequential test, and the initial test was greater than or equal to
the action level,
3. homes that had final tests (sequential or duplicates) showing at or above the
action level of 4 pCi/L
Homes will be evaluated by the following evaluation criteria and tested as follows:
• For homes that had completed sequential tests above 4 pCi/L with an RPD that
exceeds 25%, retest 10% of those homes. Retest will occur with the RAD7
(following the “continuous monitor procedure” in Figure 4-1) or alternate
approved device (following the sequential test in Figure 4-2).
• If less than 10% of homes need to be retested due to not having met the RPD
criterion, then for homes that had initial tests under the sequential test option, but
no additional test to complete the sequential test, and the initial test was greater
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•
than or equal to the action level, then the home will be retested. Retest may
occur with the same initial CH device used if the test is started within two days of
the ending of the initial test, otherwise, the RAD7 or alternate approved device
will be used.
If less than 10% of homes need to be retested due to previous criteria, then for
homes that had final tests (sequential or duplicates) showing at or above the
action level of 4 pCi/L, the home will be retested. Exception: if a home that was
found with radon levels at or above the action level was already tested under the
simultaneous (duplicate) option, then additional testing is unnecessary and that
test will be considered as a contribution to meeting the 10% retest QC
requirement.
Test results from retesting will be reported as QC tests and used to qualitatively
evaluate data from those homes. The table in Figure 6-3b will guide the evaluation, and
for any tests that appear to have disagreeable results compared to the control limits,
then the final home result may be left out of final analysis. Sequential QC retests
outside the warning limits at the rate described by ANSI/AARST MS-QA (ANSI/AARST,
2019) result in retesting the home with a RAD7 or alternate approved device according
to ANSI/AARST MAH (ANSI/AARST, 2019).
If more than 10% of homes are found above the 4 pCi/L threshold, all efforts will be
made to provide a QC retest for all homes above 4 pCi/L. In the situation that more than
10% of homes are found above the action level, this signifies a deeper radon issue in
Puerto Rico, and EPA will convene with the PR Department of Health and selected
members of the Healthy Buildings Long-term Recovery initiative for a path forward
beyond the scope of this project.
7.0
Data Analysis, Interpretation, and Management
7.1
Reduction
Radon readings from the home devices will be recorded after the initial seven-day test
period. For homes that show readings above 4pci/L, the reading generated from the 4448-hour RAD7 or Corentium Pro test will supersede that of the home device. All RAD7
and Corentium Pro test results (even those associated with random QA) will replace
results generated by the home devices. These test results will be compiled into a GIS
dataset to be used in the creation of a project-specific radon map. All data collected,
regardless of its inclusion in the reduction process, will be kept for reporting purposes.
7.2
Validation
All recorded data will be validated by trained personnel to ensure that the data were
collected and logged appropriately. Validation will consist of Student Leads looking at all
data collection forms to ensure completeness and by interview of adult home occupants
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to evaluate if the test parameters were maintained during the duration of the test (e.g.
devices did not lose power, were not moved, and were not in any other way disturbed
during the test period). In addition, test forms and accompanying photos will be verified
100% for accuracy after being entered into the data spreadsheet containing all radon
points. Data in RadResponder will be verified 100% for accuracy from data forms to a
printout of the RadResponder entries. In addition, the internally stored data from the
RAD7 and Corentium Pro will be verified against the inputted data on the data
spreadsheet for 100% of the readings above 10 pCi/L. QC test needs and deployment
will be monitored by EPA Team with calculations verified at 100%.
7.3
Data Storage Requirements
Data will be stored both electronically and physically. All data will be archived
appropriately for future reference. The home-occupant will be given the Citizen’s Guide
to Radon in English (EPA, 2016) and Spanish (EPA, 2017). Project Team will collect
site-specific information on a data collection form (see Appendix A). The form will
document the location by general area, time period of measurement, result of
measurement, and contact person. In addition, electronic records will be entered in
RadResponder by trained Project Team. Appendix B contains a Spanish version of
Appendix A and radon background information for homeowners and interested parties.
8.0
Data Reporting
8.1
Reporting Requirements
Reporting requirements for this project include:
•
•
•
•
•
•
•
8.2
Duration of test (days)
Radon reading: CH seven-day average reading from the home device. If
two devices are placed (duplicates and simultaneous), both results will be
reported on forms and data spreadsheet; however, the average of the two
readings will serve as the final radon result. If RAD7 or Corentium Pro is
used for a home test, the test is 44-48 hours and the test results from the
RAD7 or Corentium Pro will supersede CH readings.
Device Type: CH or RAD7 or Corentium Pro serial number
Device location within the home (floor/room/position)
Weather conditions
Remedial action needed, if any
Test type (initial: duplicate or sequential, post-intervention)
Data-Related Deliverables
Data-related deliverables include the following: final activities reporting, data reports,
summaries, charts and maps for post-project communication pieces, as well as a final
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report of results, lessons learned, and scalability to other communities, and a report of
selected policy options to municipalities based on results of sampling:
•
Radon level report: This is a preliminary report that will explain a home’s
radon readings to the occupant. It will include radon levels from either the
seven-day average from the home device, or the test results from the RAD7
or Corentium Pro as applicable. Test results will be explained, and remedial
action options will be outlined as necessary.
•
Post-intervention action assessment: Post-intervention action assessment
will discuss the retest of the homes that were recommended to take
remedial action. The assessment will show the results of the second test
and highlight the overall success of the suggested intervention.
•
GIS-based map: The documentation of location, time period of
measurement and radon concentration will be recorded in electronic form
using RadResponder (Chainbridge Technologies, 2021) by the Project
Team. Generalized geolocations, excluding PII, will be utilized in
conjunction with radon test results to generate a workable geodatabase
for radon levels in seven municipalities of Puerto Rico. RadResponder will
export maps in formats compatible with the ArcGIS. This information will
be used to create a geospatial map of radon levels for the various
communities being tested. An ArcGIS story map will be developed. Story
maps use GIS tools to combine geospatial data with photos, video, audio,
and text to visualize a theme or sequential events. Story maps are
designed for nontechnical audiences; users do not need experience with
GIS software to read or use story maps. Maps will be disseminated to
appropriate stakeholders and will also be incorporated into the final report
of the project assessment. The purpose is to visually represent radon
levels in various neighborhoods throughout the communities of Puerto
Rico so that stakeholders can have a better understanding of the potential
radon risk in their areas.
•
RadResponder Database – Cloud-based, official EPA radiological data
database. Instrument database. Instrument assignments to Data
Collectors (students), radon sampling results with corresponding
coordinates, residential addresses, names, photos, comments,
observations, maps (non-public access)
•
Measurement Requests Database – information listing home address,
contact person, phone, status (pending, in-progress, complete, follow-up).
Each municipality is listed separately (non-public access)
•
Measurement Instrument Log – Instrument measurement performance
must be logged, each dual measurement identified and agreement
tracked (PC backup to RadResponder), measurements implemented in
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professional Radon Report Manager database software Version 3.7.0,
already installed and currently in use for E-Perm functionality checks (nonpublic access).
Table 8-1 lists the data-related deliverables, format of each deliverable, and personnel
responsible.
Table 8-1. Data-Related Deliverables
Deliverable
Radon Levels Report
Custodian
EPA Team,
UPRM Team
Post-intervention
Action Assessment
EPA Team,
UPRM Team
GIS-based Map and
Story Map
Technician
9.0
Person Delivered to
UPR-School of Public Health,
PR Dept. of Health; Healthy
Buildings workgroup; Joint
Disaster Recovery Group
Format
Word Document,
Personal
Communications,
and Web
UPR-School of Public Health,
PR Dept. of Health; Healthy
Buildings workgroup; Joint
Disaster Recovery Group
Word Document,
Personal
Communications,
EPA, Healthy Buildings Longterm Recovery Work Group
GIS Map and
Word Document
References
ANSI/AARST. (2019). MAH-Protocol for Conducting Measurements of Radon and
Radon Decay Products in Homes. Hendersonville: ANSI/AARST. Retrieved from
https://standards.aarst.org/MAH/index.html
ANSI/AARST. (2019). MS-QA-Radon Measurement Systems Quality Assurance.
Hendersonville, NC: AARST. Retrieved from
https://standards.aarst.org/MAH/index.html
ANSI/ARST. (2015). MS-PC-Performance Specifications for Instrumentation Systems
Designed to Measure Radon Gas in Air. Hendersonville, NC: AARST. Retrieved
from https://standards.aarst.org/MS-PC-2015/index.html
Chainbridge Technologies. (2021, 2 23). Resource Library. Retrieved 2 23, 2021, from
RadResponder: https://www.radresponder.net/#resources/library
Durridge Inc. (2021, 2 23). Retrieved 2 23, 2021, from Radon Capture & Analytics:
https://durridge.com/
EPA. (1992). National Residential Radon Survey-Summary Report. EPA 402-R-92-011.
Washington: EPA. Retrieved 2 23, 2021, from
https://nepis.epa.gov/Exe/ZyNET.exe/910180YH.TXT?ZyActionD=ZyDocument&
Client=EPA&Index=1991+Thru+1994&Docs=&Query=&Time=&EndTime=&Sear
chMethod=1&TocRestrict=n&Toc=&TocEntry=&QField=&QFieldYear=&QFieldM
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onth=&QFieldDay=&IntQFieldOp=0&ExtQFieldOp=0&XmlQuery=
EPA. (2016). A Citizen’s Guide to Radon. EPA 402/K-12/002. Washington, DC: EPA.
Retrieved 2 23, 2021, from https://www.epa.gov/radon/citizens-guide-radonguide-protecting-yourself-and-your-family-radon
EPA. (2017). Manual Informativo Sobre el Radon. Washington, DC: EPA. Retrieved 2
23, 2021, from https://espanol.epa.gov/sites/production-es/files/201709/documents/manual_informativo_sobre_el_radon.pdf
EPA. (2020). Interim EPA COVID-19 Health & Safety Guidelines for Field Activities –
July 6, 2020. Washington, DC: EPA. Retrieved from
https://www.epa.gov/sites/production/files/202007/documents/interim_epa_covid19_h_s_guidelines_field_work_final_07062020.pdf (accessed on 2/23/2021)
EPA. (2021, 2 23). Find Information about Local Radon Zones and State Contact
Information. Retrieved from Find Information about Local Radon Zones and State
Contact Information: https://www.epa.gov/radon/find-information-about-localradon-zones-and-state-contact-information
KSU. (2021, 2 23). Device Performance Test Procedure. Retrieved from KSU Radon
Chamber: https://ksuradonchamber.org/DPT%20Procedure
PR DOH. (1996, April). Retrieved 2 23, 2021, from ESTUDIO DE RADON EN PUERTO
RICO: https://www.yumpu.com/es/document/read/14365361/estudio-de-radonen-puerto-rico-departamento-de-salud
Rad Elec Inc. (2021, 2 23). Retrieved 2 23, 2021, from Rad Elec Inc. Radon
Measurement Systems: https://www.radelec.com/
RaData. (2021, 2 23). Retrieved 2 23, 2021, from RADATA: https://radata.com/
USGS. (1995). Geologic Radon Potential of Guam and Puerto Rico, Report 93-292-K.
Washington, DC: USGS. Retrieved 2 23, 2021, from
https://pubs.usgs.gov/of/1993/0292k/report.pdf
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Appendix A
Instructions for Testing Residence for Radon Using “Corentium Home” Radon
Monitor
Radon is colorless, odorless radioactive gas that comes from the natural decay of
uranium that is found in nearly all soils. It typically moves up through the ground to the
air above and into your home through cracks and openings in the foundation. For more
information about radon, visit www.epa.gov/radon. You can’t see radon, but you can
find out the level of radon in your home. Please follow the instructions below.
1. You will be using Corentium Home monitor, manufactured by AIRTHINGS, Inc.
(https://www.airthings.com/home). Familiarize yourself with the monitor using
attached monitor’s User Manual and online description.
2. Disinfect the monitor before and after each test by lightly wiping it off with the paper
napkin moistened by provided disinfectant. Do not spray any liquid on the monitor.
Do not apply an excessive amount of moisture on the monitor.
3. Look at the screen, it should display various sets of letters and numbers.
a. If the screen is blank or flashing, check that the batteries are installed
correctly.
b. If the low battery level indicator icon appears in the upper left corner
change batteries as soon as possible.
4. Find a proper Test Location:
a. Choose a lowest livable room such as the living room, office or bedroom
where no cooking, showering, excessive ventilation, open windows, or
laundering takes place.
b. Choose a place to set down the monitor that is inaccessible to small
children.
Place the monitor about waist high, more than three feet from any doors to
the outside, windows, or ventilation points, and more than one foot from
exterior walls. Place monitor at least four inches from other objects and, if
possible, away from the house wall that is heated by sun during the day.
Follow the picture below for placement instructions.
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5. Reset the monitor to begin a new measurement cycle:
a.
With the end of a paper clip or pen,
reset the radon monitor by placing the end of
Screen appearance after
the paper clip in the reset button in the back of
initial reset
the monitor, lightly press & release.
b.
Ensure that after series of internal
commands the monitor displays a series of one to four dashes (----) as
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in the figure on the left. The indicator on top right of the screen flashes
when instrument is active as in the figure on the right. These two screens
would alternate after reset. If not, reset again.
c. Set down the device, screen up, and leave it in place for seven days.
d. Monitor will collect data for some time and will begin displaying some
readings after 6-24 hours depending on the level of radon in home.
e. Some homes will receive two monitors; set them side-by-side but at least
4 inches apart and begin the tests at about the same time.
6. Record Information:
a. Fill in address, phone, test location, and start date and time below.
b. Take photo of the monitor in place.
c. After seven days, write the end date and time, and the final test result,
which is displayed in small numbers on the bottom of the screen. Note that
the readings on the bottom alternate every second between “1-DAY” and
“7-DAYS” measurements. Record
“7-DAYS” reading. See location of
Screen appearance after
the required reading in the figure
seven days have passed after
below. Do not record large
reset
numbers at the top of the screen.
This “7-DAYS”
reading needs to be
recorded
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d. Enter any comments (e.g. rainstorm for two days, window open on day
five, exposure to direct sunlight, monitor was dropped, exposed to water
etc.)
e. If “7-DAYS” reading is not displayed after seven days, and only “1-DAY” is
displayed, wait for two more days and check the screen again. Monitor
may reset itself during test. Monitor may reset itself if dropped. If that
happens, wait for seven more days again after reset. If “7-DAYS” reading
is still not displayed, contact UPRM.
7. Send Photo of Final Test Result, and the Form below:
a. Take a photo of the screen face after seven days of testing. Note that the
readings on the bottom alternate every second between “1-DAY” and “7DAYS” values. Make sure “7-DAYS” is displayed on the left bottom corner
of the screen.
b. After recording all information on this form, take a photo.
c. Send the two photos to the UPRM contact.
d. Send the UPRM contact any questions/concerns you have about your
radon test.
8. Upload results, photos and observations into RadResponder database.
Address:______________________________________________________________
Name &
Phone:_______________________________________________________________
Test Location:
________________________________________________________________
Start Date and Time:
__________________________________________________________
End Date and Time:
___________________________________________________________
Test Result (pCi/L): ____________________
COMMENTS:___________________________________________________________
SEND PHOTO OF DEVICE’S FINAL READING AND A PHOTO OF THIS FORM
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Appendix B
Instrucciones para hacer la prueba de radón en su hogar usando el monitor “Corentium
Home”
El radón es un gas radiactivo sin color ni olor que proviene de la descomposición
natural del uranio que se encuentra en casi todos los suelos. Por lo general, este gas
fluye a través del suelo al aire y entra a su hogar a través de las grietas y aberturas en
los cimientos. Para obtener más información sobre el radón, visite la página web
https://espanol.epa.gov/cai/acerca-del-radon o en inglés www.epa.gov/radon. Usted no
se puede ver el radón, pero sí puede determinar cuál es el nivel de radón en su hogar.
Por favor, siga las siguientes instrucciones.
1. Usted utilizará el monitor “Corentium Home” fabricado por AIRTHINGS, Inc.
(https://www.airthings.com/home). Familiarícese con el monitor utilizando el
manual de usuario del monitor adjunto y la descripción en línea.
2. Desinfecte el monitor antes y después de cada prueba limpiándolo con la
servilleta de papel humedecida con el desinfectante provisto. No rocíe ningún
líquido sobre el monitor. No humedezca excesivamente el monitor
3. Mire la pantalla, la misma debe mostrar various conjuntos de números.
a. Si la pantalla está en blanco o parpadea, verifique que las baterías estén
instaladas correctamente.
b. Si el indicador de batería aparece en la esquina superior izquierda,
cambie las baterías lo antes posible.
4. Encuentre una ubicación adecuado para la prueba.
a. Elija una habitación como la sala o el dormitorio, donde no se cocine, se
duche, no haya ventilación excesiva, ventanas abiertas o donde se lave
ropa.
b. Elija un lugar para colocar el monitor que sea inaccesible para los niños
pequeños.
c. Coloque el monitor a la altura de la cintura, a más de 3 pies de cualquier
puerta que abra hacia el exterior, ventanas o puntos de ventilación, y a
más de 1 pie de las paredes exteriores. Coloque el monitor al menos a 4
pulgadas de otros objetos y, si es posible, lejos de la pared de la casa que
se calienta con el sol durante el día. Siga la imagen a continuación para
ver instrucciones de ubicación.
5. Reinicie el monitor para comenzar un nuevo ciclo de medición.
a. Con la punta de un clip o bolígrafo, reinicie el monitor de radón colocando
la punta del clip en el botón de reinicio en la parte posterior del monitor,
presione y suelte ligeramente.
b. Asegúrese de que después de una serie de comandos internos, el
monitor muestre una serie de hasta 4 guiones (----) como en la figura de
la izquierda. El indicador en la parte superior derecha de la pantalla
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parpadea cuando el instrumento está activo como en la figura de la
derecha. Estas dos pantallas se alterarían después del reinicio. Si no es
así, reinicie nuevamente.
c. Coloque el monitor con la pantalla hacia arriba y déjelo en el lugar durante
7 días.
d. El monitor recopilará datos durante algún tiempo y comenzará a mostrar
algunas lecturas después de 6 a 24 horas, según el nivel de radón en el
hogar.
e. Algunos hogares recibirán dos monitores por razones comparativas o
para confirmar la medición. Colóquelos uno al lado del otro pero al menos
a 4 pulgadas de distancia y comience las pruebas aproximadamente al
mismo tiempo.
6. Registre la Información:
a. Escriba la dirección, el teléfono, la ubicación de la prueba y la fecha y
hora de inicio a continuación.
b. Tome una foto del monitor ya en su lugar.
c. Después de 7 días, escriba la fecha y hora de finalización y el resultado
final de la prueba, que se muestra en pequeños números en la parte
inferior de la pantalla. Tenga en cuenta que las lecturas en la parte inferior
alternan cada segundo entre las mediciones de”1 día” y “7 días”. Registre
la lectura de “7 días”. Vea la ubicación de la lectura requerida en la figura
siguiente. No registre números granes en la parte superior de la pantalla.
d. Ingrese cualquier comentario (por ejemplo, tormenta de lluvia durante dos
días, ventana abierta el quinto día, exposición a la luz solar directa, el
monitor se cayó, se expuso al agua, etc.)
e. Si la lectura de “7 días” no se muestra después de los 7 días, y solo se
muestra “1 día”, espere 2 días más y revise la pantalla nuevamente. El
monitor puede reiniciarse si se cae. Si eso sucede, espere 7 días más
nuevamente después del reinicio. Si aún no se muestra la lectura de “7
días”, comuníquese con UPRM.
7. Envíe una foto del resultado final de la prueba y el siguiente formulario:
a. Tome una foto del frente de la pantalla después de 7 días de prueba.
Tenga en cuenta que las lecturas en la parte inferior alternan cada
segundo entre los valores de “1 día” y “7 días”. Asegúrese de que
muestre “7 días” en la esquina inferior izquierda de la pantalla.
b. Después de registrar toda la información en este formulario, tome una
foto.
c. Envíe las dos fotos al contacto de la UPRM.
d. Envíe cualquier pregunta o inquietud que tenga sobre su prueba de radón
al contacto de la UPRM.
e. Escriba los resultados, la dirección, las fotos y las observaciones en la
base de datos de “RadResponder”
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Dirección:
______________________________________________________________________
Nombre y teléfono:
_______________________________________________________________
Lugar de la prueba:
_______________________________________________________________
Fecha y hora de inicio:
_____________________________________________________________
Fecha y hora de conclusión:
_________________________________________________________
Resultado de la prueba (pCi/L):
______________________________________________________
Comentarios:
_____________________________________________________________________
Envíe una foto de la lectura final que aparece en el monitor y una foto de este
formulario a:
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Attachment:
Corentium Home User Manual
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Attachment:
E-Perm System User’s Manual
®
| File Type | application/pdf |
| Author | ctsuser |
| File Modified | 2021-04-20 |
| File Created | 2021-04-20 |