TABLE OF CONTENTS
| Topics | Sections |
|---|---|
| OVERVIEW | 12.1 What is the purpose of this chapter? 12.2 What is the scope of this chapter? 12.3 What is the Service’s overall policy on radon management? 12.4 What are the authorities for this chapter? 12.5 What terms do you need to know to understand this chapter? |
| RESPONSIBILITIES | 12.6 Who is responsible for the management of radon testing and mitigation? |
| IMPLEMENTATION | 12.7 What are the components of radon management? |
OVERVIEW
12.1 What is the purpose of this chapter? This chapter describes the U.S. Fish and Wildlife Service’s (Service) requirements and procedures for:
A. Determining whether radon gas is present in our facilities and drinking water systems, and if so, at what levels, and
B. Implementing mitigation measures when necessary.
12.2 What is the scope of this chapter? This chapter applies to occupiable spaces and non-public subsurface drinking water sources in Service-owned or leased buildings and structures.
12.3 What is the Service’s overall policy on radon management? Our policy is to prevent Service employees and their family members, contractors, volunteers, and visitors from being exposed to unsafe levels of radon gas.
12.4 What are the authorities for this chapter?
A. General Services Administration (GSA) Memorandum, Radon (PBS P 5940.2).
B. Standards for Protection Against Radiation, Appendix B: Derived Air Concentrations of Radionuclides for Occupational Exposure, as amended (10 CFR 20).
C. Toxic Substances Control Act, as amended, Indoor Radon Abatement (15 U.S.C. 53.2669).
D. 485 Departmental Manual (DM) 2,Safety and Occupational Health Program, Responsibilities.
12.5 What terms do you need to know to understand this chapter?
A. Mitigation. Radon mitigation is any system or steps designed to reduce radon gas concentrations in the indoor air of a building or a non-public subsurface drinking water system.
B. Non-public subsurface drinking water system. This is a non-municipal drinking water source that is underground (e.g., a well that pumps water from an aquifer).
C. Picocurie per liter (pCi/L). A pCi/L is a unit of radioactivity corresponding to an average of one decay every 27 seconds in a volume of one liter of air.
D. Radon. Radon is an inert, colorless, odorless, naturally occurring, radioactive gas that is formed by radioactive decay of radium atoms. Radon, which may be found in drinking water and indoor air, can cause lung cancer.
RESPONSIBILITIES
12.6 Who is responsible for the management of radon testing and mitigation? See Table 12-1.
Table 12-1: Responsibilities for Radon Management
| These employees… | Are responsible for… |
|---|---|
| A. The Director | Approving Service policy for the management of radon testing and mitigation. |
| B. The Assistant Director - Business Management and Operations | Ensuring that policy regarding radon testing and mitigation is in place. |
| C. Regional Directors | Ensuring radon testing and mitigation activities in the Regions occur as required by this policy. |
| D. The Chief, Division of Engineering | Providing policy, technical assistance, and guidance on implementation of radon testing and mitigation measures to ensure compliance with applicable environmental laws and regulations. |
| E. The Chief, Division of Safety and Health | Assisting the Regions in control and mitigation of radon exposure. |
| F. The Chief, Division of Contracting and General Services (CGS) | Facilitating radon testing and mitigation at Service locations in buildings that the GSA owns or administers. |
| G. Regional Engineers/ Regional Environmental Compliance Coordinators (RENs/RECCs) | (1) Providing technical assistance to: (a) Project Leaders/Facility Managers regarding radon testing, acceptable radon levels, and mitigation measures; and (b) Personnel who conduct radon testing with “do-it- yourself” test kits in accordance with the instructions; (2) For buildings we lease from GSA or others, coordinating with CGS personnel to ensure that the owner or lessor conducts radon testing and mitigation; and (3) Maintaining a Regional inventory of Service buildings and non-public subsurface drinking water sources that have been tested for radon, including sampling and mitigation documentation. |
| H. Regional Safety Specialists | Providing technical assistance to Project Leaders/Facility Managers when acceptable radon levels are exceeded and when medical surveillance may be required. |
| I. Project Leaders/Facility Managers | (1) Ensuring that knowledgeable personnel have performed required radon testing at field stations; (2) Ensuring that structures, buildings, and water systems that have installed radon mitigation systems are tested for radon whenever they conduct a renovation or a repair project; (3) Maintaining records of radon testing and mitigation; and (4) Notifying the RECC and Regional Safety Specialist when acceptable radon levels are exceeded. |
IMPLEMENTATION
12.7 What are the components of radon management? Effective management of radon gas includes testing, evaluation of radon test results, and mitigation where needed to reduce radon to acceptable levels.
A. Radon Testing. Although all occupiable spaces and non-public subsurface drinking water sources in Service-owned or leased buildings and structures require radon testing, residences, bunkhouses, and dormitories are the highest priority for testing.
(1) You do not need to test buildings or structures that are not occupied (e.g., enclosed parking structures, warehouses that do not have offices in them, pole barns, pesticide storage buildings).
(2) You may use either:
(a) A U.S. Environmental Protection Agency (EPA)-approved contractor or knowledgeable local, state, or Federal health services personnel; or
(b) A radon “do-it-yourself” testing kit, which generally is low-cost and available online or at home improvement retail stores.
(3) If using a “do-it-yourself” kit, test for radon in the following manner:
(a) Place the radon-sampling device on the lowest occupiable level of the structure structure
Something temporarily or permanently constructed, built, or placed; and constructed of natural or manufactured parts including, but not limited to, a building, shed, cabin, porch, bridge, walkway, stair steps, sign, landing, platform, dock, rack, fence, telecommunication device, antennae, fish cleaning table, satellite dish/mount, or well head.
Learn more about structure in a location where it will not be disturbed.
(b) Conduct short-term measurements that last 90 days or less under closed-building conditions, such as during the heating or air conditioning season. Avoid taking measurements in the spring or fall when windows are open.
(c) Sample Service-owned non-public subsurface water sources at the point of entry into the structure.
(4) Contact your RECC for additional guidance on testing.
B. Evaluating Radon Levels.
(1) Table 12-2 lists the acceptable radon levels for buildings and non-public subsurface water sources, which are based on GSA radon standards and the Nuclear Regulatory Commission’s exposure limits for the workplace.
Table 12-2: Acceptable Radon Levels
| Radon levels less than… | Are acceptable for… |
|---|---|
| 4 pCi/L |
|
| 25 pCi/L |
|
(2) Buildings tested prior to the date this policy was signed and that have radon levels less than the thresholds in Table 12-2 require no additional testing.
C. Mitigation. When the acceptable radon levels are exceeded for a building or structure, the Project Leader/Facility Manager must ensure mitigation is performed according to the schedule in Table 12-3.
Table 12-3: Radon Mitigation Schedule
| Radon levels… | Require… |
|---|---|
| Above 200 pCi/L | (1) Immediate retesting, (2) Starting mitigation activities within 1 month, and (3) Temporarily removing the employees from the workspace or occupants from residences. |
| Between 25 pCi/L and 200 pCi/L | (1) Immediate retesting, (2) Starting mitigation activities within 6 months, and (3) Considering temporary removal of employees or occupants when levels are at the higher end of the range. |
| Between 4pCi/L and 25 pCi/L | (1) Retesting within 6 months, (2) Long-term (1-year) measurements to determine realistic levels of radon, and (3) Starting mitigation within 1 year based on the testing and analysis. |
| Less than 4pCi/L | No further action. |
D. Mitigation methods.
(1) In general, you can reduce radon levels with one or a combination of more than one of the following mitigation techniques:
(a) Activated carbon,
(b) Aeration,
(c) Depressurization,
(d) Pressurization,
(e) Sealing,
(f) Suction, or
(g) Ventilation.
(2) Contact your RECC or refer to the U.S. EPA Consumer's Guide to Radon Reduction for additional guidance on mitigation techniques.
E. Post-Mitigation. After installation of a radon mitigation system:
(1) You should measure the radon gas over at least the next 3 months, and preferably during the winter. Secondary, longer-term measurements, usually over 12 months, will provide a more definitive picture of radon reduction.
(2) Radon testing must be conducted after completion of renovation or repair projects for structures, buildings, and water systems with an installed radon mitigation system.