Thread: Radon Remediation Systems not up to EPA Standards

Guys,
I'm looking for some back up here or let's say additional backup to the EPA standards for radon remediation systems and maybe some good retorical comments I can put to some let's say less than honest realestate agents. I know it's hard to believe they exist! Here's the thing I've been running into lately. A radon reduction system installed in a basement over the sump pit, which is properly sealed, but having 2" ABS piping extending out from the cover expanded with a rubber joint to fit a 4" radon pump mounted inside the conditioned space (just above the sump) then reduced again by a rubber reducer to 2" ABS run up through the wall to the attic and through the roof.
Now the EPA standards as of 1991 (the house was built in 1996) say the pump can not be mounted inside the conditioned space (as this one is) and must be plumbed with 3" or better piping (which this one isn't). We all know this. I rate it as a defect on the basis, it is not up to the EPA standard (notice I did not use the code word), it poses a health, moisture and fire risk if or when the seals fail and/or a considerable expence to my client to have to remove it and put in a proper system. We're talking a thousand bucks or better here! Please where am I wrong?
This agent is THE highest producing agent with the company that has over 60% market share in my area of WI. He was the listing agent for 2 of the instences, and has called me into a meeting to convince me to change my rating to only fair because the system was working, there by depriving my client of the opportunity to have this addressed by a radon speciallist as I recommended and repaired by the seller. Of coarse you know I'm not having any of that! He then shows up at another job knowing the samething will pop up and trys to intimidate me in front of my client and his agent, then sends his drop dead gorgeous assitant to play the sweet card on me by trying to be the go between and work this out. As far as I'm concerned it is worked out, I'm right and he's wrong, and our area radon speciallist aggrees with me.
I have since been approached by more caring agents to do a PR presentation to each office on the dangers of these builder installed radon systems.
Anybody have any suggestions or ammunition I can use on this guy?

Jim Weyenberg
HouseMaster Inc.
Senior Inspector
2006 HouseMaster Inspector of the Year
jimweyenberg@new.rr.com
920-309-3410

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Hi Jim,

Your correct with the vent/run piping should be a minimum of 3 inch ID and the fan should NOT be located in conditioned space. But, last year (2006) the EPA withdrew its standards and have adopted ASTM2121 as the standard. You need to get a copy of this document and refer to it when stating standards in non-regulated states. Also, since I'm sure you documented the problems I would also point your clients and agents to the radon professionals (certified) from NEHA-NRPP (National Radon Proficiency Program) or NRSB (www.nrsb.org). Also, Conrad from the WI health department might give you more direction. If you need his email address let me know.
A big problem in WI is that there is no regulation or requirement to have radon professionals certified or trained so make sure your contact is certified in radon mitigation.... good luck.

Paul,
Thank you very much for bringing me up to speed on the changes. I did as you suggested and ordered a copy of the ASTM E-2121 and did at each of the last 3 inspection where this concern was apparent recommend our area radon specialist and as you pointed out he is certified by 4 of the major governing boards. This information will be most helpful as I put together a short presentation for all the area real eastate offices on this concern, with a goal of avoiding upset agents by imforming them of the safety as well as cost concerns that could affect my clients.
Thanks Again Paul

Jim Weyenberg
HouseMaster Inc
Senior Inspector
2006 HouseMaster Inspector of the Year
jimweyenberg@new.rr.com
920-309-3410

I learned something (I think) at last months ASHI meeting. A mitigation specialist from Denver spoke at the meeting. He said the radon exhaust CANNOT exit under an eave. That makes EVERY one I have seen here wrong. Anybody else know about this. I cant see hacking through the soffit and roof for the exhaust.

Originally Posted by Paul Kondzich

I learned something (I think) at last months ASHI meeting. A mitigation specialist from Denver spoke at the meeting. He said the radon exhaust CANNOT exit under an eave. That makes EVERY one I have seen here wrong. Anybody else know about this. I cant see hacking through the soffit and roof for the exhaust.

See ASTM E2121-03, which supersedes the EPA “Radon Mitigation Standards,” EPA 402-R-93-078, April, 1994. The EPA will mail you ONE paper copy free. The PDF version or more copies cost $41 each from ASTM. The standard was published in February 2004 and the EPA discontinued all support of its own program in May, 2006.

The following pertains specifically to your question:

7.3.2.9 To reduce the risk of vent stack blockage due to
heavy snow fall, to reduce the potential for re-entrainment of
radon into the living spaces of a building, and to prevent direct
exposure of individuals outside of buildings to high levels of
radon, the discharge from vent stack pipes of active soil
pressurization systems shall meet the following minimum
requirements. The discharge from vent stack pipes shall be:

(1)

Vertical and upward, outside the structure, at least 10 ft
(3 m) above the ground level, above the edge of the roof, and
shall also meet the separation requirements of (2) and (3).
Whenever practicable, they shall be above the highest roof of
the building and above the highest ridge.

(2)

Ten feet (3 m) or more away from any window, door, or
other opening into conditioned or otherwise occupiable spaces
of the structure, if the radon discharge point is not at least 2 ft
(0.6 m) above the top of such openings.

(3)

Ten feet (3 m) or more away from any opening into the
conditioned or other occupiable spaces of an adjacent building.
Chimney flues shall be considered openings into conditioned or
otherwise occupiable space.

(4)

For vent stack pipes that penetrate the roof, the point of
discharge shall be at least 12 in. (0.3 m) above the surface of
the roof. For vent stack pipes attached to or penetrating the
sides of buildings, the point of discharge shall be vertical and
a minimum of 6 in. (150 mm) above the edge of the roof and
in such a position that it can neither be covered with snow, or
other materials nor be filled with water from the roof or an
overflowing gutter. In areas where it snows the point of

discharge shall be 12 in. (0.3 m) above the surface of the roof.

I just had the local old-time mitigation "expert" blow a gasket over this at an ASHI Chapter meeting. I think some of his installations were rated deficient in some recent home inspections and he was edgy about the subject. At the next meeting, he brings in class materials from the class at Auburn University, and had the same passage (almost the same) as above all nicely highlighted to show me that there was no requirement to bring the exhaust above the edge of the roof (Gloat, Gloat) that did not include anything about "above the edge of roof". The problem as apparently due to the fact that he had not kept up with specification changes. I cannot say if he bothered with the CE required by certification or not. Anyway, I sent him the above too. Haven't heard anything else.

I guess the answer is if it was installed prior to May 2006, it didn't have to be above the roof. If anyone has better transition dates, please let me know.

Guys,

I think the EPA incorporated the ASTM standard by reference and kept theirs in effect.

You may also go the AARST American Association of Radon Scientists and Technologists and nose around for that standard.

It frosts me that our government makes us pay for a document that was written by "experts" who paid to be on the committee that wrote it.

Jim,
You have gotten all good information in this post. Stand your ground.

Bruce
PS I have a PA power point laying around here that you can adapt, If you Email me I'll send it to you

From the PA DEP website:

RadonvideoPart3

Jim,

You can pull Joe's video off of the PA web site at Bureau of Radiation Protection--Radon Division

Quick and easy way to inform the agents, but also point out pipe size.

Bruce

The following is the opening paragraph for mitigation from EPA publication page.

EPA’s Recommended Residential Radon Mitigation Standard of Practice

EPA recommends the Standard Practice for Installing Radon Mitigation Systems in Existing Low-Rise Residential Buildings* for residential radon mitigation (EPA 402-K-03-007). This voluntary, consensus-based standard was developed and issued by the American Society for Testing and Materials International, and is identified as ASTM E-2121.

The Agency first cited ASTM E-2121 in 2003 as a national consensus standard appropriate for reducing radon in homes as far as practicable below the national action level of 4 picoCuries per liter (pCi/L) in indoor air. As of May 2006, EPA no longer recommends, and will no longer distribute its own, superseded Radon Mitigation Standards (EPA 402-R-93-078, Revised April 1994).

I noticed the PA specifications, dated 1994, call for above the edge of the roof exhaust.

The above EPA statement calls it a "voluntary" standard. Hmm. Would this mean that if a particular state or locality doesn't have an established specification or code, it would be left to the individual mitigator?

Great job standing up to the Realtor. I gather you may be newer, so standing up to a big realtor can be intimidating.

What I've found over the years is that once you gain a reputation for being ethical, ethical agents will use you. It may take a while, but there ARE in fact some ethical agents out there LOL....

Good luck and your ethics WILL in time pay off. Way to stand tough. Just stand tough with a smile on your face and DO NOT waver, especially when you know you're correct.

And yes, termination of a mitigation system below the roof line is NOT automatically a defect.

Stu,

The EPA has no enforcement. That has been left up to the states or the Home Inspection Professional. PA where I am is a certified state. They have to power to fine and enforce. The states that don't have certification laws are wide open.

I maintain that a system should be installed in a safe manner, which includes the fan outside of the living area, exhaust above the roof line, the correct pipe size and wired correctly.

The bottom line is that the system is effective in bring the level below 4 pCi/L with a proper post test and a test every 2 years there after.

To my knowledge there has never been a reentrainment study done. (Radon getting back into the house after the system removes it) Exhaust above the roof line is important but nobody has proven the need. We ran into that issue when writing the AARST mitigation protocols. Some of the committee members wanted to have it above the ridge, which in my opinion is just not practical.

So now we are running into a political issue. If there is no law in your state you have to go by the ASTM standard and convince every one that they should abide by it. Not an easy task when all they want to do is sell their house.

Just my 3 cents (inflation)

Bruce

Originally Posted by Bruce Lunsford

And yes, termination of a mitigation system below the roof line is NOT automatically a defect.

Bruce,

First, please click on 'User CP' and update your profile to include your location for us, thanks in advance.

Second, and me not being knowledgeable in radon, why is a radon mitigation system terminating below the roof line NOT an automatic defect?

Jerry,

Thanks, thought I had done that. Greensburg is about 35 miles east of Pittsburgh.

The air coming out of a mitigation stack may have a very high concentration, depending on the house, in the hundreds. The idea of "above the roofline" is to prevent radon from being power driven into eve vents or reentering the home some other way (reentrainment).

I didn't mean to imply that the system shouldn't exhaust above the roof line. In fact I said "I maintain that a system should be installed in a safe manner, which includes the fan outside of the living area, exhaust above the roof line, the correct pipe size and wired correctly."

Now to really confuse things, define "roof line". In PA it is defined as above the gutter, above the soffits if installed on a gable end or at least 10 feet above the ground, which ever is higher.

Now here is a situation that I ran into a lot when I installed systems. 2 story home, gable roof, blank wall where the system exits. If you run the pipe to the roof line as the rules say, it could be over 20 feet. That much pipe on the exhaust side of the fan will significantly reduce the efficiency of the system, especially in the winter when the air cools and gets heavy and people don't want to see that pipe. Only in those cases I would normally just go up 10 feet and put a 45 on top. It's not according to Hoyle but it's safe and more efficient.

Bruce

Originally Posted by Jerry Peck

Second, and me not being knowledgeable in radon, why is a radon mitigation system terminating below the roof line NOT an automatic defect?

Originally Posted by Bruce Thomas

Jerry,

Thanks, thought I had done that. Greensburg is about 35 miles east of Pittsburgh.

Bruce,

You still haven't explained that comment. Maybe I'm just dense or something, but nothing you said explained "why is a radon mitigation system terminating below the roof line NOT an automatic defect".

Is there any requirement that there be 20 feet of pipe on the exhaust side of the fan which would prohibit the exhaust fan being placed at or near the end of that 20 feet of pipe?

Originally Posted by Jerry Peck

Bruce,

You still haven't explained that comment. Maybe I'm just dense or something, but nothing you said explained "why is a radon mitigation system terminating below the roof line NOT an automatic defect".

Is there any requirement that there be 20 feet of pipe on the exhaust side of the fan which would prohibit the exhaust fan being placed at or near the end of that 20 feet of pipe?

I agree with you Jerry. As far as I'm concerned, "Roof line" means "Roof line" and "edge of roof" means "edge of roof" where the pipe extends. If your ladder slips, just try to grab hold of that imaginary line that extends from the bottom of the soffit. The only thing I can see is the difference between the old EPA and the ASTM (and AARST) guidelines. It's one of those times when a simple sketch would clarify everything.

If one holds a mitigation certification, it can be pulled for not following the guidelines even if it is something the client requests or demands.

The primary reason for any great difference in the cost of a mitigation installation is due to what it takes to make the client happy. Don't want to see pipe? OK, but it will cost $12000 and take a week to put in. I bet that $800 basic job with some exposed pipe looks better already.

Guys,
Help me out here, I don't see where I said under the eve isn't a defect.

Bruce

Originally Posted by Bruce Thomas

Guys,
Help me out here, I don't see where I said under the eve isn't a defect.

Bruce

Bruce,

The 'other' Bruce.

Originally Posted by Bruce Lunsford

And yes, termination of a mitigation system below the roof line is NOT automatically a defect.

Originally Posted by Jerry Peck

Bruce,

The 'other' Bruce.

"THE" 'other' Bruce? There's more than ONE other Bruce. How about "One of the 'other' Bruces"?

This Bruce just woke up and has not even finished my 1st cup of tea yet , but I have learned a few things this a.m.

Good thing we have pictures (maybe) they keep that Bruce confusion thing down.

If you see a radon system exhausting under the eve, or anywhere except above the roof line, write it up. There are times when it's necessary but they are rare and as a home inspector you may not be qualified to determine that. In any case it doesn't meet any protocol that I know of. They all say "Above the roof line"

If you write it up, the mitigator can justify it or fix it.

Hope that's clear.

Bruce

PS PA still uses the eve line whether you like it or not.

I am an NRSB certified radon mitigation specialist (RRS) and required to install radon mitigation systems in low rise and residential buildings in accordance with ASTM E2121-03 standards.

The EPA’s ONLY Recommended Residential Radon Mitigation Standard of Practice is also ASTM E2121

I wish to commnet on some of the previous posts regarding:

A) Minimum pipe size of 3 inch.

In general, 3 inches is the minimum pipe size BUT alternative pipe sizes may be used when sufficiently justified by field diagnostic measurements, including, static pressure, air velocity, and rate of air flow measurements, and documented using methodologies found in “Industrial Ventilation: A Manual of Standard Practice, 23rd edition or its equivalent”. ASTM E2121 – 7.3.2.1 Note: Any justification shall be included and become part of the system documentation.

I sometimes use different pipe sizes when space or asthetics are an issue.

B) Discharge pipe above the roof line

ASTM E2121 Standard states that all discharge pipe in a sub-slab or sub-membrane depressurization system shall extend above the roof – NO EXCEPTION.

ASTM E2121-7.3.2.9 (4): “For vent stack pipes that penetrate the roof, the point of discharge shall be at least 12” above the surface of the roof. For Vent stack pipe attached to or penetrating the sides of the building, the point of discharge shall be vertical and a minimum of 6” above the edge of the roof and in such a position that it can neither be covered by snow or an overflowing gutter. In areas where it snows the point of discharge shall be 12” above the surface of the roof.

C)

Originally Posted by Bruce Thomas

Now here is a situation that I ran into a lot when I installed systems. 2 story home, gable roof, blank wall where the system exits. If you run the pipe to the roof line as the rules say, it could be over 20 feet. That much pipe on the exhaust side of the fan will significantly reduce the efficiency of the system, especially in the winter when the air cools and gets heavy and people don't want to see that pipe. Only in those cases I would normally just go up 10 feet and put a 45 on top. It's not according to Hoyle but it's safe and more efficient.

Going up to 10 feet and installing a 45 on top is not in accordance with EPA or NRSB standards.

20 feet of pipe is perfectly acceptable. It is safe if you install it with proper supports and in my opinion does not significantly reduce the efficiency of the system. It may slightly increase the total static pressure but may not affect fan curve performance or increase required HP. System efficiency is a system design and fan selection dependant. This slight increase (10 feet of 3 inch pipe @ 50 cfm = .08 inches wg) is minimual. (I didn't subtract the 45 degree fitting which is equivalent to 5' of pipe)

I recommend that if you find a suspected deficiency in a radon mitigation system you advise your client to contact a certified radon mitigation specialist for further review and evaluation prior to purchase.

Ken,

Where are you from?

I'll do an Abraham Lincoln and answer you tomorrow.

Bruce

Hi Bruce,

I'm from the wonderful state of MA.
Looking forward to yuor response

Originally Posted by Ken Amelin

I am an NRSB certified radon mitigation specialist (RRS) and required to install radon mitigation systems in low rise and residential buildings in accordance with ASTM E2121-03 standards.

The EPA’s ONLY Recommended Residential Radon Mitigation Standard of Practice is also ASTM E2121

I wish to commnet on some of the previous posts regarding:

A) Minimum pipe size of 3 inch.

In general, 3 inches is the minimum pipe size BUT alternative pipe sizes may be used when sufficiently justified by field diagnostic measurements, including, static pressure, air velocity, and rate of air flow measurements, and documented using methodologies found in “Industrial Ventilation: A Manual of Standard Practice, 23rd edition or its equivalent”. ASTM E2121 – 7.3.2.1 Note: Any justification shall be included and become part of the system documentation.

I sometimes use different pipe sizes when space or asthetics are an issue.

B) Discharge pipe above the roof line

ASTM E2121 Standard states that all discharge pipe in a sub-slab or sub-membrane depressurization system shall extend above the roof – NO EXCEPTION.

ASTM E2121-7.3.2.9 (4): “For vent stack pipes that penetrate the roof, the point of discharge shall be at least 12” above the surface of the roof. For Vent stack pipe attached to or penetrating the sides of the building, the point of discharge shall be vertical and a minimum of 6” above the edge of the roof and in such a position that it can neither be covered by snow or an overflowing gutter. In areas where it snows the point of discharge shall be 12” above the surface of the roof.

C)

Going up to 10 feet and installing a 45 on top is not in accordance with EPA or NRSB standards.

20 feet of pipe is perfectly acceptable. It is safe if you install it with proper supports and in my opinion does not significantly reduce the efficiency of the system. It may slightly increase the total static pressure but may not affect fan curve performance or increase required HP. System efficiency is a system design and fan selection dependant. This slight increase (10 feet of 3 inch pipe @ 50 cfm = .08 inches wg) is minimual. (I didn't subtract the 45 degree fitting which is equivalent to 5' of pipe)

I recommend that if you find a suspected deficiency in a radon mitigation system you advise your client to contact a certified radon mitigation specialist for further review and evaluation prior to purchase.

YEA! Thanks Ken! I tried to point that out earlier but it was kinda brushed over.
I think there is a sticky point though. Pre-ASTM E2121, at least one mitigation certification course provider was setting up what I consider arbitrary standards to define "Edge of roof". I was shown the course materials used in a class held in 2005. Doesn't make'm right, just that there are mitigators (Certified) who didn't have the ASTM spec and apparently haven't kept up with changes. Is there a possibility that there are some course instructors who have made up their own rules (couldn't be mitigation contractors could they?) that could seem reasonable and still "kind of" meet the pre-ASTM spec.

I agree that the best way to handle an exhaust pipe that is not extended as required by ASTM E2121 is to rate the installation deficient and note that the installation needs to be brought up to current specifications. Call it a deficiency because it is directly related to a health and safety issue.

My run-in with an old-time mitigator over an exhaust stack extension, just as the as above discussion, helps justify the argument that just because someone does something a thousand times and have been doing it for decade doesn't mean they do it right.

Sometimes I can't see the forest through the trees. We shouldn't forget the big picture here.

We are home inspectors, not Certified Radon Mitigation contractors.

We should always include a disclaimer that Radon Systems are not included in the home Inspection and that the client should contact a Licensed and/or Certified Radon Contrator for Inspection and Review prior to purchase..

Ok here goes,

Sorry this may be a bit long but hopefully it will be worth it. First of all a bit of background so you know where I'm coming from. I was a mitigator from '93 to 03'. We stopped doing mitigation for several reasons, one is we weren't making a profit and another is we bought an infrared system for home inspection which reduced the time available for mitigation. I'm the founding president of Tri-State AARST and served on the national AARST board for 2 years. I also served on the AARST mitigation standards committee.

PA doesn't follow the ASTM E2121 standards, we have had our own since about '95.

A bit of politics: In my opinion ASTM hijacked the Radon Mitigation industry as they tried to do to the Home Inspection Profession. Do I have animosity, Ya, some. I don't know who made up the ASTM committee, I was asked to serve but I declined because at that point I was worn out from the AARST standards that we just finished. By the way publishing even part of an ASTM spec. on the web may be a copy right violation, you better check with them before you do it again.

If you understand how these papers are developed you'll understand the results a bit better. It takes months, some times years of endless conference calls, emails and votes, sometimes on just 1 word in a sentence. They are consensus documents. They are not Devine and they aren't written in stone. They will change as soon as a committee member with enough will or political pull desires it so.

That said, these documents are minimum standard guidelines, especially in unregulated states. In those states they are a good idea to follow for liability purposes but there is no law enforcement. So go by them if you want too but nobody is going to fine you if you don't (unregulated states only).

Now, you can read the standards, memorize the standards, follow them to the letter if you want too and you should in my opinion because it gives you something to fall back on when you need to. When I was installing systems I did just that and I found that it didn't ALWAYS work. Since every house is different and so is every system, there are times when you have no choice but to make stuff up on the spot.

I'll stop rambling now 'cause I have to go make money. The bottom line is this question. Did the system bring the radon level below 4 pCi/L and keep it there. If it did, problem solved. If not fix it.

Bruce

Originally Posted by Ken Amelin

Sometimes I can't see the forest through the trees. We shouldn't forget the big picture here.

And that 'seeing the big picture' includes reporting on things which the HI observes and knows about and knows is not correct - it should go into the report.

We are home inspectors, not Certified Radon Mitigation contractors.

*Most* are not, *some* are.

First let me say that all current standards ASTM E2121 that I am aware of require the exhaust point to be at least 6 inches or 12” (Illinois 12”) above the edge of the roof. Is this safer then under the roof edge? or 10 feet above the ground with a 45 ? or 2 Ft above a window (above the roofline). That (safety) is subjective and everyone has an opinion since there is no reference or documented cases of re-entrainment of the radon gas.

What we should be reporting are the facts with current standards as reference. If a defect, report it and have a specialist fix-it if necessary. When I inspect a system (I’m a licensed Home inspector, licensed tester and licensed mitigation contractor also with NRSB and NEHA-NRPP) I tell them the obvious and (standards) does it meet it or not. I also tell them the only way to know if the system is effective is with a radon test during a real estate transaction and then follow up with a long term test (90-365 days).

Most states, cities or localities do not require active mitigation systems and thus don’t do a good job at policing for enforcement. Also, all/most states, cities and localities allow the homeowner to install their own system and at that point any standard does not need to be followed. The point of this is that a contractor should follow the rules ASTM, ARST or individual states Mitigation Standards AND the only way to know that a system works is to perform a measurement.

Paul,

I agree with everything you said, except that in PA even home owners have to follow the State standards. If a system doesn't meet you local standard it should be reported on in your home inspection report.

In my earlier posts I was merely trying to point out that when a committee sits down to design a standard for a horse the out come is usually a standard for a camel. Good or bad it's the only system we have and we have to abide by it.


Bruce

Hi Bruce,
When I looked at Pennsylvania Radon Mitigation Standards it only affected contractors. But even if it was a homeowner install I would point out any/all deficient items.

“DEPARTMENT OF ENVIRONMENTAL PROTECTION
OFFICE OF POLICY AND COMMUNICATIONS
DOCUMENT ID: 294>2309>002
TITLE: Pennsylvania Radon Mitigation Standards
EFFECTIVE DATE:
AUTHORITY: 25 Pa. Code chapter 240
POLICY: This document is being provided to the certified radon mitigation contractors for its implementation.

PURPOSE: The purpose of this standard is to help assure uniformity, for the purposes of effectiveness and durability, during the installation of radon mitigation systems by certified mitigation contractors.

APPLICABILITY: This document applies to all individuals and/or firms, certified by the Department, to perform radon mitigation work within the Commonwealth.

DISCLAIMER: The policies and procedures outlined in this guidance are intended to supplement existing requirements. Nothing in the policies or procedures shall affect regulatory requirements.
The policies and procedures herein are not an adjudication or a regulation. There is no intent on the part of DEP to give the rules in these policies that weight or deference. This document establishes the framework within which DEP will exercise its administrative discretion in the future "

Thanks for updating me on this item.
Paul

Paul,

You missed your calling, maybe Law would come naturally to you.

I was told by the guy that wrote to regulation that the intent was to have it apply to all homes.

I know it doesn't say that but that was the intent.

Bruce