Radon Remediation Systems not up to EPA Standards - InspectionNews

Jim Weyenberg · #1 (**permalink**) 11-16-2007, 02:01 PM

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

Paul Ybarra · #2 (**permalink**) 11-16-2007, 06:28 PM

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.

Jim Weyenberg · #3 (**permalink**) 11-19-2007, 04:55 PM

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

Paul Kondzich · #4 (**permalink**) 11-22-2007, 12:23 PM

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.

Stuart Brooks · #5 (**permalink**) 11-22-2007, 06:14 PM

Quote:

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.

Bruce Thomas · #6 (**permalink**) 11-23-2007, 01:08 PM

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

Joseph P. Hagarty · #7 (**permalink**) 11-23-2007, 02:41 PM

From the PA DEP website:

RadonvideoPart3

Bruce Thomas · #8 (**permalink**) 11-23-2007, 03:07 PM

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

Stuart Brooks · #9 (**permalink**) 11-23-2007, 04:00 PM

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?

#10 (**permalink**) 11-23-2007, 07:15 PM

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.

Bruce Thomas · #11 (**permalink**) 11-24-2007, 10:37 AM

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

Jerry Peck · #12 (**permalink**) 11-24-2007, 01:04 PM

Quote:

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?

Bruce Thomas · #13 (**permalink**) 11-24-2007, 01:57 PM

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

Jerry Peck · #14 (**permalink**) 11-24-2007, 05:01 PM

Quote:

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?

Quote:

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?

Stuart Brooks · #15 (**permalink**) 11-24-2007, 06:29 PM

Quote:

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.

Bruce Thomas · #16 (**permalink**) 11-25-2007, 02:07 PM

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

Bruce

Jerry Peck · #17 (**permalink**) 11-25-2007, 02:43 PM

Quote:

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.

Quote:

Originally Posted by Bruce Lunsford

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