EPA Region IV Stakeholders Meeting on Radon in Karst Areas
(Three Perspectives:  CRCPD Committee on Radon; Alabama; Kentucky)

Introduction by Ron Fraass, CRCPD Executive Director
The Environmental Protection Agency, Region IV Office, held a stakeholders meeting in Atlanta, Georgia on September 15th and 16th. The meeting was held to discuss guidance to states in Region IV where the combination of Karst geology and a strong radon source combine to cause radon measurements to fluctuate widely over the course of a year. Short-term tests in homes may vary by two orders of magnitude depending upon time of year, outside air temperature, and wind conditions. This extreme variability makes it difficult to obtain appropriate radon measurements on which to base decisions on mitigation. The stakeholders were brought together to obtain general consensus on the best methods to recommend to homeowners for testing their homes whether or not the testing is during a real estate transaction. Members of CRCPD's E-25 Committee on Radon participated as well as appropriate Region IV states.


Report by Adrian Howe, Chairperson, CRCPD's E-25 Committee on Radon
On September 15 and 16 members of CRCPD’s E-25 Committee on Radon participated in the EPA Region IV Radon in Karst Areas Stakeholders Meeting in Atlanta, Georgia. Participating on behalf of the CRCPD’s E-25 Committee on Radon were Adrian Howe (NV), Committee Chair, and committee members Mike Gilley, (FL) and Bill Bell (MA). Also in attendance were the CRCPD Executive Director, EPA Region IV staff, EPA OAR headquarters staff, radon measurement and mitigation industry representatives, real estate industry representatives and state radon program staff from Alabama, Kentucky and Tennessee.

Karst geology results in significant fluctuations in radon concentrations that result in many false negatives in short-term testing results. As the EPA action level of 4 pCi/l is based upon an annual average this can result in improper mitigation decisions especially in measurements done for real estate transactions. EPA Region IV has had a State Indoor Radon Grant condition on the States of Alabama, Kentucky and Tennessee that required those state radon programs to work with their state geologists to identify specific Karst areas where 12-month radon testing should be recommended. This condition has resulted in some confusion and the meeting was intended to produce a consensus on testing methods in identified Karst areas.

During the course of the meeting it became evident that the issue is wide spread as Karst areas exist in more that just the three EPA Region IV states and there are probably other anomalies that would result in similar conditions such as in structures built above underground mining operations and other geologic formations. In addition to the concerns of false negatives in short-term measurements, the group had concerns that 12-month testing would result in reduced testing among homeowners and have a negative impact on real estate transactions. It was noted during the meeting that the EPA publication A Citizen’s Guide to Radon has a weakness in the language that recommends 12-month and follow-up testing and in light of Karst and variability anomalies existing in other areas of the United States this language should be reviewed and changed to encourage 12-month testing while not discouraging short-term testing. It was also noted that there are discrepancies between the EPA’s A Citizen’s Guide to Radon and Consumer’s Guide to Radon Reduction. To eliminate the discrepancies and to address concerns about false negative results of short-term testing while not discouraging short term testing, at the urging of EPA the E-25 Committee on Radon committed to review the A Citizen’s Guide to Radon, the Consumer’s Guide to Radon Reduction and the Home Buyer’s and Seller’s Guide to Radon for language change recommendations.

A consensus was reached by the group on language for the EPA Region IV SIRG condition to the States of Alabama, Kentucky and Tennessee. The condition language indicates that the three states are expected to work with their state geologists to identify specific areas where 12-month testing recommendations should be made and establishes the guidance that will be provided to persons performing testing in those areas. The guidance provides for 12-month testing and mitigation recommendations, recommends 12-month follow-up testing even when short-term tests indicates indoor radon levels below 4 pCi/l, provides for 12-month post mitigation testing and recommends periodic retesting for mitigated, unmitigated and newly renovated structures (to account for continually changing subsurface formations.

The E-25 Committee on Radon appreciated the opportunity to participate in this meeting to stay advised and provide comment on important issues faced by state radon programs in the public health and safety efforts to deal with radon.


Report by James McNees, Alabama Radon Coordinator
Dating back to the FY '01 SIRG grants, EPA Region 4 has placed a "karst" condition on the SIRG grants of three states, Alabama, Tennessee, and Kentucky, karst areas being defined as areas under laid by carbonate rock containing solution cavities. This special condition essentially restricted the state to only recommending year-long tests for radon testing in karst areas based upon the annual average indoor radon concentration. The FY '02 and FY '03 SIRG grant karst conditions states that short-term radon testing should be discouraged in karst areas.

Alabama's good faith efforts to implement the karst conditions revealed that the citizenry was much less inclined to perform a test that required a full year to complete than a short-term test. The medicine, year-long tests, did cure the problem of seasonal variability. However, the medicine's side effect of reduced public acceptance of radon testing resulted in the medicine causing more harm than benefit.
The September 15 and 16, 2004 Atlanta meeting was the culmination of requests from the radon industry, the state of Alabama, and others to review and revise the "karst" condition. The focus of the meeting was to achieve a methodology to address the karst induced seasonal variability problem in a way that would not be inimical to voluntary radon testing by the public or radon testing in real estate transactions. Under the leadership of Ms. Beverly Banister [Director, Air, Pesticides & Toxics Management Division, Environmental Protection Agency, Region 4], significant progress was made towards achievement of that goal.


Report by Edward Lohr, Kentucky Radon Coordinator
The EPA Region 4 sponsored karst – radon stakeholders’ meeting was presented to bring the interest parties together to help improve implementation strategies in the three affected states, Kentucky, Tennessee, and Alabama. At least that is what was on the agenda. The meeting turned out to be a history lesson of how we got to where we are at, a forum for complaints from various attendees, and a work session on what the EPA SIRG conditions should read for fiscal year 2004-05 to the three affected states.

Attendees from Kentucky included the State Radon Coordinator, the University of Kentucky Radon Extension Associate, and representatives from the Kentucky Association of Realtors and Kentucky Association of Home Inspectors.

Because short term radon tests are not a good indicator of what the year round average is in karst areas of the effected states, year long tests are recommended. Each effected state, utilizing their state’s geologist, identified areas of karst geology in their respective states. 92 of Kentucky’s 120 counties were identified as being in areas of karst. Louisville, Lexington, and Bowling Green, the 3 larges metropolitan areas in Kentucky, are in these karst areas. This is a major challenge to the Kentucky Radon Program but is being addressed with some success.
Although the Atlanta meeting did not contribute to implementation strategies as hoped, it did bring more of a focus on the karst issue in the region. Avenues of communications were revisited and the participants seemed to be satisfied with the wording that will be in the effected states SIRG documents. Kentucky will continue to cooperate with all stakeholders and move this important public health issue forward.