Quality Assurance Plan For Conducting Radon

Summary

Quality Assurance Plan
For Conducting Radon Measurements
MDH Standard QA Plan V3.1
Date of original QA Plan
10/31/2019
Date of Last Revision
--/--/-----
RADON MEASUREMENT QUALITY ASSURANCE PLAN
ContentsQuality Assurance Plan ..................................................................................................... 1
For Conducting Radon Measurements ........................................................................................... 1
1. Introduction ......................................................................................................................... 4
Policy and Commitment.......................................................................................................... 4
Quality Assurance Plan Purpose ............................................................................................. 4
Quality Assurance Goal and Objectives .................................................................................. 4
2. Organization ......................................................................................................................... 4
3. Description of Operations .................................................................................................... 5
Duties of the Quality Assurance Officer ................................................................................. 5
Personnel and Subcontractor Qualifications .......................................................................... 5
Documents and Records ......................................................................................................... 5
4. Measurement Procedures ................................................................................................... 5
Measurement Devices ............................................................................................................ 5
Measurement Standards of Practice ...................................................................................... 6
Inform Client about Required Test Conditions ....................................................................... 6
Safety ...................................................................................................................................... 6
Measurement Placement and Assessment of Test Conditions .............................................. 6
New Construction Test Conditions ......................................................................................... 7
Post-Mitigation Measurements .............................................................................................. 7
5. Data Collection, Validation, Reporting, Entry and Retention .............................................. 7
Data Collection ........................................................................................................................ 7
Data Validation ....................................................................................................................... 8
Data Reporting ........................................................................................................................ 8
6. Internal Quality Control ....................................................................................................... 9
Commitment to Quality and Objective ................................................................................... 9
Continuous Radon Monitors ................................................................................................. 10
Calibration ............................................................................................................................. 10
Routine Instrument Checks................................................................................................... 10
Duplicates.............................................................................................................................. 10
Crosschecks ........................................................................................................................... 11
Passive Devices ..................................................................................................................... 11
Routine Instrument Checks................................................................................................... 11
2
RADON MEASUREMENT QUALITY ASSURANCE PLAN
Duplicates.............................................................................................................................. 12
Blanks .................................................................................................................................... 12
Spikes .................................................................................................................................... 13
7. Corrective Action................................................................................................................ 13
8. Quality Assurance Training ................................................................................................ 14
9. Quality Assurance Audits and Reports ............................................................................... 15
10. Definitions ...................................................................................................................... 15
11. References ...................................................................................................................... 19
Radon Test Placement and Retrieval Checklist..................................................................... 22
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RADON MEASUREMENT QUALITY ASSURANCE PLAN
1. Introduction
Policy and Commitment
In order to protect health and financial interests of building owners and occupants, it is the
policy of our organization to provide accurate, reproducible, and valid measurements of indoor
radon concentrations. Each measurement employee is individually and collectively committed
to the highest quality work in accordance with this plan

Quality Assurance Plan Purpose
The purpose of this Quality Assurance (QA) Plan is to: set policies, performance goals, and
objectives; identify responsibilities; establish procedures for assessing performance relative to
quality; and to define corrective actions when needed

It is important to recognize that usually quality assurance (QA) practices result not in the
identification of out-of-control processes, but in the continued documentation of stable, within
limits operations. Only with such documentation can the validity of measurement results be
defended

This QA plan will be revised with any adjustments involving changes of personnel and
measurement devices as well as regulatory requirements or professional association
recommendations. If there are no revisions triggering changes, this plan will be reviewed a
minimum of annually

Quality Assurance Goal and Objectives
Our staff are committed to providing customers with accurate, valid, reproducible, and
defensible radon measurements which may be used to make critical decisions about radiation-
related environmental health

The objectives of the QA plan are to maintain a quality measurement program and to
document relative quality. In addition, a QA program adds greatly to an operators
understanding of the methods they use and provides early detection of problems so that they
can be rectified quickly and completely

We collect evidence of the relative quality of our performance and evaluate that evidence
through Quality Control (Section 6), take Corrective Action as needed (Section 7), and conduct
Quality Assurance Audits (Section 9). A record of this evidence and resulting actions are
maintained with those of this QA Plan

2. Organization
Licensed radon professionals are responsible for our organization’s field radon measurements

The owner/president is responsible for all aspects of operations. Quality Assurance Officer is
responsible to the President for all QA as related to field operations and for field measurements
and data analysis

This QA Plan was reviewed by all personnel involved with radon work and will continue to be
made available for future reference

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RADON MEASUREMENT QUALITY ASSURANCE PLAN
3. Description of Operations
Duties of the Quality Assurance Officer
The Quality Assurance Officer’s responsibilities are to:
▪ ensure proper storage of radon measurement devices;
▪ design and present training to new employees and, on an annual basis, to all employees;
▪ oversee measurement device use including placement and retrieval;
▪ create and maintain QA records;
▪ prepare or oversee client test reports and to specify how they are distributed to clients;
▪ manage and oversee quality control (QC) measures;
▪ initiate QA audits;
▪ make recommendations on corrective action and to insure corrective action is carried out;
▪ initiate QA audit reporting to management; and
▪ participate in all meetings regarding staffing, training, equipment, record keeping, and
changes in practices and procedures

Personnel and Subcontractor Qualifications
Staff members and/or contractors conducting radon measurement services are individually
licensed as radon measurement professionals by Minnesota Department of Health (MDH). This
includes anyone placing and/or retrieving testing devices

Documents and Records
All records and documents are maintained so they are legible, retrievable, and protected from
fire, water, theft, and deterioration for a minimum period of 3 years. Computer software and
records for our radon measurements are routinely backed up to the cloud or a remote server

Each individual radon professional shall submit their quarterly measurement data to MDH on
the schedule outlined in the radon licensing rules:
▪ April 30 for the period of January 1 through March 31;
▪ July 30 for the period of April 1 through June 30;
▪ October 30 for the period of July 1 through September 30; and
▪ January 30 for the period of October 1 through December 31 of the previous year

4. Measurement Procedures
We perform radon measurements in accordance with Minnesota state statutes, rules, adopted
measurement standards of practice, and the instructions of the measurement device
manufacture(s)

Measurement Devices
The measurement devices used shall be listed for meeting the requirements of Minnesota state
statutes and rules and be approved for use by the state and NRPP

The manufacturer’s operating instructions are attached to the QA Plan

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RADON MEASUREMENT QUALITY ASSURANCE PLAN
Until use, radon measurement devices shall be stored in dry, low radon environments, and per
manufacturer instructions

Measurement Standards of Practice
Our company will follow the Minnesota Radon Licensing Act and Rules and the protocols and
standards listed below:
▪ ANSI/AARST Protocol for Conducting Measurements of Radon and Radon Decay Products
in Homes (ANSI/AARST MAH-2019) or successor ANSI/AARST standards, and test each
unique foundation type;
▪ ANSI/AARST Standard: Protocol for Conducting Radon and Radon Decay Product
Measurements in Multifamily Buildings (ANSI/AARST MAMF-2017) or successor
ANSI/AARST standards;
▪ ANSI/AARST Protocol for Conducting Measurements of Radon and Radon Decay Products
in Schools and Large Buildings (ANSI/AARST MALB-2014) or successor ANSI/AARST
standards

Inform Client about Required Test Conditions
We will make reasonable efforts to inform the person responsible for the house of required
and recommended test conditions a minimum of 12 hours prior to the test as well as during the
test

The person responsible for closed-building conditions will be requested to sign a non-
interference agreement that indicates knowledge of the testing conditions contained in the
agreement and a willingness to cooperate in maintaining the required test conditions. If such
an agreement cannot or will not be signed by the responsible individual(s), the licensed radon
professional will indicate in the test report that a signature was not obtained

Safety
The licensed radon professional shall not enter any area or perform any test that would
damage property or risk the professional’s own or another’s safety. If it is known that closed-
house conditions are detrimental to the health of the occupants, then the radon survey using a
short-term test shall not be done

Measurement Placement and Assessment of Test Conditions
We will place radon measurement devices in testing sites and under conditions in accordance
with the Minnesota Radon Licensing Act and Rules and according to the protocols and
standards listed above in Measurement Standards of Practice (as shown in Table 3.3 of
ANSI/AARST MAH 2019)

The radon professional will visually assess test conditions when deploying and retrieving
device(s). Included in this assessment, to ensure essential closed-building protocol
requirements are met, the items in table 4-A, table 4-B (if applicable), and Exhibit 1 from
ANSI/AARST MAH 2019 will be visually inspected

See example placement/retrieval checklist at the end of this QA plan

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RADON MEASUREMENT QUALITY ASSURANCE PLAN
If the radon measurement is a long-term measurement of 90- days or more in duration, closed-
building conditions need not be maintained prior to, nor during the radon test. For long-term
tests, it is recommended that at least half the test period should be during the season that the
dwelling is most likely to be operated with closed-house conditions so that the results of the
test are more accurate indicators of the yearly average

Short term test periods should optimally collect at least 48 hours of valid sampling time

Deployment periods shall not be less than 46 hours. In addition, if a short-term test is longer
than 2 days, whenever practical it is recommended, but not required, to terminate the test
nominally at 24-hour increments to reflect day to night fluctuations in radon concentrations
within a dwelling

For continuous radon monitors, care should be taken to account for data that are produced
before equilibrium conditions have been established in a flow-through cell. Generally,
conditions stabilize after the first four hours. Measurements made prior to this time are
probably low, and the first four hours of data may be discarded or incorporated into the result
using system correction factors. If the first four hours of data are discarded, the remaining
hours of data can be averaged and are sufficient to represent a two day measurement

New Construction Test Conditions
Newly built homes are tested in accordance with this QA Plan. If the following items are part of
the completed dwelling, they must be installed and completed before the radon test is
initiated: all exterior doors, all windows, all heating appliances, all fireplaces and fireplace
dampers, all insulation and exterior siding, all wall and ceiling coverings to be completed
including interior drywall or paneling (does not include decorative finishing of walls, floors or
ceilings). If testing personnel know construction work, which will likely affect the test results, is
to be done inside the dwelling during the test period, the test must be scheduled during a time
when such interference is less likely to take place

Post-Mitigation Measurements
A post-mitigation measurement is conducted to confirm the relative impact of mitigation. The
post-mitigation measurement is a short-term test made in the same location(s) as the pre-
mitigation test(s). The test must not be started sooner than 24-hours after the start-up of the
radon mitigation system and within 30 days after the installation of the system. The test must
have 12-hours of closed house conditions before the start of the test and closed house
conditions during the test. In addition to the post-mitigation test, it must be recommended to
the client that they test every two-years thereafter

5. Data Collection, Validation, Reporting, Entry and Retention
Data Collection
If the hourly printout from the CRM is not given in the customer report, it will be available to
customer for at least three years following the test

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RADON MEASUREMENT QUALITY ASSURANCE PLAN
Data Validation
Valid data is produced when a measurement system, including storage, field deployment,
transport, analysis, and reporting are operating “in control” and within QC limits and when in-
control QC checks have been made both before and after a set of validated data. It is the
responsibility of the qualified measurement professional to conduct, record, and make
available the results of QC checks relevant to each reported result

The Quality Assurance Officer will review some radon reports to ensure the QA Plan is being
followed. Validation factors include proofreading files to see that information entered into the
computer from the test placement/retrieval checklist is correct. Any errors found during
validation checks are documented including who made the errors, the dates of the errors, and
how these errors were resolved

Data Reporting
The measurement report shall include:
▪ The complete address of the test, including zip code;
▪ Company name, contact information and identification of the measurement professional
(including MDH licensing number) placing and retrieving the test device;
▪ Exact location(s) of the detector(s) including level of home and exact room and location
within that room tested;
▪ The start and stop, date and times for each measurement device;
▪ The detector model or type and identification numbers;
▪ The calibration date if using a CRM;
▪ Hourly data from the CRM must either be included in the report or provided to the client
upon request;
▪ Removal of or backing out portions of hourly data imbedded within the contiguous
sampling period reported shall invalidate the measurement except for removing the 1 st 4
hours for correction factors, 1st 12 hours for closed-house conditions, or 1st 24 hours for
newly installed mitigation system;
▪ Identification of organization used to analyze detectors;
▪ Radon Information Sources including state radon office and how to obtain federal or state
guidance documents;
▪ The individual and average results of duplicate measurements;
▪ Description of observed building conditions and other factors that are temporary in nature
and may affect the measurement results;
▪ Deviation(s) from protocol;
▪ If a mitigation system was present;
▪ Recommendations; and
▪ If applicable, whether the occupant or responsible party has agreed in writing to abide by
the closed house conditions twelve hours before the test and throughout the test period

The measurement report should describe the general limitations of the test such as the
following statement:
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RADON MEASUREMENT QUALITY ASSURANCE PLAN
▪ There can be uncertainty with any radon measurement due to statistical variations and
other factors such as: daily and seasonal variations in radon concentrations; due to changes
in the weather and operation of the dwelling; as well as possible interference with the
necessary test conditions that could influence the results

All test results include a statement, which recommends that the dwelling be re-tested in each
of the following cases whether or not the dwelling has been mitigated:
 If a new addition is added or significant renovation occurs;
 If a ground contact area was not previously tested is occupied or a home is newly occupied;
 If the home was unoccupied during the test, the home should be retested after occupancy;
 Heating or cooling systems are significantly altered resulting in changes to air pressures or
distribution;
 If occupied by a new owner;
 If ventilation is significantly altered by extensive weatherization, changes to mechanical
system or comparable procedures;
 If significant openings to the soil occur due to:
o Groundwater or slab surface water control systems (e.g. sumps, perimeter drain tile,
shower/tub retrofits, etc.) or,
o Natural settlement causing major cracks or penetrations occur in the home’s
foundation walls or slab;
 If significant nearby construction blasting, earthquakes or formation of sink holes nearby;
 If a mitigation system is altered, modified or repaired

A sample reporting form shall be attached to this QA Plan

6. Internal Quality Control
Quality control refers to the technical activities that measure the attributes and performance of
a process, item, or service against defined standards in order to verify that they meet
established specifications, including documentation

Commitment to Quality and Objective
Our staff is committed to providing customers with accurate, valid, reproducible, and
defensible radon measurements which may be used to make critical decisions about radiation-
related environmental health. The due diligence of each employee and contractor involved with
radon measurement is critical for achieving this goal

A critical step to insure radon measurements meet nationally accepted quality standards is to
conduct quality control (QC) measurements at prescribed rates and systematically over time

QC measurements shall be recorded electronically or in a logbook as soon as practicable, and
shall be maintained for a minimum of three years. Failed QC measurements should be repeated
prior to investigation and corrective action

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RADON MEASUREMENT QUALITY ASSURANCE PLAN
A measurement system must operate in such a way as to produce repeatable and stable quality
control results. This is accomplished by performing calibration with background checks,
crosschecks and duplicates for CRMs, and duplicates, spikes, and blanks for passive methods, as
well as other method-specific checks

Continuous Radon Monitors
Calibration
Calibration refers to the process of determining the response of a measurement device to a
series of known radon concentrations and making necessary adjustments to the device

Calibration is made every 12 months or after repair for each CRM by either, the monitor
manufacturer or a national radon proficiency program approved calibration laboratory
approved by the device manufacturer

Any monitor that does not have a calibration certification, dated within 12 months, must be
removed from service

In addition to calibration, an annual background check is performed by purging with clean aged
air or nitrogen. The manufacturer or calibration laboratory completes this process at the time
of calibration

Routine Instrument Checks
Instrument checks involve using the manufacturer’s instructions for checking for proper
working condition including checking battery voltage levels, cleaning screen inlet ports, and
verifying that calibration is up-to-date. Performance checks will be made before every
measurement

Duplicates
Radon measurements, like all measurements, usually do not produce exactly the same results,
even for simultaneous, co-located measurements. Duplicate are two side-by-side
measurement devices placed 4 to 8 inches apart, or as specified by the manufacturer, that
simultaneously measure radon

The objective of duplicate tests is to assess the precision error of the measurement method or,
in other words, how well two side-by-side measurements agree or disagree

Duplicates shall be made at a rate of 10% of all measurement locations or 50 per month,
whichever is less. Tests should be randomly distributed and deployed in the normal course of
business across a variety of projects, operators, and environments

When duplicate measurements are made, the results are reported as such to the customer who
receives the primary test. The individual results and the average of the two will be reported. In
addition, results of duplicates are recorded on Duplicate Control Charts

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RADON MEASUREMENT QUALITY ASSURANCE PLAN
Precision involving duplicates is calculated by using Relative Percent Difference (RPD). RPD is
equal to the difference between the higher test result minus the lower test result divided by
the average of the two duplicate test results, which is then multiplied by 100. The RPD result is
then compared to warning levels and control limits. The Warning Level is set at the deviation
from ideal performance that would be expected to occur by chance only 5% of the time, and
Control Limits are set at that deviation from ideal performance that would be expected to occur
by chance only 1% of the time. The Warning Level indicates a potential problem, which should
be investigated. The Control Level indicates that the measurement system should be subject to
corrective action and probable recalibration

The control and warning limits for duplicates are:
▪ at concentrations averaging less than 2 pCi/L, the control limit is 1 pCi/L,
▪ between 2 and 3.9 pCi/L,
▪ the warning level is 50% RPD;
▪ the control limit is 67% RPD;
▪ 4 or more pCi/L,
▪ the warning level is 28% RPD;
▪ the control limit is 36% RPD

If within any 30-day period, precision errors are found that exceed control limits or if any two
exceed warning levels within a month, an investigation will be launched, if applicable, in
consultation with the analytical laboratory and state authorities

Crosschecks
Crosschecks are conducted to determine bias and are made every 5 to 7 months after a CRM
has been calibrated. For at least 48 hours, the CRM past calibration by 5 to 7 months
(designated as CRM-1) is cross-checked with any CRM that has been calibrated within the past
12 months but not at the same time as CRM-1 (designated as CRM-2). This procedure is most
effective when CRM 2 has been recently calibrated. When possible, a crosscheck is performed
in an environment with a radon concentration that is about 4 pCi/L or greater

When crosscheck measurements are made, the results are reported as such to the customer
who receives the primary test. The individual results and the average of the two will be
reported. In addition, the results of crosscheck measurements are recorded on a Crosscheck
Control Log and Chart

The crosscheck is also counted as a duplicate and RPD is calculated the same as a duplicate

Passive Devices
Routine Instrument Checks
Checks include examining packaging upon both receipt and disbursement of the devices

11
RADON MEASUREMENT QUALITY ASSURANCE PLAN
Duplicates
Radon measurements, like all measurements, usually do not produce exactly the same results,
even for simultaneous, co-located measurements. Duplicates are two side-by-side
measurement devices placed 4 to 8 inches apart, or as specified by the manufacturer, that
simultaneously measure radon

The objective of duplicate tests is to assess the precision error of the measurement method or,
in other words, how well two side-by-side measurements agree or disagree

Duplicates shall be made at a rate of 10% of all measurement locations or 50 per month,
whichever is less. Tests should be randomly distributed and deployed in the normal course of
business across a variety of projects, operators, and environments

When duplicate measurements are made, the results are reported as such to the customer who
receives the primary test. The individual results and the average of the two will be reported. In
addition, results of duplicates are recorded on Duplicate Control Charts

Precision involving duplicates is calculated by using Relative Percent Difference (RPD). RPD is
equal to the difference between the higher test result minus the lower test result divided by
the average of the two duplicate test results, which is then multiplied by 100. The RPD result is
then compared to warning levels and control limits. The Warning Level is set at the deviation
from ideal performance that would be expected to occur by chance only 5% of the time, and
Control Limits are set at that deviation from ideal performance that would be expected to occur
by chance only 1% of the time. The Warning Level indicates a potential problem, which should
be investigated. The Control Level indicates that the measurement system should be subject to
corrective action

The control and warning limits for duplicates are:
▪ at concentrations averaging less than 2 pCi/L, the control limit is 1 pCi/L,
▪ between 2 and 3.9 pCi/L,
▪ the warning level is 50% RPD;
▪ the control limit is 67% RPD;
▪ 4 or more pCi/L,
▪ the warning level is 28% RPD;
▪ the control limit is 36% RPD

If within any 30-day period, precision errors are found that exceed control limits or if any two
exceed warning levels within a month, an investigation will be launched, if applicable, in
consultation with the analytical laboratory and state authorities

Blanks
Blanks are measurements performed to determine if the measurement device may have
unintended exposure (background) during storage, handling and shipping. A blank is an
unexposed measurement device that is opened, immediately closed and sealed, and, like an
exposed measurement device, labelled with plausible start and stop dates and times, and then
12

The purpose of this Quality Assurance (QA) Plan is to: set policies, performance goals, and objectives; identify responsibilities; establish procedures for assessing performance …

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Frequently Asked Questions

What is the american national standard for radon mitigation?

This new American National Standard addresses the complexities of properly mitigating multifamily dwelling over four units that require specialized techniques and quality assurance. This American National Standard is the first complete consensus standard and is an update of the 1993 EPA Protocol on Radon and Radon Decay Measurement in Homes.

Should the federal government develop its own indoor radon standards?

As a general principle, the Federal government’s reliance on privately developed voluntary consensus based standards is to be preferred over the Federal government developing such standards. For more information, please visit " Guidance on the Use of Voluntary Consensus Standards for State Indoor Radon Grant Recipients ."

What is the ansiaarst radon standard?

This new American National Standard addresses the complexities of properly measuring radon in large and complicated building structures that require specialized techniques and quality control and assurance to address complicated building designs and specialized airflow. This ANSI/AARST standard is for measuring radon levels in multifamily housing.

What is the radon 222 standard?

This standard specifies minimum requirements for quality systems designed to quantify the concentration of radon-222 gas in air by qualified professionals (QPs) and laboratories, whose data are intended to be used to determine the need for, or success of mitigation.