Radon Reporter Dec 2024

20 | December 2024 THE RADON REPORTER | 21 COMPLIANCE INSPECTION COMPLIANCE INSPECTION AMitigation Case Study and Reason To Obtain SGM-CI Greg Johns, WIN Home Inspection Cookeville Coming across poorly designed and/or executed soil gas mitigation systems is seemingly easy, especially in one of the 30 U.S. states that does not have or enforce any variant of radon licensing or certification. Things can get wild. The question, for many of us in the industry and field, is what to do about it if you work in one of these (and even in the 20 states where some variant of licensing/certification is in effect). How do we ensure quality and effectiveness in a manner that shows industry knowledge and authority? The Soil Gas Mitigation – Compliance Inspector (SGM-CI) certification is a reasonable place to begin. This certification, offered through the National Radon Proficiency Program (NRPP), can help professionals bridge that gap. Whether you are a certified radon testing/analyst entity, or a certified mitigator, the SGM-CI credential can help you wear a secondary hat for critiquing systems, citing inconsistencies, and sharing with appropriate parties. Case Study: House Built over a Cave One home in the middle Tennessee market, built in the 1970s, over a cave system provides a good example of a mitigation system that needs further attention. True story – the then-owners explored the cave via entry from within their crawlspace (it is a very tall crawlspace along the rear half of the house). Cave systems are common in this region of Tennessee. This home had, at some point, been mitigated for radon via a sub-membrane depressurization assembly. There was a ground loop under the vapor retarder that encircled most of the crawlspace perimeter. Each end of this sub- membrane loop tied into its own exhaust fan. Both exhaust fans were located inside the crawlspace. This assembly then terminated at the exterior at chest height. At the time of the inspection, one exhaust fan was non-functional while the other one was spewing all its contents directly into the inspector’s lungs. Let’s make a quick, over-arching tally of applicable standards ignored, deficient, or otherwise improper: Section 6.0 of the ANSI/AARST standards address several deficiencies of our system in question, inclusive of 6.1.3.1 (sealing of the suction point in relation to membranes), 6.1.3.2 (sealing of the retarding membrane), 6.1.3.3 (labeling of the membrane and access port), 6.1.4-.1(non-habitable space and sealing of the membrane), 6.2.2 (duct pipe slope – this one had several low spots for water accumulation), 6.2.3 (positively pressurized piping – this one had portions under the habitable space), 6.2.4 (labeling required – none here), 6.2.6 (Flexible couplings – tape was in use for this assembly), almost ALL of 6.4 (ASD Exhaust Discharge), 6.5.2 (location of the exhaust fans below habitable space), 6.5.4 (fan installation guidelines), 7.7.1 (seam sealing of the vapor retarder), 7.7.3-.4 (fastening of vapor retarders around perimeter to hold in place and sealing), the majority of Section 8.0 (OM&M, electrical, and labeling related items – non- existent for our system in question). There may have been a few more. Accepting that this mitigation system in question was pre-existing to the newest iteration of our approved standards, there is one last section worth noting – Section 8.5, Inspection for Compliance. The very first line of this section reads, “Prior to delivery and release of the completed system(s), a qualified radon mitigation professional or qualified soil gas mitigation professional , as applicable, shall have verified…” appropriate compliance to industry standards, as well as any local/state standards appropriately applicable. Section 8.5.1 elaborates that “such inspection for compliance shall be limited to visual inspection and photographic evidence of readily accessible components that do not require disassembly of components or finishings to achieve access.” It reads that the contractor performing said work cannot assess conformance of said work. This system is not an anomaly. In Tennessee, noncompliant systems have been historically acceptable. Unlicensed entities can perform any work on a home as long as the total project cost is under $25,000. There is no review or code enforcement for lower-priced work. There is no requirement for mitigation standards to control radon in new or existing buildings. A Viable Option: Obtain the SGM-CI Credential and Access to the App For those who run a radon testing business, the SGM-CI certification can help. With this credential, you can show you are exactly the entity to assess and critique. You also can show involved parties deficiencies via the IEA/AARST SGM-CI mitigation inspection report. It’s an app. All those sections and standards we referenced a few paragraphs back? They all are included in the app. You fill in the fields (ideally while on site), upload related photos, and that’s it. The app walks you through the process to inspect and document/catalogue deficiencies without having to recall every detail in every section of the standard. The app requires you to select “correct,” “non-compliant,” or “N/A” (in some instances) for each item. If you choose “non- compliant,” the app requires a photo to document the deficiency, as well as the option to add some text. When you get through all app categories and fields, you have verified the conditions and deficiencies according to the ANSI-AARST SGM industry standards. Report done. But only those who take and pass (and maintain) their SGM-CI certification can have access to the app. The SGM-CI certification does require study and testing, but there’s a reason not everyone has the certification. You must know your stuff. You also must have a certification for testing/analysis, or mitigation. Once anyone achieves the SGM-CI certification, having access to the app and its step-by-step guidance for report documentation is extremely helpful…and, let’s be honest, easy. The goal is to cite and document accordingly so that consumers are protected by that for which they pay (a mitigation system), and contractors are protected by being critiqued and given opportunities to improve. A mitigation contractor could offer a higher level of service to clients as part of their QA/QC to bring in a third-party SGM-CI to review and assess prior to commissioning the system. Involved parties will come to understand the role of the certified SGM-CI reviewing mitigation system with the knowledge to competently do so. Consumers are better protected, contractors are better presented, and business relationships can be established based on trust and knowledge. Generating a report via an app is just a nice bow to make it professionally pretty! Section 2.2 of the Soil Gas Mitigation – Single Family (SGM-SF) says that any mitigation standard does not apply to pre-existing systems prior to said standard’s effective date…except those portions altered, or those found to not be in compliance with Section 6.4 (ASD Exhaust Discharge). Obviously, the discharge location was an issue for this particular system. But, keep in mind this ambiguous point related to systems “aged.” We might not be able to say they are deficient , but we could say they exhibit deficiencies based on current industry standards. For the system in question, per time of review, there was no labeling. No signage. No system operation monitor. No OM&M. No identifiers for installation date or installer. No other feature required by the current standard. Additionally, the fans were installed below habitable space, with questionable materials and orientation(s), and the exhaust terminated in a very hazardous location.