I got the email yesterday (5 emails, different aspects) for the radon tests Arlington County wants for its schools. I have included the scope of the project below. This is a long post, and I don't expect everyone to read everything - too much time. However, I have some problems:
-- They want only charcoal cannisters to be used. I don't do charcoal.
-- They want a lab other than the testing company to do the testing.
-- They need them all (over 2,000) done between March 31 and April 6)
-- No one is likely to be at the schools to let anyone inside on April 6.
-- They want a company who has two years experience testing radon in Virginia schools. I do not.
-- There are so many schools involved - 36-39 -- they only want devices dropped off between 6-8am. I would need 19 people to drop them all off. Monday and Tuesday, and pick up Wednesday and Thursday. Then I would be dropping 2,000 cannisters on a lab in two days! And on a weekend...
Your thoughts gentlemen... I am not optimistic. Thanks for your time!
_____________________________
Arlington Public Schools
2770 S. Taylor Street
Arlington VA. 22206
FINAL REVISED
RADON TESTING SCOPE OF WORK
February 18, 2009
Arlington Public Schools (APS) requests Radon testing to bring schools into compliance with Environmental Protection Agency, the Commonwealth of Virginia Department of Education and the Virginia Department of Health and as stated below:
GENERAL REQUIREMENTS
Radon testing shall be turnkey and include all labor materials, reports, quality assurance plan, postage etc. for approximately 35 school buildings and will require approximately 2,000 test kits. Testing contractors, field personnel and the analysis laboratory shall have a minimum of two years experience in radon testing in schools and shall be certified by either National Radon Safety Board or the National Environmental Health Association and EPA’s Radon Gas Measurement Proficiency.
Testing shall include: providing activated charcoal devices, deployment, retrieval, required documentation of devices, laboratory analysis, final report and delivery of reports to Arlington Schools. Electronic measuring devices shall not be utilized on this project.
Through EZIQC (Job Order Contracting) the general contractor will provide turn-key project management and shall provide a proposed schedule of school buildings to be tested at least one week prior to testing and shall contact school staff to confirm and coordinate access at least 24 hours prior to testing, APS Facilities will inform school staff of the testing and to expect your call. Arlington Public Schools will provide 81/2” X 11” floor plans (school maps) to be utilized in the placement, tracking and reporting of radon test data. All field testing shall be performed during weekday mornings from approximately 6:00-8:00 am and evenings from 2:30-10:30 pm and anytime during spring break the week of March 31, 2009.
GENERAL REQUIREMENTS CONTINUED
The testing contractor shall sign in through the main office at each school and shall ask for the head-custodian to gain access. The contractor shall confirm with the head-custodian that the school maps used for testing locations and documentation are current and that room numbers match existing room numbers. If the maps are not current, the contractor will obtain a school map from the custodian prior to deployment of devices. The contractor shall select the individual rooms to be tested per state and local requirements and as outlined below.
NOTE: Smoking is not permitted on Arlington Public School property regardless of time of day or day of the week.
The general contractors proposal shall be broken down to include the following information: A per testing device price to include complete turn-key radon testing reporting etc. and fees for general contractor project management. Proposal shall also include APS criminal convictions forms from testing contractor, a sample of the data logs to be used to document device location, etc., and certificates OF insurance naming Arlington Public Schools.
Additionally the proposal shall contain a written description of the proposed quality assurance program, copies of the following certifications: National Radon Safety Board or the National Environmental Health Association for the testing device, the laboratory who will analyze the samples and the individuals who will be placing testing devices / completing device logs and reports.
Testing shall be conducted in all frequently occupied rooms in contact with the ground to include classrooms, offices, labs, cafeterias, libraries, auditoriums and gymnasiums. Rooms that do not need to be tested are rest rooms, hallways, stairs, elevators, utility closets, storage areas, and the kitchen. Ground contact means any room over a crawl-space, slab-on-grade, or in the basement.
The contractor shall select and document the required locations. Prior to testing the contractor shall confirm that unusual or severe weather that would invalidate the testing is not predicted during the scheduled test period. It is the contractors responsibly to ensure that all required rooms are tested, APS will pay per test needed however APS will not pay for expenses etc. due to contractor errors.
MEASUREMENT DOCUMENTATION
Testing contractor shall record sufficient information on each measurement in a permanent log to allow for future data comparisons, interpretations, and reporting to clients. The measurement log shall be kept on file by the contractor for at least five years. Contractor shall comply with EPA’s Radon Measurement in Schools EPA 402-R-92-014 1993.
MEASUREMENT DOCUMENTATION CONTINUED
Four sets of the final report shall be provided to Arlington School Board in three-ring binders and shall contain the required testing information including the measurement results, index referencing divider sections, a summary of all recommendations concerning retesting and mitigation. One additional set shall be sent electronically to Doug martin at the above email address.
Final reports shall contain the following:
1. The name address of the school / building measured, including zip code.
2. The exact locations of all measurement devices deployed shall be recorded by room number and diagramed on floor plans provided by APS.
3. Exact start and stop times and dates of each measurement period as required for analysis.
4. A description of the device used, its manufacturer, model or type, and the device identification (serial) numbers and Radon Gas Measurement Proficiency (RMP) device identification number and serial number,
5. The name and RMP identification number (EPA 520/ 1-91-014-3N; U.S. EPA 1992e) of the service or analysis organizations used to analyze devices
6. Copies of certifications for device, lab and testing personnel by National Radon Safety Board or the National Environmental Health Association.
7. The name and RMP identification number (or State license number) of the individual who conducted the test.
8. A description of any variations from or uncertainties about standard measurement procedures, closed-building conditions, severe weather conditions, or other factors that may affect the measurement result.
9. A description of non-interference or tampering controls used the outcome of tampering controls.
10. A record of all documentation and measurements associated with the Quality Assurance Program, such as results of simultaneous or secondary measurements blanks, spikes and the associated laboratory analysis as well as the Quality Assurance Program and measurements for the laboratory providing analysis.
11. Copies of the hand written or electronic data logs.
12. Follow-up recommendations.
13. Measurement results shall be explained in detail.
14. Methods to calculate conversions shall be reported in the units that the device measures and in Picocuries Per Liter (pCi/L).
15. The name and any relevant identification numbers of the organization and individual placing and retrieving the device and the organization analyzing the device, if they are different.
16. A statement concerning any observed tampering or deviations from the required test conditions.
17. This scope of work shall also be included in the final report.
PLACING RETRIEVING AND ANALYZING DETECTORS
1. Do not place detectors near drafts resulting from heating, ventilating vents, air conditioning vents, fans, doors, and windows.
2. Place detectors where they are least likely to be disturbed or covered up.
3. Do not place detectors in direct sunlight or in areas of high humidity.
4. Place detectors at least approximately 50 centimeters (20 inches), from the floor and 10 centimeters (4 inches) from other objects and away from the exterior walls of the building.
5. Place detectors about every 2,000 square feet for large spaces.
6. Open-Plan or Pod Design: If sections of a pod have moveable walls that can physically separate them from other sections, measure each section separately.
7. If moveable walls are absent or inoperable, measure the pod as one room placing detectors every 2000 square feet.
8. Do not disturb the test device at any time during the test.
9. Devices shall be shipped to the analyzing laboratory as soon as possible, preferably within one or two days after testing ends. Devices that are not returned quickly may produce invalid results.
10. Arrangements shall be made with the laboratory to analyze the devices upon delivery.
11. If a device is picked up or discovered after two days, record the serial number of the device, record the actual retrieval time, and call the analytical laboratory or testing service for advice.
QUALITY ASSURANCE PROGRAM
To be considered for award of this contract contractors shall submit a quality assurance plan with their bid. A Quality Assurance Program is a complete program designed to produce results which are valid, scientifically defensible, and of known precision, bias, and accuracy. This system of activities is to ensure a quality product, including measurements made to ensure and monitor data quality and includes calibrations, duplicate, blank, and spiked measurements, inter-laboratory comparisons and audits and planning documentation and reporting. The plan shall include the following quality assurance methods as the absolute minimum required and a copy of the plan shall be included in the final report: Contractor shall state the number and type of quality assurance samples that will be required for a job of this size.
All detectors utilized shall be from the same manufacturer throughout the project from testing through Q/A. Quality Assurance samples shall be labeled and submitted to the laboratory in the same manner as ordinary samples to preclude special processing. In order to conceal the quality assurance samples from the laboratory the contractor shall create false room numbers, for blanks spikes and duplicate samples so that the data can be combined to look like actual testing data. The contractor shall make notations on the permanent copy of the data logs (that the laboratory will not see) identifying these as QA samples and distinguish which ones were blanks, duplicates spikes. In order to maximize the quality assurance program the testing contractor shall utilized an independent laboratory for analysis and the samples shall not be analyze in-house or by a sister company.
Personal Data Assistants PDA may be utilized to scan canister serial number and all pertinent information provided that the laboratory is not made aware of which samples are blanks duplicates and spikes.
Contractor shall specify the device Lower Limit of Detection (LLD) to be used in the bid document and final report. The Lower limit of detection is the smallest amount of sample activity which will yield a net count for which there is confidence at a predetermined level that activity is present. For a five percent probability of concluding falsely that activity is present, the LLD is approximately equal to 4.65 times the standard deviation of the background The contractor shall utilize devices with a Lower Limit of Detection as required by State Federal and local requirements.
Assessing the Precision of Your Measurements EPA
Duplicates are pairs of detectors deployed in the same location side-by-side for
the same measurement period. Duplicates should be placed in 10 percent of all
measurement locations in a school building (they need not exceed 50 extra detectors). They are stored, deployed, placed, removed, and shipped to the laboratory for analysis in the same manner as the other devices so that the processing laboratory cannot distinguish them.
Since duplicates are placed side-by-side, the measured values for radon should be the same. Problems in handling the detectors during the measurement process, in the laboratory analysis, or in the detector may introduce error into the test results. Large precision errors may be caused by detector manufacture, and/or improper data transcription or handling by suppliers, laboratories, or technicians performing placements. Precision error can be an important component of the overall error, so it is required that all users monitor precision.
The contractor shall state the expected testing precision in their proposal and in the final report and the methods utilized to calculate precision.
The analysis of data from duplicate samples shall follow the methodology described in EPA’s documentation for school testing. If the precision estimated by the user is not within the precision expected of the measurement method, the cause shall be investigated and corrected. The problem shall be reported to the analysis laboratory and Arlington Public Schools ASAP.
Contractor shall randomly pull test kits for quality assurance spiking, duplicates and blanks. Device serial numbers shall be utilized to randomly select testing devices from the full range of serial numbers used for this project such that QA devices represent the full range of the devices not just one or two boxes of devices. The locations selected for duplication shall be distributed systematically throughout the entire population.
Final reports shall be checked for errors correct typos in items such as the school names and room numbers prior to submission to APS. Any concerns, errors omissions etc. identified during quality assurance testing shall be brought to the attention of Arlington Public Schools and shall be documented in the final report. Required retesting to correct quality and accuracy issues shall be at the testing contractor’s expense.
Calibration Measurements
The analysis laboratory shall conduct calibration measurements that are measurements made in a known radon environment, such as a calibration chamber. Charcoal canister detectors are exposed in a calibration chamber and then analyzed.
Calibration measurements must be conducted to determine and verify the conversion factors used to derive the concentration results. These factors are determined normally for a range of concentrations and exposure times, and for a range of other exposure and/or analysis conditions pertinent to the particular device. Determination of these calibration factors is a necessary part of the laboratory analysis, and is the responsibility of the analysis laboratory. These calibration measurement procedures, including the frequency of tests and the number of devices to be tested, should be specified in the quality assurance program maintained by manufacturers and analysis laboratories and shall be provided as part of the final report.
Known Exposure Measurements Spikes
Known exposure measurements or spiked samples consist of detectors that have been exposed to known concentrations in a radon calibration chamber. All organizations providing measurement services with passive devices shall conduct spiked measurements at a rate of three per 100 measurements, with a minimum of three per year and a maximum required of six per month.
Spiking data shall be assessed and summarized at the end of the testing project and all data shall be included in the final report. Spiking quality control measurements shall be preformed on a sample of new kits and periodically throughout the testing project and again at the end of the project this will provide a series of measurement that can be used to identify potential problems and or to document the accuracy and reliability of the test results. To avoid conflict-of-interest spiking samples shall be sent to an independent laboratory to be spiked and than analyzed with the other samples.
Known Exposure Measurements Spikes Continued
Contractor shall report the actual dates and times that kits were placed into and removed from the radon chamber so that the samples can be analyzed in laboratory using the actual exposure dates.
Field Blanks
Field blanks are radon test kits that are not exposed to room air and are used to determine whether the test kits have been contaminated during storage. Field blanks are opened and immediately re-sealed to keep room air from infiltrating the test kit. Per the EPA the number of blanks should be 5% of the detectors deployed or 25 whichever is less.
While radon cannot travel through the plastic and enter the charcoal during storage, humidity in the storage area may be able to find a pathway through tiny leaks in the packaging. Excessive moisture finding its way into the charcoal can reduce the effectiveness of the test kits.
These controls should be set aside from each detector shipment, kept sealed and in a low radon environment, labeled in the same manner as the field samples to preclude special processing, and returned to the analysis laboratory along with each shipment. These field blanks measure the background exposure that may accumulate during shipment and storage, and the results should be monitored and recorded.
Follow-up requirements
Follow-up testing (when needed) shall start within one month after receiving the initial test results. Follow-up testing must be made in the same location and under the same conditions as the initial measurement.
Reporting
All reporting shall be directly with Arlington Public Schools attention Doug martin 2770 S. Taylor Street Arlington VA. 22206. One copy of the initial test results shall be provided to Arlington Public Schools and shall identify locations where follow-up testing is required.
The Final report shall be submitted to Arlington Public Schools and then APS will deliver the final report to the Virginia Department of Health Bureau of Radiological Health, 109 Governor Street, Room 730, Richmond VA, 23219
END OF RADON SCOPE OF WORK
