We are working on a five-story student dormitory including a partial basement area in EPA Radon Zone 1.  Are we required to follow the guidance for 'residential only' projects in high-risk areas for radon?  More specifically, does the definition of "residential units" and "dwelling unit" apply to dormitory facilities?  These units do not include full living accommodations (in-room kitchens, laundry, etc.).

According to the reference guide, the requirements for 'residential only' projects in EPA Zone 1 reads as follows:

"...In addition to the requirements above, if the project building contains residential units, each dwelling unit must meet all of the following requirements. For projects in high-risk areas for radon, EPA Radon Zone 1, design and construct any dwelling unit on levels one through four above grade with radon-resistant construction techniques..."

Thank you.