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Although regulators
agree that developing guidance to address vapor intrusion concerns is now
a priority, they are taking disparate and frequently inconsistent
approaches. Several key differences relate, for example, to the
reliability of modeling and sampling techniques, derivation and utility of
screening numbers for groundwater and soil vapor, determination of
background concentrations of contaminants in indoor air, and
quantification of risk resulting from potential inhalation
exposures. EPA
Guidance EPA has tried unsuccessfully for six years to finalize its Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (67 Fed. Reg. 71169, 11/29/02). In the meantime, more than 26 states have developed guidance documents, some of which establish groundwater or soil vapor screening levels for assessing vapor intrusion. The Interstate Technology and Regulatory Council, a coalition of state regulators and other stakeholders, attempted to address the many variations in policy among regulatory agencies in Vapor Intrusion Pathway: A Practical Guideline, published in 2007 ("ITRC Guidance"), which provides a general framework for evaluating the vapor intrusion pathway, rather than prescriptive standards or methods, for use in conjunction with applicable federal or state requirements. The new concerns about vapor intrusion, coupled with uncertainties about regulatory responses, have proven serious impediments to a variety of transactions. Companies that thought they had resolved their liabilities for waste sites, for example, are finding in some cases that regulators are now seeking to reopen remedies based on vapor intrusion, creating new concerns in acquisitions or financing transactions. | ||||
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The ASTM Standard's
purpose is to "define good commercial and customary practice in the United
States of America for conducting a vapor intrusion assessment (VIA) on a
property parcel involved in a real estate transaction with respect to
chemicals of concern (COC) that may migrate as vapors into existing or
planned structures on a property due to contaminated soil and groundwater
on the property or within close proximity to the property." Like ASTM E
1527, the ASTM Standard focuses on identifying potential conditions
resulting from historical releases of hazardous substances to the
environment that may give rise to liability or affect the value of a
property that is the subject of a proposed
transaction. CES is fully equipped
and experienced to handle these new concerns for the customary practices
of VIA's. Source of the above
article : http://www.epa.gov/ | ||
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Thank you for allowing us to spend a few moments with you. If you ever have any questions regarding the information contained in this e-newsletter, please call me direct at 951-808-8585. CES is a certified: SBE, MBE, VOBE
Sincerely,
Esteban J. Garcia, CEM phone: 951.808.8585
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