INTRUSION 2 PART 2 SERIES

Technology and tools, like the newly patented remote monitoring device known as the Vapor Sentinel. Properly drafted can be very effective to manage potential future VI pathway liability. There are important legal mechanisms, including environmental restrictive covenants or ordinances, which when There is state and federal guidance available to draft a successful LTS Plan or equivalent approach. That embraces and effectively uses new regulatory, legal, and technical tools to manage the VI pathway is consideredĪ best practice. Developing a so-called Long Term Stewardship (LTS) Plan The third phase is site-specific and data-driven. Plan, and updating the VI Conceptual Model. If it is determined that the VI pathway was notĪdequately assessed or evaluated, then you should consider developing a VI Decision Matrix, VI Sampling and Analysis The second phase could involve collecting additional samples. This expert should consider, among other criteria, the applicable screening levels for the VI pathwayĪnd conduct an updated receptor survey for both on and off-site land uses. This audit should be conducted through legal counselĪnd include an experienced consulting expert to help evaluate the risk-based assumptions and evaluate any new Ways to help ensure that the audit is privileged and confidential.

The first phase should focus on an internal audit of your portfolio of active and/or closed sites. Maintain regulatory closure for a contaminated site? A phase-based approach may be the best choice, coupled with So, given the rapidly changing regulatory climate, how can a responsible party secure and, perhaps more importantly, Including New York, Michigan, Minnesota, and Massachusetts, systemically started to reevaluate and, whereĪppropriate, reopen closed sites with TCE contamination. The VI pathway was quickly designated a primary conduit for TCE vapors toĮnter a structure and amplified this potential risk.Īs a consequence of evolving VI guidance and developmental toxicity concerns with TCE exposure, many states,

That the EPA used identified that even a woman’s single exposure to TCE during fetal development may be sufficient to Potentially result from short-term TCE inhalation exposures during pregnancy. Suggested that a low level of TCE may pose an immediate potential hazard and adverse developmental outcomes could Ubiquitous chlorinated solvents, Trichloroethylene or TCE, in our nation’s groundwater. The VI guidance landscape remains in flux and continues to evolve, with more emphasis on the movementĪs the regulatory scrutiny intensified on the VI pathway, the EPA updated its toxicological review for one of the most During the EPA’s carefulĭeliberation and release of its VI guidance, the vast majority of state environmental agencies published their own VI The EPA finalized its VI pathway guidance well over a decade later, in the summer of 2015. In late 2002, the United States Environmental Protection Agency (EPA) first released draft guidance on the VI pathway. Toxicity can disrupt this delicate balance. Evolving VI pathway guidance and dramatic changes to a contaminant’s To effectively manage liability, a responsible party must find the balance between source reduction and risk Depending on known or anticipated risks to human health and the environment, an integrated risk-based approach may include monitoring and data collection, active or passive remediation, containment, institutionalĬontrols, or a combination of these actions. Management of a cleanup to ensure it protects human health, applies sound science and common sense, and is flexibleĪnd cost-effective. Risk-based decision-making is a mechanism to integrate source reduction and risk

Site, instead of simply removing all of the contaminant or achieving a numerical closure level for unrestricted use Risk-based approach generally allows the responsible party to tailor the remedy to the real-world exposures at each The VI pathway reveals some of the potential future risks flowing from the risk-based closure of contaminated sites. This emergingĬontamination “pathway” has affected thousands of closed and contaminated sites across the country. Shares many common characteristics with the intrusion of naturally occurring radon gas into buildings. Vapor intrusion (VI) is the migration of volatile chemicals from subsurface soil and groundwater into buildings. Of contaminated sites where this pathway is potentially present. This article discusses some of the challenges and new tools to secure and maintain regulatory closure

INTRUSION 2 PART 2 SERIES

This is the second in a series of articles focusing on an unseen villain known as vapor intrusion.

Intrusion 2 part 2