History of Vapor Intrusion
|
|
- Gabriella Bennett
- 5 years ago
- Views:
Transcription
1 History of Vapor Intrusion USEPA.GOV 1950s Use of VOCs as root zone fumigants. 1970s VOCs viewed as inhalation carcinogens VOC plume mapping by soil gas surveys developed. 1990s Some states require evaluation of the Vapor Intrusion Pathway. ASTM develops RBCA standard for petroleum releases including vapor intrusion Nicholas Albergo, PE, DEE HSA Engineers & Scientists Florida Brownfields Conference s Vapor intrusion risk from acute exposure or fire/explosion, mostly from petroleum Landfill gas and radon surveys. 1980s Love Canal vapor intrusion into basements part of Risk Assessment. RCRA OSWER Corrective Action Directive required investigation to characterize suburface gasses from hazardous constituents. 2001/2002 USEPA Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater & Soils. 1
2 Challenges of Vapor Intrusion Unforeseen Obligations Risk-based Cleanup Exposure Contaminant Levels Involves risks not from acute exposure, but from chronic longterm exposure to extremely low levels of contaminants. Low levels of contaminants are difficult to sample because the action thresholds approach laboratory detection limits. Engineering Controls Institutional Controls No Further Action (with controls) Background Levels Difficult to distinguish vapors attributable to subsurface contamination from background levels. Natural sources Chemicals commonly used in buildings and workplaces Combustion of fossil fuels for heating purposes; or Air pollutants in the ambient or outside air. 2
3 Current Vapor Intrusion Issues CERCLA, RCRA, and state remedial programs do not provide remedies for damages involving personal injury or property damage. State Common Law Potential state common law causes of action include negligence, strict liability in tort, nuisance, trespass, and premises liability. The lawsuits usually allege common law claims such as trespass and nuisance. Frequently, vapor intrusion is the only completed exposure pathway. 3
4 Vapor Intrusion Exposure Potential vapor intrusion concerns to occupants or nearby properties may be discounted because a site may be enrolled in a state dry cleaning program (for example) and has been assigned a low priority. State dry cleaner programs primarily focus on impacts to drinking water and do not consider potential vapor intrusion when ranking sites for funding. While the owner of a contaminated site may have to wait years for state funding, vapors could be migrating off the property. Relevant Laws Principal statutory sources of liability for vapor intrusion Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Resources Conservation and Recovery Act (RCRA) Toxic Substances Control Act (TSCA) 4
5 Connection to RCRA Vapor intrusion conditions associated with discharges or disposal of hazardous waste may be addressed under a variety of RCRA authorities including corrective action requirements for: Permitted facilities, 42 U.S.C (u) and (v); Non-permitted facilities, 42 U.S.C. 6928(h); Petroleum releases from underground storage tanks and other regulated units, 40 C.F.R and Injunctive Orders, 42 U.S.C Citizens Suits, 42 U.S.C. 6972; and Section 7002 Actions Connection to CERCLA CERCLA imposes liability on 4 categories of potentially responsible parties (PRPs) Category 1 Category 2 Category 3 Category 4 The current owner and operator of a facility where there has been a release of a hazardous substance. Any person who formerly owned or operated the facility at the time of disposal of any hazardous substance. Any person who arranged for the disposal, treatment, or transport of hazardous substances at or to the facility. Any person who transported hazardous substances to the facility. 5
6 May not only include initial discharge of VOCs from a dry cleaner or subsequent escape of the liquid VOCs through cracks in the sewer system as well as the migration of contaminated vapors from hazardous substances in subsurface. Includes any area where hazardous substances have come to be located, a CERCLA facility may include buildings where contaminated vapors are migrating. Liability under CERCLA Costs incurred to investigate and address a vapor intrusion condition may qualify as costs of response 42 U.S.C (23)-(25). E Standard Practice for Environmental Site Assessments: Phase I ESA Process The E 1527 Standard Practice for Environmental Site Assessments was designed to assist an owner or operator of contaminated property from incurring CERCLA liability by asserting one of the CERCLA affirmative defenses (collectively referred to as the Landowner Liability Protections ), such as: The third-party defense, 42 U.S.C. 9607(b)(3); The innocent landowner (ILO) defense, 42 U.S.C. 9601(35)(A); The bona fide prospective purchaser (BFPP) defense, 42 U.S.C. 9601(40); and The contiguous property owner (CPO) defense, 42 U.S.C. 9607(q). 6
7 Why Doesn t E 1527 Address Vapor Intrusion? E1527 was designed as an antidote to CERCLA liability. Hazard Ranking System (HRS) is Appendix A to the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), pursuant to section 105(a)(8)(A) of CERCLA. HRS evaluates risks posed by sites by analyzing four (4) pathways: surface water, groundwater, air and soils. Vapor intrusion was not a regulatory concern when the HRS was revised in 1990, the vapor intrusion pathway was (is) not one of the pathways that are evaluated when scoring a site. Oddly enough, once a site is on the NPL, vapor intrusion has to be accounted for during the risk assessment included in the Remedial Investigation (RI). What is the Nature of the Release? Confusion also stems from the CERCLA definition of a release in section 9601(22)(A). The definition excludes from the definition of release: A release that results in exposure to persons solely within a workplace (CERCLA does not provide any remedy for personal injury); and With respect to a claim which such persons may assert against their employer (refers to workers compensation claims) 7
8 Where Does E Leave Us? How Vapors Impact a Property Current E could be viewed as having contradictory statements when considering the discrepancy between indoor air as a non-scope item (ASTM ) and the REC definition. Includes releases into structures on the property (ASTM ), and thus offers little direction other than vapor intrusion is not part of the current Phase I Standard. 8
9 EPA Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (Subsurface Vapor Intrusion Guidance), 67 Fed. Reg EPA s Office of the Inspector General (OIG) recommended that EPA update its Vapor Intrusion Guidance. EPA s Position EPA began soliciting public feedback on topics related to the potential revisions to the HRS including vapor intrusion Revisions to E (due out in 2012) Bottom Line: Hazardous Substances that reach a Property via the subsurface vapor pathway are no different from those that reach it by other means, be it groundwater, direct leakage ( source area ), or airborne deposition (i.e., smelting, mining, or poorlycontrolled nearby large-scale removal) GAO Report to Congressional Requesters. If vapor intrusion sites are not assessed and, if needed, listed on the NPL, there is the potential that contaminated sites with unacceptable human exposure will not be acted upon. 9
10 Revisions to the 2005 Standard are focused on adding a definition for release. Perhaps by adding a definition for this term that was closely tailored to the CERCLA definition, we could accomplish several goals at once: Adding further clarity to the standard, which is a good thing, and Addressing the vapor intrusion issue. Revisions to E Release ASTM E Standard Guide for Vapor Encroachment Screening on Property Involved in Real Estate Transactions Focuses on screening for the likelihood of vapors migrating onto a property from off-site sources. If likelihood exists for vapors to reach the boundary of the property, the EP is to identify this potential as a vapor encroachment condition (VEC). Provides a methodology for an EP to determine if vapors are potentials coming onto a site, but the mere presence of a VEC does not necessarily mean the site has a REC. 10
11 E 2600 Is it worthless? No longer informs a property owner or lender if there is a vapor intrusion problem at its property, but instead is limited to whether there is a possibility that vapors may be present at the target property boundary. The term vapor encroachment has no regulatory significance. In other words, the federal and state programs are concerned about vapor intrusion, not vapor encroachment. VECs could be simply determined to be a de minimis condition (and thus not a REC). 11
VAPOR ENCROACHMENT VAPOR INTRUSION; TRANSACTIONAL ASSESSMENT OF THE POSSIBLE VAPOR INTRUSION PATHWAY
VAPOR ENCROACHMENT VAPOR INTRUSION; TRANSACTIONAL ASSESSMENT OF THE POSSIBLE VAPOR INTRUSION PATHWAY By Russell Griebel, P.G., C.P.G. United Consulting Presentation Talking Points How We Got Here Vapor
More informationHave You Caught a Case of the Vapors?
Have You Caught a Case of the Vapors? By: Staige Miller, EP, Director of Environmental Services March 2012 Why is Vapor Intrusion an Environmental Risk? There is a new buzz word that is making its way
More informationEnvironmental Site Assessment for Lenders April EPA All Appropriate Inquiry and. ASTM Phase I Environmental Site Assessment
Environmental Site Assessment for Lenders April 2017 EPA All Appropriate Inquiry and ASTM Phase I Environmental Site Assessment 1 CONTENT 1. CERCLA Liability & AAI 2. Typical Contaminants Encountered 3.
More informationVapor Encroachment Screening Under the Newly-Revised ASTM E Standard
em feature by Anthony Buonicore Vapor Encroachment Screening Under the Newly-Revised ASTM E 2600-10 Standard Anthony J. Buonicore, P.E., DEE, QEP, is chief executive officer of The Buonicore Group, and
More informationEarly History of the Vapor Intrusion Pathway
Early History of the Vapor Intrusion Pathway 14 th Steven Amter,, MS Disposal Safety Incorporated Washington, DC Vapor Intrusion Attenuation Workshop th Annual West Coast Conference on Soils, sediments,
More informationAssessing the Impact:
Assessing the Impact: ASTM E1527-13 and EPA s Final Rule on AAI. Presented by Michael P. Carvalho, Esq. President & Shareholder, Carvalho & Associates, P.C. Copyright 2014 Carvalho & Associates, P.C. All
More informationEnvironmental Due Diligence Principals for CRE Professionals
Environmental Due Diligence Principals for CRE Professionals May 16, 2017 Presented by: Sean Leary, Executive Vice President Vieau Associates, Inc. Edina, MN Who Can Sell a Superfund Site? Who wants to
More informationAtlanta SMAC Conference April 18, 2017
Atlanta SMAC Conference April 18, 2017 New Construction Pre-Application Training 3 rd Party Environmental Phase I ESA Scope of Work Compliance with NEPA and other related Federal and state environmental
More informationASTM E Updates and Impacts on Vapor Intrusion Evaluation. Presented by Gordon Cobb, PhD ENVIRON International Corporation
ASTM E-1527-13 Updates and Impacts on Vapor Intrusion Evaluation Presented by Gordon Cobb, PhD ENVIRON International Corporation Quick Poll How familiar are you with Phase I Environmental Site Assessment
More informationEnvironmental Group Liability In Coal Ash Management
Environmental Group Liability In Coal Ash Management By: Joshua R. More Overview Statutory Resource Conservation Recovery Act (RCRA) Comprehensive Environmental Response, Compensation, and Liability Act
More informationVapor Intrusion: A Game Changer For Environmental Due Diligence And Environmental Liability
Vapor Intrusion: A Game Changer For Environmental Due Diligence And Environmental Liability Lawrence P. Schnapf Think that old Phase 1 will be enough to protect your client from vapor intrusion claims?
More informationVapor Intrusion in New York: Five Years After Release of New York s Strategy and Vapor Intrusion Guidance By Katherine Rahill
Vapor Intrusion in New York: Five Years After Release of New York s Strategy and Vapor Intrusion Guidance By Katherine Rahill I. Introduction In 2006, the state of New York changed the landscape for contaminated
More informationTier 1 Vapor Migration Screening for Property Transactions Using ASTM E
Tier 1 Vapor Migration Screening for Property Transactions Using ASTM E2600-15 Presented by Todd Elmore, EDR Business Development Manager Southeast Atlantic Southeastern States Vapor Intrusion Symposium
More informationU.S. Environmental Law Overview
U.S. Environmental Law Overview Tracy Hester Environmental Enforcement August 28, 2014 U.S. Environmental Requirements for Exploration and Production Background for liability tort laws (nuisance, trespass)
More informationRISK BULLETIN. Vapor Intrusion An Emerging Environmental Liability WHAT IS VAPOR INTRUSION?
RISK BULLETIN Vapor Intrusion An Emerging Environmental Liability From companies that use volatile organic compounds (VOCs) in their processes to firms that develop land, environmental impacts to soil
More informationFurther Investigation Phase I/II & Site Remediation
Further Investigation Phase I/II & Site Remediation Office of Environment and Energy April 2016 1 Presentation Objectives Introduction to further investigations Evaluating professional reports Online resources
More informationPrivate Party CERCLA Cost Recovery
245 Fischer Avenue, Suite D-2 Costa Mesa, CA 92626 Tel. +1.714.770.8040 Web: www.aquilogic.com November 2013 Private Party CERCLA Cost Recovery Private parties, such as land owners, Cities or water utilities,
More informationVapor Intrusion Assessment. Kaitlyn S. Rhonehouse, P.E. Florida Brownfield Association 16 th Annual Conference, Brownfields in Motion
Vapor Intrusion Assessment Kaitlyn S. Rhonehouse, P.E. Florida Brownfield Association 16 th Annual Conference, Brownfields in Motion VI Assessment what to consider? Potential for VI Phase I ESA ASTM E1527
More informationFACTS ABOUT: Vapor Intrusion
Maryland Department of the Environment FACTS ABOUT: Vapor Intrusion The Land Restoration Program (LRP) is charged with assessing and cleaning up uncontrolled hazardous waste sites throughout Maryland to
More informationPROCEDURES FOR EVALUATION OF RESPONSE ACTION ALTERNATIVES AND REMEDY SELECTION FOR REMEDIAL RESPONSE PROGRAM SITES
Page: 1 PURPOSE: BACKGROUND: This policy describes the process and criteria used by the Division of Emergency and Remedial Response (DERR) in the analysis of response action alternatives for state authority
More informationOVERVIEW CAPACITY & CONDITION
OVERVIEW Over 18,000 sites and an associated 22 million acres of land are related to the primary hazardous waste programs that comprise much of the nation s hazardous waste infrastructure, and more than
More informationBrownfields Prevention Transformed. Deborah Orr August 2008
Brownfields Prevention Transformed Deborah Orr Orr.deborah@epa.gov August 2008 1 1 Region 5 Message Municipalities can take easy steps toward preventing Brownfields by being proactive. By helping companies
More informationRisk and Required Mitigation
1 2.3 Critical Exposure Pathways 2.3.1 Identification of a Critical Exposure Pathway (CEP) 2.3.1.1. The CEP Concept The CEP requirements in the MCP are focused on human receptors in homes, schools and
More informationRegion 6 Risk Management Addendum - Draft Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities
United States Region 6 Multimedia EPA-R6-98-002 Environmental Protection Planning and Permitting July 1998 Agency Division www.epa.gov/region06 Region 6 Risk Management Addendum - Draft Human Health Risk
More informationVapour Intrusion Regulatory Framework and Case Law Review
Vapour Intrusion Regulatory Framework and Case Law Review John Georgakopoulos Partner Willms & Shier Environmental Lawyers LLP www.willmsshier.com Remediation Technologies Symposium 2013 October 16-18,
More informationThe Cleanup Process. Operation and Maintenance Construction Completion Post Construction Completion NPL Deletion Reuse
SUPERFUND The Cleanup Process Compiled from http://www.epa.gov/superfund/cleanup/pasi.htm Site discovery PA/SI NPL Ranking and Listing RI/FS Scoping Site Characterization Development and Screening of Alternatives
More information7.0 EVALUATION OF REMEDIAL ALTERNATIVES
7.0 EVALUATION OF REMEDIAL ALTERNATIVES This section provides a description of the developed remedial alternatives based on viable remedial technologies and process options, as identified in Section 4.0,
More informationRelease Reporting Requirements. Stoel Rives LLP
Release Reporting Requirements By Stoel Rives LLP I. INTRODUCTION Unexpected Problems Scope of Remarks Unexpected Problems Scenarios Unexpected Release - Your plant operator calls you in the middle of
More informationANALYSIS OF BROWNFIELD CLEANUP ALTERNATIVES
ANALYSIS OF BROWNFIELD CLEANUP ALTERNATIVES Preliminary Evaluation for Wells & Son Metal Recycling aka Cardinal Grain Property 607 South Chauncey Street Columbia City, Indiana 46725 1.0 INTRODUCTION This
More informationMr. Fonda Apostolopoulos, P.E. Colorado Department of Public Health and Environment. September 21, 2011
Mr. Fonda Apostolopoulos, P.E. Colorado Department of Public Health and Environment September 21, 2011 Became effective July 1, 1994 1 Banks: Provide Loans Without Fear of Superfund Liability Help Frustrated
More informationSection 3.11: Hazardous Materials
Section 3.11: Hazardous Materials Section 3.11 Hazardous Materials 3.11 HAZARDOUS MATERIALS 3.11.1 Introduction to Analysis This section provides information regarding known contaminated sites and general
More informationVapor Intrusion in Massachusetts Gerard Martin
Vapor Intrusion in Massachusetts Gerard Martin Chief Compliance, Enforcement and Brownfields Redevelopment Section Bureau of Waste Site Cleanup, MassDEP Proposed MCP Amendments Relative to Vapor Intrusion
More informationASTM E Standard Update. Key Revisions to E Impacting Phase I Investigations
ASTM E1527-13 Standard Update The ASTM published the new standard for conducting Phase I Environmental Site Assessments, ASTM E1527-13 on November 6th, 2013. ASTM E1527-13 is in effect and replaces the
More informationTHE AMERICAN LAW INSTITUTE Continuing Legal Education. Environmental Law
83 THE AMERICAN LAW INSTITUTE Continuing Legal Education Environmental Law Cosponsored by the Environmental Law Institute February 5-7, 2014 Washington, D.C. Superfund Update By Walter E. Mugdan Marla
More informationTitle 26 DEPARTMENT OF THE ENVIRONMENT Subtitle 14 Hazardous Substances Response Plan. Notice of Proposed Action
Title 26 DEPARTMENT OF THE ENVIRONMENT Subtitle 14 Hazardous Substances Response Plan Notice of Proposed Action The Secretary of the Environment proposes: Under COMAR 26.14.02 Investigating, Evaluating,
More informationVapor Intrusion: Due Diligence Issues
Vapor Intrusion: Due Diligence Issues Lawrence Schnapf Schulte Roth & Zabel 919 Third Avenue New York, New York 10022 212-756 756-2205 (phone) 212-593 593-59555955 (fax) Lawrence.Schnapf@srz.com Liability
More informationU.S. Environmental Law and Oil & Gas Operations
U.S. Environmental Law and Oil & Gas Operations Professor Tracy Hester Environmental Law in Oil & Gas Sept. 18, 2017 Overview Who owns it? Onshore Offshore Who controls and regulates it? EPA Corps of Engineers
More informationEnvironmental Cleanup in Oregon
Environmental Cleanup in Oregon Oregon s Environmental Cleanup Program October 2008 Ann Levine Phone (503) 229-6258 levine.ann@deq.state.or.us Oregon DEQ Environmental Cleanup in Oregon Levels of government
More informationINSTITUTIONAL CONTROLS AND PETROLEUM BROWNFIELDS. By Frank M. Grenard Johnson & Bell, Ltd. Chicago, IL SHORT HISTORICAL REFERENCE
INSTITUTIONAL CONTROLS AND PETROLEUM BROWNFIELDS By Frank M. Grenard Johnson & Bell, Ltd. Chicago, IL SHORT HISTORICAL REFERENCE At the end of 2010, there were approximately 600,000 Brownfield sites in
More informationRCRA Corrective Action Workshop On Results-Based Project Management: Fact Sheet Series
United States Environmental Protection Agency Office of Solid Waste RCRA Corrective Action Workshop On Results-Based Project Management: Fact Sheet Series EPA March 2000 www. FACT SHEET #3 FINAL REMEDY
More information3.11 HAZARDOUS MATERIALS
3.11 HAZARDOUS MATERIALS 3.11.1 Introduction to Analysis This section provides information regarding known contaminated sites and general areas of potentially contaminated properties along the proposed
More informationEPA s Final Vapor Intrusion Guidance
EPA s Final Vapor Intrusion Guidance Introductory Webinar for EPA Staff by Richard Kapuscinski Office of Land & Emergency Management (OLEM) October 2017 1 I. What is Vapor Intrusion and Why Does it Matter?
More informationBROWNFIELDS PRIMER. Chicago - June 2017
BROWNFIELDS PRIMER Chicago - June 2017 PRESENTED BY THOMAS BARRASSO DIRECTOR OF ENERGY & ENVIRONMENTAL AFFAIRS CITY OF AMESBURY, MASSACHUSETTS History of EPA/Superfund/Brownfields Timeline: 1970 EPA Established
More informationRCRA ORIENTATION MANUAL
RCRA ORIENTATION MANUAL EXECUTIVE SUMMARY OVERVIEW The Resource Conservation and Recovery Act (RCRA) was enacted in 1976 to address the huge volumes of municipal and industrial solid waste generated nationwide.
More informationEligibility Requirements and Procedures for Risk-Based Remediation of Industrial Sites Pursuant to N.C.G.S. 130A to
Eligibility Requirements and Procedures for Risk-Based Remediation of Industrial Sites Pursuant to N.C.G.S. 130A-310.65 to 310.77 North Carolina Department of Environment and Natural Resources Division
More information4.1 Evaluation Criteria
Section 4 Detailed Analysis of Alternatives A detailed evaluation of the alternatives provides the relevant information necessary for decision makers to select an appropriate site remedy. In this section,
More informationA Professional Environmental & Regulatory Compliance Corporation P.O. Box Dallas, Texas quest-env.
A Professional Environmental & Regulatory Compliance Corporation P.O. Box 700112 Dallas, Texas 75370 214-908-4254 questenv@gmail.com quest-env.com Statement of Qualifications It is Quest s sole purpose
More informationEPA Superfund Program 101
EPA Superfund Program 101 Superfund 101 Agenda What is Superfund? Two types of Superfund program ogam actions Removal Remedial The Superfund process Who pays? Community Involvement Additional contact information
More informationRelease Reporting in LA. Rick Bergeron Environmental Manager Occidental Chemical Corporation (225)
Release Reporting in LA Rick Bergeron Environmental Manager Occidental Chemical Corporation (225) 562.9395 richard_bergeron@oxy.com First Assessment Has the release stopped or is it ongoing? What is the
More informationPhase 1 ESA Phase 2 ESA Site Assessment. Cleanup Planning Cleanup CNFA NFA. Gas Tank Removal at Closed Gas Station
Phase 1 ESA Phase 2 ESA Site Assessment Cleanup Planning Cleanup CNFA NFA Gas Tank Removal at Closed Gas Station Hazardous Substance - Hazardous waste, CERCLA hazardous substances, petroleum, other substances
More informationTroy L. Schultz, C.P. Ohio EPA Certified Professional AIPG Certified Professional Geologist ASTM RBCA Trainer. RAGS & RBDM 1983 to 2009
EPA Human Health Risk Assessment & Risk-Based Decision-Making 1983-2009 Troy L. Schultz, C.P. Ohio EPA Certified Professional AIPG Certified Professional Geologist ASTM RBCA Trainer 1 Risk Mismanagement
More informationThe 1984 HSWA Amendments: The Land Disposal Restrictions
University of Colorado Law School Colorado Law Scholarly Commons Getting a Handle on Hazardous Waste Control (Summer Conference, June 9-10) Getches-Wilkinson Center Conferences, Workshops, and Hot Topics
More informationInitiation of Emerging Contaminants Characterization and Response Actions for Protection of Human Health
THE ECOS and DoD SUSTAINABILITY WORKGROUP ISSUE PAPER Initiation of Emerging Contaminants Characterization and Response Actions for Protection of Human Health Introduction: The ECOS-DoD Sustainability
More informationOSWER DIRECTIVE Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE OSWER DIRECTIVE 9355.0-30 MEMORANDUM SUBJECT: FROM: TO: Role of the Baseline Risk Assessment
More informationIssue No. 7 Fall 2017 Is It a REC? Vapor Intrusion Confusion Back in 2008 the American Society for Testing and Materials (now ASTM International) released its guidance for what was then described as an
More informationSniffing Out Vapor Intrusion
Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com Sniffing Out Vapor Intrusion Robert Howard Latham
More informationEPA S 2015 vapor intrusion guides What do they mean for your facility?
Environmental law alert Nixon peabody LLP July 22, 2015 EPA S 2015 vapor intrusion guides What do they mean for your facility? By J. Timothy Ramsey and Jean McCreary The United States Environmental Protection
More informationUpdate - Vapor Intrusion and Mitigation in Florida
Florida Brownfields Conference Update - Vapor Intrusion and Mitigation in Florida Gordon L. Walters Jr., P.E., M.B.A. October 30, 2012 What is Vapor Intrusion? Vapor Intrusion is the migration of volatile
More informationNovember 8, 2016 International Petroleum Environmental Conference. Tim Nickels Pastor, Behling & Wheeler, LLC
November 8, 2016 International Petroleum Environmental Conference Tim Nickels Pastor, Behling & Wheeler, LLC Long term, non-voluntary constant inhalation exposure to toxic compounds Non-voluntarily inhale
More informationonline environment regulatory and compliance training EPA Institute COURSE CATALOG
COURSE CATALOG 2009 www.epainstitute.com 00 1.PUBLIC HEALTH SECURITY AND BIOTERRORISM PREPAREDNESS AND RESPONSE ACT OF 2002 Per Person Price: FREE Group Fixed Price: NA NA compliance and management staff,
More informationCHAPTER 1 INTRODUCTION
CHAPTER 1 INTRODUCTION The Comprehensive Environmental Response, The goal of the Superfund human health Compensation, and Liability Act of 1980, as evaluation process is to provide a framework for amended
More informationRESTORING THE ENVIRONMENT By James A. Chaffee, P.E., Stevens Point Office Manager RUST Environment & Infrastructure
RESTORING THE ENVIRONMENT By James A. Chaffee, P.E., Stevens Point Office Manager RUST Environment & Infrastructure Since 1980, we have invested over $16 billion investigating and attempting to clean up
More informationChapter 11: Hazardous Materials A. INTRODUCTION
Chapter 11: Hazardous Materials A. INTRODUCTION This chapter relies on the analysis from the Fresh Kills Park Final Generic Environmental Impact Statement (FGEIS) and summarizes the conclusions drawn from
More informationModern Electroplating Site Update. Dudley Vision Advisory Task Force September 2008 Meeting
Modern Electroplating Site Update Dudley Vision Advisory Task Force September 2008 Meeting 1 Modern Electroplating Uncontrolled Waste Site Key elements that define a site relative to MA DEP and US EPA
More informationGeneric numerical standards.
3745-300-08 Generic numerical standards. [Comment: For dates of non-regulatory government publications, publications of recognized organizations and associations, federal rules, and federal statutory provisions
More informationRisk-Based Decision Making for Site Cleanup
Risk-Based Decision Making for Site Cleanup The Oklahoma Department of Environmental Quality (DEQ) has adopted a risk-based decision-making process to provide a framework for determining cleanup requirements
More informationState of Minnesota Minnesota Pollution Control Agency
State of Minnesota Minnesota Pollution Control Agency MINNESOTA DECISION DOCUMENT Pursuant to the Minnesota Environmental Response and Liability Act (MERLA), Minn. Stat. 115B.01 to 115B.24 (2017). I. SITE
More informationLEAD IN SOIL. Commercial/Industrial Site Assessment & Remediation
Benjamin M. LaPointe, CHMM Assessment/Remediation Manager Metric Environmental, LLC. benjaminl@metricenv.com Commercial/Industrial Site Assessment & Remediation LEAD IN SOIL I. WHY? PURPOSE OF LEAD SOIL
More informationph as supplied: 7.3 2
Health 0 Flammability 1 Reactivity 0 SECTION 6 ACCIDENTAL RELEASE MEASURES General: Hydro Green Plus with takifier is biodegradable and will not cause damage to trees or vegetation by root absorption.
More informationMINNESOTA POLLUTION CONTROL AGENCY SITE REMEDIATION SECTION
MINNESOTA POLLUTION CONTROL AGENCY SITE REMEDIATION SECTION GROUND WATER POLICY DOCUMENT WORKING DRAFT, August, 1998 Fax (651) 296-9707 NOTICE THIS DOCUMENT IS AN. The of MPCA is developing guidelines
More informationDECISION DOCUMENT. Kent Avenue Station Site Voluntary Cleanup Program Brooklyn, Kings County Site No. V00732 October 2013
DECISION DOCUMENT Kent Avenue Station Site Voluntary Cleanup Program Brooklyn, Kings County Site No. V00732 October 2013 Prepared by Division of Environmental Remediation New York State Department of Environmental
More informationBrownfield Program in California
Brownfield Program in California Weixing Tong, Ph.D. P.G., C.H.G., C.E.G. California Regional Water Quality Control Board Los Angeles Region Brownfield Definition Brownfields are real property, the expansion,
More informationENVIRONMENTAL LAW Fall I. (30 min.)
ENVIRONMENTAL LAW Fall 2001. I. (30 min.) Endangered Species Act: take, harm: - section 9(a)(1) prohibits any person from taking, harming, or having possession of an endangered species of fish or wildlife.
More informationBest management practices for vapor investigation and building mitigation decisions
www.pca.state.mn.us Best management practices for vapor investigation and building mitigation decisions Purpose This best management practices (BMPs) document describes the processes used to conduct vapor
More informationIndiana Perspectives on the Use of Institutional Controls for Leaking UST Sites. ASTSWMO LUST and State Fund-Financial Responsibility Workshop
Indiana Perspectives on the Use of Institutional Controls for Leaking UST Sites ASTSWMO LUST and State Fund-Financial Responsibility Workshop May 2014 Indiana Department of Environmental Management Remediation
More informationClearing Up the Confusion About the ASTM E Phase I ESA Standard
Environmental Professionals Organization of Connecticut: Clearing Up the Confusion About the ASTM E 1527-13 Phase I ESA Standard Tonight s presenters: Dianne Crocker, Principal Analyst, EDR Insight Pat
More informationPhase I Environmental Site Assessment (Phase I ESA) Phase II ESA. Contaminant Remediation. Underground Storage Tank (UST) Removal/Closure
Phase I Environmental Site Assessment (Phase I ESA) Commonly referred to as Due Diligence Assessment, a Phase I ESA is performed to identify environmental concerns attributed to current and past property
More informationVapor Intrusion Basics
Vapor Intrusion Basics Larry Schnapf So your client thinks that it has no more worries with its remediated site? Not so fast. There s a new factor to consider vapor intrusion. THE PAST DECADE witnessed
More informationJohanna Heywood, PE, PG
Johanna Heywood, PE, PG MEMPHIS BROWNFIELD WORKSHOP, SEPTEMBER 10, 2014 Past use of the site Chemicals used on-site Surrounding property usage Does not generally confirm or delineate contaminated areas
More informationEnsuring Occupational Worker Safety At Vapor Intrusion Sites
Ensuring Occupational Worker Safety At Vapor Intrusion Sites Shukla Roy-Semmen, William Bosan, C.Y. Jeng and Frank Parr Department of Toxic Substances Control California Environmental Protection Agency
More informationIntroduction to CERCLA: A Legal Perspective
Introduction to CERCLA: A Legal Perspective Tribal Lands & Environment Forum August 16, 2017 Tulsa, OK 1319 F Street, NW, Suite 300 Washington, DC 20004 202-821-1950 www.jillgrantlaw.com 2 Background 3
More informationPhase I and Phase II Environmental Site Assessments
Phase I and Phase II Environmental Site Assessments Society of Women Environmental Professionals Capital Chapter Ira Walton Environmental Director United Environmental Services, Inc. May 1, 2018 Who Needs
More informationProposed MCP Amendments
Gerard Martin, Chief Compliance, Enforcement and Brownfields Redevelopment Section MassDEP, Bureau of Waste Site Cleanup Southeast Regional Office September 27, 2013 Proposed MCP Amendments Process Improvements:
More informationEnvironmental Assessment. Appendix G Hazardous Materials Technical Report
Environmental Assessment Appendix G Hazardous Materials Technical Report Hazardous Materials and Waste Sites Summary Technical Memorandum Kansas City Streetcar Main Street Extension December 20, 2018 DRAFT
More informationAppendix I: Proposed Refinements Hazardous Materials Technical Report. Durham-Orange Light Rail Transit Project
Appendix I: Proposed Refinements Durham-Orange Light Rail Transit Project October 2018 Table of Contents Executive Summary... v Limited Phase I Activities... v Findings... vi Opinions... vii Conclusions...
More informationLecture 24. Brownfields and Superfund reform
Lecture 24 Brownfields and Superfund reform Definition of a Brownfield real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous
More informationDue Diligence we ll discuss how to go about doing it and the approach may vary
1 2 3 4 Due Diligence we ll discuss how to go about doing it and the approach may vary depending on your HUD project. What this training is NOT You will not a qualified EP. Rather, this is Overview of
More informationRelative hazard and risk measure calculation methodology
Relative hazard and risk measure calculation methodology R. D. Stenner, D. L. Strenge & M. S. Elder Pacific Northwest National Laboratory, Richland, WA Abstract The relative hazard (RH) and risk measure
More informationPROPOSED PLAN OF REMEDIAL ACTION. Harper-Thiel Site Wilmington, DE DNREC Project No. DE-197
PROPOSED PLAN OF REMEDIAL ACTION Harper-Thiel Site Wilmington, DE DNREC Project No. DE-197 July 2007 Delaware Department of Natural Resources and Environmental Control Division of Air and Waste Management
More informationINTRODUCTION. 1 Proposed Plan for the Former Lee Field Naval Air Station Landfill Area 2 Site
1 Proposed Plan for the Former Lee Field Naval Air Station Landfill Area 2 Site U.S. Army Corps of Engineers, Jacksonville District Formerly Used Defense Site Program PROPOSED PLAN for the LANDFILL AREA
More informationSITE REVIEW AND UPDATE ROCKY HILL MUNICIPAL WELLS ROCKY HILL BOROUGH, SOMERSET COUNTY, NEW JERSEY CERCLIS NO. NJD
SITE REVIEW AND UPDATE ROCKY HILL MUNICIPAL WELLS ROCKY HILL BOROUGH, SOMERSET COUNTY, NEW JERSEY CERCLIS NO. NJD980654156 Prepared by: New Jersey Department of Health Environmental Health Service Under
More informationCore Program Areas. Department of Environmental Quality 3/21/2017. Division of Waste Management. Division of Waste Management
Department of Environmental Quality Division of Waste Management Use of GIS to Improve Public Access & Knowledge of DWM Site Inventories Core Program Areas Division of Waste Management Superfund Section
More informationHEALTH PHYSICS SOCIETY Specialists in Radiation Safety
HEALTH PHYSICS SOCIETY Specialists in Radiation Safety Background Information on Ionizing Radiation Safety Standards for the General Public Position Statement of the Health Physics Society* Adopted: September
More informationMethodology for Identifying the Area of Concern Around a Property Potentially Impacted by Vapor Migration from Nearby Contaminated Sources
Methodology for Identifying the Area of Concern Around a Property Potentially Impacted by Vapor Migration from Nearby Contaminated Sources Paper 2011-A-301-AWMA Anthony J. Buonicore, PE, BCEE, QEP The
More informationAPPENDIX M: Hazardous Waste Technical Report
APPENDIX M: Hazardous Waste Technical Report M.1 Existing Conditions A hazardous waste review was conducted to provide preliminary information regarding the potential presence of any hazardous substances
More informationEnvironmental Risk Assessments of Coal Ash Impoundments
2017 World of Coal Ash (WOCA) Conference in Lexington, KY - May 9-11, 2017 http://www.flyash.info/ Environmental Risk Assessments of Coal Ash Impoundments George M. Huddleston III, Kathy W. Webb, Heather
More informationOSWER Directive No GUIDANCE FOR MONITORING AT HAZARDOUS WASTE SITES: FRAMEWORK FOR MONITORING PLAN DEVELOPMENT AND IMPLEMENTATION
OSWER Directive No. 9355.4-28 GUIDANCE FOR MONITORING AT HAZARDOUS WASTE SITES: FRAMEWORK FOR MONITORING PLAN DEVELOPMENT AND IMPLEMENTATION January 2004 EXECUTIVE SUMMARY This guidance document presents
More informationThe Increasingly Steep Climb to Regulatory Closure for Contaminated Sites by Keith B. Walker*
The Increasingly Steep Climb to Regulatory Closure for Contaminated Sites by Keith B. Walker* potential for significant toxic tort liability; and (iii) avoids Two recent key developments undue restrictions
More informationVapor Intrusion: Liabilities and Litigation Trends
presents Vapor Intrusion: Liabilities and Litigation Trends Compliance and Defense Strategies Amid Heightened Government Scrutiny A Live 90-Minute Audio Conference with Interactive Q&A Today's panel features:
More informationRisk Based Corrective Action Approach. Managing Change and Superfund Delisting
Risk Based Corrective Action Approach Managing Change and Superfund Delisting Topics Community Involvement Roles and responsibilities State policy: statutes and performance criteria Federal Superfund Delisting
More information