On July 26, 2012, a letter was sent to EPA’s Richard Kapuscinski from environmental organizations and citizens groups from all over the country – including Rosemere Neighborhood Association – concerned about EPA’s pending Final Vapor Intrusion Guidance.
The letter begins:
We, the undersigned are concerned that pressure from polluters, chemical producers, and property owners may weaken elements of EPA’s pending Vapor Intrusion Guidance, and we urge EPA to adopt an investigatory approach that is truly protective of Americans exposed to highly toxic vapors in their homes, schools, workplaces, and other buildings.
On July 6, 2012, Inside EPA, reported:
Industry is criticizing EPA’s approach to calculating the potential for subsurface contamination to migrate to indoor air, raising concerns over a technical document expected to be a component of the agency’s final vapor intrusion guidance and over a Region III proposal to offer government-funded mitigation for vapor intrusion at homes near a Superfund site in Pennsylvania.
Industry argues the so-called attenuation factors in the EPA documents are unnecessarily conservative and flawed because of incorrect assumptions of the rate at which contamination flows into residences.
The determination whether vapor intrusion poses a health threat at any existing building should not be based solely upon models and predictions. Models cannot account for changes in operating conditions, occupancy, building modifications, or structural changes such as adding utility lines that penetrate floors or settling that cracks slabs. One test is worth 1000 expert opinions. Decisions should be based upon multiple lines of evidence, including indoor air testing, subslab soil-gas sampling, and outdoor air monitoring.
To read the entire letter: Communities’ Letter on EPA’s Final Vapor Intrusion Guidance