“Ask Tony” column in EDR’s ESA Report newsletter - ASTM E2600 vs. Federal/State Vapor Intrusion Guidance
NOTE: Originally Posted at EDR (Environmental Data Resources) blog by Tony.
Ask Tony
An extension of the popular “Ask Tony” column in EDR’s ESA Report newsletter, this blog will address the technical aspects of conducting a Phase I ESA. Topics will cover vapor intrusion, reliance, REC determinations, consultant liability, decisions about whether sources are “reasonably ascertainable,” Phase I updates and contract language.
ASTM E2600 vs. Federal/State Vapor Intrusion Guidance
There appears to be a question about the applicability of the E2600 standard in those states already having vapor intrusion guidance policy. The E2600 standard is applicable because it is directed at real estate transactions to determine the potential for a vapor intrusion problem (screening in Tiers 1 and 2). If there is a potential for vapor intrusion (pVIC) at a site, E2600 (Tier 3) refers the user to applicable existing regulatory agency guidance that is directed at specific methodology to confirm whether or not a VIC really does exist at the site. In fact, Appendix X5 provides an excellent summary of federal/state web sites containing vapor intrusion guidance, policy or regulation.
The ASTM E2600 standard is really a vapor intrusion screening standard, and E2600 is very prescriptive on the screening methodology (in Tiers 1 and 2). The E2600 standard does not address what action should or should not be taken to determine whether a VIC does indeed exist at a property. Moreover, there is no conflict between the ASTM E2600 standard and existing federal/state guidance, policy or regulation.
Today, E2600 is for all practical purposes the only way to screen for a potential vapor intrusion problem at a property involved in a real estate transaction.
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