Vapor Migration – How to Prepare for the New U.S. EPA Guidance & ASTM E 1527 Standard

Awareness about the risks posed by the migration of contaminated vapors into overlying buildings is growing, yet there is still a great deal of confusion about how best to assess and address vapor-related risks. Two significant developments are pushing vapor intrusion onto the radar screens of environmental professionals and risk managers at financial institutions alike: the impending release of the U.S. EPA’s guidance on vapor intrusion, and the proposed revisions to the ASTM E 1527 Phase I ESA standard. To help environmental consultants and risk managers understand what these documents mean in terms of the standard of care for environmental due diligence and how it might affect their own liability, EDR Insight hosted a webinar on December 11th with these three leading experts in the field who are helping clients address vapor risk every day:

  • David Gillay, attorney (and former environmental engineer) and chair of Barnes & Thornburg’s Brownfields & Environmental Transactional Practice Group;
  • Francis Ramacciotti, Senior Manager, ENVIRON International Corporation; and
  • Robert Uppencamp, Project Scientist/Risk Assessor, ARCADIS.

This technical brief summarizes some of the key points covered during the webinar, including advice on what environmental professionals and commercial real estate lenders should be doing to prepare for the new EPA guidance and ASTM Phase I ESA standard in 2013.

Vapor Intrusion Risk in the Real World

As attested to by all three speakers, vapor intrusion is already arising as a potential issue at a wide variety of sites today. For instance, closed sites have been reopened by regulatory agencies across the country specifically to address vapor risk. Vapor can be particularly risky at properties involving residential exposure, such as multifamily properties or sites near residential developments. As noted by Uppencamp in his comments, “Vapor is becoming a medium that is just as common as soil and groundwater has been for many years.” If a vapor issue is identified during due diligence, it is not necessarily a deal killer, however. Popular mitigation options for making vapor risk less severe include: source remediation, elimination of the receptors, institutional/engineering controls, elimination or reduction of the exposure or some combination of these options.

Click here to continue reading about the U.S. EPA’s VI Guidance, vapor as part of the E 1527-13 revisions and for tips on what lenders and EPs should be doing to prepare.

Click here to view a replay of the webinar.