On November 19, 2016, the Pennsylvania Department of Environmental Protection published the Land Recycling Program Technical Guidance Manual for Vapor Intrusion into Buildings from Groundwater and Soil under Act 2 (Document # 261-0300-101, VI Guidance) in the Pennsylvania Bulletin. This new technical guidance will take effect on January 18, 2017.
What This Means For You:
The Vapor Intrusion (VI) Guidance has been substantially revised to address scientific advancements that have been made since the publication of the previous guidance in 2004. It provides new generic vapor screening levels used in the Statewide Health Standards option of Act 2, as well as new clarifications to language, definitions and procedures meant to eliminate confusion for remediators and regional office staff on how to address the VI pathway.
In some cases, the new screening levels are drastically stricter than they have been in the past. The accepted screening levels for trichloroethylene, tetrachloroethylene and benzene (chemicals commonly encountered at commercial/industrial project sites) have decreased dramatically. This will likely increase the number of sites where vapor sampling could be required and/or Clients elect to pursue compliance with the site-specific standards option, which remains in the 2017 guidance.
Other Important Points:
– Final Reports or Remedial Action Completion Reports (RACRs) received by the DEP prior to the effective date of January 18, 2017 and for which VI was evaluated under the 2004 Guidance will not need to update their VI evaluations..
– Projects that have prior reports approved but have not yet submitted a FR or RACR should incorporate the new guidance into their future submissions.
– Projects that have already been approved will not have to be resubmitted.
How Penn E&R Can Help:
Our professionals have recently completed PADEP sponsored training in the new VI Guidance and have successfully completed over 200 Act 2 investigations in our 20 years of operation. We have also completed hundreds of Phase I and Phase II ESA’s for redevelopment clients, developers, financial institutions, law firms, industry, and the energy sector, and we have years of experience in cost-effectively guiding our Clients through the Act 2 Program to achieve environmental closure and liability protection for their business interests.
If you have any further questions about this new Vapor Intrusion guidance, how it might affect you, or about the Land Recycling Program in general, contact us today to speak to a Penn E&R professional who can help you.