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EnviroGroup Limited Vapor Intrusion News - July 2004
In This Issue:
  OSHA versus Health-Based Action Levels
   Occupational Settings - RCRA EI Guidance
   New EPA Version of JE Model Available
   Error Found in Superfund Version of JE Model
   EPA Workshop on Modeling Vapor Attenuation
   California Specific Johnson and Ettinger Model
   Colorado Proposes New TCE Levels
   List of Indoor Air Testing Laboratories
 


Featured Links:
   EPA Superfund Version of JE Model
   EPA ORD On-Line Version of JE Model
   California DTSC Version of JE Model
   Memo on Error in EPA Superfund JE Model
 
   
   
OSHA versus Health-Based Action Levels
Who has jurisdiction when vapor intrusion impacts indoor air in the workplace, OSHA or EPA? Do OSHA PELs apply, or EPA risk-based action levels? This issue has become controversial since EPA published its Draft Subsurface Vapor Intrusion Guidance in November 2002. Although the draft guidance document and subsequent EI guidance clarify to some extent EPA's stance on this issue, several questions remain, particularly regarding the line that separates OSHA and EPA jurisdiction. Baerbel Schiller of the law firm Spencer, Fane, Britt & Brown and formerly an attorney with EPA concludes that EPA cannot supercede OSHA jurisdiction in the workplace. To read her article, click below

Baerbel Schiller article on OSHA vs EPA jurisdiction



Occupational Settings - RCRA EI Guidance

EPA has posted answers to Frequently Asked Questions concerning Environmental Indicators, including its policy regarding the evaluation of vapor intrusion in occupational and non-residential settings. The link to this site is provided below.

RCRA EI guidance - vapor intrusion in occupational settings



New EPA Version of JE Model Available
The EPA Office of Research and Development (ORD) has posted a new on-line version of the Johnson and Ettinger Model on its website. Although the ORD uses essentially the same model as the Superfund version, there are some differences. The ORD version calculates the "critical parameters" developed by Johnson et al. (2002) that indicate the predominant vapor transport mechanisms and parameters. The ORD version also conducts a mini-sensitivity analysis based on soil type and depth of contamination. The model is available at the following website:

ORD Version of JE Model



Error Found in Superfund Version of JE Model
A cell formula error in the groundwater screening (GW-Screen) version of the Johnson & Ettinger Model posted on the EPA Superfund website causes the total porosity in the capillary zone soil to be the same as in the vadose zone, even if the soil type is different. This only causes a difference in the calculations if the vadose zone soil is different than the capillary zone soil. The soil vapor screening model and the advanced versions of the model are not affected. Some of the California DTSC screening level models are also affected by the error. In most cases, the error is likely to have a small affect on the calculated result; however, in some circumstances, the affect could be more significant. The error was first discovered by Helen Dawson of Region 8 EPA. Details can be found at the following link:

JE model error memorandum



EPA Workshop on Modeling Vapor Attenuation
EPA will hold a workshop on modeling vapor attenuation October 18-19 in Amherst , MA in conjunction with the Annual International Conference on Soils, Sediments and Water. The call for papers is found at:

Call for Papers - Vapor Attenuation Modeling Workshop



California Specific Johnson and Ettinger Model

The Human and Ecological Risk Division of the California Department of Toxic Substance Control has incorporated California specific health criteria into the Johnson and Ettinger model for its use in California. The model can be found at:

California DSTC Johnson and Ettinger Model


Colorado Proposes New TCE Levels
The Colorado Department of Public Health and Environment (CDPHE) has issued a new draft policy for public comment, setting new indoor air action levels for TCE. The proposed action level for mitigation is 1.6 ug/m3, assumed to be equal to a nominal 10-4 cancer risk. However, concentrations as low as 0.8 ug/m3 trigger an evaluation to determine whether the source is vapor intrusion or background sources. CDPHE proposes no further action, unless extenuating circumstances are present, if the TCE indoor air concentration is less than 0.8 ug/m3. The comment period is open until July 23, 2004. The news release and proposed policy can be found at the following website.

CDPHE Proposed TCE Action Levels for Indoor Air


List of Indoor Air Testing Laboratories
EnviroGroup is developing a list of analytical laboratories that provide state-of-the-art analyses for air samples, including rental of Summa canisters. The list, including qualification statements and contact information provided by each lab, can be accessed by the link below. Other laboratories also provide similar services. We will update this list from time to time as we receive information from additonal laboratories claiming to provide state-of-the-art air testing services.

Please note that EnviroGroup does not endorse any particularly laboratory and does not make any representations regarding the qualifications of any laboratory listed or the accuracy of any information provided by the labs. Users of laboratory testing services should conduct their own inquiries and satisfy themselves that any laboratory they use is qualified and capable of providing the services they require.

 
Indoor Air Testing Laboratories


 
This newsletter is issued periodically to provide our readers with information on new regulatory and technical developments in the rapidly changing field of vapor intrusion. While every effort is made to ensure that the information and links presented in this newsletter are accurate at the time of publication, they are presentedfor general information purposes only. Users should independently verify the accuracy and applicability of this information and seek professional advice for any specific sites or purposes. Articles on or links to any document or website do not imply endorsement of that document or website by EnviroGroup. Copyright EnviroGroup Limited 2003. 7208 S. Tucson Way, Englewood, CO 80112.

Please contact us if you have any questions about the topics presented in this newsletter, or vapor intrusion in general. More information about EnviroGroup Limited, including several useful links to vapor intrusion websites, is available at:  EnviroGroup Limited - Vapor Intrusion Solutions
 
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