Thought I would share a few points discussed last week at the Environmental Law Forum, pertaining to vapor intrusion. It is becoming increasingly important to include good quality vapor intrusion evaluations in risk-based site remediation proposals. Brownfield site purchasers may also include such evaluations in pre-aquisition due diligence. If new information is generated at a site that previously obtained PA Act 2 approval, it could be grounds for reopener of that approval. However, DEP is currently not interested in affirmatively pursuing such reopeners.
In some instances it appears sensible to take indoor air samples rather than going through a soil screening process possibly followed by additiona sampling. However, indoor sampling can be inaccurate and can raise unwanted issues. Stories are told of elevated VOC levels ultimately determined to be caused by employee dry cleaning hanging in a closet, or elevated levels that are probably not related to the subsurface soil contamination but cannot be readily explained and lead to worker hysteria etc.
DEP previously proposed amending the Act 2 regulations to specifically require vapor intrusion evaluation, but finalization is still believed to be several months away.
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