Your state environmental agency may require you to assess for the migration of subsurface contaminants into buildings that are adjacent to spill or leaking tank sites.
In 2010, ASTM International (ASTM), an international organization that establishes standard procedures for materials and testing, published E2600-10: Standard Guide for Vapor Encroachment Screening on Property Involved in Real Estate Transactions. E2600-10 replaced the 2008 guidance, and established general standards for a tiered approach to assessing “vapor intrusion” into structures that could be affected by the release of pollutants. Vapor intrusion is defined as the process by which chemical vapors from a contaminant in soil or groundwater migrate into a structure and adversely affect indoor air quality.
The 2010 ASTM standard defined a vapor-encroachment condition (VEC) as the presence or likely presence of vapors from chemicals of concern (COC) in the subsurface of a property caused by the release of vapors on or near the property. Environmental Professionals (EPs) performing Phase I Environmental Site Assessments (Phase I’s) are expected to address the potential for vapor migration; however, prior to 2010 no standard existed to address the process for conducting vapor intrusion assessments. ASTM’s pending standard E1527- 13, will revise the current (2005) Phase I standard. One revision to the Phase I standard requires that EPs consider the potential for vapor intrusion by specifically citing elements of ASTM E2600-10.
The USEPA is currently working to complete a Final Subsurface Vapor Intrusion Guidance, and as of now, a number of states have developed guidance documents to address vapor migration and its assessment. The following paragraphs provide a status summary of vapor intrusion assessment specific to the respective state’s regulatory agency:
- Indiana: the Indiana Department of Environmental Management (IDEM) prepared a draft Vapor Intrusion Pilot Guidance (2006), but now provides requirements for vapor intrusion assessment in its July 2012, Remediation Closure Guide.
- Ohio: In May 2010, the Ohio EPA published a guidance document entitled, Sample Collection and Evaluation of Vapor Intrusion to Indoor Air, for Remedial Response and Voluntary Action Programs.
- Kentucky: The Kentucky Division of Waste Management (KDWM) has addressed vapor intrusion related to leaking underground storage tanks. As of July 2011, owners or operators of leaking UST sites, if ordered by KDWM’s Underground Storage Tank Branch, must perform either a Vapor Intrusion Assessment or an actual Vapor Intrusion Building Assessment. For sites with potential vapor intrusion from other releases, it appears that KDWM is relying on the USEPA to first establish its guidance prior to developing its own policies and procedures.

Has your company experienced a release of a chemical pollutant near or beneath a building? Has your property value been reduced as a result of a nearby release that could result in vapor intrusion? Have you performed a vapor intrusion assessment to assure that your employees are not being exposed to contaminants from the release? What does your state and USEPA require you to do if you suspect vapor intrusion. Are you at risk of safety or environmental regulatory noncompliance?
Midwest Environmental Services’ Consulting Services Division can assist you with the answers to these questions and help you reduce your environmental risks.
Don’t wait to find out that you should have taken appropriate steps to address occupational safety or environmental regulatory compliance. Contact Midwest Environmental Services at 800-388-5160 or our Consulting Services Division at 502-491-0991, and inquire about environmental compliance training and auditing services.
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