Re: [CPEO-BIF] Another Perspective On AAI's Potential Impact

[LSchnapf@aol.com]

In response to Emery's comment, many brownfield sites do not pose an immediate risk to residents but are brownfields because of the "perception" of contamination. Of those that do, the redevelopment often mitigates the risks posed by the site. For example, if the risk is dust-borne contaminants, the construction will establish a cap or cover that will mitigate that risk. Obviously, it is important that the actual construction does not make the airborne exposure worse. In my experience in NY and NJ, state regulators have been aware of this issue and make sure that the HSP addresses this issue. 

In most cases, groundwater is not being used so there is no direct exposure pathway for drinking groundwater. However, there probably needs to better attention on vapor control from off-gassing of contaminants either in the soil or from the groundwater.  I think the MEW experience and the recent revisions to the vapor intrusion model clearly show that regulators need to pay more attention to this issue when a brownfield is being redeveloped and where the contaminants of concern are VOCs. 

Larry Schnapf
55 E.87th Street #8B/8C
New York, NY 10128
212-996-5395 phone
212-593-5955 fax
www.environmental-law.net website

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