RE: [CPEO-BIF] [Fwd: please post on BIF and MEF]

["Walsh, William" <WALSHW@pepperlaw.com>]

In my 30 years of representing government and the private sector, I have
never encountered such a system to determine if vapors have traveled 1 mile
from the source. Air concentrations decrease with distance and in almost all
cases the concentrations drop dramatically within a relatively short
distance (much less than a mile).  EPA has a web site (I think that it is
called NATA) that models large sources in the US and gives maps of the
resulting concentrations.  

In general, a typical monitoring system is unlikely to detect any level of
chemical within a relatively modest distance.  Once you start monitoring
offsite there are a myriad of scientific complexities associated with
distinguishing the volatile chemicals in household cleaners, dry cleaning
establishments, autos, other industrial and commercial sources.  This type
of complex system and source determination is probably beyond the capability
of most monitoring system that are used today and as was noted in the
Allegiance Resources e-mail could be very expensive.  

More typically, regulators and the regulated concentration on monitoring
near or at the source and at the perimeter of the work area (which is some
distance from the source).   

The worst-case monitoring that I am aware of is the monitoring at chemical
weapon sites.  These are acutely toxic chemicals that have very low action
levels or limits.  There, the monitoring is at the source and perimeter.  At
the chemical weapon sites, they use minicam and other specialized monitors
that are calculated specially for a limited number of chemicals at a given
detection limit (there is a recent National Academies of Science study on
this type of sampling).  However, I would not think that just typical
volatile or semi-volatile chemicals would require such detail or such low
detection limits.




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> --- Begin Message ---
> Air monitoring systems exists for your purposes.  Clearly, the issue is cost
> and willingness of regulatory agency and party responsible for the
> remedition to implement such a system.  Generally, I believe in a
> comprehensive system of  on-site controls to prevent any migration off-site
> such as active dust controls, neutralizer systems coupled with on-site
> perimeter and off-site air monitors.  It is crucial that both on-site and
> off-site monitors be used to confirm or deny whether the detection of
> contaminants on an off-site monitor relates to an activity on-site.  The
> critical question is the number of contaminants that can be monitored.  I'm
> assuming that the primary concern is hazardous volatile or semi-volatile
> organic contaminants.  Monitoring for each individual volatile or
> semi-volatile organic contaminant can be very expensive.  You can use a
> group parameter - such as total organics as a basis for assessing impacts.
> This can be done via continuous, automated logging system. .
>
> Hope this is helpful
>
> -----Original Message-----
> From: brownfields-bounces@list.cpeo.org
> [mailto:brownfields-bounces@list.cpeo.org]On Behalf Of Lenny Siegel
> Sent: Wednesday, June 07, 2006 2:44 PM
> To: Brownfields Internet Forum
> Subject: [CPEO-BIF] [Fwd: please post on BIF and MEF]
>
>
>
>
> -------- Original Message --------
> Subject: please post on BIF and MEF
> Date: Wed, 7 Jun 2006 11:25:11 -0700
> From: peter  <petestrauss1@comcast.net>
> To: <lsiegel@cpeo.org>
>
>
> I have a client approximately 1 mile from a hazardous waste disposal
> facility.  There have been a number of releases of liquids at the site
> and my client (the community) asked the question of whether it is being
> exposed during the periods when there have been releases.  So I have an
> important query: does anyone know of an air monitoring system at
> disposal sites (with some treatment of groundwater liquids) that is used
> to continuously or intermittently monitor air for a broad spectrum of
> contaminants.
>
> Thanks for your response.
>
> Peter Strauss
>
>
>
>
> --
>
>
> Lenny Siegel
> Director, Center for Public Environmental Oversight
> c/o PSC, 278-A Hope St., Mountain View, CA 94041
> Voice: 650/961-8918 or 650/969-1545
> Fax: 650/961-8918
> <lsiegel@cpeo.org>
> http://www.cpeo.org
>
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>
> --- End Message ---
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