2014 CPEO Brownfields List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: Thu, 9 Oct 2014 13:00:32 -0700 (PDT)
Reply: cpeo-brownfields
Subject: [CPEO-BIF] Vapor Intrustion Guidances under White House review
On September 25, 2014 U.S. EPA sent its two draft vapor intrusion guidances to the White House Office of Management and Budget (OMB) for review. These are the main Vapor Intrusion Guidance, focused on chlorinated volatile organic compounds, and the Petroleum Vapor Intrusion Guidance. Neither draft is available for public inspection.
Based on the external review drafts that EPA circulated in April, 2013, it's hard to understand why the White House is reviewing these documents. They impose no new regulatory obligations. They are more like "cookbooks" designed to guide the investigation of potential vapor intrusion sites and the mitigation of buildings with likely or confirmed vapor intrusion.
I was pleased that EPA solicited comments last year. Diverse commenters submitted a large number of practical suggestions, and I suspect that EPA accepted many of them. But some industry groups, such as the RCRA [Resource Conservation and Recovery Act] Corrective Action Project and the American Chemistry Council made it clear that they intend to take their concerns to the White House, hoping to use the more political OMB to reverse decisions made by EPA professionals. For example, industry groups propose that EPA defer, in workplace situations, to the Occupational Safety and Health Administration's extremely unprotective Permissible Exposure Levels, and they oppose re-opening RCRA Corrective Action remedies.
I hope that the public will be notified of any interaction between OMB and industry and that public interest groups be given the opportunity to weigh in as well.
Note that the Vapor Intrusion Guidance does not address the question of short-term exposure to trichloroethylene, which EPA toxicologists have found may cause cardiac birth defects if pregnant women are exposed during the first trimester of pregnancy. Such chemical-specific guidance is not included in the documents sent to OMB.

Lenny Siegel

Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
278-A Hope Street
Mountain View, CA 94041
Voice: 650-961-8918 or 650-969-1545
Fax: 650-961-8918

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