On April 16, 2013, the EPA’s Office of Solid Waste and Emergency Response published a draft of the Final Guidance for Assessing and Mitigating the Vapor Intrusion Pathway from Subsurface Sources to Indoor Air, and a draft of the Office of Underground Storage Tank’s Guidance for Addressing Petroleum Vapor Intrusion and Leaking Underground Storage Tank Sites, for public comment.
In an article entitled “Lawyers’ View of EPA’s Draft Final Guidance for Vapor Intrusion,” its authors Cutler, Davis, and Roe of Fox Rothschild LLP, express their concerns about the published drafts, and call on the EPA to make changes to that facilitate a “more practical approach” to vapor intrusion regulation.
Their article is found in the June 5th, 2013 issue of Daily Environment Report and in Bloomberg BNA. The opinions expressed in the article are those of its authors.
The EPA’s draft of the Guidance for Addressing Petroleum Vapor Intrusion and Leaking Underground Storage Tank Sites is available here. However, public comment on the guidance has since closed (as of June 24th, 2013).