ASTM Brief / Proposed Revisions to the ASTM

E 2600-08 Vapor Intrusion Standard

by Anthony J. Buonicore
Vapor intrusion into structures on a property can poten-
tially create significant liability for property owners and
prospective purchasers and have a material impact on
property value. As such, it is a growing concern in prop-
erty environmental due diligence associated with real
estate transactions (Buonicore and Crocker 2005; Buoni-
core 2007). On March 3, 2008, ASTM (2008) published E
2600-08, Standard Practice for Assessment of Vapor Intru-
sion into Structures on Property Involved in Real Estate
Transactions. Based on feedback from the marketplace
after almost nine months of use, a number of revisions have
been proposed to improve the standard.
Proposed Revisions to E 2600-08
Use of the standard in the field since its passage identi-
fied a number of revisions to improve the standard. These
revisions can be divided into three categories: technical,
legal, and clarification.
Technical
Two technical revisions have been proposed, both
involving Tier 1 methodology:
1. Differentiate in Tier 1 between what should be done
if ground water flow direction is not able to be esti-
mated (in the Phase I investigation) and when it can be
estimated.
2. Eliminate the secondary area of concern (AOC) in Tier
1. Field experience to date has shown it not to be neces-
sary and that it can waste considerable time and money
investigating sites a considerable distance from the tar-
get property (TP) that are highly unlikely to result in
a vapor intrusion problem.
Legal
Four revisions have been proposed by the legal com-
munity. These include:
1. Redefine that a potential vapor intrusion condition
(pVIC) identifies only the potential for vapors to reach
the subsurface of the TP, which does not without further
investigation necessarily result in an indoor air quality
problem (i.e., a vapor intrusion condition, or VIC). To
evaluate whether or not a VIC exists is the purpose of
the Tier 3 investigation, and for that the standard directs
the user to applicable federal or state guidance, policy,
or regulation.
2. Indoor air quality assessment is a nonscope consider-
ation in E 1527. A Phase I under E 1527 would not
include an assessment of whether vapors potentially
reaching the TPs subsurface could migrate into a struc-
ture on the TP and cause an indoor air quality problem,
i.e., create a VIC. Such a determination would require
a VIC assessment (as identified in Tier 3).
3. A pVIC should not automatically result in a recognized
environmental condition (REC) on the TP. Any such
determination is the responsibility of the environmental
professional.
4. Rather than presuming that a pVIC exists if it cannot be
ruled out by screening, E 2600-08 should be revised to
state instead that the screening cannot rule out the pos-
sibility of a pVIC, but further investigation would be
necessary.
Clarification
Six revisions have been proposed for clarification
purposes.
1. Clarify that the prescriptive part of the standard, Tiers 1
and 2, constitute vapor intrusion (VI) screening, which
is only a part of the VI assessment process associated
with a real estate transaction. E 2600-08 should clearly
differentiate between VI screening and VI assessment.
The E 2600-08 standard is effectively a VI screening
standard for real estate transactions to eliminate sites
where VI is unlikely. If a site cannot be screened out, it
means that additional information and investigation may
be necessary to assess the issue (much the same as
a Phase II might be conducted to investigate a REC
identified in a Phase I).
2. Reword what specifically is required under Tier 1 and
Tier 2 so that it is easier to understand.
Copyright 2009 The Author(s)
Journal compilation2009 National Ground Water Association.
58 Ground Water Monitoring & Remediation 29, no. 1/ Winter 2009/pages 5859 NGWA.org
3. In Tier 1 clarify that the source is the property where
the contamination originated. There has been confusion
in the field associated with contaminated groundwater
or soil being viewed as the source since the vapors are
actually off-gassed from these media. The standard
should distinguish between a primary source (e.g., a dry-
cleaner) and a secondary source (e.g., contaminated
groundwater).
4. The standard includes a flow chart of the vapor intrusion
assessment process, but does not include a flow chart of
the Tier 1 and Tier 2 screening process, and it should.
5. Clarify that there must be evidence of contamination
above regulatory acceptable levels at a source property
in the AOC for it to be considered in the screening.
Such evidence can be either direct or indirect (such as
where experience has shown a high probability for con-
tamination, e.g., a drycleaners).
6. Clarify that if there are preferential pathways (natural or
man-made), Tier 2 invasive sampling may be required
to assess if a pVIC exists.
These revisions will be balloted in February and March
2009 and discussed at the April 2009 Task Group meeting.
There will be another ballot in summer 2009. It is antici-
pated that the revised standard should be approved by the
Task Group at its October 2009 meeting and published by
ASTM at the end of the year.
References
ASTM. 2008. ASTM Standard Practice E 2600-08 for Assess-
ment of Vapor Intrusion into Structures on Property Involved
in Real Estate Transactions. West Conshohocken, Pennsylvania:
ASTM.
Buonicore, A.J. 2007. Development of a new ASTM standard for
assessment of vapor intrusion. Environmental Manager Febru-
ary: 1517.
Buonicore, A.J. and D.P. Crocker. 2005. Vapor intrusion and real
estate transactions: Uncovering a hidden threat. Environmental
Manager December: 3233.
Biographical sketches
Anthony Buonicore, PE, BCEE, QEP, is a consultant with Buo-
nicore Group. He chaired the ASTM Task Group responsible for
developing the vapor intrusion assessment standard. He can be
reached at Buonicore Group, Milton, CT;(800) 238-1841; ajb@
edrnet.com.
NGWA.org A.J. Buonicore/ Ground Water Monitoring & Remediation 29, no. 1: 5859 59