Questions submitted to EPAs Pat Seppi on September 12, 2014. I am waiting for a response and answers to these important questions. I just received EPA Newsletter and had one question that would help clarify exactly what you mean by this: Although the Vapor Intrusion Screening Levels have changed, there have been no changes to DuPont’s 2008 Vapor Interim Remedial Measures Work Plan that allows for a vapor mitigation system to be installed at any property located above shallow groundwater contamination associated with the DuPont Pompton Lakes Works site. What specifically is DuPont requesting? It is difficult to understand all these complex issues without access to the underlying documents. Thats why weve requested them. What specifically are the implications of the changes NJDEP already made to NJDEP screening levels with respect to the DuPont 2008 VIRM Work Plan? Is EPA obligated under RCRA to incorporate a non-delegated State agencys screening values in a federal RCRA Corrective Action permit? What is the regulatory basis for the current VI screening values EPA is relying on for the 2008 VIRM Work-plan? Where did those values come from? What is their scientific basis? Is EPA Region II aware of other EPA Regional VI screening values? Are there nationally applicable RCRA VI screening values in EPA national Guidance or regulations? Is EPA Region II making decisions on the basis of policy? What are the specific implications should EPA approve of DuPont request? We had assumed that the various DEP VI screening values were used to define the scope of the vapor mitigation area, i.e the geographic boundaries of the plume - and thereby the homes that would be tested for vapor issues. If any of those screening values change, are you saying that there is NO change to the delineation of the plume, the off-site release, the homes that are impacted, or any other sampling or analytical, notification, or remedial requirements? We also assumed that vapor mitigation systems were required, not allowed, subject to homeowner approval. We also assume that the scope of the plume defined DuPont regulatory obligations to remediate off site releases. We are aware of other vapor intrusion sites where EPA was more conservative and rejected NJDEP VI screening values based on a concern about false negatives. Specifically, at this site, NJDEPs screening values were not exceeded and suggested no additional soil gas, sub-slab, or indoor air testing was required. However, EPA rejected these findings and conducted indoor air sampling and installed a vapor mitigation system, in this case in a school. #EPA #PomptonLakes #VaporIntrusion #toxic #DuPont #environment #environmentaljustice #environmentalimpact #publichealth #citizensrights #NewJersey #NorthJersey #PassaicCounty #NJDEP
Posted on: Mon, 22 Sep 2014 15:27:59 +0000
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