evaluating the vapor intrusion pathway

Also in this issue:

Risk Communication How-To

New for 2011—Asian Connections:Highlights from the Better Air Quality Conference

Plus: Spotlight on A&WMA’s Brazil Section

FEBRUARY 2011

Evaluating the Vapor Intrusion PathwayIncorporating science and best practices into guidance

Copyright 2011 Air & Waste Management Association

Orl

ando

201

1

Beyond A

ll Bo

rde

rs

A&WMA’S 104TH

ANNUAL CONFERENCE & EXHIBITIONJUNE 21-24, 2011 • DISNEY’S CORONADO SPRINGS RESORT & CONVENTION CENTER • ORLANDO, FLORIDA

Sponsorships and exhibit space are now available! Call Malissa at 1-412-232-3444

Resolve now to tend to your environmental career in 2011.

The Air & Waste Management Association makes it easy with its 104th Annual Conference & Exhibitionin Orlando, June 21-24.

Look inside the latest technical developments in air quality, resource conservation, and environmentalmanagement. Gain perspective on the Gulf Oil Spill from those living with its legacy and mull potentialsolutions to our “upgrade” addiction with a critical review on e-waste management. And visit the exhibithall for the latest tools of the trade.

Don’t forget networking, professional development courses, tech tours, and Florida sunshine.

www.awma.org/ace2011

awma.org february 2011 em 1Copyright 2011 Air & Waste Management Association

Printed on Recycled Paper

COLUMNSInside the Industry: Vapor Intrusion Seeps Into Indoor Air Nationwide…and Into the Minds of Regulators, Attorneys, and the PublicAre You Prepared?. . . . . . . . . . . 30by Dianne Crocker

YP Perspective: How I Became anEnvironmental Scientist . . . . . . . 33by Alison Hendricks

IT Insight: IT Trends and Predictions for 2011. . . . . . . . . . 34by Jill Barson Gilbert

NEW for 2011A new quarterly column sponsored by A&WMA’s International Affairs CommitteeAsian Connections: Highlights from the Better AirQuality Conference Asia’s Largest Air Quality Management Event . . . . . . . . . . 36by Sophie Punte and Ritchie Anne Guzman-Roňo, CAI-Asia

ASSOCIATION NEWSMessage from the President . . . . 2Setting (and Achieving) Our Goals for 2011by Jeff Muffat

Spotlight on A&WMA’s Brazil SectionSpecial Place, Special People . . . 38by Rick Sprott, Jeff Muffat, and MiltonNorio Sogabe

In Memoriam . . . . . . . . . . . . . . . 41Garry Wayne Brooks

Warm Up with Hot News about A&WMA’s 104th Annual Conference . . . . . . . . . . . 42

Member Minute . . . . . . . . . . . . . 48Mingming Lu

DEPARTMENTSWashington Report . . . . . . . . . . . . . . 45

Canadian Report . . . . . . . . . . . . . . . . 46

Calendar of Events . . . . . . . . . . . . . . 47

JA&WMA Table of Contents. . . . . . . 47

EM, a publication of the Air & Waste Management Association (ISSN 1088-9981), is published monthly with editorial and executive offices at One Gateway Center, 3rd Floor, 420 Fort Duquesne Blvd., Pittsburgh, PA 15222-1435. ©2011 Air & Waste Management Association. All rights reserved. Materials may not be reproduced, redistributed, or translated in any form without prior written permission of the Editor. Periodicals postage paid at Pittsburgh and at an additional mailing office. Postmaster: Send address changes to EM, Air & Waste Management Association, OneGateway Center, 3rd Floor, 420 Fort Duquesne Blvd., Pittsburgh, PA 15222-1435. GST registration number: 135238921. Subscription rates are $280/year for nonprofit libraries and nonprofit institutions and $425/year for all other institutions. Additional postage charges may apply. Pleasecontact A&WMA Member Services for current rates (1-800-270-3444). Send change of address with recent address label (6 weeks advance notice) and claims for missing issues to the Membership Department. Claims for missing issues can be honored only up to three months for domes-tic addresses, six months for foreign addresses. Duplicate copies will not be sent to replace ones undelivered through failure of the member/subscriber to notify A&WMA of change of address. A&WMA assumes no responsibility for statements and opinions advanced by contributors to thispublication. Views expressed in editorials are those of the author and do not necessarily represent an official position of the Association.

NEXT MONTH:

Emerging Issues in Waste Management

Evaluating the Vapor Intrusion Pathway: Incorporating Science and Best Practices into Guidanceby Gina M. Plantz , Haley & Aldrich Inc.

Over the past decade, vapor intrusion (VI) has gained significant attention from the regulatory, scientific, and legal communities because ofconcerns for potential exposure to chemicals in the indoor air attributed to subsurface contamination. The regulatory landscape for VI continuesto change in response to the changing science. However, the unfortunate truth is that the recommended approaches to addressing VI arestill fragmented into many different state and federal-led programs. The articles in this issue of EM address some of the key regulatory andpolicy issues of current interest. They should serve to both educate and stimulate further debate.

Vapor Encroachment Screening Under the Newly-Revised ASTM E 2600-10 Standardby Anthony J. Buonicore, The Buonicore GroupPage 4

Proposed Regulatory Framework for Evaluating the Methane Hazard due to Vapor Intrusionby Bart M. Eklund, URS Corp.Page 10

Evaluation of EPA’s Empirical Attenuation Factor Databaseby Stephen Song, Francis C. Ramacciotti, Barry A. Schnorr, Michael J. Bock, and Christopher M. Stubbs, EnvironPage 16

A General (Evidence-Based) Framework for Assessing the Vapor Intrusion Pathwayby Henry J. Schuver, U.S. Environmental Protection Agency; and William E. Wertz, formerly of the New York State Department of Environmental ConservationPage 22

How-ToRisk Communication: Issues and Challengesby Steve Gibb, The Scientific Consulting Group Inc.Unique challenges are associated with communicating risk to different audiences, even for those with experience and comfort in publicspeaking. This article outlines a number of tips for communicating risk effectively and highlights how to deal with the fact that peoplebring their own agendas to risk communication and tend to personalize risk information.Page 26

10

22 26

4

16

3

awma.org

In last month’s message, I offered you my visionfor the Association in 2011. In summary, my visionwas to:• streamline and flatten operations to improve the

Association’s productivity;• focus staff resources on member services;• provide tools for self-directed member record

keeping;• enhance member-led forums and discussion

groups;• allow members to use social networking tools to

enhance membership value; and• offer Section & Chapter support for event plan-

ning and registration.

This month, I would like to share with you my fourmain goals for the Association in 2011 and provideyou with a glimpse of how I see each goal tying intomy vision, including a couple of examples of howwe are already starting to meet these goals.

Goal 1 – Grow the Association. Increase mem-bership on a global scale. As I think you will agreeafter reading this message, all of my other goalswill help us achieve this first goal. One only needsto take a look at the article on page 38 to see thatthis growth is already happening. A&WMA’s Brazil-ian Section added 12 new members to its ranksat the Section’s December meeting. This hap-pened in the wake of a very successful first-of-its-kind international seminar on market regulation forair emissions in November organized by the Brazil-ian Section. (Vision: Member-led forums and dis-cussion groups.)

Goal 2 – Maintain a Strong Financial Position.Continue to ensure that the fiscally responsiblepolicies, procedures, and oversight put in place in2010 are adhered to throughout 2011, becausewithout a strong financial position, the Associationcannot be effective and cannot meet its objectivesand goals. To help achieve this, I have appointed aseasoned Finance Committee that will be workingclosely with A&WMA Staff and Executive Director,Mike Kelly, to ensure financial stability in 2011.

ADVERTISINGMalissa [email protected]

EDITORIAL Lisa BucherManaging [email protected]

EDITORIAL ADVISORY COMMITTEEDan L. Mueller, P.E., ChairMueller Consulting GroupMingming Lu, Vice ChairUniversity of Cincinnati

John D. BachmannVision Air ConsultingJane C. BartonPatterson ConsultantsPrakash Doraiswamy, Ph.D.State University of New York at AlbanyJennifer B. Dunn, Ph.D.URS Corp.Steven P. Frysinger, Ph.D.James Madison UniversityChristian HogrefeNew York State Department of

Environmental ConservationJohn D. KinsmanEdison Electric InstituteAshok KumarUniversity of ToledoMiriam Lev-On, Ph.D.The LEVON GroupJulian A Levy, Jr.Independent ConsultantCharles E. McDadeUniversity of California at DavisAnn McIver, QEPCitizens Energy GroupPaul J. MillerNortheast States for Coordinated Air

Use ManagementChris Pepper Jackson WalkerS.T. RaoU.S. Environmental Protection AgencySusan S.G. WiermanMid-Atlantic Regional Air

Management AssociationJames J. Winebrake, Ph.D.Rochester Institute of Technology

PUBLICATIONS COMMITTEEJudith C. Chow, ChairDesert Research Institute

A&WMA HEADQUARTERSMike P. KellyExecutive Director

Air & Waste Management AssociationOne Gateway Center, 3rd Floor420 Fort Duquesne Blvd.Pittsburgh, PA 15222-14351-412-232-3444; 412-232-3450 (fax)[email protected]

Setting (and Achieving) Our Goals for 2011by Jeff [email protected]

Mike and several members of this committeebrought the Association “back in the black” in2010 after almost three years of being “in the red”and I believe that this year’s Finance Committee iswell positioned to further that goal. (Vision: Stream-lining and flattening operations for productivity andfocusing staff resources on member services.)

Goal 3 – Successfully Implement the New Assoc-iation Management System. To make sure thatstaff implements our new Association managementsystem on time to facilitate the electronic manage-ment of Association business and to provide betterand faster access to Association information for allmembers. This new system will also provide in-creased opportunities to network with other envi-ronmental professionals and is most certainly a“value added” part of Association membership.Staff has a very aggressive schedule to have all ofthe aspects of the implementation plan in place byJune 1, 2011, so that we can all start benefitingfrom this major endeavor in the second half of theyear. (Vision: Personalized and self-directed memberrecord keeping, Section & Chapter support for eventplanning and registration, and membership value.)

Goal 4 – Strengthen Our Relationships withPartnering Organizations. Increase our partner-ships with state, federal, and international agencies,as well as with academia, nongovernmental, andother environmental organizations. We need tostrengthen our ties to all of these stakeholders because through collective leadership we canmake significant improvements for all peoplethroughout the world, which is, I believe, the charterof the Air & Waste Management Association. (Vision: Section & Chapter support for event plan-ning, registration, and member services.)

Again, I want to express how honored I am to beyour President. Please contact me if you have anyquestions or suggestions as to how we can helpthis Association achieve its full potential.

emawma.org

em • message from the president

2 em february 2011Copyright 2011 Air & Waste Management Association

awma.org february 2011 em 3

Numerous guidance documents have been devel-oped to assist site investigators in assessing whetheror not the pathway poses a significant health risk topotentially-exposed individuals in both residentialand commercial settings. The development of updated toxicity information for VOCs such as fortrichloroethylene (TCE) and tetrachloroethylene(PCE) is among the factors in recent years that havecomplicated the evaluation of VI. In addition, theU.S. Environmental Protection Agency’s (EPA) recentobservations and experiences have indicated thatthere may be greater complexity in the processesand variables that affect the migration and distri-bution of VOCs than was originally contemplatedwhen EPA issued the 2002 Draft Vapor IntrusionGuidance. The regulatory landscape for VI contin-ues to change in response to the changing science.

The unfortunate truth is that the recommended approaches to addressing VI are still fragmentedinto many different state and federal-led programs.While there are some underlying similarities, thesetend to be overshadowed by differences in the spe-cific requirements from one regulatory jurisdictionto another. This may be particularly confusing topotentially responsible parties who are working toaddress VI within multiple states and also to stake-holders who may look to the guidance of otherareas when trying to gain an understanding of acomplex pathway.

One area that can vary drastically among regula-tory programs is the decision as to when and howto sample indoor air. Rather than follow tiered,step-wise investigation approaches, some state regulatory guidance programs drive the need tocollect indoor air samples during the initial stageof the VI pathway evaluation. Some regulatoryagencies reference the use of data from the pastradon studies to suggest that indoor air and long-term sample collection intervals (greater than 24

hours) would be more repre-sentative to assess the VIpathway. However, one sig-nificant difference betweenradon and common VOCsof concern for the VI pathwayis that there are generally no confounding backgroundsources of radon; what ismeasured in the indoor air iscoming from the subsurface.Somehow this crucial factorhas been lost during discus-sions of lessons learned fromthe radon industry and howthey can be applied to as-sessment of the VI pathway.When evaluating the VIpathway, the potential andcommon overlap of site con-taminants from subsurfacesources and personal, indoor, and ambient sourcesrequires careful consideration. Multiple lines of evidence should be considered to be able to understand the site characteristics and to supportthe VI pathway evaluation.

New technical approaches for evaluating the VIpathway are still evolving and the scientific commu-nity continues to learn from shared case studies. Weare making progress and the experiences have ledto an improved understanding and approaches forassessing and managing VI. The articles in this issueof EM address some of the key regulatory and policy issues of current interest. They should serve toboth educate and stimulate further debate. em

Gina M. PlantzHaley & Aldrich [email protected]

em • cover story

Evaluating the Vapor Intrusion Pathway: Incorporating Science and Best Practices into Guidance Over the past decade, vapor intrusion (VI) has gained significant attention fromthe regulatory, scientific, and legal communities because of concerns for potentialexposure to volatile organic chemicals (VOCs) in the indoor air attributed to subsurface contamination.

The regulatorylandscape for VI continues tochange in response to the changing science.


4 em february 2011 awma.orgCopyright 2011 Air & Waste Management Association

awma.org

em • feature

by Anthony Buonicore

Anthony J. Buonicore,P.E., DEE, QEP, is chief executive officer of TheBuonicore Group, and Chairof the ASTM Vapor Intru-sion Task Group. E-mail:[email protected].

Vapor migration and intrusion into structures on a property can potentially create significant liability and have a material impact on property value. As such,it is a growing concern for property owners, prospective purchasers of property,and environmental professionals conducting due diligence.1,2 To respond to thisindustry concern, in June 2010 ASTM published E 2600-10, Standard Guide forVapor Encroachment Screening on Property Involved in Real Estate Transactions.3

Vapor Encroachment Screening Under theNewly-Revised ASTM E 2600-10 Standard

Rationale for Revising the StandardThe original ASTM E 2600-08 standard was pub-lished in March 2008. After more than a year inthe marketplace, it became clear that the standardcreated a considerable amount of confusion. Forexample, there was confusion over whether thestandard was a vapor intrusion assessment stan-dard or a vapor intrusion screening standard. Therewas confusion over the standard’s relationship withthe ASTM E 1527 Phase I environmental site assessment4 standard. There was confusion as towhy, if there was insufficient data to rule out a potential vapor intrusion condition, it was presumedto exist.

The standard also found considerable resistance inthe legal community, where it was believed thestandard may have overstepped its bounds anddrew legal conclusions in direct contradiction toComprehensive Environmental Response, Com-pensation, and Liability Act (CERCLA) and the U.S. Environmental Protection Agency’s (EPA) All Appropriate Inquiries (AAI) regulation. Unfortu-nately, this confusion in the marketplace had a detri-mental impact on the standard’s adoptability andnecessitated revisions be made.

RevisionsTo resolve the confusion, substantial revisions weremade and balloted in March and April 2010. Theresult was a revised standard, E 2600-10, publishedby ASTM in June 2010.3 The revised standard isrefocused solely on screening for the likelihood ofvolatile vapors to encroach upon or otherwisereach the subsurface of a property involved in a

real estate transaction (thereby, creating a VaporEncroachment Condition or VEC). The title of the standard was also changed to better reflect thisapproach.

In addition, the revised standard was issued as astandard guide, rather than a standard practice, togive the environmental professional conducting thevapor migration screening greater latitude, partic-ularly in view of the considerable uncertainty thatstill exists in vapor migration assessment. This“guidance” approach has been used by EPA, theU.S. Department of Defense, and virtually all gov-ernment agencies that have addressed vapor intrusion. The presumption that “a VEC exists ifthere is insufficient data to rule it out” no longer exists. Finally, a new legal appendix was includedto clarify the relationship with the ASTM E 1527-05 Phase I standard, CERCLA, and AAI.

Experience to date suggests the newly revised standard has eliminated much of the confusion andresulted in its adoption much more readily by government agencies, lenders, and prospectivepurchasers of real estate.

Tier 1 Screening Under E-2600-10The only significant difference between Tier 1screening in the revised standard as compared tothe methodology in the previous E 2600-08 stan-dard is that the secondary area of concern (AOC)was eliminated in E 2600-10. This was done because experience had demonstrated that including the secondary AOC wasted time andmoney investigating contaminated sites much too


awma.org

Vapor migration onto aproperty involved in areal estate transactionneeds to be evaluated in a Phase I investigation,no different than groundwater migration.


far from the target property and which were un-likely to impact it from a vapor migration/intrusionviewpoint.

The information required for Tier 1 screening in E 2600-10 is essentially the same information collected as part of an ASTM E 1527-05 Phase I.The first check in the screening process is a searchdistance test to identify if there are any known orsuspect contaminated sites with volatile or semi-volatile hazardous substances or petroleum prod-ucts, referred to as chemicals of concern (COC),within the AOC. If there are none, no further actionis required.

Search distances are different for sites contami-nated with [non-petroleum hydrocarbon] COC,such as chlorinated volatile organics, versus sitescontaminated with petroleum hydrocarbon COC.Search distances are shorter for the latter becausethey are known to undergo significant biodegra-dation in the presence of oxygen.

To identify the AOC for contaminated sites with[non-petroleum hydrocarbon] COC, the search radius is 1,760 feet (1/3 mile) from the contaminatedsite to the boundary of the target property (TP). Forsites with petroleum hydrocarbon COC, the searchdistance is 528 feet (1/10 mile). The AOC searchdistances were determined based upon conserva-tive consideration of both contaminated plumelengths and the distances vapors volatilized fromcontaminated plumes might travel along a path ofleast resistance in relatively permeable soil from asource through the vadose zone directly to a TP. Ifgroundwater flow direction can be estimated, theAOC in the cross-gradient and down-gradient distances can be reduced significantly.

If a known (or suspect) contaminated site withCOC is located in the AOC, the environmentalprofessional may then apply judgment with respectto deciding whether or not this site represents aVEC. For example, if there is a hydraulic or physicalbarrier (such as a river) between the TP and thecontaminated site, the presence of such a barrierwould likely impede any migrating contaminantvapors. The environmental professional may alsonot be concerned about migrating vapors basedupon experience with local subsurface geology andsoil characteristics.

The possible existence of significant man-made ornatural preferential vapor pathways between thecontaminated site and the TP must also be evalu-ated. Natural preferential pathways may include,for example, fractured bedrock or karst terrain.Man-made pathways may include, for example,major utility corridors or sewer lines. If such significantpreferential pathways do exist, then proceeding directly to invasive sampling (e.g., soil gas sampling)under Tier 2 may be necessary to determine if vapors have impacted the TP.

The location of the contaminated site relative to the TP is also important in the screening. If the contaminated site is located up-gradient of the TP,there is much greater concern than if it is locateddown-gradient or cross-gradient. To understandwhy, it is necessary to understand the definition of“critical distance” (CD) in the standard. Effectively,the critical distance is the upper distance a vapormay migrate through soil in the vadose zone assuming the path of least resistance is directlyfrom the nearest edge of the contaminated mediasuch as groundwater or soil to the nearest boundaryof the TP.

The standard specifies a CD for both [non-petroleum hydrocarbon] COC and petroleum hydrocarbon COC. For [non-petroleum hydrocar-bon] COC, the CD is 100 feet. For petroleum hydrocarbon COC, CDs are specified for both lightnon-aqueous phase liquids (LNAPL; i.e., “free prod-uct” that can accumulate on the water table) and dissolved petroleum hydrocarbon situations. TheCD for dissolved petroleum hydrocarbon COC is30 feet. The CD for petroleum hydrocarbon COCvapors from LNAPL is the same as for [non-petroleum hydrocarbon] COC (i.e., 100 feet).

If a contaminated site is located down-gradientfrom the TP, it generally can be eliminated fromconcern if it is beyond the CD. If the contaminatedsite is cross-gradient, it generally can be eliminatedfrom concern if it is beyond the CD plus an additionaldistance that can approximately account for thewidth of the plume. A conservative methodologyfor estimating plume width for use in this standardhas been presented.5,6

The conclusion from Tier 1 screening is that a VECexists, is likely to exist or cannot be ruled out, or


that it can be ruled out because it does not exist oris unlikely to exist. If a VEC exists, is likely to exist,or cannot be ruled out, the client and the environ-mental professional must decide if further investi-gation, such as proceeding to Tier 2, is warranted.A user may, for example, decide alternatively toproceed preemptively to mitigation.

Tier 2 Screening Under E 2600-10The only significant difference between Tier 2screening in the revised standard as compared tothe methodology in the previous E 2600-08 stan-dard is that the risk-based concentration test waseliminated. In this test, the concentration of theCOC in the contaminated media (e.g., groundwater)is compared to the state (or federal) risk screeninglevels (RSLs) developed for this media. The risk-based concentration test was not included in Tier 2of E 2600-10 because this test goes beyondscreening (which is the sole purpose of the revisedstandard) and is better associated with an actualvapor intrusion assessment investigation.

Tier 2 screening under E 2600-10 consists of eithera noninvasive or an invasive investigation, depending

upon the availability of contaminated plume dataassociated with the contaminated site creating theVEC identified in Tier 1. If contaminated plumedata is available in state regulatory files or else-where that can provide insight into the extent ofcontamination associated with a contaminatedproperty, the extent of plume migration, plumecharacteristics, and the status of any remediation,then the noninvasive screening methodology involves assessing whether the contaminatedplume edge nearest the boundary of the TP iswithin or outside the CD.

If no information on the contaminated plume andits characteristics is available (or if there are prefer-ential vapor pathways), then it may be appropriateto evaluate whether or not invasive sampling (e.g.,soil gas and/or groundwater sampling) at the TPboundary would be a viable option. If sampling isconducted, the results may be used to determineif a VEC exists or that it can be ruled out becauseit does not or is unlikely to exist.

If a VEC exists or is likely to exist or cannot beruled out after the Tier 1 and Tier 2 screening, the

Changes are coming to NAAQS, NSR, PM2.5, and Ozone regulations. NewGreenhouse Gas Tailoring rules are about to kick in. Pretty soon, you’ll be needing a lot of new information.

The Air & Waste Management Association has you coveredwith a series of workshops focused on what you need to know,not just about permitting changes, but about their local and regional impacts.

The “Understanding Today’s Clean Air Act Permit Programs” 2011 Workshop Series

View draft agenda and register now!March 1-2, 2011, InterContinental New Orleans Hotel, New Orleans, LA

Mark your calendar, more information coming soon!April 13-14, 2011, Houston, TXMay 4-5, 2011, Denver, CO

Researching and studying so many changes at once would be a full time job. That’s why we’re doing it for you. www.awma.org/events

CATRGreenhouse Gas

Tailoring

8 hr. OzoneStandard

TitleV

PM2.5

NSR

Everything you know about Clean Air Act permitting is about to change.

Don’t worry. We’ll point you in the right direction.


client and environmental professional must decideon what further investigation, if any, is appropriate.Such further investigation is beyond the scope of E2600-10. Consultants may, for example, recom-mend proceeding to a vapor intrusion assessmentinvestigation following the state’s vapor intrusionguidance document or policy, assuming one exists,or recommend proceeding preemptively to miti-gation, which may be more cost effective. Alter-nately, the client may decide to proceed no furtherwith the deal.

Relationship Between E 1527-05and E 2600-10The Legal Appendix of E 2600-10 clarified thatvapor migration onto a property involved in a realestate transaction needs to be evaluated in a PhaseI investigation, no different than groundwater migration. Tier 1 screening in the E 2600-10 stan-dard provides an industry consensus methodologythat can accomplish this. If vapor migration screen-ing using E 2600-10 is conducted in conjunctionwith an E 1527-05 Phase I and a VEC is found toexist or is likely, then the environmental professionalwill also need to determine if the VEC represents arecognized environmental condition (REC).

VECs will not automatically result in a REC. For example, if the depth to contaminated groundwateror the distance between the edge of a contami-nated plume and the nearest structure on theproperty is greater than the critical distance, then itis possible the VEC might not be considered aREC. Also, if the concentration of the COC in thecontaminated plume is below the state RSL, it isunlikely the VEC would be considered a REC. Ifthe environmental professional determines theVEC is a REC, then it will be up to the client andthe consultant to determine what further investi-gation, if any, might be appropriate.

The rationale supporting the need to considervapor migration in a Phase I conducted accordingto E 1527-05 is included in the Legal Appendix.The rationale relied upon definitions included inboth CERCLA, AAI, and ASTM E 1527-05. InCERCLA, the definition of “release” includes theterms “emitting” and “escaping” into the “environ-ment”7 and the courts have included costs for

investigation and remediation of hazardous substance vapors as potentially recoverable response costs. Moreover, in its 2002 draft vaporintrusion guidance document,8 EPA indicated it wasdeveloped for use at CERCLA, RCRA correctiveaction, and brownfield sites.

In the AAI rule,9 the environmental professional is required to provide “an opinion as to whether theinquiry has identified conditions indicative of releasesor threatened releases of hazardous substances…on, at, in, or to the subject property.” The rule further states that the ASTM E 1527-05 standardmeets the requirements of an AAI investigation.

The ASTM E 1527-05 standard,4 which is drivenby CERCLA, defines a REC as the “presence orlikely presence of any hazardous substances or petroleum products on a property under conditionsthat indicate an existing release, a past release or amaterial threat of a release…into the ground,groundwater or surface water of the property.”

Stakeholder Concerns AddressedThe E 2600-10 standard resolves a number of con-cerns raised by current and prospective propertyowners. These include

1. The standard establishes a prescriptive screen-ing methodology for use in conjunction withASTM E 1527-05 that may be used to evaluatevapor migration.

2. Vapor encroachment screening can avoid potential future investigation expenses that maybe required after a property is acquired shouldstate regulators become concerned in the futureabout potential vapor intrusion issues.

3. Property owners/operators/managers may beable to provide a safer working environment foremployees/tenants by screening for vapors thatmay encroach upon a property being consid-ered for acquisition.

4. Future liability, including potential toxic tort litigation, arising from tenant or other third-partyvapor intrusion suits, can potentially be avoidedby screening for vapors that may encroach upona property being considered for acquisition.

5. Property stigma, with consequent property devaluation, due to vapor migration/intrusion

The newly revised standardhas eliminatedmuch of the confusion.


may be avoided by screening for vapors thatmay encroach upon a property being consid-ered for acquisition.

The standard resolves a number of environmentalconsultant concerns. These include

1. The standard establishes a screening methodol-ogy for use in conjunction with ASTM E 1527-05that may be used to evaluate vapor migrationand assist in making a REC determination.

2. Litigation related to vapor migration/intrusionmay be avoided by screening in the Phase I forvapors that may encroach upon a property andpotentially cause a vapor intrusion problem.

The standard resolves a number of attorney con-cerns. These include

1. The standard establishes a screening methodol-ogy for use in conjunction with an ASTM E1527-05 Phase I that may be used to evaluatevapor migration.

2. For the Phase I to comply with EPA’s AAI regu-lation and maintain all available defenses toCERCLA liability, the Phase I must considervapor migration, analogous to groundwater migration, consistent with the REC definition inE 1527-05.

The standard resolves a number of lender concerns.These include

1. An adverse impact on the property used as col-lateral and its value can be avoided by requiringscreening for vapor migration when propertydue diligence is conducted.

2. A potential negative impact [of unexpectedvapor intrusion investigation costs] on the bor-rower’s creditworthiness and ability to repay the

loan can be avoided by including screening forvapor migration in property due diligence priorto deal closing.

3. Potential foreclosure complications to deal witha vapor migration/intrusion problem can beavoided by screening for vapor migration inproperty due diligence prior to deal closing.

Finally, the standard resolves a number of insurancecompany concerns. These include

1. Proactive VEC screening by the insurance industry may avoid reopener policy claims atclosed (no further action) sites reopened by regulatory agencies in the future to investigatepotential vapor intrusion problems.

2. Proactive VEC screening may result in fewerclaims related to vapor intrusion against propertypollution liability policies.

3. Proactive VEC screening may result in fewer errors and omissions (E&O) claims against policies held by environmental consultants formissing a vapor intrusion problem.

4. Proactive VEC screening may result in avoidanceof toxic tort litigation related to vapor intrusion.

Implications for Environmental ProfessionalsEnvironmental professionals conducting a Phase Itoday must consider vapor migration in their investigation, analogous to groundwater migration.The only choice that exists is the methodologyused to evaluate vapor migration. Should their ownmethodology be used or should the industry consensus methodology identified in E 2600-10be used? From a liability viewpoint, it is expectedthat most environmental professionals will rely onASTM E 2600-10. em

References1. Buonicore, A.J.; Crocker, D.P. Vapor Intrusion and Real Estate Transactions: Uncovering a Hidden Threat; EM December 2005, pp. 32-33.2. Buonicore, A.J. Development of a New ASTM Standard for Assessment of Vapor Intrusion, EM February 2007, pp. 15-17.3. ASTM E 2600-10, Standard Guide for Vapor Encroachment Screening on Property Involved in Real Estate Transactions; ASTM: West Conshohocken,

PA, 2010.4. ASTM Standard Practice E 1527-05 for Environmental Site Assessments: Phase I Environmental Site Assessment Process; ASTM: West Conshohocken,

PA, 2005.5. Buonicore, A.J. Screening for Potential Vapor Intrusion Problems under the Proposed Revisions to the ASTM E 2600 Standard. In Proceedings of

the A&WMA Annual Conference & Exhibition, Detroit, MI, 2009, June 16-19; Paper No. 129.6. Buonicore, A.J. A Smaller Intrusion; Pollution Engineering, May 2009, pp. 26-31.7. 42 USC 9601 § (22).8. Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils; EPA530-D-02-004; U.S Environmental

Protection Agency, November 2002.9. 40 CFR 312.11 (C)(I).


em • feature

by Bart Eklund

Bart M. Eklund is principalscientist with URS Corp.,Austin, TX. E-mail: [email protected].

Methane is often found at percent levels in soil gas and it has become a chemicalof concern at some vapor intrusion (VI) sites. The evaluation of methane, however,differs fundamentally from the evaluation of volatile organic compounds (VOCs)and the regulatory framework for addressing methane is either nonexistent orinadequate in most cases.

Proposed Regulatory Frameworkfor Evaluating the Methane Hazard due to Vapor Intrusion

The following discussion addresses the differencesin conceptual site models for VI evaluations involv-ing methane versus those involving VOCs, thephysical properties of methane, the fate and trans-port of methane in soil, and existing regulations formethane. The key decision points for regulating VIof methane are listed and a framework for evalu-ating methane hazard is proposed.

Methane is often present in the unsaturated zone,especially in wet, organic soils and the probability

of detecting methane tends to increase with increasing depth below ground surface.This is because biogenic methane may beproduced in the subsurface via anaerobic biological processes.

Even “clean” fill soil can generate methane if it hassome organic fraction and is wet and devoid ofoxygen. The biogas produced by microbes in thesubsurface consists of roughly 50% methane and50% carbon dioxide. Any bubble of biogas or soilgas readings taken near the location where biogasis produced may contain relatively high concentra-tions of methane.

The explosive range for methane at 1 atm of pressure is 5–15%. The lower explosive limit (LEL)of 5% is higher than, for example, gasoline or theBTEX compounds. Soil acts as a natural flame arrestor, so methane in a typical soil matrix cannotexplode. So, there is no LEL for soil gas (methanein a large void in the soil is a different scenario).The soil gas, however, can lead to a hazard if a sufficient volume of gas migrates into enclosed orpoorly ventilated spaces where ignition sources are present.

Conceptual ModelPotential VI of methane is fundamentally differentthan potential VI of VOCs for several reasons, assummarized in Table 1.

For VOC releases, we start with a given mass ofVOCs in the subsurface and this tends to slowlydecrease over time due to degradation, volatiliza-tion, and other processes. For methane, however,gas production can start whenever conditions areconducive.

In VI studies, it is common practice to use concen-tration data and compare indoor concentrations tooutdoor concentrations, indoor concentrations tosoil gas concentrations, and so forth, and draw Conceptual model of a methane molecule.


conclusions based on these comparisons. In suchcomparisons, it is important to recognize that concentration is used as a surrogate, or proxy, forwhat is truly important, which is mass flow. For gastransport, mass flow is concentration multiplied bygas flow rate. We usually focus on concentrationbecause flow rate is difficult to measure and we canmake conservative assumptions about flow rate(e.g., vapor intrusion is 5 L/min into a residential-sized building, building ventilation is about 0.5 airchanges per hour, etc.).

For VOCs, the concentration present in soil gas isdirectly related to the potential risk. In general, thehigher the VOC concentration in soil gas, thegreater the potential for indoor air impacts due toVI. For methane, this is not the case. Even smallrates of methanogenesis will result in soil gas con-centrations approaching 50% at the point of gen-eration. There is essentially no correlation betweenmethane gas production rates and methane concentrations in soil gas at the point of generation.

With VOCs, the focus is almost always on chronicexposure and, therefore, VI evaluations addresslong-term average concentrations. For methane,we’re concerned about the worst-case short-termconditions.

Investigations of past methane explosions invari-ably show that pressure-driven (advective) flow occurred. If a utility line or pipeline has a break,large volumes of gas under high pressure can bereleased and move through the soil. Similarly, thelarge gas generation that occurs at municipal solid-waste (MSW) landfills can result in pressure-drivenflow into overlying or nearby buildings. In somecases, methane in soil gas can be induced to moveby pressure gradients resulting from barometricpressure changes or infiltrating water.

Fate and TransportMethane can be generated in soils (via microbescalled methanogens) and also can be consumed insoils (via microbes called methanotrophs). All soilstend to be either net sources or sinks of methane.Within a given soil column, methane may be pro-duced at depth where the soils are anaerobic and anyvapors migrating upwards may be consumed withinshallower soil layers where the soils are aerobic.

Methane production may begin in an area if the

conditions are conducive. Subsurface conditionsmay change over time and methanogenesis maybegin without a recent leak or spill. The generallyaccepted mechanisms for degradation of petroleumhydrocarbons in groundwater start with aerobicdegradation. Once the available oxygen is gone,other process such as denitrification, iron reduction,and sulfate reduction may occur. Only after thesepathways have been exhausted will methanogen-esis (i.e., biogas production) begin. Methanogenesisis not a favored pathway. A site may have relativelywidespread dissolved non-aqueous phase liquid(NAPL), for example, but only isolated pockets ofmethane. This may be due, in part, to the specificmicro-environments present across the site.

A huge amount of literature is available where theemission flux of methane has been measured fromvarious types of soils or other sources. Based onprevious literature searches, the emission fluxes ofmethane from various sources can be approxi-mated as shown in Table 2. The highest reportedmethane flux was 14,000,000 μg/m2-sec from acrack at a landfill surface that allowed for preferentialmigration of landfill gas.1

Removal mechanisms for methane in soil gas alsocan be an important process. Surface soils tend tobe capable of destroying large amounts of methanevia aerobic degradation. Oxidation rates up toabout 1 L per minute per square meter are possible(40 g/m2-hr). This is far higher than rates of diffu-sion through soil columns, so methane generallywill be 100% removed if there is an aerobic soillayer beneath a building.

Table 1. Comparison of VOCs and methane for vapor intrusion.

VOCs Methane

Given starting mass No given starting mass

Mass flux is related to concentration Concentration in soil gas is not a goodin soil gas proxy for mass flux

Focus on long-term average Focus on short-term maximumconcentrations concentrations

Typical attenuation factors are Attenuation factor must be >0.05~10-3 or lower to reach 5% indoors

Transport via diffusion with advection Transport via advection is the important near buildings main concern

Soil gas levels for some VOCs Soil gas levels for methane inverselyinversely proportional to oxygen levels proportional to oxygen levels


RegulationsIn general, methane in soil gas is not regulated inthe United States, but there are federal regulationsfor certain specific types of sites. For MSW landfills,there is a requirement that methane must not exceed 25% of the LEL (i.e., 1.25% methane in indoor air) within buildings or other facility struc-tures and not exceed the LEL in soil gas at theproperty boundary.2

For tunnels and other underground construction,the Occupational Safety and Health Administration(OSHA) defines a potentially gassy operation asone where there is 10% or more of the LEL (i.e.,0.5% methane) measured 12 inches from the roof,face, floor, or walls for more than a 24-hr period.3

The operation is considered to be gassy if >10% ofthe LEL is measured for three consecutive days.

Local fire codes or building safety plans often includesomething similar to the U.S. Environmental Protec-tion Agency (EPA) MSW action level (e.g., 20% or25% of the LEL) as an action level for indoor air totrigger evacuation.

There are some existing regulations or guidancedocuments put forth in recent years for methane insoil gas in California. Portions of southern Californiahave underlying thermogenic (fossil) methane. Thismethane originates deep in the earth and can moveunder pressure to the surface. Action levels from var-ious California regulations or guidance have recentlybeen summarized.4 The existing methane guidance,as with VI guidance in general, is evolving and ex-isting guidance is often contradictory and not alwaysbased on valid technical assumptions. In general, theCalifornia documents are considered to be overlyconservative and are not good templates for devel-oping a regulatory framework for methane.

Decision MatrixThere are three key parameters for evaluating hazards related to soil gas and these parametersshould be considered in conjunction with one another rather than independently:

1. Methane concentration in soil gas;2. Differential pressure; and3. Whether or not the soil gas is saturated with

methane or biogas.

Methane ConcentrationIf the soil gas concentration of methane is lowenough, no hazard exists. A de minimis level forscreening purposes is 1.25% (i.e., 12,500 parts permillion [ppm]). Any methane concentrations belowthis level are trivial in terms of hazard. There is noconcentration of methane in soil gas that is intrin-sically unsafe, but methane concentrations above40% in soil gas suggest that biogas production islocally significant and merits further investigation.The biogas produced by microbes is roughly one-half methane, so methane at high concentrationscan be found in soils, even clean fill, if conditionsare conducive for methanogenesis. For decision-making purposes, it is important to determine ifthere is significant methane generation over a rea-sonably large area.

Differential PressureDiffusion of soil gas is not expected to result in anunsafe indoor environment; pressure-driven flowis necessary to move the volumes of gas requiredto result in indoor air approaching the LEL formethane. Therefore, differential pressure (ΔP) is animportant variable to measure. If significant biogasproduction is underway, elevated pressures will beobserved. A screening value of 2 in. H2O has beenproposed.5 Pressures below this screening valueare considered to be negligible and pressuresabove this screening value require further consid-eration. If the pressure exceeds 2 in. H2O, methanesoil gas control measures should be implemented.This might involve engineering controls at buildingsof concern (e.g., venting systems) and/or source re-duction (e.g., provide alternative electron receptors).

Differential pressure for a given site will be a func-tion of the permeability of the soil. A given rate ofbiogas production will result in a lower differentialpressure in more permeable soils. For example, differential pressures within MSW landfills tend tobe <10 in. H2O even though the rate of biogas

Table 2. Typical emission fluxes for methane from various source types.

Emission Source Typical Emission Flux (μg CH4/m2-sec)

Wetlands 0.1

Lakes 0.5

Tundra, moors <3

Rice fields 6

Manure >15

MSW landfills <4,000


production is high, because the waste material ishighly permeable. The 2 in. H2O rule-of-thumb results in a rate of advective transport that is approximately 30 times higher than diffusive transport in soils with a permeability of 10-8 cm2

(e.g., sandy soils). This screening value may need tobe made more conservative for sites with soils thatare more permeable than 10-8 cm2.

Soil Gas SaturationIsolated “hot spots” of high methane concentrationin soil gas generally are not a concern, but wide-spread elevated concentrations suggest that biogasproduction is or has been significant. At methaneconcentrations of 40% and above, biogas likely isbeing generated at a sufficiently high rate to com-pletely displace other gases from the soil. Belowthis level, the gas production rate is likely to be toosmall to displace other gases from the soil porespaces. For added conservativeness, 30% can beused as a rule-of-thumb (rather than 40%).

If a large reservoir of methane exists in the soil gasnear a building, it may pose a potential hazardeven if there is no on-going gas production or elevated differential pressure. Under certain

circumstances, the methane can be induced tomove (e.g., extremely low barometric pressure,methane flashing out of formerly confined ground-water, etc.). Therefore, if the soil gas surrounding abuilding is largely “whole” or undiluted biogas (e.g.,if CH4 + CO2 are >90%), it would be prudent tomitigate even if the differential pressure was belowthe rule-of-thumb discussed above.

Decision-Making FrameworkA generic framework for decision-making that outlines the logic and thought process most oftenused in VI evaluations was developed and is presented in Table 3. The framework builds uponprior work by John Sepich and others. The deci-sion matrix is based on a combination of indoor air data and shallow soil gas data. These are twovery important lines of evidence, but are not the only lines of evidence that may need to be considered for a given building. So, the decisionmatrix cannot completely replace the typical case-by-case evaluation that considers all availableinformation (e.g., soil gas oxygen levels) and is intended for informative purposes to illustrate thegeneral thought process proposed for use in VIevaluations.

Thermal treatment technology. Waste combustion. Incineration.

No matter what you call it, it’s under fire around the globe. Plant operators everywhere are looking for ways to make thermal waste treatment work while satisfying intensifying environmental regulations and activist objections.

How will the need to comply impact an industry few embrace but many require for effective waste management?

The International Conference on Thermal Treatment Technologies & Hazardous Waste Combustors (IT3/HWC) brings together industry experts from around the world to share experiences, lessons learned, and new ideas on how to best operate thermal treatment facilities.

Register now – and find out how thermal treatment technology is changing the way waste is managed.

www.awma.org/IT32011

30th International Conference on Thermal Treatment Technologies & Hazardous Waste CombustorsMay 10-13, 2011 • Jacksonville, FL


The general form of the matrix is based on thatused by the New York State Department of Healthin 2006.6 Recommended actions are given basedon the measured values in indoor air and shallowsoil gas. In this way, the matrix addresses both current conditions and future conditions (e.g., if theshallow soil gas concentrations are sufficiently high,action may be recommended even if the currentindoor air quality is acceptable). Methane shouldbe evaluated in terms of short-term, maximum effects rather than long-term, average conditions,as is done for VOCs. Therefore, averaging ofmethane soil gas concentrations is not recom-mended and Table 1 is based on maximum meas-ured values within or very near the building footprint.Nonetheless, it should be recognized that VI of iso-lated pockets of methane will be mass-limited.

There are several assumptions inherent in Table 3.One, there is no soil gas methane concentrationthat is inherently dangerous. It is important to consider concentration, differential pressure, andthe volume of methane present in the soil. Two, ifmethane levels indoors reach 1.25%, this requiresimmediate action, regardless of whether or not VIis contributing to the indoor air levels. This actionlevel is 25% of the LEL for methane in indoor airand if this concentration is detected, it suggests thatexplosive conditions may exist somewhere in the

building. Three, indoor methane values that equalor exceed 100 ppm are sufficiently above typicalbackground levels that it suggests a methanesource is present. In such cases, it is prudent to fur-ther investigate to determine whether methanereadings anywhere in the building approach theLEL of 5%. In many cases, elevated indoor con-centrations are found to be due to unlit pilot lightsor other indoor sources.

The decision matrix for methane is intended for com-mercial/industrial buildings, which are assumed to beslab-on-grade construction and have some form ofventilation. The decision matrix is not applicablesmall, unventilated spaces in the subsurface, such asutility vaults, which are more prone to VI issues.

SummaryVapor intrusion of methane requires a differentconceptual model than VI for petroleum hydrocar-bons and chlorinated solvents. At this time, there isvery little guidance for methane at VI sites andwhat guidance does exist is of limited usefulness.Relevant information about the basic underlyingconcepts of methane fate and transport is brieflysummarized here. A decision matrix is presentedthat can be used to “screen out” sites with minimalpotential hazard. em

References1. Eklund, B.; Anderson, E.; Walker, B.; Burrows, D. Determination of Landfill Gas Composition and Pollutant Emission Rates at Fresh Kills Landfill; EPA

902-R-95-001; U.S. Environmental Protection Agency Region II, December 1995.2. 40 Code of Federal Regulations Part 258.23 [Resource Conservation and Recovery Act Subtitle D]. Criteria for Municipal Solid Waste Landfills,

Explosive Gases Control. Available at http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=72cda062b68ac7e9da9f0a73cc05dd67&rgn=div5&view=text&node=40:24.0.1.4.38&idno=40#40:24.0.1.4.38.1 (accessed May 5, 2010).

3. 29 Code of Federal Regulations Part 1926.800. Safety and Health Regulations for Construction, Underground Construction. Available atwww.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10790&p_table=STANDARDS (accessed May 5, 2010).

4. Eklund, B. Proposed Regulatory Framework for Evaluating the Methane Hazard due to Vapor Intrusion. In Proceedings of A&WMA Vapor IntrusionSpecialty Conference. Chicago, IL, September 29-30, 2010.

5. Sepich, J. Hazard Assessment by Methane CVP (Concentration, Volume, Pressure). Presented at the Sixth Annual Battelle Conference, Monterrey,CA, May 19-22, 2008.

6. Guidance for Evaluating Soil Vapor Intrusion in the State of New York; New York State Department of Health, October 2006.

Table 3. Decision matrix for methane in soil gas and indoor air.

Shallow Soil Gas Indoor Air ConcentrationConcentrationa None Available <0.01% (i.e., <100 ppm) 0.01 to <1.25% > 1.25%

<1.25% to 5% No further action No further action No further actionb Immediately notify authorities, recommend owner/operator evacuate building

>5% to 30% c No further action unless No further action unless No further action unless Immediately notify authorities,ΔP >2 in. H2Ob ΔP >2 in. H2Ob ΔP >2 in. H2Ob recommend owner/operator

evacuate building

>30% c Collect indoor air data Evaluate on case-by-case Evaluate on case-by-case Immediately notify authorities,basis basis recommend owner/operator

evacuate building

Notes: aMaximum methane soil gasvalue for area of building footprint.bLandowner or building owner/manager should identify indoorsources and reduce/control emis-sions. If no sources are found, addi-tional subsurface characterizationand continued indoor air monitoringare recommended. cThe potentialfor pressure gradients to occur inthe future at a given site should be considered.

This table is intended for sites withexisting buildings. To address futuredevelopment, no further action isrequired if the shallow soil gas concentration is <30% and ΔP <2 in. H2O. If the combined soilgas concentrations of methane andcarbon dioxide are >90%, mitiga-tion should be considered.

Here’s just a sampling of the benefits you receive as an A&WMA Member:

Quality Information: from the Journal of the Air & Waste Management Association to EMmagazine to technical books and publications, you get the technical, practical, and professionalinformation you need.

Professional Development and Education: improve your professional skills and expertise atmore than 30 continuing education programs, specialty conferences, and a wide variety ofworkshops held each year, in addition to the Annual Conference & Exhibition.

Networking and Contacts: take advantage of numerous opportunities to meet with yourpeers and expand your circle of valuable business contacts.

Job Search and Employment: find a position in the environmental field or fill a vacancy inyour organization through our online job board.

Membership and Resource Directories: your quick reference for finding colleagues and arange of products and services.

Discounts: members receive substantial discounts on publications, conferences, educationalseminars, insurance coverage, logo merchandise, and more.

Recognition: get recognized for your accomplishments through the A&WMA awards programs, publishing an article in EM or the Journal, or serving on an A&WMA committee.

A&WMAMembership Benefits

For more information on these great member benefits, contact A&WMA Member Services at 1-800-270-3444 or visit us online at www.awma.org.


em • feature

by Stephen Song, Francis Ramacciotti,Barry Schnorr, MichaelBock, and ChristopherStubbs

Stephen Song, Ph.D., is a principal, Francis C. Ramacciotti is a manager,and Barry A. Schnorr is asenior associate at Environ’sPrinceton, NJ office;Michael J. Bock, Ph.D.,is a manager at Environ’s Portland, ME office; andChristopher M. Stubbs,Ph.D., P.E., is a senior man-ager at Environ’s Emeryville,CA office.

The U.S. Environmental Protection Agency’s (EPA) 2002 draft vapor intrusionguidance1 recommended default attenuation factors for the generic screeningstep of a tiered vapor intrusion assessment process, in which the generic screeningstep is followed by semi-site-specific screening and then site-specific assessment(i.e., “non-generic assessment”).

Evaluation of EPA’s EmpiricalAttenuation Factor Database

As discussed in the 2002 draft guidance, the defaultattenuation factors of 0.1 for subslab soil gas and0.001 for groundwater were based on an EPA data-base of empirical attenuation factors calculatedusing measurements of indoor air, soil gas, and groundwater from different sites. The default attenuation factor of 0.01 for deep soil gas wasbased on EPA’s belief that this value should be between those for groundwater and subslab soilgas. The default attenuation factors were to be usedin generic screening but not in the non-generic assessment steps of the tiered process.

In 2008, EPA made available an updated databaseof empirical attenuation factors and a draft report2

describing a preliminary evaluation of the database.The draft report noted that the updated databasecontains a much larger number of attenuation factors than in 2002. It also reported on a statisti-cal analysis of the empirical attenuation factors inthe 2008 database and suggested that the analysissupports the 2002 default subslab and groundwaterattenuation factors.

As EPA works on issuing final vapor intrusion guid-ance,3 the 2008 database and the draft 2008 report are likely to be cited as bases for a numberof updates to the 2002 draft guidance. It is likelythat EPA is intending to include default attenuationfactors in the final guidance that are based on the


Table 1. Empirical attenuation factors in EPA’s 2008 database and Data Set 2 (DS2).

Subslab Soil Gas Groundwater Crawl SpaceResidential Other Residential Other Residential Other Residential Other

Soil Type DS2 All DS2 All DS2 All DS2 All DS2 All DS2 All DS2 All DS2 All

Very Coarse 17 82 0 0 7 68 0 0 17 83 0 0 0 0 0 0

Coarse 144 967 71 330 35 62 11 17 261 500 10 20 25 74 0 0

Fine 19 71 2 6 32 81 0 0 300 444 8 11 20 36 0 0

Unknown 58 128 0 0 1 9 0 0 0 0 0 0 0 0 0 0

Sum 238 1248 73 336 75 220 11 17 578 1027 18 31 45 100 0 0

2008 database and statistical analysis. Also, EPAappears to be considering the use of default attenu-ation factors not only for generic screening but alsoto replace the use of other methods of estimatingattenuation factors in the non-generic assessmentallowed in the 2002 draft guidance.

In light of the potential importance of the draft2008 report in setting final vapor intrusion guidance,we conducted an evaluation of this database togain insight on (1) whether the 2008 database isrobust enough to support the identification of defaultattenuation factors that could obviate the need forestimating attenuation factors to account for site-specific considerations in the non-generic assess-ment; and (2) whether the default attenuationfactors recommended in the 2008 draft report arereasonable for generic screening.

Representativeness of the DatabaseIf EPA intends to rely on the 2008 database andstatistical analysis to derive default attenuation factors that would limit the use of other methodsfor estimating attenuation factors in non-generic assessments, then an important question is whetherthe empirical attenuation factors in the databaseare representative of the range of site conditionsfor which non-generic assessment is often used(e.g., residential versus nonresidential, high- vs. low-permeability soils, shallow versus deep sources).

Table 1 shows a breakdown of the four types of attenuation factors by soil type and building type,which are important for judging the relevance ofthe 2008 database to the vapor intrusion assessment

for a particular site/building. The table also showsa breakdown of the attenuation factors in the data-base and the attenuation factors that formed thebasis of the conclusions of the 2008 statisticalanalysis (identified as “Data Set 2” [DS2]).

As shown in Table 1, a vast majority of attenuationfactors are for residential buildings, both in thedatabase (87%) and in DS2 (90%). As indicated inthe 2008 draft report, five sites contributed 75% ofthe attenuation factors for residential buildings.

Table 1 also shows that most of the attenuation fac-tors are for coarse-grain soil or very coarse-grainsoil. Fine-grain soil attenuation factors comprise22% of the database and 37% of DS2, which aremostly groundwater attenuation factors. Approxi-mately 43% of the groundwater attenuation factorsin the database and 52% of the groundwater attenuation factors in DS2 are for fine-grain soil.

Another aspect of the database is that almost all ofthe attenuation factors in the database are for chlo-rinated volatile organic compounds (VOCs), prima-rily trichloroethene and tetrachloroethene, and notpetroleum hydrocarbons, such as benzene, toluene,ethylbenzene, and xylenes (BTEX). In fact, DS2 included only five attenuation factors for BTEX.

Other aspects, such as the depth of a contaminantsource (especially in combination with other factorssuch as soil type), can affect the potential for vaporintrusion at a particular site. Hence, it would usefulto know if the 2008 database has adequate repre-sentation by attenuation factor for these other


aspects. However, breakdown of the database bysuch additional aspects was not possible becauseinformation on such aspects is not included.

Eliminating Obvious BiasMuch of the discussion in the 2008 draft reportwas concerned with excluding attenuation factorsfrom the statistical analysis. EPA began by excluding25% of the attenuation factors because (1) fieldnotes indicated the presence of a backgroundsource; (2) the indoor air concentration is higherthan the subsurface concentration; or (3) the attenuation factor for a chemical is inconsistent withthe attenuation factors for other chemicals in thesame sample. The result was Data Set 1 (DS1). EPAthen excluded an additional 40% of the attenua-tion factors because they were calculated using indoor air concentrations lower than the 95th percentile indoor air background level or below analytical reporting limits. The result after excludingthese attenuation factors was DS2.

Overall, EPA excluded 65% of the attenuation factors before performing its analysis. The percentexcluded for the four attenuation factor types are:

80% for subslab, 64% for soil gas, 59% for crawlspace, and 44% for groundwater. Figure 1 showsthe distributions of the attenuation factors in thedatabase (All), in DS1, and in DS2. The distributionlabeled as “300x” in the subslab, soil gas, andgroundwater graphs is discussed below.

As shown in Figure 1, the exclusion of unusableattenuation factors had the most effect on the dis-tribution of the subslab attenuation factors wherethe initial distribution is bimodal with one peaknear 1 and the other near 0.01. The area underthe first peak was reduced, but not completelyeliminated, through exclusion of 80% of the subslabattenuation factors. In contrast, the exclusion of unusable soil gas and groundwater attenuation factors had a much less noticeable effect on the distributions, even though a substantial percent ofattenuation factors were excluded.

As discussed in the 2008 draft report, the mainreason for excluding the vast majority of the atten-uation factors was because of concerns about theeffect of indoor sources on the empirical attenuationfactors. While it is appropriate to exclude empirical

Figure 1. Distribution of log-transformed attenuationfactors as bias is reduced.


attenuation factors higher than 1 and those calcu-lated based on indoor air concentrations likely tobe within background levels, it does not necessar-ily mean that all the remaining attenuation factorswere unaffected by indoor sources. For example,DS2 still has subslab attenuation factors as high as0.9, which means the indoor air concentration wasalmost equal to the subslab concentration (60 and68 μg/m3, respectively, in this case). It is very likelythat this and other attenuation factors in DS2 arebiased high by indoor sources.

Further Reducing BiasTo investigate the degree to which empirical sub-slab attenuation factors can be biased by indoorsources, we considered the combined effects of in-door sources and vapor intrusion for a single-zone,well-mixed indoor space that is ventilated with out-door air at rate Qbldg, as shown in Figure 2. Achemical in subslab soil gas enters the indoor spaceat a soil gas entry rate Qsoil and concentration Css,and soil gas entry via diffusion is assumed to benegligible, which is almost always the case.

A mass balance analysis for this indoor space givesthe following equation for the empirical attenua-tion factor α∼ss:

where Ci is the indoor air concentration due solelyto indoor sources. It can be shown by mass bal-ance analysis that the ratio Qsoil/Qbldg representsthe true attenuation factor (without effects of anyindoor source). Thus, the empirical attenuation fac-tor is the true attenuation factor αss plus a term forthe indoor sources. This additional term biases theattenuation factor, and the bias will be noticeablewhen the magnitude of the term is comparable toor larger than αss = Qsoil/Qbldg.

The size of the ratio Qsoil/Qbldg can be estimatedby considering plausible values for each para-meter in the ratio. For residential buildings, EPA’s guidance on vapor intrusion modeling4 has rec-ommended default values for both Qsoil and Qbldg.For Qsoil, EPA recommended a rate of 5 L/min. ForQbldg, EPA recommended a residential buildingwith a basement that is 100 m2, has a mixingheight of 3.66 m, and air exchange of 0.25/hr,

which corresponds to a ventilation rate of 1,525L/min. The ratio of these numbers is 0.003.

This estimate of Qsoil/Qbldg can be considered tobe conservatively high because EPA chose Qsoil tobe conservatively high5-8 and Qbldg to be conserv-atively low.9 Additionally, choosing Qsoil and Qbldgindependently and inversely of each other is con-servative in itself, because in situations with highQsoil due to large building under-pressurization,stack effects will tend to increase Qbldg.

Taking 0.003 as the ratio of Qsoil/Qbldg, the equa-tion for α∼ss shows that Ci/Css will bias αss by a fac-tor of 2 or more when it is 0.003 or higher. Thismeans the subslab concentration Css must be ap-proximately 300 times higher than the indoor airconcentration due to indoor source Ci to calculateempirical attenuation factors that are minimally biased by the effects of indoor sources.

EPA’s DS2 included empirical attenuation factorsthat were calculated using subslab concentrationsthat were as little as 2 times higher than the indoorbackground level (e.g., 1.7 μg/m3 of trichloroeth-ylene (TCE) in subslab, 1 μg/m3 of TCE in indoorair, and background TCE of 0.8 μg/m3). In DS2,72 of the 311 subslab attenuation factors were calculated from subslab concentrations less than300 times higher than the background level. Assuch, nearly a quarter of the subslab attenuationfactors in DS2 are likely to be biased by effects ofindoor sources.

Figure 2. Mass balance for subslab soil gas entry into building.

α∼ ssCbldg

=Qsoil

+Ci

Css Qbldg Css

Ri (Qbldg + Qsoil) CbldgQbldg Co

Qbldg Outdoor air flow rate through building

Qsoil Subslab soil gas entry rate

Co Concentration in outdoor air (assumed to be zero)

Cbldg Concentration in building indoor air

Css Concentration in subslab soil gas

Ri Rate of generation from indoor sources

Qsoil Css

IndoorSources


Removing these 72 attenuation factors and 22other attenuation factors for chemicals that lack abackground level gave a data set with 217 subslabattenuation factors that are less likely to be greatlybiased by indoor sources (i.e., by no more than afactor of 2). The distribution of this data set (300x)is shown in Figure 1 for comparison with the data-base, DS1, and DS2. Figure 1 shows that the dis-tribution of the new data set excludes almost all ofthe area under the peak with a mode of approxi-mately 1 in the initial data set. As a point of refer-ence, the 95th percentile of the new data set is0.018 as compared with 0.15 for DS2.

Applying this approach to DS2 for soil gas attenu-ation factors produced similar results. For soil gasattenuation factors in DS2, 47% of 86 attenuationfactors were calculated from soil gas concentrationsless than 300 times higher than background levels.Removing these 40 and 2 more for chemicals thatlack a background level left 44 attenuation factors,whose distribution is shown in Figure 1. The 95thpercentile of the new data set is 0.029 as com-pared with 0.33 for DS2.

Applying the approach to DS2 for groundwater attenuation factors produced little change. The reason is that only 3 of the 596 groundwater attenuation factors in DS2 were calculated fromgroundwater vapor concentrations less than 300times higher than background levels and 16 werefor chemicals that lack a background level.

After applying the approach to the subslab and soilgas attenuation factors in DS2, a nontrivial propor-tion of the remaining attenuation factors are stillhigher than 0.003. A review of these attenuationfactors found that a large number of these subslabattenuation factors are noted in the database as

having “confounding factors,” which indicate thatthe attenuation factors are potentially affected byindoor sources (e.g., the note, “Potential VOCsources noted. Observed attenuation factors forTCA and DCA may be biased high due to a confounding indoor source,” is associated with anattenuation factor for 1,1,1-trichloroethane of 0.11).Additionally, some of the attenuation factors in thisdata set differ from other attenuation factors for thesame sample by more than a factor of 10, whichshould have been excluded from DS1, accordingto the discussion in the 2008 draft report. In total,45% of the 217 subslab attenuation factors, 5% ofthe 44 for soil gas, and 8% of the 577 for ground-water have one or more of these characteristics,which indicates that indoor air concentrations inthese cases may have been higher than the 95thpercentile indoor air background concentrationEPA used in the 2008 draft report.

Some of the subslab and soil gas attenuation factors that remain after trimming DS2 are also statistical outliers. The subslab attenuation factors(without log-transform) have 19 high and 0 lowoutliers. The distribution of the 217 untransformedsubslab attenuation factors is shown in Figure 3,which gives a clearer picture of the distribution’sskewness than Figure 1. The cutoff for identifica-tion of high outliers is approximately 0.013. EPA’sdefault value of 0.1 is well beyond this cutoff andis at the 99.5th percentile.

SummaryOur evaluation found that approximately 90% ofthe attenuation factors in the 2008 database andstatistical analysis are for residential buildings. Nonresidential buildings were represented in thestatistical analysis by only 73 attenuation factors forsubslab, 11 for soil gas, and 18 for groundwater.

0.00 0.02 0.04 0.06 0.08 0.10 0.120

10

20

30

40

50

subslab attenuation factor

coun

t

Figure 3. Distribution after further bias reduction (withoutlog-transform).


The evaluation also found that most of the subslaband soil gas attenuation factors are for coarse-grainor very coarse-grain soil, and approximately half thegroundwater attenuation factors are for fine-grainsoil. Fine-grain soil is represented in the statisticalanalysis by 21 attenuation factors for sublab, 32 forsoil gas, and 308 for groundwater. These findingsindicate that the 2008 database and statisticalanalysis provide little information on vapor intru-sion scenarios involving nonresidential buildings orfine-grain soil (except they provide a reasonablerepresentation of scenarios with residential build-ings on fine-grain soil over chlorinated VOCgroundwater sources). The database also consistsalmost entirely of data for chlorinated VOCs andincludes very little data for petroleum hydrocar-bons (e.g., BTEX).

In conducting its statistical analysis, EPA excluded amajority of the attenuation factors in the 2008database because of various considerations relatedto the reliability of the empirical attenuation factorestimates. Most of the attenuation factors were excluded because of concerns with the effect of indoor sources. Although EPA excluded many attenuation factors for this reason, we found the remainder to include many that are still likely tohave been affected by indoor sources. To identifysuch attenuation factors, we performed a mass balance analysis for an indoor space that is subjectto the effects of both indoor sources and vapor intrusion. This analysis showed that to calculate em-pirical attenuation factors for residential buildingswith minimal bias due to indoor sources the sub-surface concentrations should be at least 300 timeshigher than potential background indoor air levels.

A large proportion of the subslab and soil gas em-pirical attenuation factors EPA used in the statisticalanalysis (DS2) were calculated with subsurface concentrations less than 300 times higher than potential background indoor air levels. Excludingthese from DS2 greatly reduced the right tail ofthese attenuation factor distributions (e.g., the 95thpercentiles dropped by approximately 10-fold). Incontrast, virtually no groundwater attenuation factors in DS2 warranted exclusion on this basis.

In summary, the findings of this evaluation showthat large numbers of empirical attenuation factorsin the 2008 database are likely to be biased highby the effects of indoor sources, and the prevalenceof such attenuation factors is greater than recog-nized by the exclusion criteria used in constructingthe data sets used in the 2008 statistical analysis.Our analysis shows that an important additional criterion is the consideration of the magnitude ofsubsurface concentrations relative to potential back-ground indoor air levels. Application of this crite-rion to the 2008 database removes many of theupper percentile subslab and soil gas attenuationfactors in DS2, which were calculated with subsur-face concentrations that are insufficiently high togive reliable estimates. Removing these attenuationfactors still leaves a number of attenuation factorsthat are higher than predicted by our mass balanceanalysis. A review of these attenuation factorsshows that at least some of them may have beenaffected by indoor sources to a greater degree thancould be accounted for by the indoor air back-ground levels that EPA used in the 2008 statisticalanalysis, which we also used in our analysis. em

References1. OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (Subsurface Vapor Intrusion Guidance);

U.S. Environmental Protection Agency: Washington, DC, 2002.2. EPA’s Vapor Intrusion Database: Preliminary Evaluation of Attenuation Factors; U.S. Environmental Protection Agency: Washington, DC, 2008.3. Lack of Final Guidance on Vapor Intrusion Impedes Efforts to Address Indoor Air Risks; Office of Inspector General; U.S. Environmental Protection

Agency: Washington, DC, 2009.4. User’s Guide for Evaluating Subsurface Vapor Intrusion Into Buildings; U.S. Environmental Protection Agency: Washington, DC, 2004.5. Nazaroff, W.W.; Lewis, S.R.; Doyle, S.M.; Moed, B.A.; Nero, A.V. Experiments on Pollutant Transport from Soil into Residential Basements by Pressure-

Driven Air Flow; Environ. Sci. Technol. 1987, 21, 459-466.6. Garbesi, K.; Sextro, R.G. Modeling and Field Evidence of Pressure-Driven Entry of Soil Gas into a House Through Permeable Below-Grade Walls;

Environ. Sci. Technol. 1989, 23, 1481-1487.7. Garbesi, K.; Sextro, R.G.; Fisk, W.J.; Modera, M.P; Revzan, K.L. Soil-Gas Entry into an Experimental Basement: Model Measurement Comparisons

and Seasonal Effects; Environ. Sci. Technol. 1993, 27, 466-473.8. Fischer, M.L.; Bentley, A.J.; Dunkin, K.A.; Hodgson, A.T.; Nazaroff, W.W.; Sextro, R.C.; Daisey, J.M. Factors Affecting Indoor Air Concentrations of

Volatile Organic Compounds at a Site of Subsurface Gasoline Contamination; Environ. Sci. Technol. 1996, 30, 2948-2957.9. ASHRAE Standard 62.2-2007: Ventilation and Acceptable Indoor Air Quality in Low-Rise Residential Buildings; American Society of Heating,

Refrigerating and Air-Conditioning Engineers: Atlanta, 2007.


em • feature

by Henry Schuverand William Wertz

Henry J. Schuver is an environmental protectionspecialist with the U.S.Environmental ProtectionAgency’s Office of ResourceConservation and Recovery,Washington, DC.* WilliamE. Wertz was formerly withthe New York State Depart-ment of EnvironmentalConservation (NYSDEC),Albany, NY, and recentlyjoined Geosyntec Consultants. E-mail: [email protected].

*Disclaimer: This article is a personal effort and does not represent agency poli-cies or recommendations.

This article follows on from some of the concepts discussed during the vapor intrusion screening levels panel at A&WMA’s Vapor Intrusion Specialty Conference,held September 2010 in Chicago. It describes a general conceptual approach forassessing the subsurface contaminant vapor intrusion (VI) into indoor air pathwayfor exposure.

A General (Evidence-Based) Framework for Assessing the

Vapor Intrusion Pathway


Although each site is unique, the proposed approachcan serve as both a framework for conducting a siteinvestigation and as a vehicle for meaningful publicinvolvement. Note that the approach describedbelow is primarily geared for sites with potential off-site residential impacts and a more streamlined approach may be possible at sites that are primarilycommercial/industrial or that have relatively few potentially impacted buildings.

Proposed Site Evaluation ApproachThe overall objective of the VI site evaluationprocess is to identify and take actions to addressVI-related exposures (or potential exposures) in theindoor air at all structures that exceed specified decision criteria. The proposed approach essentiallyfollows the scientific method (i.e., hypothesis andtesting) to achieve that objective. Data collectedduring the course of the investigation are used toformulate and refine a conceptual site model(CSM). Hypotheses regarding the nature and extentof contamination, the pathway that the contami-nants follow as they move from the source towarda structure, and the impacts of the contaminantson the indoor air of structures at the terminus ofthe pathway, spring from the model and are testedduring an iterative series of data acquisition phases.

Engaging StakeholdersBecause VI may directly impact the well-being ofbuilding occupants and because the VI evaluationprocess ultimately requires the participation ofthose occupants, it is essential that all stakeholders,including the general public, are included as earlyas possible in the evaluation process and at keypoints during the evaluation. Experience has shownthat the public’s opportunity to understand and beactively involved in the course of the investigationfrom the beginning increases the ease with whichthe investigation will proceed, and the likelihood ofpublic acceptance of its outcome.

The nature of VI-related exposures presents aunique challenge to both those conducting theevaluation and to the public. In most cases, thepresence of VI-related contaminants (e.g., volatileorganic contaminants) in the indoor air is not readilydiscernable without testing the air. In addition, thereis often a substantial period of time between the

point at which a structure is identified as being potentially impacted by VI and the point at whichan exposure is either confirmed or ruled out. Duringthat time, building inhabitants are in the difficultposition of not knowing whether they are beingexposed, and not having any practical alternativesto avoid exposures if they are occurring. For thatreason, it is imperative that the public has a clearunderstanding of the existing evidence regardingthe potential for VI exposures and a clear view ofhow the evaluation process will proceed and howlong it will take. Those responsible for the evaluationshould also provide the public with information regarding the possible health impacts that may beassociated with these exposures (which are currentlytypically considered to be of a chronic nature).

In addition to concerns about the impacts of VI ontheir health, many residents worry about its financialimpacts as well. For many people, their home is thesingle most important asset they have. The possi-bility that the value of their home will be substan-tially diminished as a result of the environmentalcontamination heightens their level of frustrationand adds to their feeling of being locked into a situation in which both their health and financialwell-being are suffering through no fault of theirown. It is not unusual for people in that situation toavoid participating in a structure (i.e., indoor airand/or sub-slab) sampling program in the hopethat this will help protect the value of their home,or to consider litigation as their only option to correct the perceived injustice that has been visitedupon them. Although these considerations don’ttypically come to mind when one thinks about aCSM, empathy for the potentially impacted residents, and consideration of possible actions toaddress their financial concerns (e.g., a “home valueprotection program”) should not be overlooked.

VI EvaluationThe evaluation approach described in this article isillustrated in Figure 1. The process is one in whichhistorical and new data are used to build and refinethe CSM. The CSM is the vehicle that serves to integrate and compare lines of evidence, identifydata gaps and the next steps in closing them, andcommunicate with stakeholders. Typically, the firstphases of a VI evaluation involve establishing the


nature and extent of the contaminant source andan area where structures could be potentially impacted by VI. At the start of that process, thegoals of the investigation, the criteria that will beused in making decisions and the overall approachto the evaluation should be developed in conjunc-tion with the appropriate regulatory authorities.

As soon as practical thereafter, the reasons for undertaking the VI evaluation, the results to date,and the likely next steps in the investigation shouldbe shared with local government officials and withthe public. The public’s response to the informationand their suggestions to improve the evaluationprocess should be considered and adjustments tothe program should be made where practicable.Periodically thereafter, and whenever a critical mile-stone in the evaluation is reached, there should beother rounds of communication with the public toensure that they understand how the evaluation is

proceeding and are apprised of any significantchanges in the CSM that could possibly affect them.

Typically, once the nature and extent of the vapor“source” has been reasonably well established,characterization of the vadose (unsaturated) zonepathway is used to test and enhance the CSM. Forexample, deep and shallow soil gas samples, geo-logic and physical characterization of the vadosezone, and identification of anthropogenic featuresthat could affect contaminant vapor migration wouldbe used to further refine the expected areal extentof potentially impacted structures. In the case ofdegradable vapor forming compounds (e.g., in petroleum), an appropriate vadose zone character-ization program may be sufficient to document theimpacts of biodegradation on the distribution ofthose compounds and to eliminate the need forstructure samples.

Evaluations where recalcitrant (e.g., chlorinated)vapor-forming compounds are the contaminantsof concern will usually involve collection of a “rep-resentative” suite of structure samples to observewhether VI is taking place in the tested buildings, andif it is, to identify all buildings that require actions toaddress VI-related exposures. Ultimately, due tothe variability in individual buildings (e.g., due tovarying location, orientation, design, construc-tion, condition, appliances, operations, and occu-pants), all potentially impacted structures may needto be sampled unless an area-wide or purely preemptive mitigation approach is offered in lieuof sampling.

CommunicationPrior to undertaking (interior) structure sampling, itis absolutely critical that the public, especially thepotentially impacted building owners and occupants,understand why the sampling is taking place andthe outcomes that will follow the sampling results,that is (1) no further action, (2) further sampling toresolve uncertainty (e.g., due to spatial and tem-poral variability and/or confounding ‘background’sources), or (3) vapor controls/mitigation and/orsource remediation.

Figures and maps illustrating the nature and extentof the groundwater or soil vapor source “plume,”

Figure 1. Proposed VI evaluation approach.


the distribution of compounds of concern in thevadose zone (soil gas), and the area where structuresampling will likely take place should be a standardpart of any communication package. For example,a map view of the proposed “vapor source area”could be combined with or supplemented by amap illustrating the estimated potential for vapormigration through the subsurface (vadose zone)materials above the “vapor source area.”

To help the public better understand the informa-tion, the figures could include identification of areaswith relatively high, moderate, and low subsurface“vapor migration potential.” In addition, charts thatcompare the reasonably likely range of potentialVI-related indoor air concentrations that could beexpected, the applicable regulatory health-riskscreening levels, and the typical background indoor air concentration ranges for the chemicalcontaminants of concern, as well as other possiblesoil-gas contaminants, such as naturally occurringradon, are all useful for putting the risks associatedwith potential VI exposures into perspective.

VolunteersBecause the process of identifying property ownerswho are interested in being sampled can be quitecumbersome, seeking potential volunteers duringthe course of a public meeting may be a goodtechnique for identifying those most interested inbeing sampled and expediting that process. Theinterested public could also be invited to commenton and/or request additional sampling to test theproposed extent (e.g., samples from areas not pre-viously measured). Not uncommonly, a reasonablysmall number of quality assurance (QA) samples(e.g., 10%) are collected in most sampling effortsand perhaps that QA sample concept could be expanded to include additional community-requested samples. Such hypothesis testing couldhelp ensure that the investigation has both prop-erly identified the full “vapor source” area (with apotential for unacceptable VI) and accurately delin-eated the surrounding areas without vapor sources.

Improved transparency can help the potentially-affected community members become more actively involved and able to contribute their knowl-edge of local conditions and concerns that can lead

to better hypothesis testing and more defensibleconclusions.

As the investigation proceeds, the figures shouldbe periodically updated to illustrate the current status of the investigation. Plots of the indoor airresults from the sampled buildings, could be usedto illustrate the observed effects (if any) of VI on indoor air quality and to compare these with thepreviously estimated potentials for VI in thoseareas. These comparisons could be used to sug-gest the potential for VI in other (still untested)buildings, in the particular site setting (and at thespecific time of sampling). When charts are addedto illustrate the observed and expected range oftemporal variation in indoor air impacts due to VIin tested buildings the public could have a fullerappreciation of the nature of the potential for VIinto (their) indoor air.

Summary The framework depicted in this article is not meantto prescribe a “one-size-fits-all” process for con-ducting an evaluation. Although we do believe thatit is important to develop and test hypotheses re-garding the nature and distribution of contami-nants along the VI pathway, and that the overallgoal for all sites should be the same (see Figure 1),we recognize that each site is unique.

The course of the investigation will be influencedby both the data that are developed during the in-vestigative process and by the resource allocationchoices that the investigative team makes. Moreoften than not, multiple rounds of groundwaterand vadose zone characterization and structuresampling may be necessary before completing anevaluation of all but the smallest sites. At some sites,investigators may perform highly detailed environ-mental characterizations with the hopes of mini-mizing the need for structure sampling. At othersites, the team’s approach might be to use struc-ture samples as the primary method for complet-ing the evaluation. At all sites, you should expectsurprises! em


em • how-to

by Steve Gibb

Steve Gibb is a senior scientist with The Scientific Consulting Group Inc.,Gaithersburg, MD. E-mail:[email protected].

Unique challenges are associated with communicating risk to different audiences,even for those with experience and comfort in public speaking. This article out-lines a number of tips for communicating risk effectively and highlights how todeal with the fact that people bring their own agendas to risk communication andtend to personalize risk information.

Risk Communication:Issues and Challenges

Whether your background is in engineering, envi-ronmental science, or another field, you’ve probablylearned technical terms that serve as a convenientshorthand way to cover a lot of ground quicklyamong your peers and colleagues. Communicat-ing with nontechnical audiences may require somebacking off in the use of technical terms. Often,the most successful technical people are not oneswho use the latest jargon, but who express findingsin simple, compelling ways to their audience.

Risk communication is both a science and an art,and allows you to draw on your background, ex-periences, and knowledge to carry you through theprocess. Taking action to prepare for the unex-pected is often the most important step, but alsothe most easily overlooked.

Imparting real information to audiences so they canparticipate as fully-informed citizens and at thesame time putting your best foot forward are notmutually exclusive. There’s nothing to apologize forabout framing your approach as being a com-monsensical perspective that supports your homeinstitution, community, and environmental goals.

One of the most important bottom-line messagesto take from this article is the importance of takingthe “high road.” Respecting your audience is key toavoiding shout-downs and discourteous remarks,especially when dealing with accusatory or ill-informed comments. By providing information, you


give the audience an opportunity to become as ed-ucated as possible about the situation, the optionsbefore you, programmatic constraints, and whereyou think their input would be especially valuable.

The Golden Rule of Risk Communication The golden rule is: There are no rules. Every situa-tion is unique, making it difficult to create a singletemplate for successful meetings or presentations.This leaves us with a paradox of sorts: expect theunexpected.

Unique situations confront communicators, andthat is especially true of risk communicators, aspeople tend to get personally involved in risk issues.1

One meeting I covered as a reporter for a risk assessment publication in 2005 was a U.S. Envi-ronmental Protection Agency (EPA) public infor-mation session during a peer review of dioxinscience. It involved a coalition of Native Americanwomen activists who wore papier-mâché platesthat made them look pregnant to protest repro-ductive risks of dioxin exposure. They also held upsigns when scientists were introduced with thenames of companies they had consulted for tohighlight their view of conflicts of interest on thepanel. There were a lot of highly charged emotionsand comments, but facilitators accommodatedthose who asked to speak, were respectful, andkept the meeting within the rules of the FederalAdvisory Committee Act, and the show went on.

While there may not be golden “rules,” some key issues continually resurface in the literature.

• Credibility—comes up time and again in studiesof risk communication.2 This must be activelyenhanced and not assumed.

• Cultural Competence—example: if a samplingwell placement is being considered near or on aNative American burial ground, be prepared tooffend the parties involved even at a hint this isbeing considered. Likewise, if you’re in theNorthwest and salmon may be contaminated,they are part of the Umatilla tribes’ view of thesacred, and should not simply be considered afood source/route of exposure.

• Preparation—creating quality posters, handouts,frequently asked questions documents, and Webpostings offer opportunities to communicateeffectively before meetings and after conversa-tions take place.

• Sharing Control—for ongoing audience en-gagement processes, allowing the community tohave real input and learn about the situation andoptions is often a key to perceptions that theoverall engagement is a success.

• Respect/Courtesy—can be shown in a multitudeof ways. Learning names, assuring the groupthat there are no “dumb” questions, usingnametags, and having a greeter at meetings canhelp smooth the way.


Part of preparing for the unexpected and gearingyour communications appropriately is anticipatingwho your target audiences might be. Go throughan exercise where you anticipate who may come:residents who live near contaminated areas, schoolpersonnel, parents of young kids, etc. These areyour “target groups,” which is an informal way of“segmenting the market,” as advertisers do. Thekey is keeping the list to four or five target audi-ences for any given presentation or publication.Once you get more than that, the message tendsto get too diluted and generic and you may windup missing everyone in an effort to connect withtoo many subgroups at once.

In general, you want to keep science-related infor-mation at the eighth-grade level, unless your targetaudience identification indicates otherwise. I had acolleague who worked at Oak Ridge National Lab-oratory and their community meetings were full ofPh.D.s—so it’s different everywhere.

In anticipating press coverage, scrub your publica-tions with an eye toward someone who is lookingfor a media story. Ask, “What’s the worst headlineI could write?” about what’s in your documents.

Experts and CredibilityAs noted above, credibility should never be assumedand active steps will be necessary throughout theprocess to enhance it. Research supports the fact thatlocal experts from a nearby college or university aretrusted and given more credence than distant experts, however prestigious. Approaching commu-nications from the “we have a good story to tell” per-spective can help structure your talking points,especially regarding controversial issues.

Rehearsing risk communication talks with a non-technical person can be helpful. I once wrote a“year in review” article on science policy develop-ments and was asked to present it to a board ofthe National Academy of Sciences (NAS). I prac-ticed at home and my wife helped me see that sen-tences that worked on the written page needed tobe shorter and punchier for verbal presentation.This improved my presentation greatly by allowingme to spend time connecting with the audience instead of reading long breathless sentences.

Learn to “pivot” on controversial topics to empha-size the good story you have to tell. Negative ques-tion: “Why isn’t the company telling us the truth

about toxins under our buildings?” Pivot: “We aregathering information about the sources of toxinsin indoor air and will be releasing it fully once the collection process is complete.”

If you are asked to appear on a television or radioprogram, ask about the show’s demographics.Work to ensure that your talking points and responses connect with your target audiences andask how their producers screen callers.

Preparing for Media Events: Using a Murder BoardAnother way to anticipate the unexpected in riskcommunication is to prepare by organizing a “mur-der board.” This is an NAS activity I participated induring my time there, where you set up a mockpanel of “journalists” who ask tough, far-reachingand challenging questions, such as: What pre-vented you from addressing the issue of X? Whydid you ignore the views of X group? Why shouldwe accept your findings when X is obviously misleading? The panel then provides feedback onpositives, alternative framings, and how you canemphasize points that support a “we have a goodstory to tell on X” explanation.

Create a core communications team in advance,complete with listed cell phone numbers, so you canconvene quickly if something emerges. Involve keyexperts; include your managers, and any others toensure the most up-to-date information is availablefor communications purposes. Maintain an active listof key points of contact at other agencies, nonprof-its, industry groups, and regulators at the local, regional, and federal level when they have a role.Even when things are quiet, cultivate and maintainthese partnerships. Consider spending 15 minuteson the phone per month with them, sharing yourlatest developments and catching up with them onwhat they’re up against, new challenges, and staffingchanges. This will pay off in the event of somethingemerging rapidly and your needing to work withthem closely for an intense, but hopefully brief, timecommunicating about emerging risks, possible reg-ulatory actions, or other key developments.

Avoid a bunker mentality and be especially responsive to concerns from community leaders,lawmakers, and those who represent potentiallyvulnerable groups, such as the elderly and children.If you’ve maintained good partnerships with yourpartners and sister agencies, it’s less likely that they

Avoid a bunkermentality and be especially responsive toconcerns fromcommunity leaders.


will leak damaging internal documents to leverageaction (and yes, as a reporter, I was the recipient ofa number of leaked documents that were likelymotivated by action-forcing agendas).

Lastly, avoid “greenwashing” or making somethingappear environmentally friendly when it’s not. Thepublic today is deluged with green messages aboutproducts and programs and skepticism is growing.

Challenges: Agendas and the Tendency to Personalize RiskIf you’re communicating well, conveying risk infor-mation becomes easier. However, it’s still fraughtwith potential challenges:

• Each listener brings different experiences andagendas to risk conversations. Maybe someonein their family experienced lead poisoning orperhaps high-velocity lead was a greater risk intheir occupation or neighborhood than chronicexposures.

• Communicating technical information in astraightforward way with lay audiences can poseobstacles.

• The slippery nature of words and ideas plays arole here.

• Even good listeners retain only about 10% ofwhat they hear, so again scrubbing your docu-ments or talking points for “worst possible head-line” fragments could be helpful.

Leery of Communicating Risk?If you’re leery of communicating risk, congratula-tions, you have a healthy respect for the process.The different agendas people bring are not alwaysevident until you’ve said something that peoplelatch onto. An activist told a colleague of mine at aCalifornia military base: “But I’ve seen drums float-ing down the creek!” He didn’t mention that thatmeant they probably didn’t have anything in them,but very neutrally re-stated what the installationhad determined about risk for the stream. Profes-sional activists or advocates can also use commu-nity meetings to pursue agendas and campaigns.

Given these different agendas and experiences,this neutral, facts-driven stance may be your bestoption. Assuming a neutral, officious demeanor isexpected of people representing institutions andthe government. You may consider some ways thatpeople do this somewhat stuffy or a little aloof, but

when it comes to the risk component of any com-munication, that may be the best way you can nav-igate the conversation. You can’t control people’sbackgrounds and the agendas they bring, but youcan control the objective information you impart.3

Here are some things to keep in mind:

• It pays to pay attention. They are at your meetingbecause they’re concerned or curious—they’renot home watching TV or a little-league game.

• People tend to get personally involved in risk issues. Being earnest and factual and not misleading people is the best way to maintaintrust and credibility.

• Risk is a serious business for many people, so a“hail fellow well met” approach may not be appropriate in interacting with people at com-munity meetings.

• Neither is hand-waving to distract people, or the “nothing to see here in terms of risk folks”approach.

• Also, avoid equations and technical-talk. Useyour words.

There are some contexts where you will be dealingwith people who interpret risks for a living, such asEPA and state regulators. Public settings may notbe the best place for you to interpret risks, for example, by saying people accept more risks fromtheir kitchen sponges than is posed by a neigh-borhood solvents plume.

ConclusionIt’s healthy to be leery of how to communicate risksbecause people bring their own experiences andagendas to risk conversations and can get personallyinvolved in the issue. Identifying target audiencesand speaking their language using a neutral, objec-tive tone to convey risk information will enhanceyour effectiveness. Collaborating with partnergroups, sister agencies, and other community rep-resentatives involved in your work in preparing forcommunication events that include risk issues canunderscore your credibility and reduce problems.Having a consistent, respectful person speak on be-half of the program improves communication effortsthrough continuity and courtesy. Acting on behalfof your organization and in the public interest willmaintain and enhance your credibility and publicperceptions of your organization’s actions. em

Respecting youraudience is key to avoiding shout-downs anddiscourteous remarks, especiallywhen dealingwith accusatory or ill-informedcomments.

References1. Kasperson, R.E.; Renn, O.; Slovic

P.; et al. The Social Amplificationof Risk: A Conceptual Framework;Risk Anal. 1988, 8 (2), 177-187.

2. Slovic, P. Informing and Educatingthe Public about Risk; Risk Anal.1986, 6 (4), 403-415.

3. Fischoff, B. Risk Perception andCommunication Unplugged:Twenty Years of Process; RiskAnal. 1995, 15 (2),137-145.


em • inside the industry

Vapor Intrusion Seeps Into Indoor Air Nationwide—andInto the Minds of Regulators, Attorneys, and the Public

Are You Prepared?

Vapor intrusion cases are on the rise across theUnited States–some estimates put the number ofpotentially affected properties in the thousands–and real estate stakeholders, not to mention thegeneral public, are understandably concerned. Ifyou are not yet familiar with the issues surroundingvapor intrusion, or are unaware that the newly revised ASTM E 2600 vapor encroachmentscreening standard is changing environmental duediligence best practices, read on.

Vapor Intrusion: A PrimerAs an environmental professional, you probablyknow that a vapor intrusion condition occurs whenrapidly evaporating chemicals from polluted soil orgroundwater make their way into indoor air. Whatyou may not know is that recent scientific devel-opments suggest that vapor intrusion is more wide-spread than previously reported, and that it canaffect human health even in low concentrations.

As a result, federal and state regulators are takingaction. The U.S. Environmental Protection Agency(EPA) is in the process of determining the extent towhich it will assess vapor intrusion risk as part ofits process of adding sites to the National PrioritiesList (NPL). Currently, the agency’s Hazard RankingSystem–the mechanism used to identify sites thatqualify for listing on the NPL–does not assess therisk of vapor intrusion caused by subsurface haz-ardous substances. As of this writing, 30 stateshave published vapor intrusion guidelines, and reg-ulators in Massachusetts, California, and New Yorkare reopening hundreds of formerly closed sites toexamine for the condition. What this means is that

formerly “clean” sites may not necessarily be problem-free.

What’s at Stake?Property owners who hold the deed to a propertyidentified as the cause of a vapor intrusion issuemay not only face property value losses and poten-tially hefty cleanup costs; they may also be the targetof class action lawsuits from nearby residents, seek-ing claims for property devaluation, personal injury,or other types of damages.

The risks are just as serious for lenders. Aside fromhealth concerns and the negative impact on prop-erty values, a vapor intrusion condition can lead toborrowers defaulting on their loans as the result ofcostly litigation. In the event of foreclosure, lendersbecome unwilling property owners, and thereforesubject to the same federal and state cleanup liability laws–and potential for lawsuits–that takingtitle to a property entails.

And in today’s market, where refinancing is on therise, vapor intrusion is becoming an important concern because contamination from the vapor path-way may exist today, but may not have at the time ofloan origination. Or, what was believed to be a lowlevel of contamination at the time may now exceedthe screening level for vapor intrusion. “During a recent refinance, we identified vapor intrusion fora loan that previously closed in 2002,” says RichardBelyea, PG, REA, vice president with Comerica Bank.“An off-site property currently undergoing remedia-tion had significantly impacted the subject propertygroundwater with chlorinated solvents.”

by Dianne Crocker

Dianne P. Crocker ismanaging director of theMarket Research Group at Environmental Data Resources Inc. (EDR) inMilford, CT. E-mail:[email protected].

A preparatory school in Minnesota. A Nevada shopping center. A popular NewYork supermarket. An environmentally-themed school in Los Angeles. What dothese sites have in common? They have all made recent headlines due to vaporintrusion risk, and the attention is showing no signs of abating.


Impact on Due Diligence Best PracticesIn response to all this recent attention, a growingnumber of due diligence consultants are incorpo-rating vapor intrusion into their practice and activelytalking to clients about the risk. “If a bank is con-cerned enough to require a Phase I assessment, itshould require a vapor encroachment assessment,”says Edward Devine, CEI, EP, senior consultant atDue Diligence Inspection & Assessment Services.

Consultants who have not yet approached clientsabout adding a vapor encroachment screen to theirenvironmental site assessments should considerdoing so, not only because of the potential for regulatory noncompliance, losses, and lawsuits, butbecause they could be held to a new standard ofcare. As reflected in the legal appendix of ASTM’srevised vapor encroachment screening standard,many attorneys now recognize vapor encroachmentas a Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA, alsoknown as “Superfund”) risk, rather than as an issuethat is beyond the basic scope of a Phase I envi-ronmental site assessment.

“Vapor intrusion issues should already be part ofenvironmental due diligence,” says Susan Phillips,an environmental attorney and partner with MintzLevin, who adds that ASTM’s vapor encroachmentscreening standard helps environmental profes-sionals identify whether they can dismiss a vaporintrusion concern at an early stage in the process.“If your Phase I identifies the likelihood of a releaseof a contaminant that is volatile, then if initialscreening can’t dismiss it, it warrants further evalu-ation. Regulatory agencies are looking at this issueall over the country, and the liability risk dictates acloser look as well,” Phillips says.

Other attorneys agree. “I have seen a dramatic increase in the number of environmental profes-sionals who are addressing vapor intrusion as acomponent of advising clients regarding due dili-gence,” says Peter Serrurier, an environmental attorney and partner with the Environmental, LandUse, and Natural Resources practice group at StoelRivers. “I suspect that, based on the current trend,vapor encroachment screening could become astandard part of performing environmental duediligence in the future.”


An important component of the industry transitionis client education. Environmental professionalsshould explain to their clients who are propertyowners and investors that a number of key factors distinguish vapor intrusion from other types of en-vironmental risks. Phillips explains: “First, vapor intrusion can arise as a result of a release on a different property from the one affected, as vaporsmigrate not only from contaminated groundwater,but also independently through soil and along conduits. Second, vapor intrusion is a particularconcern for even commercial tenants, who are unlikely to want to remain in a space where the airis potentially ‘unhealthy,’ especially if that tenanthas employees it is responsible for protecting. Finally,the concept of acceptable risk is a difficult onewhen it comes to the air we breathe, particularly ina residential context. Even if contaminant levels inindoor air are determined to be below risk-basedstandards, the concerns of owners and occupantsof a building with any levels of contamination canbe disproportionate to the risk involved and increase the risk of litigation.”

If you’re worried about approaching clients with yetanother service they need to buy (especially intoday’s tough market), focus on an approach thateducates them on the basics and points them tothe ASTM standard as a consensus-based approachfor screening out vapor intrusion as a concern upfront. “ASTM’s E 2600 guide is certainly an important step toward standardizing the discussionbetween environmental professionals and theirclients,” says Serrurier.

You should also talk to your clients about the pos-sible need for additional investigation. “We haveseen states reopening old sites that had achievedregulatory closure in order to examine potentialvapor intrusion issues, which is a frightening prospectfor those owners and their lenders and investorswho are holding No Further Action [NFA] letters,”says Phillips, who adds that NFA letters generallycontain a “reopener” clause that allows an agencyto reopen closed sites where there is a new concern.“I recommend that potential buyers and lendershave their environmental professionals evaluate thepotential for vapor intrusion risk even on sites thatachieved regulatory closure, particularly if closurewas granted before the vapor intrusion pathwaywas considered.”

You can also point out to clients that savvy buyersare using vapor intrusion to their advantage.“Some investors who take the time to understandthe science behind vapor intrusion may be willingto take the risk to purchase contaminated propertyat very low prices, with the benefit of grants andloans under Brownfield programs,” says Bill Wagner,an attorney and partner with the EnvironmentalLaw and Litigation Practice Groups at Taft Stettinius& Hollister. “These investors are cleaning the prop-erties to residential or commercial closure levelswhile the market is down, anticipating that theproperties will be cleaned up and re-sold when thereal estate market turns.”

EP LiabilityProperty owners and lenders are not the only onesthat need to worry about vapor intrusion liability, asan environmental professional, you should beaware of your own exposure. “We have defendedenvironmental professionals who have been suedby their clients for malpractice, negligence, andbreach of contract for having failed to identify risksrelated to vapor intrusion,” confirms Wagner. “Mal-practice is nothing more than a professional failingto exercise reasonable and ordinary care of that ofhis or her profession where that failure results ininjury or damages to the client. Because of the sub-stantial body of knowledge developed regardingvapor intrusion by EPA and state governments,ASTM, and other professional organizations, an environmental professional could easily be subjectto a malpractice or negligence claim if they fail toidentify a vapor encroachment condition.”

What this all points to is that the field is changingquickly with every new case involving vapor intrusion that surfaces. And it is important for environmental professionals to come up to speedas well in order to protect their clients–and them-selves. To learn more about vapor intrusion and thenewly revised ASTM E 2600 standard, visitwww.edrnet.com/vi. (Editor’s Note: You can readmore about vapor intrusion, the focus of thismonth’s feature articles, starting on page 3.) em

ErrataIn the October 2010 edition ofInside the Industry (see “BEPAs:A Growing Opportunity forEnvironmental Consultants,” p. 28), the last name of Carl de Stefanis, P.E., CEM, CRM,president of Energy ReductionSolutions, was misspelled. Weregret the error.


em • yp perspective

As a child living in the farmlands of Illinois, I de-veloped a fascination with the power of nature. Iwas always catching bugs and frogs and playingout in the corn fields. I remember a spring daywhen the tornado sirens went off in our neighbor-hood and the news reporter stated that a twisterwas headed our way. As my mother panicked andhustled us to a safe spot indoors, my interest in nature, specifically science and weather, intensified.

I started reading field guides and learned thenames of the clouds. My science fair project focused on the effect of deforestation on tempera-ture. My parents bought me the book, 50 SimpleThings You Can Do To Save the Earth–and I tried todo them all. I kept a journal of the daily weatherconditions for several years, so I could begin understanding trends. While my friends were scoping out the horoscopes and movie sections ofthe newspaper, I was studying the weather page.

So becoming an environmental scientist at an accounting firm was a natural career path, right?Well, not exactly...

I really wanted to work for the U.S. NationalWeather Service (NWS) as a hazardous weatherforecaster–I wanted to be the person that turnedthe sirens on. After graduating from high school, Iattended the University of Michigan and majoredin meteorology within the College of Engineering.I had a great internship working for the chief meteorologist at WGN TV in Chicago, Tom Skilling,between my sophomore and junior years, anddabbled in forecasting for the University of Michi-gan. Although I was fortunate to have these expe-riences, I learned that neither a television careernor the NWS was for me–the pressure of beingso-often wrong was too much! It took some time,but I realized that my passion was the environ-mental sciences.

I shifted my major to environmental atmosphericscience and obtained a minor in climate change.That winter, I landed an internship with the U.S.Environmental Protection Agency in Ann Arbor,MI. I worked closely with scientists in the ClimateChange Group at the Office of Transportation andAir Quality; we conducted technical analysis of climate policy regarding fuel economy and emis-sions. I was also hired by the University of Michi-gan to measure air pollutants for research studiesusing air quality machines.

Soon after my internships ended, I began my career with an environmental consulting firm, performing Phase 1 Environmental Site Assess-ments, subsurface investigations, and regulatorycompliance audits. I found that I really enjoyed thechallenge of environmental compliance audits andbecame a Certified Professional Environmental Auditor (CPEA) and a Certified Hazardous Materi-als Manager (CHMM).

Today, I work for an accounting firm where myaudit skills are tested by analyzing companies’ environmental liabilities. Additionally, I calculatecarbon footprints, audit environmental and safetyprograms, and assure corporate social responsibilityreports. It’s not quite the career path I originally envisioned, but I really enjoy helping clients understand and fulfill their sustainability objectives.

While a career in weather forecasting didn’t panout, I still enjoy forecasting. My friends and familyuse me as a resource all the time! I am also a certified NWS Storm Spotter, which means I canstill (inadvertently) turn the sirens on. em

by Alison Hendricks,CPEA, CHMM

This month’s column is written by Alison Hendricks,a senior environmentalscientist with Ernst & Young’sFraud Investigation and Dispute Services practice inChicago. She focuses on theEnvironment and Sustain-ability Practice within thefirm and is credentialed as a Certified Professional Environmental Auditor(CPEA) and Certified Hazardous Materials Manager (CHMM). Alison is also the Professional Development Chair forYPAC. E-mail: [email protected].

The views expressed hereinare those of the author anddo not necessarily reflect theviews of Ernst & Young LLP.

How I Became an Environmental Scientist

YP Perspective is a newmonthly column organ-ized by A&WMA’s YoungProfessionals AdvisoryCouncil (YPAC). If youhave a topic you wouldlike to see young profes-sionals discuss, e-mail:[email protected].

An amateur weather forecaster turns her attention to environmental atmosphericscience and climate change.


em • it insight

Anything as a ServiceWe purchase utilities on a subscription basis, payingas we go. We do not own the power generation facilities or transmission lines. In urban areas likeNew York, people often opt out of car ownership,instead subscribing to a service that allows carrental by the hour.

Hard-copy periodicals, movies, and books soon willbecome artifacts. Newspapers have published theirdaily papers on the Internet for some time, to thedetriment of hard-copy subscriptions. Netflix andothers have captured the video subscription market.Amazon, iTunes, and Wal-Mart lead the e-Musicmarket, while Barnes & Noble (Nook), Amazon(Kindle), and Sony have created a book and peri-odical market—buy one copy of a book, and readit on your e-book reader, SmartPhone, or PC.

The Cloud–computing infrastructure, platform, applications, and content delivered as a service–isgrowing as well. Many organizations recognizethat software is not their core business, and thatother companies can deliver computing powerfaster, better, and cheaper than software installedon the premises. Software as a service is growingat 17% a year,2 from front-office and sales applica-tions to enterprise-wide software.

SustainabilityIT plays a dual role with respect to sustainability. ITis a significant contributor of greenhouse gas emis-sions. However, IT can eliminate many times its environmental footprint in areas such as smartpower grids, efficient buildings, power planning,and better logistics planning. Companies are beginning to address the environmental impactsof IT, and the IT hardware industry is building

IT Trends andPredictions for 2011

TrendsSocial NetworkingA group of Harvard students invented Facebook sothat students could get to know each other. Today,Facebook has more than 500 million subscribers,and many big businesses have a Facebook presence.Social networking is here to stay. With advances intechnology, in a few years social networking maybear little resemblance to its current format.

Mobile EverythingCell phones and personal digital assistants (PDAs)morphed into SmartPhones (see “Get Smart(phones),” EM March 2010, p. 32). The iPad en-tered a market where Netbooks, tablet computers,and ultraportable notebook computers abound.With an astounding 500 million cell phones in operation, fully 90% can access the Internet. Smart-Phones have all but made obsolete consumervideo cameras, MP3 players, eReaders, satellitenavigation, and remote controls.1

CollaborationEnvironment, health, and safety professionals, likeother knowledge workers, are stuck in the 1990swith tools that do not promote knowledge sharing.Much “knowledge capital”–which can lead to competitive advantage–lies locked in the heads ofindividuals, as well as in spreadsheets, word pro-cessing documents, e-mails, and slide presenta-tions. This limits productivity.

Existing technologies such as wikis, blogs, and videoconferencing can help promote knowledge sharingfor better business decision-making. Technology byitself does not foster collaboration. A leap forward inknowledge worker productivity requires process innovations, training, and technology.

by Jill Gilbert

Jill Barson Gilbert, QEP,is president of Lexicon Systems, LLC. E-mail:[email protected].

This column discusses five information technology (IT) trends that continue to unfold, plus three technologies that could make a world of difference in the future.


electronics with a greener footprint (See “High-Tech Industry Heats Up Efforts to Lessen ClimateChange,” EM August 2008, p. 36).

Technologies to WatchThese three technologies could unlock a universeof possibilities.

Efficient Energy Storage and Ultra-Low Energy Consumption Battery life and energy consumption limit our tech-nical capabilities. Today’s SmartPhones and otherultraportable Internet-connected devices have better battery life than their predecessors, thoughbattery life remains limited, requiring a tether to anelectrical charger. Despite several generations ofimprovements in battery technology, rechargeablebatteries have a shelf life whose expiration is notpredictable.

The Massachusetts Institute of Technology, Uni-versity of Maryland, and others conduct nanotech-nology research on a new generation of batteries.The key is to achieve the needed combination ofhigh energy density, high power, and fast rechargethat are essential for our energy future,4 whetherfor electric cars, small communications devices, orentire manufacturing plants.

Silicon Chip AlternativesSilicon-based technology has its limitations forcomputing power, information storage, and access,especially in high-power and high-temperature devices. As silicon chips decrease in size and theirtransistors get smaller, they become less efficient,leaking electrical current, and producing heat. Researchers look to nanotechnology for alterna-tives to silicon chip circuitry. Gallium nitride (GaN)transistors could reduce energy consumption andimprove the efficiency of power electronics systems

in everything from motor drives and hybrid vehi-cles to household appliances and defense industryequipment, while combining several electronicfunctions onto a single chip.5 Chinese and Danishresearchers are collaborating on alternatives thatuse organic materials. Some of the latest Smart-Phones use organic LED screens.

Low-Cost or Free Communications NetworksFor those whose livelihood depends on communi-cations, poor data, voice, and video communica-tions infrastructure makes doing business difficult attimes. Only 21% of the population of Asia has access to the Internet, while more than 77% of theNorth American population has access.6 Internetbandwidth and reliability varies by service provider,type of service selected, the number of concurrentusers, and other factors. Cell phone and Smart-Phone users can experience intermittent serviceand poor data quality.

New 4G networks could make major improve-ments. Sprint, Verizon, T-Mobile, and AT&T all have4G networks under construction, replacing older,copper wiring with fiber optics. All the advertisingof faster, better networks leads us to believe thatthat 4G is a revolutionary technology. So far, it’smostly advertising, as the networks have yet to bebuilt, available in limited markets at best. On December 1, 2010, Verizon turned on its 4G network, but not for SmartPhones–where sub-scribers could see the greatest benefits.

IT provides capabilities that we could not have predicted just a few years ago. Cutting-edge technologies could be even more exciting… stay tuned. em

References1. Phillips, A. Five Technologies Made Obsolete by SmartPhones; Business Review Europe, November 19, 2010. See www.businessrevieweurope.eu/

tags/gadgets/five-technologies-made-obsolete-smartphones.2. Bughin, J.; Chui, M.; Manyika, J. Clouds, Big Data, and Smart Assets: Ten Tech-Enabled Business Trends to Watch; McKinsey Quarterly, August

2010.3. Joel Schindall, Department of Electrical Engineering and Computer Science, Massachusetts Institute of Technology. See www.eecs.mit.edu/

eecsenergy/storage.html.4. Gary Rubloff, University of Maryland NanoCenter, as reported by WRIV-TV Philadelphia, March 17, 2009. See http://www.greenrightnow.com/

wpvi/tag/maryland-nanocenter.5. GaN Transistor Bests Silicon, photonics.com, May 2008. See www.photonics.com/Article.aspx?AID=33765.6. See www.internetworldstats.com/stats.htm.

‘The realization oflong-lasting andrapidly recharge-able electrical energy storage isperhaps the mostimportant barrierto the replace-ment of carbon-based fuels byelectrical energysystems.’

>> Joel Schindall, MIT3


em • asian connections

At the Third Governmental Meeting on Urban AirQuality, organized with the United Nations Envi-ronmental Programme and held during BAQ 2010,senior government officials representing 17 nationalenvironment agencies in Asia discussed challengesand priorities for reducing air pollution and green-house gas emissions to achieve the long-term vision of urban air quality in Asian cities close toWorld Health Organization air quality guideline values by 2030.

Additionally, A&WMA organized a workshop on“Experiences in Developing and ImplementingStationary Source Standard,” covering policy aspects and technical issues associated with stan-dards development and enforcement strategies.Experiences in establishing emission standardswere shared by Asian policy-makers and industrypractitioners. The process for moving forward collaboratively, such as development of a StationarySource Emission Reduction Program for Asia, wasalso discussed.

Rapid Urbanization in Asia Requiresa Total Shift in City PlanningOver the next several decades, hundreds of millionsof people will be added to Asian cities, adding to airpollution and causing a bigger carbon footprint.The Health Effects Institute launched a major studyat BAQ indicating that 55% of the Delhi populationand 76% of the Beijing population live within 50meters of a major road. Addressing transport emis-sions and better urban planning are, therefore, keyparts of protecting people’s health.

Highlights from the BetterAir Quality ConferenceAsia’s Largest Air Quality Management Event

BAQ was organized by CAI-Asia, in partnershipwith Singapore’s National Environment Agency,Land Transport Authority, Asian DevelopmentBank, and the World Bank, and was supported byseven corporate sponsors and 24 other partner organizations. The conference theme reflected thegrowing relevance of climate change for air qualitymanagement, the rapid urbanization in Asia andthe changing role of stakeholders.

Growing Relevance of ClimateChange for Air Quality Management BAQ featured more than 120 presentations, manyof which focused on how air pollution interacts withclimate change. While “co-benefits” is a relativelynew concept, BAQ introduced initiatives and casestudies for Asia where air quality management andclimate change mitigation go hand-in-hand. Ex-amples of co-benefit estimation included Jakarta’semission inventory and China’s integration of airpollution and energy policies, while a case study inBangladesh integrated both issues in a co-benefitsvaluation study for compressed natural gas (CNG)conversions of cars, buses, and mini-buses.

To support cities and countries in co-benefits application, CAI-Asia introduced the Clean AirScorecard tool and presented the results from thepilot study in eight Asian cities with concrete rec-ommendations. The Institute for Global Environ-mental Strategies (IGES) also launched an AsianCo-Benefits Partnership to support mainstreamingof co-benefits into national development plans andsectoral policies and projects in Asia.

by Sophie Punte andRitchie Anne Guzman-Roňo

This month’s column is written by Sophie Punte,executive director, andRitchie Anne Guzman-Roňo, communications officer, both with CAI-Asia Center, Manila,Philippines. E-mail: [email protected].

At the Better Air Quality (BAQ) 2010 conference in November, 550 participantsfrom 36 countries, representing government, research institutes, donor agencies,and private companies gathered in Singapore to network, learn, and share experiences under the conference theme “Air Quality in a Changing Climate.”

Asian Connections is a newquarterly column sponsoredby A&WMA’s InternationalAffairs Committee. A&WMAhas invited the Clean Air Initiative for Asian Cities (CAI-Asia; www.cleanairinitiative.org)to contribute one columneach quarter to highlight airquality and climate change issues in Asia. The CAI-AsiaCenter serves as the secretariatof the CAI-Asia Partnership, anonbinding, multi-stakeholdernetwork of governmentagencies, nongovernmentalorganizations, research institutions, international organizations, and privatesector firms committed to improving air quality in Asia.A&WMA has collaboratedand partnered with CAI-Asiadating back to 2006.


Visible changes are possible in a matter of weeksand can be a catalyst for long-term change in theuse of public spaces, as explained by New York’sTransport Commissioner Janette Sadik-Khan in herkeynote speech. She made her experience visible toBAQ participants on how New York City reclaimedstreet sections for people in Times and HeraldSquares. Singapore’s Minister for Environment andWater Resources, Dr. Yaacob Ibrahim, shared howSingapore is able to strike a balance betweenprogress and low-emissions urban development.

Many other initiatives and examples in support oflivable cities were presented, ranging from cityplanning, bus rapid transit, and parking policy to thewalkability of city streets. During a debate session,the audience voted that addressing climate changeprovides an essential trigger for sustainable trans-port. A recurring message was that low emissionsdevelopment is complementary to, not at conflictwith, Asian growth.

Changing Role of StakeholdersA dialog session facilitated by the BBC’s Asia Todayanchor Rico Hizon showed that universities andnongovernmental organizations need to conductresearch with public policy needs in mind. Likewise,media plays a huge role in translating scientific datato shape public opinion.

Development banks and agencies emphasized the

need to integrate air pollution and climate changeissues into urban development projects. In additionto providing broader interest in green financingacross the region, their role also now includes providing expertise and experience needed bycountries to build their own capacity in developingtheir cities, transport system, and industries in a sustainable fashion.

Members of CAI-Asia’s eight country networks(China, India, Nepal, Sri Lanka, Pakistan, Philippines,Indonesia, and Vietnam) met during a roundtablessession to discuss what is needed to improve urbanair quality, reduce greenhouse gas emissions, andmake their cities more livable. Similarly, the UnitedNations Centre for Regional Development broughttogether various stakeholder groups to define theirrole in supporting governments with achieving theBangkok 2020 Declaration for EnvironmentallySustainable Transport goals.

Indeed, BAQ is a true gathering of the CAI-AsiaPartnership of 200 organizations and the widerAsian air quality community. What is clear is thatthe support of all stakeholders is needed to achievebetter air quality and livable cities in Asia. Perhapsthe biggest challenge is ensuring that stakeholderstruly work in partnership, as no one can clean Asiaskies alone. em

Photo 1. CAI-Asia Center Executive Director SophiePunte with representatives ofthe BAQ 2010 OrganizingCommittee, in addition toGuest of Honor Dr. YaacobIbrahim, Singapore’s Minister of Environment and Water Re-sources, and Keynote Speaker,Janette Sadik-Khan, New YorkCity’s Department of Trans-portation Commissioner.

Photo 2. BAQ 2010 sponsorsand supporting organizations.

Photo 3. Sophie Punte andRitchie Anne Guzman-Roňowith BBC’s Asia Today news anchor Rico Hizon, who facilitated the BAQ Clean Air Plenary.

Photo 4. CAI-Asia Partnershipmembers and the wider airquality community in Asiapleads, “clean air, clean airplease!”

For details on how you canparticipate in the next BetterAir Quality conference, BAQ2012, visit www.baq2012.org.

1

3 4

2


em • association news

The SectionThe Brazil Section was established by João BaptistaGalvão Filho in 1996. Wai Nam Chan, a chemicalengineer at the Petrobras refinery in Paulínia, ap-proximately 150 km north of Sao Paulo, served asPresident 2009-2010. The section is a small (withonly 40 members), but tight, association of diverseprofessionals like Chan; Milton Norio Sogabe,planning manager with CETESB, the São PauloState environmental agency; and Antonio Pireswith MWM International (a Navistar Company); allkey forces behind FIMAI 2010. “We had a majorregulatory program and many questions; it seemedperfect for the A&WMA model of the ‘neutralforum’ so we decided to try an international event,”explained Section President Chan.

The Regulatory and Environmental SettingThe relationship between Brazilian states and thefederal government is somewhat similar to that ofCanadian provinces and their federal governmentin Ontario. In these countries, the regional govern-ments often take the lead in environmental regu-lation. In the United States, states are often thepioneers, but the U.S. Clean Air Act (CAA) clearlydirects the U.S. Environmental Protection Agency(EPA) to set standards and largely dictate to thestates how they will be implemented. In addition,EPA conducts strong oversight of how states

implement programs delegated to them under theCAA. States in Brazil have far more latitude.

São Paulo is the most populous state (the capital—São Paulo city of over 10 million people, the met-ropolitan area about 20 million, and the entire state40 million) and Brazil’s economic engine with ahigh concentration of industry much like Californiain the United States. CETESB—Companhia Ambi-ental do Estado de São Paulo (São Paulo State Environmental Agency) has a track record of forgingnew environmental standards. The São Paulo metropolitan area has high levels of pollution, especially ozone and particulate matter. São Paulohas ambient pollution standards and compliancecriteria that operate similarly to those in NorthAmerica, although the actual levels and form ofstandards vary. Steady progress has been made inreducing ambient concentrations of ozone; how-ever, the standard continues to be exceeded.

Several years ago, CETESB was directed to cease issuing air quality licenses since the city of SãoPaulo was violating the ozone standard (termed“saturated” in São Paulo’s decrees or regulations).Faced with this impasse, CETESB devised a morecreative approach. Decree Number 52.469 issuedin December 2007 provided for a cap-and-tradeprogram for basically particulate matter and ozoneprecursors (nitrogen oxides [NOX] and volatile

The moment you catch sight of Brazil as your flight approaches its destination, youknow there is something special waiting. What you are yet to learn is that the trulymagnificent thing about Brazil is the people…their warmth, energy, optimism, andthe sense that they have arrived on the world scene. A nationally televised “60Minutes” feature on December 12 clearly illuminated the excitement and distinctlyBrazilian approach to life. The forthcoming World Cup in 2014 and OlympicGames in 2016 are appropriate symbols for the sports world, but it was the Inter-national Seminar on Market Regulation for Air Emissions, part of Feira Internacionalde Meio Ambiente Industrial (FIMAI 2010), which marked a major milestone forthis vibrant A&WMA Section.

by Rick Sprott, Jeff Muffat, and Milton Norio Sogabe

Rick Sprott is the formerexecutive director of theUtah Department of Environ-mental Quality and a PastPresident of A&WMA; Jeff Muffat is manager ofenvironmental and regulatoryaffairs for 3M Co. and currentA&WMA President; andMilton Norio Sogabe is aplanning manager withCETESB, the São Paulo Stateenvironmental agency, and a member of A&WMA’sBrazil Section.

Acknowledgments: Thanks toA&WMA Past President EdithArdiente of Navistar andAntonio Pires from their Brazilian subsidiary for facilitating participation byA&WMA President Jeff Muffatand Past President Rick Sprott.A&WMA especially wishes tothank Julio Tocalino Neto, Director of Revista Meio Ambiente Industrial, for organizing the host event,Feira Internacional de MeioAmbiente Industrial (FIMAIXII), and sponsoring the Section’s conference. All photos courtesy of FIMAI and the Brazil Section.

Spotlight on A&WMA’s Brazil SectionSpecial Place, Special People


organic compounds, excluding methane) and general implementation procedures. The programshares some objectives with the California SouthCoast Air Quality Management District’s (SCAQMD)Regional Clean Air Initiatives Market (RECLAIM)program that regulates NOX and SO2 in the LosAngeles air basin.

The ChallengeThis was the first air emissions cap-and-trade program in Brazil, so growing pains were to be expected. The trading market has not really flour-ished. To date, only three trades have beenrecorded with a fourth in the works. Industry appears uncertain about the future of the systemand CETESB is anxious to find mechanisms to ensure the program’s success in reducing emissionsand allowing business activity.

International Seminar on MarketRegulation for Air EmissionsAs Immediate Past President Gwen Eklund oftensays, the “sweet spot” for A&WMA is our ability totackle difficult policy and technical issues in a balanced and respectful way…the neutral forum.The Brazil Section decided that São Paulo’s cap-and-trade program was a crucial policy that warranted such an approach.

Cap-and-trade programs are a complicated andcontroversial business. Our Brazilian leaders rec-ognized that this needed in-depth presentationswith ample opportunity for questions and discus-sions. Hence, they opted for a series of one-hourpresentations and similar periods for questions.This approach represents an innovation and departure from the current practice of squeezingfour or more speakers into a single 90-minute session that is common in most conference settingsthese days. It turned out to be an excellent recipefor the topic!

The format for the International Seminar on MarketRegulation for Air Emissions, part of FIMAI 2010,was for regulators from Brazil and the UnitedStates to speak in the morning followed by industryexperts in the afternoon. The day opened to apacked house with introductions and an overviewof A&WMA by Section President Chan.

Carlos Eduardo Komatsu, manager of the CETESB

Department of Environmental Quality and Treas-urer of the Brazil Section followed with an overviewof the air quality situation in São Paulo, the basis for the 2007 decree establishing the cap-and-trade program, and the current situation with implementation.

This was followed by Rick Sprott, former executivedirector of the Utah Department of EnvironmentalQuality and A&WMA Past President, who focusedon the SCAQMD RECLAIM program, discussingimplementation details, results, and lessons learnedas listed in agency analyses and reports from EPAand the Pew Center. Sprott also provided insightsfrom Laki Tisopulos, SCAQMD Assistant DeputyExecutive Officer and member of A&WMA’s Boardof Directors.

Following a delicious lunch in the FIMAI Exhibitiondining area, it was industry’s turn. The afternoonwas opened by Glenda Rangel Rodrigues, corpo-rate environmental consultant for Petrobras, who

Section President Chan introduces panel.

Carlos Eduardo Komatsu fromCETESB describes the historyand implementation of Decree Number 52.469 that established the cap-and-trade program.


provided a very interesting commentary on thechallenges for industry of the rule. It was strikinghow common they were with many in the UnitedStates…uncertainty with the market process andmonitoring challenges were among them.

The final speaker of the day was Jeff Muffat, man-ager of environmental and regulatory affairs for3M Co. and current President of A&WMA. Muffatreviewed his company’s sustainability practices andprovided a comparison of the U.S. ambient airquality standards and those of São Paulo. He alsoprovided insights into cap-and-trade program challenges in the United States.

The day concluded with an hour-long spiritedquestion-and-answer session. Topics covered variedfrom “this cap-and-trade program will never work”

to lots of questions and suggestions for monitor-ing and the need for future industry-regulator discussions to improve the program.

So how would the conference be described? Ahuge success by any measure. The conference attracted more than 100 attendees with the roomnearly as full at the end of the day as it was at thebeginning. Attendees remarked again and againhow important the issue was and the value of theday’s discussions. Regulators and industry in SãoPaulo agreed that further meetings could revitalizethe cap-and-trade program with strong interest inmore consultations in the near future. Regulatorsand business also agreed on the need for improvedemission monitoring, inventories, and reporting toimprove market transparency. Laki Tisopulos evenextended an invitation for representatives fromBrazil to visit SCAQMD to see how the RECLAIMprogram works first hand.

Conferences within a ConferenceFeira Internacional de Meio Ambiente Industrial (FIMAI 2010)FIMAI is a huge exhibition featuring dozens of exhibitors from countries in Latin America, NorthAmerica, Europe, and Asia (www.fimai.com.br/v2).The scope and quality of exhibits were very impressive and included “national clusters” of companies from a single country together in theirown mega-booth.

FIMAI’s founder is Julio Tocalino Neto, Director ofRevista Meio Ambiente Industrial (an industry en-vironment magazine), who has been a tremendoussupporter of A&WMA in providing a venue for theSection’s Conference. Neto extended incrediblehospitality to the U.S. panelists. It turns out thathospitality is a fine art in Brazil!

SIMAI XII—International Seminar on Industrial Environment and SustainabilityThis three-day event featured international speakersfrom North and South America and Europe. Theprogram was packed and diverse addressing sus-tainability policies in government and business,economic concepts, corporate strategies, and tech-nology. The program read exactly like what youwould see in North America, but was more impressive by the diverse global participation. Forexample, Sprott did a presentation on current

Glenda Rangel Rodrigues ofPetrobras discusses the impactof Decree Number 52.469 on industry.

A full house during the afternoon session.


climate policy in the United States on a panel withwaste-to-energy technology from Kawasaki in Japanand General Motors Brazil’s sustainability program.

The FutureWithout question the most impressive part of the“Brazil Experience” for A&WMA President Muffatwas the caliber and commitment of the environ-mental professionals he met in Brazil: “The BrazilSection did an incredible job and we are commit-ted to assisting in any way in future events.” It isdifficult to conceive how rapidly the legal and professional infrastructure has developed in Brazil.The United States celebrated the 40th anniversaryof the Clean Air Act in September at a day- longevent in Washington, DC. Brazil’s major environ-mental laws date from the end of the 1980s, yetSão Paulo is endeavoring to implement one of themost challenging of all environmental programs:cap and trade. As Past President Sprott commentedduring his presentation, “This is really tough stuff.”São Paulo has much work left to realize their goalsfrom their Decree Number 52.469, but theA&WMA Brazil Section could be a major part ofthe solution.

The Section held its annual luncheon meeting inSão Paulo in December and was the first sectionoutside North America to use the Association’s new

online membership link. They already have 12 newmembers…an increase of almost 30%! Newly-elected Section President Sidney Aluani, businessdirector for SGW Services, has wasted no timepreparing for 2011. Discussions are well underway for an even bigger and more ambitious FIMAIthis November. The Section’s future looks as brightas Brazil’s itself. Check out the Brazil Section onlineat www.awma.org.br. Hint: Try Google Translator ifyou are not fluent in Portuguese. em

In Memory of A&WMA MemberGarry Wayne Brooks

Garry Wayne Brooks died on October 9, 2010, in Apex, NC. A member of the Association since 1981,Garry had more than 30 years of professional experience in air pollution control and air quality managementprograms for clients such as the U.S. Environmental protection Agency’s (EPA) Office of Air Quality Planningand Standards, EPA’s Office of Research and Development, state/local/tribal air agencies, international environmental agencies, and industrial facilities. He worked to support EPA in emission inventory and emissionfactor development for 20 years, and managed the project that produced the AP-42 Fifth Edition; as well asbeing very experienced in the development of EPA regulations, having directed New Source Performance

Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) development projects since 1979.He also authored numerous technical and regulatory documents published by EPA. He was a vice president of Eastern ResearchGroup Inc., Research Triangle Park, NC.

Brooks attended the University of Virginia (UVA), where he graduated with high distinction with a bachelor’s degree in Environ-mental Science. He was an avid UVA fan and a member of the UVA Alumni Association. Brooks was a born leader and wasdedicated to the preservation of our environment. He was a man of great integrity with a kind heart and gentle soul. His lifewas enriched by his family. He is survived by his wife, Carolyn; his daughter; son; son-in-law; and grandson.

Panel and Section leaders.(Standing: Flavio MoratoGalvão, Antonio Pires, WaiNam Chan, Milton Norio Sogabe, Paulo Hasegawa,José Mateus Bichara, JoãoBaptista Galvão Filho. Seated:Glenda Rangel Rodrigues,Carlos Eduardo Komatsu, JeffMuffat, and Rick Sprott.)


42 em february 2011

Early Event HighlightsAdmiral Thad Allen of the U.S. Coast Guard (retired) is A&WMA’s featured keynote speaker.Admiral Allen led the Unified Command responseto the 2010 Deepwater Horizon disaster and

resulting oil spill prior to his retirement. He remains a critical voice in the ongoing activity surrounding the cleanup andanalysis of the spill as a civilian. Having

worked with nearly every group involvedin the incident, from BP and TransOcean

to impacted industry groups and cleanup volun-teers, Allen’s perspective on the largest environ-mental disaster in history is certainly unique, andwill likely generate much discussion throughoutACE. He speaks Tuesday morning, June 21

at 8 a.m. Register now atwww.awma.org/ACE2011,

em • 2011 annual conference

Warm Up with Hot News aboutA&WMA’s 104th Annual ConferenceIt may be cold outside, but A&WMA’s 104th Annual Conference & Exhibition(ACE 2011), scheduled for Orlando, FL, June 21-24, is already heating up. Fromthe destination location to the caliber of speakers and programs, ACE 2011 looksto be this year’s “can’t miss” event.

Orl

ando

201

1

Beyond A

ll Bo

rde

rs

www.awma.org/ACE2011


so you don’t miss a word of this intriguing presen-tation. Additional perspective on the spill will be offered throughout the conference during poster,platform, and panel discussions.

Tuesday morning’s opening keynote session willalso feature Gwen Fleming, regional director forthe U.S. Environmental Protection Agency’s Region4 Offices in Atlanta. Fleming, formerly Atlanta’s District Attorney, is the first African-American tolead Region 4, which includes Alabama, Florida,Georgia, Kentucky, Mississippi, North Carolina,South Carolina, and Tennessee, as well as six Native American Nations. Region 4 leads the nation in the number of environmentally relatedemergency response calls, and faces a variety of issues related to population growth and shifts, fast-paced development, and its various industrial sectors. Non-attainment with ozone and particulatematter standards impact 20 million people in theregion, as well as the Great Smokey MountainsNational Park. Managing water quality in Region4 is a mounting challenge, as competition for waterwithdrawals is increasing rapidly. Fleming’s com-ments on these issues, many of which are top ofmind for Floridians, are bound to get ACE 2011attendees talking.

A&WMA’s Annual Critical Review once againpromises to be a highlight of the 2011 technicalprogram. On Wednesday morning, Dr. TimothyTownsend of the University of Florida will presentan all-encompassing perspective on electronicwaste (e-waste) management, track current initia-tives, and explore how the world’s “upgrade addiction” makes the problem grow. Townsend, aprofessor of environmental engineering sciences,has conducted extensive research on a variety ofwaste management topics, including bioreactorlandfills, pharmaceutical wastes, waste leaching,treated wood, and plasma arc gasification. He is anationally recognized expert on waste and e-wastemanagement issues.

After his presentation, Townsend’s study and con-clusions will face the scrutiny of A&WMA’s panel ofexperts, themselves veterans of environmentalmanagement. Bring along your own questions—thefloor is opened for questions and comments fromthe audience once the panel’s critique is complete.

A Destination LocationACE 2011 will take place at Disney’s CoronadoSprings Resort in Walt Disney World, which will serveas the event’s singular convention, exhibition, andlodging destination. Complimentary transportation is

Dr. Timothy TownsendAdmiral Thad Allen

Outstanding Speakers

Orlando is the perfectbackdrop forconductingboth businessand pleasure.

44 em february 2011

available to and from Orlando International Airport,and around the Walt Disney World property. Trans-portation is also provided for all off-site tours andvisits. Out-of-town attendees will have little need torent vehicles, cutting the overall carbon footprintof the meeting significantly. However, the Coron-ado Springs Resort is expansive, and will requireattendees to wear comfortable shoes and planahead to be on time for key events.

Scheduling ACE 2011 at Walt Disney World offersattendees a wide variety of conveniences and additional incentives to participate in the industry-leading event for environmental professionals. Ofcourse, there is the convenience of building a family vacation onto a business event—A&WMA isadding a variety of events for family members,such as the family breakfast with a Disney characteron Tuesday morning and the Epcot Dessert Reception on Wednesday evening.

In addition, A&WMA’s annual golf outing to bene-fit the Scholarship Fund will be held at Walt DisneyWorld’s Palm Golf Course. Rated a four-star courseby Golf Digest, the Palm offers challenges for bothadvanced and novice players. It, along with Disney’sMagnolia Course, has hosted the PGA’s Children’s

Miracle Network Classic for 40 years. The Palmshowcases the beauty of Florida’s woodlands andincorporates strategic transitions between teeboxes and fairways to encourage proper drainageto wetland areas. Be on the look out for deer andother wildlife that often visit.

But there’s more than just fun.

Disney, long known for itsamazing ability to man-age waste inside its parks,opens its doors to attendeeswith an exclusive back-stage tour of its practicesand operations. Be sure tosign up early, tour space is limited. Addi-tionally, Walt Disney World Resorts is the2011 sponsor of the Environmental Chal-lenge International (ECi), which invites futureenvironmental professionals to tackle a “real-world” environmental problem. Teamsbring their solutions to Orlando to competefor $15,000 in prizes (see “Is it the Impos-sible Question?” above). em

Is it the Impossible Question?

It could be one of the biggest challenges facing the world today. Just how do you satisfy grow-ing global energy demand while meeting and sustaining ambitious goals for renewable energygeneration?

Difficult? A bit tricky? None the less, that’s the question A&WMA is asking students studying forfuture environmental careers to answer in the 2011 Environmental Challenge International (ECi).

The annual ECi competition, which culminates at ACE, encourages students to assemble a team offellow students, research a real-world environmental challenge, and present a potential solution forcash rewards totaling up to $15,000. The 2011 ECi competition is sponsored by Walt Disney WorldResorts.

The detailed ECi question and assignment is posted on the ACE 2011 Web site at www.awma.org/ACE2011. Students are askedto put themselves in the shoes of an environmental consulting team tasked with presenting the U.S. government with the most prac-tical, economical, and sustainable pathway to achieving a goal of 25% renewable electric generation nationwide by 2025. Plans mustbe able to withstand the scrutiny of the harshest critics and political opponents.

Just to make the experience as close to reality as possible, student teams will receive a “tweak” to the question scenario when theyarrive in Orlando. The “tweak” is to be incorporated into the final presentation. Students are encouraged to use A&WMA membersand professional attendees on site as resources for this final bit of research.

The ECi competition is open to undergraduate and graduate students in colleges and universities studying for environmental careers. Faculty can be used as a resource, but student teams must be able to prove research and proposal planning is their ownwork. Student registration fees and housing rates are available. Go to www.awma.org/ACE2011 for details.

ACE 2011 SponsorsIn addition to Walt DisneyWorld Resorts, sponsors for the2011 event include: 3M Co.,Golder Associates, Arcadis,PG&E Corp., The Shaw Group,Inc., BMW Manufacturing Co.,Capital Power Corp., FloridaPower & Light Co., The MosaicCo., and Progress Energy.

awma.orgCopyright 2011 Air & Waste Management Association


Study Finds Tailoring Rule Jeopardizes134 Renewable Energy ProjectsThe National Alliance of Forest Owners (NAFO) released a study saying the U.S. EnvironmentalProtection Agency’s (EPA) greenhouse gas tailoringrule could result in the cancellation of 134 renew-able energy projects that use wood chips and otherwoody biomass for fuel, putting as many as 26,000jobs at risk.

The NAFO study, conducted by Forisk Consulting,said canceling these projects, which are in devel-opment, would reduce capital investment in renewable energy by $18 billion and result in 5,384fewer megawatts of renewable electricity generat-ing capacity. As many of 30 states will not meet a15% renewable electricity target in 2021 under thetailoring rule, compared to 19 without it, accordingto the study, Economic and Regional Impact Analysisof the Treatment of Biomass Energy Under the EPAGreenhouse Gas Tailoring Rule. The study said 23biomass energy projects are already being delayedbecause of the tailoring rule.

The tailoring rule, published by EPA in June, subjectslarge new and modified sources of greenhouse gasemissions to prevention of significant deterioration(PSD) requirements. Under the tailoring rule,sources that use biomass must comply with PSD,which requires sources of regulated air pollutantsto control emissions using best available control

technology (BACT) and to obtain permits for thoseemissions.

States See Conflict Between EPAGuidance, Objections When Administering PermitsEPA has paired its authority to object to state-issuedpermits for air pollution, water discharges, and mining with interim guidance in ways that oftenforce state and local regulators to choose betweencomplying with state laws and federal mandates,according to a report by a state advocacy group.

Since 2009, EPA has required state and local reg-ulators to implement interim guidance on admin-istering various permits, threatening to overridethose permits if states do not apply the guidance,according to the Environmental Council of theStates report, Recent U.S. EPA Positions on InterimGuidance, Rules, and Policies. EPA is doing so despite potential legal and regulatory barriers statesface in applying the guidance, the report said.

The report cites interim guidance EPA has issuedon administering surface coal mining permits in Appalachia and pollutant discharges at powerplants as examples of guidance that states arebeing expected to apply before the agency has finalized its regulations or before states have hadan opportunity to complete their own regulatoryprocesses to implement the guidance. em

em • washington report

Report Says States Largely Ignore Carbon Emissions in Transportation DecisionsMost states are doing a poor job of using their transportation policies to reduce greenhouse gas emissions, according to areport released by the Natural Resources Defense Council and Smart Growth America. The report, Getting Back on Track:Aligning State Transportation Policy with Climate Change Goals, also ranked how well each state uses its transportation decisions to reduce greenhouse gas emissions, finding that very few connect the two issues directly.

“Most states do not make any effort at all to connect transportation policy with climate change and energy goals, and someput in place systems that effectively sabotage these goals,” the report said. The transportation sector accounts for nearlyone-third of the nation’s greenhouse gas emissions.

The report made several policy recommendations for states wanting to improve their work on emissions and transportation.First, it suggested that states balance their transportation spending by increasing public transportation, prioritizing highwayrepair and safety over greater capacity, supporting pedestrian and bicycle infrastructure, and adjusting fuel tax levels to ensure adequate spending on all modes of transportation. It also recommended that states manage road traffic throughcongestion pricing, in which drivers pay a fee that rises or falls along with demand, or through commuter programs thatprovide incentives for low-pollution transportation. Finally, the report recommended that states set per-capita reductiontargets for either vehicle miles traveled or greenhouse gas emissions.

Compiled by Mark WilliamsThe Bureau of National Affairs, Inc.www.bna.com

Note: All amounts in U.S. dollars.



em • canadian report

Canadian Report is compiledwith excerpts from EcoLogNews and the EcoCompli-ance.ca newsletter, both pub-lished by EcoLog InformationResources Group, a division ofBIG Information Product LP.For more Canadian environ-mental information, visitwww.ecolog.com.

Note: All amounts in Canadian dollars.

rigorous planning process and to develop and certify plans prior to the due date.

Phase II plans and plan summaries would still be due December 31, 2013. The first year inwhich all plans are to be reviewed would be 2018.

Feds Invest in Environmental Performance of Alberta Paper MillThe federal government is giving WeyerhaeuserCompany more than $32 million to improve theenvironmental sustainability of its pulp and papermill in Grande Prairie, Alberta.

The money, from the federal Pulp and PaperGreen Transformation Program (PPGTP), will helpWeyerhaeuser outfit the mill with a steam turbinegenerator, which will produce steam-generatedelectricity. The turbine will improve the mill’s energy efficiency and create enough clean electricityto power 2,800 homes.

In addition to federal funding, Weyerhaeuser is receiving $4.5 million from the Alberta governmentfor the $50-million project. The company is con-tributing the remaining amount. em

New Canadian Environment Minister NamedOn January 4, 2011, Prime Minister Stephen Harperappointed Peter Kent as the new federal Environ-ment Minister. Kent previously served as the federalMinister of State of Foreign Affairs (Americas).

Ontario to Extend Toxic ReductionPlan Deadline to December 2012The Ontario Ministry of the Environment is proposing to extend the deadline by which toxicreduction plans must be submitted to the ministryunder the Ontario Regulation 455/09 by one year,from December 31, 2011 to December 31, 2012.

The extension is to give industry sufficient time toundertake thorough planning to develop mean-ingful toxic substance reduction plans, as toxic substance reduction planning is a new approachfor many facilities in the province.

The extension applies only to Phase I of the ministry’stoxics reduction strategy, which deals with 47 prior-ity substances identified in Table A of the OntarioRegulation 455/09.

The extension would also provide regulated facili-ties with additional time to make use of variousguidance and technical resources, and to ensurethere are enough planners in place to undertake a

New Online Directory to Promote Green Job TrainingTo advance green job training in North America, Canadian-based Commission for Environmental Cooperation (CEC) hasdeveloped an online directory that lists more than 100 renewable energy training courses offered in a variety of renewableenergy sectors, including solar, wind, hydropower, geothermal, and bioenergy, in Canada, the United States, and Mexico.

A 2010 CEC report, which analyzed the state of renewable energy training inNorth America and recommended ways to improve it, found that a trinational collaborative system could help build and share best practices among Canada, theUnited States, and Mexico.

As a result, CEC launched a Web-based information system, www.cec.org/energycourses, to promote renewable energy training courses. According to the report, there are 196 renewable energy training courses in the United States, 32 in Canada, and six in Mexico. The majority of Canada’s courses are in Ontario.


Listed here are the articles appearing in theFebruary 2011 issue of the Journal. For orderinginformation, go to www.awma.org/journal or call1-412-232-3444.

FEBRUARY 2011 • VOLUME 61

JOURNAL

In This Issue...

Total Diesel Exhaust Particulate Length MeasurementsUsing a Modified Household Smoke Alarm IonizationChamber

Intercomparison Exercise for Gases Emitted by a CementIndustry in Spain: A Functional Data Approach

Model of Municipal Solid Waste Source SeparationActivity: A Case Study of Beijing

Windsor, Ontario Exposure Assessment Study: Designand Methods Validation of Personal, Indoor, and Out-door Air Pollution Monitoring

Using a Chemistry Transport Model to Account for the Spatial Variability of Exposure Concentrations inEpidemiologic Air Pollution Studies

An Analysis of Flaring and Venting Activity in the Alberta Upstream Oil and Gas Industry

Size-Differentiated Chemical Characteristics of AsianPaleo Dust: Records from Aeolian Deposition on Chinese Loess Plateau

Treatment of Benzene and n-Hexane Mixtures inTrickle-Bed Air Biofilters

Investigation into the Use of Satellite Data in AidingCharacterization of Particulate Air Quality in the Atlanta, Georgia Metropolitan Area

Adsorption of Carbon Dioxide from Flue Gas Streamsby a Highly Efficient and Stable Aminosilica Adsorbent

Events sponsored and cosponsored by the Air &Waste Management Association (A&WMA) arehighlighted in bold. For moreinformation, call A&WMAMember Services at 1-800-270-3444 or visit theA&WMA Events Web site:www.awma.org/events.

To add your events to this calendar, send to: Calendar Listings, Air & Waste Manage-ment Association, One GatewayCenter, 3rd Floor, 420 FortDuquesne Blvd., Pittsburgh, PA15222-1435. Calendar listingsare published on a space-available basis and should be received by A&WMA’s editorialoffices at least three months inadvance of publication.

em • calendar of events

2011MARCH1–2 Understanding Today’s CAA Permit

Programs, New Orleans, LA

13–18 PITTCON 2011, Atlanta, GA; pittcon.org

14–18 Opportunities in Air Quality-Climate Research in Asian-Pacific Region, Kona, HI;www.globalaqac.org

21–24 Analyzing Risk: Science, Assessment, and Management, Boston, MA; ccpe.sph.harvard.edu/risk2

30 Climate Change Financial DisclosuresWorkshop, Dallas, TX

APRIL5 Climate Change Financial Disclosures

Workshop, Chicago, IL

13–14 Understanding Today's Clean Air Act Permit Programs, Houston, TX

MAY4–5 Understanding Today's Clean Air Act

Permit Programs, Denver, CO

10–13 2011 International Conference on ThermalTreatment Technologies & HazardousWaste Combustors, Jacksonville, FL

22–25 Residuals and Biosolids 2011—AdaptingResiduals Management to a Changing Climate, Sacramento, CA;www.wef.org/ResidualsBiosolids

JUNE21–24 A&WMA’s 104th Annual

Conference & Exhibition, Orlando, FL

AUGUST30–31 Understanding Today's Clean Air Act

Permit Programs, Seattle, WA

SEPTEMBER13 Climate Change Financial Disclosures Work-

shop, Washington, DC

OCTOBER23–27 21st Annual Meeting of the International

Society of Exposure Science: Advancing Exposure Science for Environmental Health,Baltimore, MD; www.isesweb.org

NOVEMBER15 Climate Change Financial Disclosures

Workshop, San Francisco, CAawma.org

In Next Month’s Issue…

Waste Management—Emerging Issues within a Constant ConcernIssues continue to arise even for what are sometimes described as mature programs such as waste management.The March issue will address a wide range of topics, includ-ing the continued discussion on the regulatory definition ofhazardous waste under the Resource Conservation and Recovery Act (RCRA), the newly proposed rules addressingcoal combustion residuals (potentially bringing managementof this material under the hazardous waste management requirements of RCRA), and electronic waste recycling.

Also look for…• PM File• Competitive Strategy• YP Perspective• IPEP Quarterly

... and a comparison of the recent Cancun Agreements onclimate change to that of the Copenhagen Accord



em: What inspired you to become an environmental professional?Lu: Confucius. He taught me to work with people/students by understanding them. Two of Confu-cius’s students asked for his advice about studyingaboard (2000 years ago, on foot). He said yes toone and sent the other to ask for permission fromhis father and elder brother. Careful but a little hesitant, Student A needs more encouragement to pursue what he deemed right, while the im-promptu Student B needs more guidance from theexperienced. (Mingming is pictured above at theConfucius Institute in Singapore in 2009.)

What advice would you give to students and/or young professionals just starting out inthe field?Always keep an open mind and become involvedin professional organizations like A&WMA.

What does A&WMA membership mean to you?I started out as a student member, mainly to benefitfrom the highly reduced annual conference regis-tration fee. Membership in A&WMA opens up opportunities to network. We have a very active regional chapter in Southwest Ohio, and an award-winning student chapter at the University of Cincin-nati. I am proud to see my students recognized byA&WMA for their work.

What was the best A&WMA Annual Confer-ence you’ve attended?I was able to get something out of every conference

I have attended. My senior colleague at the Uni-versity of Cincinnati, Dr. Tim Keener, and I stronglyencourage our students to attend A&WMA’s Annual Conference, and they enjoy our dinnertreats outside “home.” I especially enjoyed themeeting in Indianapolis (2004) for the hospitality,and the Centennial celebration in Pittsburgh (2007)for the activities. Location, interesting sessions, activities (such as the meet-and-greets), nice fieldtrips, all contribute to make a successful meeting.

Are you currently working on any interesting projects? One group of my students is trying to makebiodiesel from trap grease. We were able to processwaste cooking oil with high fatty acid content andthen expand to trap grease, which is currently anuisance in large volume, wastewater treatmentplants. Another group is studying transportation-related air pollutant emissions, which began whena student traveled to Singapore with me for threemonths in 2009.

What’s the single biggest environmentalproblem facing the world today?I’d say sustainability. We need to strike a balancebetween the natural environment and the envi-ronment we have created.

How do you like to let off steam?The best tactic is to pause or leave the scene asquickly as possible to avoid blowing off steam. Clichéas it is, I cool down with cooking, Tai Chi, and shop-ping. I also get recharged when I plunge myself intoa pool of cold water in the early morning. em

MinuteMingming LuAssociate ProfessorSchool of Energy, Environmental, Biological, andMedical Engineering, University of CincinnatiCincinnati, OH

East Central Section; Southwest Ohio Chapter

A&WMA Member Since 1999

em • association news

The Member

“I am proud to see my studentsrecognized byA&WMA for their work.”

Each month, this page profiles a different A&WMA member to find out what makes them tick at work and at home.

Tell Us What Makes You Tick!The Member Minute is a greatway to share your experiences,work, and accomplishmentswith A&WMA’s membershipand EM readers. Want to seeyour photo and story high-lighted in EM, or do you wantto recommend someone to be featured? Just e-mail yourcontact information to EMat [email protected].

Association leadership roles held: Vice Chair, EM’s Editorial Advisory Committee


REACH OVER

8,500ENVIRONMENTALPROFESSIONALSEACH MONTH!

EM readers are industry leaders with buying power. Contact Malissa Wood at

[email protected], or 412-904-6012, to find out how advertising

in EM can get your company the exposure it needs in 2011.

evaluating the vapor intrusion pathway

Documents