The new ASTM E2600-10 Standard Guide for Vapor Encroachment Screening on Property Involved in Real Estate Transactions (the Standard) was designed to screen properties for the presence or likely presence of chemicals of concern (COC) vapors in the subsurface of the target property (TP) cause by the release of vapors from contaminated soil and/or groundwater either on or near the TP. The ASTM E2600-10 Vapor Encroachment Standard procedures were intended to complement and be conducted concurrently with the Phase I ESA process, but can also be used as a stand-alone screen.
However, the ASTM 2600-10 Standard may not be a “one-size fits all” approach according to the environmental consulting community, including panelists at the recent Environmental Bankers Association (EBA) conference in Fort Myers, FL. The discussion centered around which approaches consultants currently use, the impact of the 2010 revisions to the ASTM E2600 Standard on the Phase I ESA process, and the regulatory factors at play.
Some use the ASTM E2600-10 Standard as a valuable tool but consider it to be just one option, and use their own checklists or individual case consultations as appropriate based on the site characteristics. Others noted that the ASTM Standard may not be stringent enough in the search distances for certain types of releases. Of particular concern were the variations in regulations from state to state. Many states do not consider vapor encroachment at all, and some states allow closure of a release incident with residual contamination at levels high enough to still cause a vapor concern.
The consensus seemed to be that consultants do not have to use ASTM 2600-10, but they do have to consider the potential for a vapor encroachment condition (VEC) during the Phase I ESA process. Exactly how they consider and evaluate that risk appears to still be up for debate, as each site is unique and many complexities contribute to vapor migration.
Partner Engineering and Science, Inc. has always considered the potential for vapor concerns during the Phase I ESA process. Our geologists, engineers and environmental professionals analyze the various factors that can affect a potential vapor migration pathway, such as soil type, design and use of a building, groundwater depth and the type of chemical released, in order to evaluate whether the subject property may be affected. Our Partners are well versed in both the ASTM 2600-08 and 2600-10 Standards and their value as tools to evaluate vapor encroachment.