Jun 26, 2013· Comment submitted by Bruce J. Bauman, Ph.D., Research Program Coordinator, Soil/Ground Water, Regulatory Analysis and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-RCRA-2002-0033-0162
American Petroleum Institute comments on "Guidance for Addressing Petroleum Vapor Intrusion at Leaking Underground Storage Tank Sites - External Review Draft" and "OSWER Final Guidance for Assessing and Mitigating the Vapor Intrusion Pathway from Subsurface Sources to Indoor Air - External Review Draft," June 24, 2013, EPA Docket No. EPA-HQ-RCRA-2002-0033.
May 17, 2011· Comment submitted by Bruce Bauman, Regulatory Analysis and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-RCRA-2002-0033-0057
Filed on regulations.gov — full text not in the inline record.
Oct 20, 2005· Comment submitted by Harley Hopkins, Senior Environmental Scientist, Regulatory Analysis and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-RCRA-2002-0033-0049
Follow-up comments; RCRA-2002-0033-0009
It is API?s position that by incorrectly applying the same attenuation factors to degradable and non-degradable compounds, the following undesirable consequences will result: 1) adoption of unnecessarily conservative screening values by states that currently do not have their own screening values, 2) dis-incentive for states such as Utah, Colorado and Minnesota to continue to collect site data to learn which, if any, petroleum sites pose real risks, and 3) the agency will be in the difficult position of having to defend an empirically-based screening approach for BTEX in any future UST-oriented or BTEX-only guidance, in the face of overly-conservative screening values that are ?on the books? in the OSWER guidance.
In summary, the reason for excluding petroleum sites from the guidance is straightforward: Attenuation due to biodegradation of compounds found in petroleum, such as BTEX, (universally recognized to readily biodegrade in the subsurface) will not be reflected in screening values developed from data collected at sites with non-degradable, chlorinated compounds. As a result, the guidance will likely trigger costly assessments at many sites that pose low risk for vapor exposure. These assessments will be burdensome on regulatory staff and site owners (oil industry, Brownfields developers, DOD site managers, etc.) and unnecessarily disruptive to homeowners and businesses.
API additional information; BTEX screening values
Feb 27, 2003· Comment submitted by Harley Hopkins, Senior Environmental Scientist, Regulatory Analysis and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-RCRA-2002-0033-0009
Filed on regulations.gov — full text not in the inline record.