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1
Person
County
People
Rising
in
Defense
of
Ecology
Physicians
for
Social
Responsibility
-‐
Los
Angeles
(PSR-‐LA)
Voluntary
Clean-‐Up
Advisory
Board
Western
North
Carolina
Alliance
Wild
New
Jersey
U.S.
Environmental
Protection
Agency
EPA
Docket
Center
Superfund
Docket,
Mail
Code
28221T
1200
Pennsylvania
Avenue,
NW.
Washington,
DC
20460
April
15,
2011
Re:
Docket
ID
No.
EPA–HQ–
SFUND–2010–1086
Dear
US
EPA:
We
are
writing
to
fully
support
EPA’s
proposal
to
update
the
Hazard
Ranking
System
(HRS)
to
include
the
vapor
intrusion
pathway,
so
that
sites
with
significant
documented
or
potential
vapor
intrusion
can
be
placed
on
the
“Superfund”
National
Priorities
List
(NPL).
This
action
is
long
overdue,
because
an
uncounted
number
of
Americans
are
exposed
to
toxic
volatile
substances
in
our
homes,
schools,
and
workplaces.
Many
of
us
live,
work,
or
have
children
that
attend
schools
near
legacy
industrial
sites,
military
sites,
gas
stations,
dry
cleaning
facilities,
and
other
sources
of
hazardous
vapors.
We
believe
that
dangerous,
complex,
and/or
large
vapor
intrusion
sites
may
need
to
be
addressed
under
Superfund
because
many
states
lack
the
capability
to
adequately
evaluate
the
pathway.
In
addition,
EPA-‐led
sites
that
are
addressed
under
other
programs,
such
as
Emergency
Response,
sometimes
use
unprotective
exposure
standards.
At
many
sites
where
vapor
intrusion
is
being
mitigated
there
is
no
long-‐term
strategy
for
eliminating
the
source.
Listing
would
require
that
remediation
alternatives
be
evaluated.
It
should
be
simple
for
significant
sites
with
completed
vapor
intrusion
to
qualify
for
Listing,
but
the
HRS
should
also
recognize
sites
with
potential
vapor
intrusion:
1.
Most
potential
vapor
intrusion
sites
have
not
experienced
soil
gas
or
indoor
air
sampling.
Significant
levels
of
volatile
substances,
particularly
chlorinated
volatile
organic
compounds
(CVOCs),
in
shallow
groundwater
should
be
enough
to
place
these
sites
on
the
NPL.
This
should
apply
to
undeveloped
property
where
occupied
structures
are
a
reasonably
anticipated
future
land
use.
2.
Many
occupied
buildings
with
elevated
levels
of
CVOCs
in
underlying
soil
gas
do
not
manifest
elevated
concentrations
indoors
because
the
slab
or
floor
is
currently
impermeable
or
ventilation
rates
are
high.
These
temporary
conditions
should
not
be
considered
protective,
and
listing
should
be
considered.
2
3.
At
a
growing
number
of
sites,
overseen
by
EPA
or
other
regulators,
as
well
as
those
where
the
environmental
response
is
conducted
by
volunteers,
mitigation
such
as
subslab
depressurization
has
been
installed.
Such
mitigation
is
necessary,
but
these
are
interim
measures.
Short
term
reductions
in
indoor
air
contamination
should
not
prevent
a
site
from
NPL
Listing.
We
recognize
that
not
every
site
with
confirmed
or
potential
vapor
intrusion
will
qualify
for
the
NPL—the
nation’s
worst.
We
also
understand
that
once
sites
are
listed
that
remedies
will
be
selected
according
to
the
nine
criteria
of
the
National
Contingency
Plan.
Nevertheless,
we
strongly
believe
that
adding
the
vapor
intrusion
pathway
as
a
factor
in
NPL
Listing
will
provide
EPA
with
an
important
tool
to
protect
Americans
further
from
continuing
exposure
to
highly
toxic
volatiles
substances.
In
summary,
we
strongly
support
EPA’s
proposal
to
add
the
vapor
intrusion
pathway
as
a
component
of
the
Hazard
Ranking
System
for
listing
properties
on
the
“Superfund”
National
Priorities
List.
We
thank
you
for
the
opportunity
to
comment
on
this
important
matter.
Sincerely,
Pamela
K.
Miller,
Executive
Director
Nancy
Swan
Alaska
Community
Action
on
Toxics
(ACAT)
Children's
Environmental
Protection
Anchorage,
AK
Alliance
Bob
Moss
Barbara
J.
Warren,
Executive
Director
Barron
Park
Association
Foundation
Citizens'
Environmental
Coalition
Palo
Alto,
CA
Albany,
NY
Jeanne
Rizzo,
R.N.
President
and
CEO
Lisa
Riggiola
,
Executive
Director
The
Breast
Cancer
Fund
Citizens
For
A
Clean
Pompton
Lakes
San
Francisco,
CA
Pompton
Lakes,
NJ
Jerry
Bowling
III
Laura
Olah,
Executive
Director
BVOCAL
(Behr
VOC
Area
Leaders)
Citizens
for
Safe
Water
Around
Badger
Dayton,
OH
(CSWAB)
Merrimac,
WI
Lois
Marie
Gibbs,
Executive
Director
Center
for
Health,
Environment
&
Justice
Clay
G.
Colson,
Board
Director
and
Water
(CHEJ)
Issues
Chair
Falls
Church,
VA
Citizens
for
Sanity.Com,
Inc.
Pasco,
FL
Lenny
Siegel,
Executive
Director
Center
for
Public
Environmental
Oversight
Katie
Hicks
Mountain
View,
CA
Clean
Water
for
North
Carolina
Asheville,
NC
3
Christina
Walsh
Hartwell
Carson
Cleanuprocketdyne.org
French
Broad
Riverkeeper
West
Hills,
CA
Western
North
Carolina
Alliance
Asheville,
NC
Duane
De
Witt,
Executive
Director
Community
Builders
Corporation
Denny
Larson,
Executive
Director
Santa
Rosa,
CA
Global
Community
Monitor
El
Cerrito,
CA
Sarah
Anker,
Suffolk
County
Legislator
Community
Health
and
the
Environment
Cheryl
Wisecup,
President
Mt.
Sinai,
NY
Global
Indoor
Health
Network,
Inc.
Henderson,
Nevada
Chris
Borello,
President
Concerned
Citizens
of
Lake
Daniel
Parshley,
Project
Manager
Twp./Uniontown
IEL
Glynn
Environmental
Coalition
Uniontown,
OH
Brunswick,
GA
Carol
Meschkow,
President
Eva
Navon,
Community
Manager
Concerned
Citizens
of
the
Plainview-‐Old
Green
Spaces
NY
Bethpage
Community
Inc.
New
York,
NY
Plainview,
NY
Robert
S.
DeLuca,
President
Dave
Ogren,
Buncombe
County
Group
for
the
East
End
Commissioner
Appointed
Southold,
NY
CTS
Citizens
Monitoring
Council
Asheville,
NC
Michael
Heimbinder,
Executive
Director
HabitatMap
Stephen
Brittle,
President
Brooklyn,
NY
Don't
Waste
Arizona
Phoenix,
AZ
Rachel
Lincoln
Sarnoff,
Interim
Executive
Director/CEO
Robert
Spiegel,
Executive
Director
Healthy
Child
Healthy
World
Edison
Wetlands
Association
Los
Angeles,
CA
Edison,
NJ
Debra
Hall,
Co-‐Chair
Judy
Braiman
Hopewell
Junction
Citizens
for
Clean
Water
Empire
State
Consumer
Project
NYVIA
New
York
Vapor
Intrusion
Alliance
Rochester,
NY
Hopewell
Junction
NY
Bill
Burns
Ed
Dlugosz
Environmental
Awareness
Foundation
Hudson
River
Sloop
Clearwater,
Inc.
Atlanta,
GA
New
Jersey
Friends
of
Clearwater,
Inc.
Red
Bank,
NJ
Kent
Slowinski,
Co-‐Founder
Environmental
Health
Group
John
Filcher
Washington,
DC
Incinerator
Free
Brown
County
Green
Bay,
WI
4
Marion
J.
Lamberth,
Outreach
Chair
Laura
Haight,
Senior
Environmental
Inter
PAC
Environmental
Justice
Associate
Committee
New
York
Public
Interest
Research
Group
Durham,
N.C.
(NYPIRG)
Albany,
NY
Mary
Moore
Lindon
Park
Neighborhood
Association
Dana
Patterson,
Manger
Phoenix,
AZ
New
Green
Media
Edison,
NJ
Donna
A.
Lupardo
Member,
NYS
Assembly
Amy
Goldsmith,
State
Director
Binghamton,
NY
NJ
Environmental
Federation.
Belmar,
NJ
Glen
Horecky,
Chair
Mills
Gap
Road
Ground
Water
John
G.
Andrade
Executive
Director
Contamination
Site
CAG
Old
Bedford
Village
Development,
Inc.
Asheville,
NC
New
Bedford,
MA
Kathleen
Schmid,
Executive
Director
Pat
Hill,
Co-‐Chair
Newtown
Creek
Alliance
Person
County
People
Rising
in
Defense
of
Brooklyn
and
Queens,
NY
Ecology
Roxboro,
NC
Karen
A.
Vilandry
New
Bedford
Environmental
Justice
Martha
Dina
Argüello,
Executive
Director
Network
Physicians
for
Social
Responsibility
-‐
Los
New
Bedford,
MA
Angeles
(PSR-‐LA)
Los
Angeles,
CA
Joel
Shufro,
Executive
Director
New
York
Committee
for
Occupational
Tim
Lopez,
President
Safety
and
Health
(NYCOSH)
Voluntary
Clean-‐Up
Advisory
Board
NeNew
York,
NY
Denver,
CO
David
Wheeler,
Founder
Wild
New
Jersey
Edison,
NJ
CC:
EPA
Administrator
Lisa
Jackson
EPA
Assistant
Administrator
Mathy
Stanislaus,
OSWER