Superfund Gets New Site Solely Because of Vapor Intrusion for the First Time
Clear and present indoor air hazard to 400 workers moved EPA to add Mississippi site to the National Priorities List.
For the first time in history, on September 13, 2018, EPA added a site to the National Priorities List (NPL or “Superfund”) based solely on risks posed by indoor air vapor intrusion.
The former Rockwell International Wheel & Trim facility in Grenada, Mississippi has a long history accessible on EPA’s website. In 1966, the site became home to a wheel cover production and chrome plating plant. After chrome plating operations ended in 2001, a metal stamping facility operated onsite. These intensive operations were performed that contributed to heavy pollution by Rockwell International, then by Textron Automotive, and later by Grenada Manufacturing.
And while these intense and poorly managed past operations resulted in multiple recognized environmental conditions (RECs), including trichloroethene, toluene, and hexavalent chromium into the surrounding soil and adjacent wetland, EPA’s given reasoning for adding the site to Superfund is risk to human health posed by the potential for airborne volatile organic compounds (“VOCs”) to seep through cracks, joints, and other openings to pollute the air breathed by the sites 400 workers.
The former Rockwell International Wheel & Trim facility Superfund site joins a list of ~1,300 other priority sites comprised of the country’s most contaminated and dangerous properties.
While the result of EPA’s decision to list the former Rockwell International Wheel & Trim site on the NPL based solely on risks from indoor air contamination is unprecedented, it should come as no surprise given the sense of urgency behind EPA’s focus on vapor intrusion in recent years, since better science improved our ability to understand the risks to human health by indoor air presented by underground contamination.
Risk of reopening previously remediated and closed sites due to newly understood risks of vapor intrusion had emerged at numerous site across the country in the preceding years. Operations at several working facilities was interrupted, including at a Google satellite campus in California. For at least two months in 2012 and 2013, workers and visitors at Google’s office complex in Mountain View were exposed to exceedingly high levels of TCE after workers disabled a critical part of the ventilation system at the campus built on a Superfund site. Risks posed to indoor environments by vapor intrusion was simply not well understood when the EPA and the city of Mountain View agreed on the remedial remedy in the 1990s.
In 2011, EPA had begun requiring new buildings at the Mountain View Superfund site have sub-slab ventilation systems and vapor barriers. And the next year, Region 9 began setting stricter standards for TCE exposure. Region 9 now requires that it be notified if the level of TCE in a building exceeds safety thresholds measured in micrograms per cubic meter of air.
More recently, in May 2017, EPA passed a final rule expanding the list of factors the agency is allowed to consider when designating NPL sites to specifically include risks to human health from impacted indoor air.
EPA’s history-making designation of the former Rockwell International Wheel & Trim site onto the Superfund list marks a new era of vapor intrusion concerns in which every potentially responsible party must be on notice that vapor intrusion may increase the chances a site gets designated on the NPL. Moreover, any site on which engineering controls are maintaining compliance with indoor air quality should take special care to monitor their safety and environmental control systems.
Read more about the former Rockwell International Wheel & Trim site on EPA's website here.
NB: The Superfund program has been providing important health benefits to communities across the country for more than 35 years. Superfund cleanups also strengthen local economies. Data collected through 2017 shows that at 487 Superfund sites in reuse, approximately 6,600 businesses are generating $43.6 billion in sales and employ 156,000 people who earned a combined income of $11.2 billion.
Special thanks to BL Sponsor ERIS:
A Redfield is real property with known environmental contaminants or conditions that the owner, the government or a reliable third party have determined is in need of remediation as a prerequisite to future development—to mitigate potential human health risks or to comply with environmental laws. Unlike a Brownfield, there is no doubt about whether a Redfield requires remediation.