TDEC has established teams of experienced staff from the Divisions of Remediation, Solid and Hazardous Waste Management, and Underground Storage Tanks to address consistency in site cleanup issues common among state programs. Currently, there are three teams focusing on the issues of Vapor Intrusion Assessment, Institutional Controls, and Site Investigation.
The Vapor Intrusion Assessment team has been working to develop TDEC guidance based in part on “external review drafts” (issued April 11, 2013) of guidance that would finalize U.S. EPA’s 2002 Draft Vapor Intrusion Guidance. These drafts include separate documents for vapors from underground petroleum storage tanks and organic vapors from other sources. TDEC has indicated that, like EPA, it recognizes that petroleum compounds are more readily biodegradable than other organics but that its guidance will be less detailed and describe a more general framework for assessing vapor intrusion that can be applied across all TDEC divisions. This generic approach will allow individual TDEC divisions to establish more specific requirements as necessary. However, this approach may also leave the door open for potential inconsistency among the TDEC divisions, including differing vapor intrusion assessment methodologies and screening levels.
The leader of the Vapor Intrusion Assessment team is Ahmet Bulbulkaya. He has invited anyone who wants to be involved with or follow the developments in this process to e-mail him.