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477 Response

wo peer responses (100 words/each, 3 points/each) are due SUNDAY.

In your responses to peers, how widespread do you think the risk of vapor intrusion is?
How could you, as a safety professional, anticipate, recognize, evaluate, control, and
confirm the effectiveness of controls for vapor intrusion mitigation activities?

Dawson

If soils are contaminated on a construction project, the best way to clean up the land is
to dig up the soils and send them to a landfill (Department of Ecology, n.d.a). This has
potential to greatly alter the footprint of the construction site depending on the volume of
soil that needs to be removed. In addition, the presence of contaminated material
should halt operations in affected areas to ensure the wellbeing of the workers
(Valencia-Gica, n.d.). If contaminated groundwater were detected, a remedial
investigation/feasibility study should be done to determine potential strategies for
cleanup in accordance with Washington State’s MTCA standards (Valencia-Gica, n.d.).
Ultimately, the potentially diverse and drawn out mitigation efforts to deal with
contaminated soil and groundwater could heavily disrupt the schedule and site
topography at a construction site. 
A notice of intent (NOI) permit application requires the following information/actions:

 Site Information
 Operator/Permittee Information
 Property Owner Information
 On-site Contact Person Information
 Electronic Discharge Monitoring Reporting Information
 Existing Site Conditions Information
 Existence and Use of a Stormwater Pollution Prevention Plan (SWPPP)
 Use of Best Management Practices (BMPs)
 Discharge/Receiving Water Information
 Meet State Environmental Policy Act (SEPA)
 List any other Water Quality Permits for the Site
 Publish a Public Notice
 Certification of Permittees (Department of Ecology State of Washington, n.d.c).
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The SWPPP is not necessarily a permit that needs to be submitted, but it is required to
be developed prior to starting construction both for the NOI permit and for the
Construction Stormwater General Permit (CSWGP) (Department of Ecology, n.d.c)
(Department of Ecology, n.d.b). The SWPPP utilizes much of the same information
detailed in the NOI application, since it is a plan that details how a specific site will
prevent “discharges of turbid or polluted stormwater” to waters of the state (Department
of Ecology, 2017).
If a building is built over contaminated soils and groundwater, hazardous vapors can
migrate from the vapor source and into buildings through openings and/or cracks
(Environmental Protection Agency, 2020b). These vapors can accumulate over time
until they reach a concentration that can threaten the health of the workers and/or
create an explosion hazard (Environmental Protection Agency, 2020b).
Exposure can be prevented entirely through remediation by removing contaminated soil
and groundwater, doing in-situ remediation, or relocating (Environmental Protection
Agency, 2008). If this is not an option, the effects can be mitigated by eliminating the
contaminant’s entry routes, removing or reversing the processes that force
contaminants into the building, or by installing another path that diverts contaminants
away from the site (Environmental Protection Agency, 2008). Both passive and active
options are available that include depressurization, foundation modification, increasing
the air exchange rate, and many other methods (Environmental Protection Agency,
2008). 
Since a brownfield is an existing property that can be difficult to redevelop due to
existing or potential contaminants, utilizing the above methods to prevent exposure to
contaminants is vital to brownfield redevelopment (Environmental Protection Agency,
2020a).
Reply in 100 words
Hello Dawson,

Thank you for informative post, after reading it I agree with you that one of the ways of

removing contaminated soils from a construction site is by digging and removing it. Huge

amounts of soil removed can end up interfering with the stability of building, therefore limited

amounts of contaminated soils from the site should be removed. I also agree with you that there

is a difference between NOI and SWPPP, The SWPPP is not necessarily a permit that needs to

be submitted, but it is required to be developed prior to starting construction while NOI is a

completely free. Like you have stated also, Exposure can be prevented entirely through
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remediation by removing contaminated soil and groundwater, doing in-situ remediation, or

relocating

Luke 

Contaminated soils and groundwater can greatly complicate a construction project. It

will create more work for the company completing the project and likely drive the
operating cost up because of the need to remove the soil and treat the water that was
contaminated. This is a big contributing factor to why contractors go to great lengths to
prevent contamination to the site they are working on. Some information you would
need to include on your notice of intent (NOI) permit includes (Washington State
Department of Ecology, 2017):

 The name and address of applicant

 The name, address or location description of the construction site
 The total area of soil disturbance, in acres, for the applicant's project
 A description of the applicant's construction activities
 The name(s) of receiving water(s). If the discharge will be to a storm sewer,
include the name of the storm sewer operator
 A statement allowing those interested to present their views on the application
The NOI permit is closely related to stormwater pollution prevention plans (SWPPP)
because in order to disturb the soil or water on a site, there needs to be a plan in place
to mitigate any potential hazard of contamination. The development of a SWPPP is
designed to "reduce erosion and prevent stormwater pollution from your site"
(Washington State Department of Ecology, 2017).
The risk of buildings being placed on top of contaminated soils can pose a huge risk for
those above. "Vapor intrusion occurs when there is a migration of vapor-forming
chemicals from any subsurface source into an overlying building" (Environmental
Protection Agency, n.d.). The presence of the contaminated soil poses a threat to indoor
air quality which in some extreme cases can cause explosions and acute health effects.
To reduce or mitigate the risk vapor intrusion has on building occupants, it entails
remediation of the subsurface source in the soil, place engineering controls in the
building to reduce the risk, and have monitoring measure in place to determine
exposure levels in the building. This relates to Brownfield redevelopment sites because
those programs are designed to protect tenants of buildings from potential
contamination under the building.
Reply in 100 words
Hello Luke, thank you for your informative post. After reading it, I agree with that contaminated

soils and underground water can complicate a building construction. First, it increases the cost of

constructing the entire building because at the end of the day the costs incurred in the removal of
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the hazardous soil add up the cost of the house. NOI and SWPPP are closely related just like you

stated. They need each other to each to survive. One way of keeping the house and the people

and those round it safe is by keeping protection tool. To reduce or mitigate the risk vapor

intrusion has on building occupants, it entails remediation of the subsurface source in

the soil, place engineering controls in the building to reduce the risk, etc.